This Privacy Policy establishes general principles how Moncera OÜ (hereinafter Moncera), registration code 14866045, processes personal data. Specific details on the processing of personal data might be also included in agreements entered or to be entered between the Customer and Moncera and is reflected in Website www.moncera.com.

Moncera ensures, within the framework of applicable law, the confidentiality of personal data and has implemented appropriate technical and organizational measures to protect personal data of Customers and to provide transparent data protection rules.

The respective Privacy Policy is applicable if the Customer uses, has used or has intention to use financial services provided by Moncera, including the relationship with the Customer established before this Privacy Policy enters into force.

Moncera has the right to make changes to the Privacy Policy at any time by posting them on the Platform, as well as by informing the Customers individually by sending them an e-mail.

Personal data categories which Moncera process are the following:

• identification data such as name and personal identification code;
• contact data such as telephone number, e-mail address, country of residence;
• professional data such as educational or professional career;
• financial data such as income and liabilities;
• due diligence data that enables Moncera to perform its due diligence measures regarding money laundering and terrorist financing prevention, such as origin of funds, information on the purpose and intended nature of the business relationship and whether the Customer is a politically exposed person;
• data about the Customer’s tax residency such as data about the country of residence, tax identification number, citizenship;
• communication data collected when the Customer communicates with Moncera via telephone, visual and/or audio recordings, e-mail, messages and other communication channels, data related to the Customer’s visit at www.moncera.com.

Moncera processes personal data primarily to:

• provide services to the Customer. Upon submission of the registration application and registration with the Platform, personal data of the Customer is used to enter into the agreement and create the virtual account to be used to receive the services;
• manage customer relations in general and provide and administrate access to financial services Moncera offers;
• to protect the interests of the Customer and/or Moncera and examine the quality of services provided by Moncera and for the purpose of providing proof of a commercial transaction or of other business communication;
• provide additional services, perform customer surveys, market analyses and statistics. Offer to the Customers the services of carefully selected cooperation partners, including personalized offers, based on consent of the Customer;
• to comply with legal obligations and verification of identity. To comply with applicable law, prevent, discover, investigate and report potential money laundering, terrorist financing, if the Customer is a subject to financial sanctions or is a politically exposed person;
• prevent misuse of financial services and ensure adequate provisions of services;
• to process incoming and outgoing payments.

Profiling refers to the automatic processing of personal data used to assess certain personal characteristics of the Customer. Profiling is used for direct marketing purposes.

Moncera may process personal data to improve the Customer experience of the digital services. Moncera always ensures that Customers can make their choices and use a convenient tool to manage their privacy settings.

Moncera may also collect statistical data regarding the Customer. Statistical data for creating segments profiles can be collected from external sources and may be combined with Moncera internal data.

Personal data is shared with other recipients, such as:

• authorities (such as law enforcement authorities, tax authorities, supervision authorities);
• credit and financial institutions in order to process incoming and outgoing payments;
• auditors, legal and financial consultants, or any other processor authorized by Moncera;
• third parties maintaining registers (such as credit bureaus, population registers, commercial registers, or other holding personal data);
• debt collectors upon assignment of claims;
• courts, out-of-court dispute resolution body and insolvency administrators;
• other persons related to provision of services of Moncera such as providers of postal services or analytical services.

We note that Moncera does not transfer Customer’s personal data to third countries.

Moncera stores personal data of the Customers as long as it is necessary for the purposes of the personal data collected and as long as required by law.

If the Customer wishes to delete his/her account or any of his/her personal data on the website, he/she should notify Moncera.

In accordance with the Estonian accounting and taxation laws, invoice-related information is retained for a period of 7 years as of the end of the financial year when such information was provided to Moncera.

Information on any legal transactions between Moncera and the Customer may be retained for a period of 10 years as of their provision to Moncera in accordance with the general limitation period set for civil claims in the Estonian Civil Code Act.

A data subject (a Customer) has the rights regarding his/her data processing that is classified as personal data under applicable law. Such rights are:

• receive information about Customer’s data we process;
• require personal data to be corrected if it is inadequate, incomplete or incorrect;
• ask Moncera to stop or restrict processing, disclosing or enabling access to, delete or close Customer’s personal data the processing of which is not permitted on the basis of law;
• withdraw his/her consent to process his/her personal data;
• ask his/her personal data portability;
• not to be the subject to fully automated decision;
• lodge complaints pertaining to the use of personal data to the Data Protection Inspectorate, (info@aki.ee, Tatari 39, Tallinn 10134), if he/she considers that processing of his/her personal data infringes his/her rights and interests under applicable law.

If you have any questions, comments, complaints or requests regarding the use of personal data, you can contact us at info@moncera.com.