We are dedicated to protecting your privacy and ensuring the security of your personal data. We encourage you to review this policy carefully to make informed decisions about your privacy and the use of our services. Should you have any questions or concerns regarding this policy, please reach out to us on firstname.lastname@example.org.
Data controller details
Data Controller: InvesTRe S.A. (hereafter InvesTRe or Moniflo)
Address: 209 Rue des Romains, Bertrange, L-8041, Luxembourg
Registered Information: InvesTRe S.A. is registered with the commercial register under B249656.
Representative: Georges Bock, CEO
We have appointed a data protection officer who advises and guides us on matters related to the implementation and maintenance of our data protection management system. You can contact our data protection officer at:
Contact email: email@example.com.
As the data controller, we are responsible for the collection, processing, and protection of your personal data within the Moniflo investing app. We strive to adhere to applicable data protection laws and ensure that your privacy rights are respected. If you have any concerns or inquiries regarding the handling of your personal data, please feel free to reach out to us using the contact information provided above.
1 General Information Regarding Data Processing
1.1 Personal Information and GDPR
Personal information refers to any data that can directly or indirectly identify an individual. It includes, but is not limited to, names, contact details, identification numbers, financial information, and other relevant data. At Moniflo, we understand the importance of protecting your personal information and respecting your privacy rights.
The General Data Protection Regulation (GDPR) is a comprehensive data protection regulation that governs the processing of personal data within the European Union (EU) and the European Economic Area (EEA). The GDPR aims to provide individuals with greater control over their personal data and sets out clear guidelines for organizations on how to handle, process, and protect such data. It introduces principles for lawful and fair processing, establishes individuals' rights regarding their personal data, and imposes obligations on data controllers and processors to ensure the security and confidentiality of personal information.
As an organization subject to the GDPR, we are committed to complying with its requirements and ensuring that your personal information is handled in accordance with the regulation's principles. We implement appropriate technical and organizational measures to safeguard your data, protect it from unauthorized access, and prevent any unlawful processing.
1.2 Your Rights
As an individual whose personal information is processed by invesTRe and the Moniflo App, you have certain rights regarding the protection and control of your data. We are committed to upholding these rights and ensuring that you can exercise them effectively:
- the right to access,
- the right to rectification or erasure,
- the right to restriction of processing,
- the right to data portability,
- If you have provided us with your personal data on the basis of a consent, you can withdraw the consent at any time with effect from the future,
- You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes. We will assess your objection and cease processing your data unless we have compelling legitimate grounds to continue or if the processing is necessary for legal claims.
To exercise these rights named above you may contact us at any time via email to firstname.lastname@example.org.
You also have the right to lodge a complaint with a supervisory authority of your choice (for example: CNPD https://cnpd.public.lu/en.html.)
An overview of the Data Protection Authorities may be found here: https://cnpd.public.lu/en/commission-nationale/missions.html.
1.3 Storing and Deleting Data
The duration of the data storage depends on the respective data category and processing activity. If the storage period is not further specified, the retention period ends as soon as the purpose or legal basis for storage ceases to apply.
Upon the closure of your account, withdrawal of consent, or the expiration of the applicable retention period, we take appropriate measures to securely delete or anonymize your personal data to ensure it is no longer identifiable or retained in a form that can be linked to you, unless further retention is required for legal or legitimate purposes.
2 Types of data processed
To provide you with our website and related marketing services, we collect the following types of personal data:
- Identity and Contact Information: When you visit the websites, we may collect personal data such as your IP address. If you fill in an online form, you may give us your name, email address or phone number for referral campaigns or to receive marketing communications
- Usage Information: We automatically collect certain data about your usage patterns, including IP address, device information, and browsing activities. Some of this is necessary for us to provide you with the site. Others are optional and can be configured in your cookie settings.
- Communication Data: We may collect and store communication data, including your interactions through our Contact Forms, feedback, and survey responses, to address your inquiries, improve our services, and ensure your satisfaction.
