Privacy Policy

This privacy notice for Oleksandr Kinakh ('we', 'us', 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services (Services), such as when you:

• Download and use our mobile application (Mony), or any other application of ours that links to this privacy notice
• Engage with us in other related ways, including any sales, marketing, or events

If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at support@monyfinanceapp.com

This SERVICE is provided by Oleksandr Kinakh is intended for use as is.

This privacy policy aims to give you information on how "Mony" collects and processes your data through your use of this app, including any data you may provide through our app when you sign up.

By accepting this privacy policy, you further certify that you have full legal capacity and capacity and are of the age required by the laws of the State of Delaware, USA, or other state, country of which you are a citizen, to accept these terms.

You will be required to read and accept this privacy policy before using the application. By using the application YOU MESSAGE TO US that: (i) YOU READ, UNDERSTAND, AND AGREE TO THIS PRIVACY POLICY, AND (ii) YOU ARE MORE than 14 years old (or EXCEED THAT YOUR PTA or guardian reads and AGREE TO THIS PRIVACY POLICY FOR YOU). If you don’t accept and agree to this Privacy Policy, you must immediately stop using our app.

You must read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Changes to the privacy policy

We reserve the right to and may change this privacy policy from time to time. If we make any material changes, we will notify you through our app, or email, or by presenting you with a new version of this privacy policy for you to accept, if we, for example, add new processing activities or collect some additional personal data from you.

Your continued use of the app after the effective date of an updated version of the privacy policy will indicate your acceptance of the privacy policy as modified. In some cases, you will have to accept changes to the privacy policy explicitly.

Types of data We collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We automatically collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:

• Account registration: email address, when you register an account.
• Data from third-party services: if you register through the account of other services such as Facebook, Apple, or Google you provide us with a user ID, email address, and a photo from the profile.
• Device data: includes model, OS version, language.
• Usage Data: includes information about how you use our app, user activity within the application, app events.
• Information about in-app purchases and subscriptions: data on subscription fees, and purchase history.
• User-generated content. (We do not analyze or track it)

We also collect, use, and share Aggregated Data such as statistics or demographics. Aggregated Data may be derived from your data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific our app feature. However, if we combine or connect Aggregated Data with your data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used under this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

Lawful bases for processing

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Consent. You have given clear consent for you to process their personal data for a specific purpose.
• Contract. The processing is necessary for a contract you have with us.
• Legitimate interests. The processing is necessary for our legitimate interests or the legitimate interests of a third party.

We may process your data if you have given us specific consent to use your personal information for a specific purpose.

If you share with us the personal data of a third party, you confirm that such a third party gave you consent on the collection and processing of his/her data by us. We in turn will take the same measures and procedures to ensure the safety of such information as we do in relation to your data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on you to process your data where more than one ground has been set out in the table below.

Purpose	Type of data	Lawful basis for processing including basis of legitimate interest
For authorization users when registering an account. Communication with users.	Account registration. Email address when you register an account.	Performance of a contract with you.  Your consent.
For authorization users when registering an account. Communication with users.	Data from third-party services. If you register through the account of other сervices such as Facebook, Apple, or Google you provide us with a user ID, email address, and a photo from the profile.	Performance of a contract with you.  Your consent.
For marketing and analytical purposes. To provide, improve and develop the application.	Device data. Includes model, OS version, language.	Performance of a contract with you.  Your consent.
For marketing and analytical purposes. To provide, improve and develop the app.	Information about how you use our app, user activity within the application.	Performance of a contract with you.  Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app).
To provide access to the application, identify the user, and track the subscription period.	Information about in-app purchases and subscriptions: data on subscription fees, and in-app purchases history.	Performance of a contract with you.  Your consent. Necessary for our legitimate interests (to keep our records updated and to study how customers use our app). Necessary to comply with a legal obligation.
To use the software functions.	User-generated content	Performance of a contract with you.  Your consent.

More about use of the user-generated content

We collect user-generated content solely for storage on our servers to ensure backup and synchronization across devices. We do not analyze, track, share, or sell user content to third parties. Users have the option to disable server storage and keep their data locally on their device. Additionally, users can delete their data from our servers at any time, either individually or by deleting their account.

Third-Party Services and disclosures of your data

We share only some of your Personal Data to our service providers strictly limited to cases and purposes stipulated in this privacy policy.

We’ll not use the information gained through your use of our app for resell.

We require all third parties to respect the security of your personal data and to treat it under the law.

We will not process Personal Data in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by you in accordance with Section “Types of data We collect” of this privacy policy or collect any Personal Data that is not required for the mentioned purposes.

For any new purpose of processing we will ask your separate explicit consent. To the extent necessary for those purposes, we take all reasonable steps to ensure that Personal Data is reliable for its intended use, accurate, complete, and current.

Cross-border transfer of personal data. Some of those employees, contractors and affiliated or other third party organizations may be located either within or outside the USA, EU or the European Economic Area (EEA); by using our app, you consent to the transfer of such information to them.

We share your data with the parties set out below for the purposes set out in the table above.

We store your data on the servers of Google Cloud.

We transmit and store analytical data on the analytical services of Firebase and Adapty.

In most cases, we provide our partners with aggregated and anonymous user data (so that it can no longer be associated with you).

We require all third parties to respect the security of your personal data and to treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and under our instructions.

We may disclose user provided and automatically collected Information:

• as required by law, such as to comply with a subpoena or similar legal process;
• when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
• with our trusted services providers who work on our behalf, do not have an independent use of the information we disclose to them, and have agreed to adhere to the rules outlined in this privacy statement;
• if we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

We don’t use user data for sale (or any other commercial activity) to other companies. User’s data is used solely to ensure the functionality of the software.

Data security

We have put in place appropriate security measures to prevent your data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We also use technical data encryption tools such as SSL protocols to keep your data secure.

We use Firebase and Google Cloud services, which may involve data processing in the United States. Data transfers are carried out under Standard Contractual Clauses (SCC), ensuring compliance with GDPR requirements.

For more details on Google Cloud GDPR compliance, please visit: Google Cloud GDPR Compliance.

Data retention

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

We require all third parties to respect the security of your personal data and to treat it under the law. We do not allow our third-party service providers to use your personal data for their purposes and only permit them to process your personal data for specified purposes and under our instructions.

• Analytics data: Collected through Firebase Analytics and stored for 14 months.
• User data: Stored as long as the account remains active. Deleted upon user request or account deletion.

We do not use user data for sale (or any other commercial activity) to other companies. User data is used solely to ensure the functionality of the app.

You can request deletion of you data at any time in the application.

Children’s Privacy

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

What are your privacy rights?

If you would at any time like to terminate your account, you can:

• Log in to your account and delete your user account or/and data.
• Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page.

This policy is effective as of 2025-02-17

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at support@monyfinanceapp.com