Privacy Notice for the Moloni Sales app
This Privacy Notice is intended to help you understand how Moloni processes your personal data when using the Moloni Sales app, available for iOS and Android, as a sales force solution.
Roles and responsibilities
Moloni Unipessoal, Lda. is an integral part of the Visma Group, a Norwegian group of software development companies. Moloni acts as the data controller for the personal data related to your account and the use of the app (authentication, support, security, and subscription billing). When you use the app to process personal data of third parties in the management of your business (e.g., employees, customers), Moloni acts as a data processor, under the terms of the service agreement and data processing agreement concluded with your organisation, which remains the data controller for that processing.
Contact us
If you have any comments or questions about this Privacy Notice, or any privacy concerns, including potential data breaches or any improper processing, please contact us through our support channels for further routing, or, if you wish to contact Moloni's Data Protection Officer directly, send an email to dpo@moloni.com.
You may also contact us at our operational address:
Av. José Malhoa, n.º 2 - Tardoz
Ed. Malhoa Plaza, Escritório 1.5
1070-325 Lisboa, Portugal
Processing activities
Data processed to provide the service
The app allows you to quickly issue sales and transport documents from your mobile device, functioning as a point-of-sale terminal for mobile sales teams, with real-time synchronisation with your Moloni account.
The lawfulness of this processing is based on the performance of the service contract you have with Moloni, under GDPR Article 6(1)(b), and may also be based on legal obligations regarding tax and invoicing matters, under point (c) of the same article, where applicable.
This data is retained in accordance with the Moloni Service Privacy Notice and our Data Retention Policy, available at https://www.moloni.pt/legal/?file=retencao-dados.
Device permissions
The app may use the device camera as an item barcode scanner and the location feature to discover nearby Bluetooth devices.
App improvement and security
We strive to ensure that the app operates correctly and securely. In this framework, 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 to provide the service described above.
Categories of data processed by the app
The following table summarises, by category, whether the app processes personal data falling within that type, based on the app's functionality and current app store disclosures:
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 companies in the Visma Group. The goal 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 using 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 the EU Standard Contractual Clauses. Should you require more detailed information about our processors, please contact us at dpo@moloni.com.
Public authorities
Law enforcement 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 procedures to evaluate access requests and seek legal advice whenever necessary. We only share information strictly required by law, and only on the basis of court orders or other legally 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 guarantees high standards of security and confidentiality.
Furthermore, we ensure legal obligations in contracts with our processors, guaranteeing that they also implement organisational and security measures similar to ours.
If we receive access requests from authorities outside the EEA, we ensure compliance with Article 32 of the Data Act. Internal policies and routines comply with this regulation.
Your rights
You may exercise 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 request that we restrict the processing of your personal data.
- Portability: You may request that we provide your personal data to you or others 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, the exercise of official authority, or legitimate interests.
Please note that there may be exceptions or limitations to the rights mentioned above depending on the specific circumstances of your situation. In such cases, we will provide detailed information regarding the applicable exception or limitation and assist you in exercising your rights to the fullest extent possible under applicable laws and regulations.
If you wish to exercise any of your data protection rights, please submit a support request on the website Moloni 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 Comissão Nacional de Proteção de Dados, which can be contacted via geral@cnpd.pt.