3 Purposes of processing
Under data protection laws, we are required to notify you of the purposes of processing your Personal Information, as well as the legal basis for such processing.
Unless otherwise permitted by law, we may process your Personal Information:
- If you consent to the processing
- To satisfy our legal obligations
- If it is necessary to carry out our obligations arising from any contracts, we entered with you or to take steps at your request prior to entering into a contract with you
- In the public interest
- In your vital interests, or
- For our legitimate interests, such as to protect our property, rights, or the safety of InvesTRe, Moniflo our customers, or others
4 Processing through cookies
What are cookies?
Cookies are small text files that are placed on your device (such as a computer, smartphone, or tablet) when you visit our website. These files enable the website or app to remember your actions and preferences (such as login credentials, language, font size, and other display preferences) over a certain period, so you don't have to keep re-entering them whenever you return to the site or navigate between pages.
At Moniflo, we use third-party cookies to enhance your user experience, improve our website, and gain insights into how you interact with our website. The cookies on our website fall into the following categories:
- Necessary Cookies: These cookies are essential for the functioning of our App and enable you to access and navigate its features securely. Without these cookies, certain functionalities may not be available.
- Statistics Cookies: We utilize these cookies to collect information about how you use Moniflo, such as the pages you visit, the links you click, and any errors you encounter. This data helps us optimize and improve the App's performance and overall user experience.
- Preference Cookies: Functionality cookies allow us to remember your preferences and choices, such as your language selection, region, or personalized settings. These cookies enhance your interaction with Moniflo and make your visits more convenient and tailored to your preferences
- Marketing Cookies: We may partner with third-party advertising networks to display targeted advertisements to you based on your interests and behaviour on Moniflo. These cookies track your browsing activity and enable us to provide you with relevant ads that align with your investment preferences.
Your cookie choices
You have the right to control and manage cookies through your web browser. Most browsers allow you to accept or reject cookies automatically or give you the option to be notified when a cookie is placed on your device. Please note that by disabling cookies, some features of our websites may not function properly, and your overall user experience could be impacted.
Updates to this section on Cookies
Contact us If you have any questions or concerns regarding this section of the Policy on Cookies or your privacy on Moniflo, please feel free to contact us at email@example.com.
Cookies on our website
Managing and Rejecting Cookies
Here are the steps you can take to manage and reject cookies on our website and mobile application:
- Browser Settings: Most web browsers offer settings that allow you to manage cookies. You can modify your browser settings to accept or reject cookies automatically or request your consent before a cookie is placed on your device. To do this, please follow the instructions provided by your browser's help centre or support documentation.
- Via the cookie panel: You can control cookies in the preference, marketing and/or statistics cookie category via the cookie panels on our websites. If you have not yet set your cookies preferences, the cookie panel can be found at the bottom of each page. If you have already set your cookie preferences, you can access the cookie panel via the icon found in the bottom left corner of each page. Preference, marketing and/or statistics cookies will not be set unless you have given your consent to the use of these cookies.
Please be aware that if you choose to reject or disable cookies, certain features of Moniflo may not function properly, and you may experience limitations in using some functionalities. Additionally, by rejecting certain cookies, you might not be able to take full advantage of personalized content and targeted advertisements.
It's important to note that the process of managing and rejecting cookies is specific to each browser and device, and the steps may vary. For detailed instructions, we recommend consulting your browser's help centre or device documentation.
5 Other processing
6 Who We Share Information With
In the course of providing our website and conducting marketing activities, we may need to share certain aspects of your personal information with trusted third parties. These may include:
- Service Providers: We engage reputable service providers, such as hosting companies, email distribution services and event vendors to assist us in delivering our services effectively. These service providers are contractually obligated to handle your personal information solely for the purpose of providing their respective services and are bound by confidentiality obligations.
Some functionalities of our website require the sharing of certain aspects of your Personal Information with our service providers. Beyond this necessary sharing of data, we provide you with the option to give your consent for any other data sharing related to the website through the cookie consent banner.
