Privacy Policy

1. Introduction

Monerry Kft. ("Monerry," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and safeguard your personal data when you access or use our mobile application (the "App"), visit our website, or use our services. By using our services, you acknowledge and agree to the practices described in this Privacy Policy and our Terms of Use, available at monerry.com/terms-of-use.

This policy complies with the General Data Protection Regulation (GDPR) and other applicable European Union and Hungarian data protection laws.

1.1 GDPR Compliance Notice

Monerry Kft. is a Hungarian-based company and complies with the EU General Data Protection Regulation (GDPR) and Hungarian data protection laws. This Privacy Policy is designed to clearly inform you about how we process your personal data lawfully, fairly, and transparently, and to outline your rights under applicable data protection laws.

2. Data Controller Information

The data controller responsible for your personal data is:

3. Information We Collect

3.1 Personal Information You Provide

When you register, create an account, or use our services, we may collect personal information, including but not limited to:

• Full name
• Date of birth
• Email address
• Location Data
• Mobile number (used for verification or security purposes)
• Profile image
• Additional preferences or information you provide

3.2 Automatically Collected Information

When you access our App or website, we automatically collect certain information, including but not limited to:

• IP address
• Device type and operating system
• Browser type and version
• Pages visited, click behavior, and duration of visits
• Other usage and performance data

3.3 Financial Data

Portfolio Information: Asset holdings, quantities, purchase prices, and related financial data that you manually input into the application. We do not access your trading accounts or bank accounts directly.

3.4 Tracking Technologies

We use web beacons and mobile identifiers solely:

• To enable essential App functions
• For analytics (via Google Analytics, Cloudflare Analytics)
• For personalized content and advertising (via IDFA/AAID)

Consent & Controls: On iOS, we will request ATT consent for IDFA use. In the EU, we employ granular opt-in/out by category. You may disable non-essential tracking via your device or browser settings; note this may degrade functionality.

4. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contract Performance: To provide the Service you have requested
• Legitimate Interest: To improve our Service, ensure security, and provide customer support
• Consent: For marketing communications and optional features (where applicable)
• Legal Obligation: To comply with applicable laws and regulations

5. How We Use Your Information

5.1 Service Provision and Improvement

We use your information to:

• Operate, maintain, and enhance our App, website, and services
• Personalize and improve your user experience
• Analyze usage patterns to improve performance and security

5.2 Communication and Customer Support

Your information may be used to:

• Send newsletters, updates, and notifications
• Respond to your inquiries and provide technical or customer support

5.3 Legal and Regulatory Compliance

We may process your data to:

• Comply with legal obligations and regulatory requirements
• Protect our rights and the rights of our users

6. Data Sharing and Disclosure

6.1 Third-Party Service Providers

We may share your information with trusted third-party service providers who assist us in operating our Service, including:

• Cloud hosting and storage providers
• Analytics and performance monitoring services
• Customer support platforms
• AI and machine learning service providers for analysis features

6.2 Legal Requirements

We may disclose your information if required by law or in response to valid requests by public authorities.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer your data outside the EEA, we ensure appropriate safeguards are in place, such as:

• European Commission adequacy decisions
• Standard Contractual Clauses approved by the European Commission
• Other appropriate safeguards as required by GDPR

8. Data Security

We maintain robust, industry-standard security measures designed to protect your personal information from unauthorized access, alteration, disclosure, or destruction. We continually review and enhance our security protocols to ensure a high level of protection.

In the unlikely event of a data breach, we will promptly investigate the incident and take appropriate remedial actions to minimize any potential impact. If we determine that the breach poses a significant risk to individuals, we will notify you and any relevant regulatory authorities within the legally required timeframe.

Data Breach Response

In the event of a suspected data breach, we will:

• Investigate immediately and contain the breach
• Notify Authorities within 72 hours if required (GDPR Article 33)
• Notify Affected Individuals without undue delay if there is high risk to rights and freedoms
• Document all incidents and remedial actions

9. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including:

• Account Data: Until you delete your account or request deletion
• Usage Data: Typically retained for 2 years for analytics purposes
• Support Communications: Retained for 3 years for quality and legal purposes

10. Your Rights and Choices

10.1 Access, Correction, and Deletion

Subject to applicable law, you have the right to request access to the personal information we hold about you, request corrections to any inaccuracies, or request deletion of your data.

