Privacy Notice for the Moloni Manager app
This Privacy Notice aims to help you understand how Moloni processes your personal data when using the Moloni Manager app, available for iOS and Android, as a mobile business management solution.
Roles and Responsibilities
Moloni Unipessoal, Lda. is part of the Visma Group, a Norwegian group of software development companies. Moloni acts as the data controller for personal data relating to your account and app usage (authentication, support, security, and subscription billing). When you use the app to process personal data of third parties in the context of managing your business (e.g. employees, customers), Moloni acts as a data processor under the terms of the service agreement and data processing agreement entered into with your organisation, which remains the data controller for such processing.
Contact Us
If you have any comments or questions about this Privacy Notice, or any privacy concerns, including potential data breaches or improper processing, please contact us through our support channels for routing or, if you wish to contact Moloni's Data Protection Officer, send an email to dpo@moloni.com.
You can also contact us at the following operational address:
Av. José Malhoa, n.º 2 - Tardoz
Ed. Malhoa Plaza, Escritório 1.5
1070-325 Lisbon, Portugal
Processing Activities
Data Processed for Service Delivery
The app synchronises with your Moloni account to give you access from your mobile phone to your business information — points of sale, stores, terminals, items, item families, sales representatives, and customer debts — as well as the issuance of sales documents, rectifications, waybills, and AT road transport codes. This data, namely contact details of customers/suppliers and outstanding debt amounts, is processed to perform the Moloni service agreement you hold with your organisation.
The lawful basis for this processing is the performance of the service contract you have with Moloni, pursuant to Article 6(1)(b) of the GDPR, and may also be based on legal obligations regarding tax and invoicing matters, pursuant to point (c) of the same Article, where applicable.
This data is retained under the terms of the Moloni Service Privacy Notice and our Data Retention Policy, available at https://www.moloni.pt/legal/?file=retencao-dados.
App Improvement and Security
We strive to ensure that the app operates correctly and securely. In this context, we note that this app does not collect diagnostic data, usage data, or device identifiers for its own analytics, advertising, or error detection purposes, distinct from the data processed for service delivery described above.
Categories of Data Processed by the App
The following table summarises, by category, whether the app processes personal data falling into each type, based on app functionality and current declarations in app stores:
How Your Personal Data May Be Shared
Within the Visma Group
The Visma Group consists of several subsidiaries. In order to ensure a coherent overview and consistent learning within an integrated knowledge framework, we may share your personal data among Visma Group companies. The intention is to optimise operations and provide you with a more integrated and seamless experience.
Outside the Visma Group
We may also share your personal data with external third parties, limited to the following contexts:
Data Processors
We use data processors to process personal data. These processors are typically cloud-based service providers. When we use data processors, we enter into a data processing agreement to safeguard your privacy rights. If processors are located outside the EU/EEA, we ensure the legal basis for such international transfers, such as through the implementation of EU Standard Contractual Clauses. If you require more detailed information about our processors, please request it by contacting dpo@moloni.com.
Public Authorities
Police and other authorities may request access to information held by us. This may include personal and non-personal data.
In all such cases, we follow strict internal policies and routines to assess access requests and seek legal advice whenever necessary. We only share information strictly required by law, and only based on court orders or other binding documents.
To prevent unauthorised access to any information we hold, we also implement technical measures such as encryption and access controls. The Visma Security Programme ensures high standards of security and confidentiality.
Furthermore, we enforce legal obligations in contracts with our processors ensuring they also implement organisational and security measures similar to ours.
If we receive access requests from authorities outside the EEA, we ensure our compliance with Article 32 of the Data Act. Internal policies and routines comply with this regulation.
Your Rights
You may invoke the following rights regarding our processing of your personal data:
- Access: You have the right to request a copy of the personal data we process about you.
- Rectification: You also have the right to request the rectification of inaccurate personal data concerning you.
- Erasure: You may request the erasure of personal data concerning you.
- Restriction: You may ask us to restrict the processing of your personal data.
- Portability: You may ask us to provide you or others with your personal data in a structured, commonly used, and machine-readable format.
- Objection: You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes. You also have the right to object to the processing of your personal data based on public interest or in the exercise of official authority.
Please note that exceptions or limitations to the rights above may apply depending on the specific circumstances of your situation. In such cases, we will provide detailed information about the applicable exception or limitation and assist you in exercising your rights to the fullest extent possible in accordance with applicable laws and regulations.
If you wish to exercise any of your data protection rights, please submit a support request on our Moloni website or send an email to dpo@moloni.com.
Finally, you also have the right to lodge a complaint with data protection authorities regarding our processing of your personal data. In Portugal, the supervisory authority is the National Data Protection Commission (CNPD), which can be contacted at geral@cnpd.pt.