- Legal and Regulatory Requirements: In some instances, we may be obligated to disclose your personal data in response to lawful requests or court orders from public authorities, including compliance with legal obligations, regulatory requirements, or to investigate and prevent fraudulent activities.
- Event Partners: If we hold an event, your personal information may be transferred to the involved parties as part of the event organisations. We ensure that appropriate safeguards and legal requirements are in place to protect your data during such transfers.
- Consent and Sharing Preferences: We may share your information with third-party marketing and advertising networks, subject to your explicit consent. This enables us to effectively promote our products and services on our website and on various platforms. You have the right to manage your sharing preferences and withdraw consent at any time using cookies.
- Aggregated and Anonymized Data: We may publish, share and potentially sell generalized and anonymized information that cannot be linked to any individual. Such data may be used for research, statistical analysis, or industry reporting purposes.
We take comprehensive measures to ensure that any sharing of your personal information complies with applicable data protection laws, including the General Data Protection Regulation (GDPR). We carefully select and assess the privacy practices of our third-party partners, and we enter into agreements that include data protection clauses and confidentiality commitments. Rest assured, we prioritize your privacy and work diligently to protect your information throughout any sharing processes.
7 Data Processing outside the EU
In certain circumstances, as part of our operations, we may transfer your personal data to entities located outside the European Economic Area (EEA). These international transfers may occur when we engage third-party service providers or partners located in countries outside the EEA. We want to assure you that we take appropriate measures to ensure the protection of your personal data during these transfers. Such measures may include implementing standard contractual clauses approved by the European Commission, verifying the recipient's adherence to binding corporate rules, or relying on the recipient's Privacy Shield certification (if applicable). By providing your personal data to us, you acknowledge and consent to the transfer of your data to these countries and the necessary safeguards we have in place to protect your privacy and comply with applicable data protection laws, including the General Data Protection Regulation (GDPR). Rest assured that we will always strive to uphold the highest standards of data protection and security, regardless of the location of the data transfer.
8 Data Security
At Moniflo, we take the security of your personal data seriously and implement appropriate measures to protect it in accordance with the General Data Protection Regulation (GDPR). We maintain a robust data security framework designed to safeguard your information from unauthorized access, disclosure, alteration, or destruction.
We employ industry-standard security practices to ensure the confidentiality, integrity, and availability of your personal data. These measures include:
- Access Controls: We implement strict access controls to limit access to your personal data to authorized personnel only. Access privileges are granted based on the principle of least privilege, ensuring that individuals can only access the data necessary to perform their designated tasks.
- Regular Security Assessments: We conduct regular security assessments and audits to identify and address any vulnerabilities or potential threats to the confidentiality and integrity of your personal data. This allows us to proactively improve our security measures and maintain a robust security posture.
- Employee Training: We provide comprehensive data protection and security training to our employees to ensure they understand their responsibilities and obligations when handling personal data. This training includes awareness of data protection laws, security best practices, and the proper handling and processing of personal information.
- Data Minimization: We practice data minimization, ensuring that we only collect and retain personal data that is necessary for the provision of the website and marketing activities. We avoid collecting excessive or unnecessary information to minimize potential risks associated with data storage and processing.
- Incident Response: In the event of a data breach or security incident, we have established procedures to respond promptly and effectively. We maintain an incident response plan that includes containment, assessment, notification, and mitigation measures to minimize any potential impact on your personal data.
While we implement robust security measures, it is important to note that no method of transmission or storage is entirely secure. We cannot guarantee absolute security, but we are committed to continuously monitoring and enhancing our security practices to protect your personal data.
If you have any concerns regarding the security of your personal data or if you suspect any unauthorized access or breach, please contact us on firstname.lastname@example.org.
For further information you may contact us any time, for example via email to email@example.com or firstname.lastname@example.org.
Version 1.1.1 (29.08.2023)