10.2 Opting Out of Communications

You may opt out of receiving marketing communications by clicking the "unsubscribe" link in our emails or contacting us at [email protected].

10.3 CCPA Rights for California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including:

• The right to know what personal data we collect and the purposes for which it is used
• The right to request deletion of your data
• Obtain equal service and price even if you exercise these rights
• The right to opt out of the sale of personal data (please note, we do not sell your data)

To exercise these rights, please contact us at [email protected].

10.4 GDPR Disclosures and Data Subject Rights

If you are located in the European Union or the European Economic Area, you have rights under the General Data Protection Regulation (GDPR), including the right to access, rectify, erase, restrict, or object to processing, as well as the right to data portability. To exercise these rights, please contact [email protected].

10.5 Your Data Protection Rights

If you are located in the EU, EEA, UK or Denmark, you have the right to:

• Access - request a copy of your personal data
• Rectification - correct inaccurate or incomplete data
• Erasure ("Right to be Forgotten") - delete your data where no longer necessary
• Restriction - block processing under certain circumstances
• Data Portability - receive your data in a structured, machine-readable format
• Objection - object to processing based on legitimate interests or direct marketing
• Withdraw Consent - withdraw any consent you have previously given
• Lodge a Complaint - with your local Supervisory Authority

10.6 Canadian Privacy Rights

Under the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws, you have the right to:

• Access - request to view personal information we hold
• Correction - ask us to correct any inaccuracies
• Challenge - challenge our compliance in the handling of your data
• Withdrawal of Consent - withdraw consent for future processing (subject to legal restrictions)

To make a request, contact our Privacy Officer at [email protected].

10.7 Australia & New Zealand Privacy Rights

Under the Australian Privacy Act 1988 (and the Privacy Amendment (Notifiable Data Breaches) Act 2017) and the New Zealand Privacy Act 2020, you have the right to:

• Access - obtain confirmation and access to your personal information
• Correction - request correction of inaccurate data
• Complaint - complain to us, and/or to the Office of the Australian Information Commissioner (OAIC: https://www.oaic.gov.au) or the New Zealand Privacy Commissioner (https://privacy.org.nz) if unsatisfied
• Notifiable Data Breach - be informed if a breach is likely to result in serious harm

Email [email protected] for requests or complaints.

10.8 Your Rights Under Applicable Data Protection Laws

Depending on your country of residence, you may have rights under applicable data protection laws, including but not limited to the UK GDPR, EU GDPR, and similar laws.

These rights may include:

• The right to access and correct your personal data
• The right to request erasure or restrict processing
• The right to object to processing, including for marketing
• The right to withdraw consent at any time (where processing is based on consent)
• The right to data portability (where applicable)
• The right to lodge a complaint with your local data protection authority

We will respond to all rights requests in accordance with the timelines and requirements of the relevant laws. You may exercise these rights or raise questions by contacting us at [email protected].

11. Children's Privacy

Our services are intended for individuals who are 18 years of age or older. We do not knowingly collect or process personal data from individuals under 18. If you believe that we have inadvertently collected data from a child under 18, please contact us immediately so that we can take appropriate action.

COPPA Notice - California users: we comply with the U.S. Children's Online Privacy Protection Act (COPPA). If we learn that we have collected personal data from a child under 13, we will delete it promptly.

Parents may request deletion of a child's data by contacting [email protected].

12. Third-Party Links

Our App and website may contain links to third-party websites or services that are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of those third-party sites. We encourage you to review the privacy policies of any sites you visit.

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. When we update the Privacy Policy, we will update the "Last Updated" date at the top of this document. We encourage you to review this policy periodically for any changes.

14. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal data violates GDPR. The lead supervisory authority for Monerry Kft. is the Hungarian National Authority for Data Protection and Freedom of Information (NAIH).

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: