Privacy Notice for the Moloni Stocks app
This Privacy Notice aims to help you understand how Moloni processes your personal data when using the Moloni Stocks app, available for iOS and Android, as a stock counting and management 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 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 acts as the data controller for such processing.
Contact us
If you have any comments or questions regarding this Privacy Notice, or any privacy concerns, including potential data breaches or any inappropriate processing, please contact us via our support channels for further routing or, if you wish to contact Moloni's Data Protection Officer, send an email to dpo@moloni.com.
You can also contact our operational address at:
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 set up reading sessions by department, warehouse, or store for item counting using the device camera (barcode scanner) or manual input via EAN code/reference, synchronising the collected data with the stock levels in your Moloni account.
The legal basis for this processing is the performance of the service agreement with Moloni, pursuant to GDPR Article 6(1)(b), 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.
Device permissions
The app uses the device camera as an item barcode scanner. Captured images are processed locally to identify the item code and are neither stored nor transmitted.
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 to provide the service described above.
Categories of data processed by the app
The following table summarizes, by category, whether the app processes personal data falling within that category, based on the functionality of the app 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 insights within an integrated knowledge framework, we may share your personal data among companies in the Visma Group. The intention is to optimise operations and provide you with a more seamless, integrated experience.
Outside the Visma Group
We may also share your personal data with external third parties, limited strictly 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 in order 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 regarding our data 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 procedures to evaluate 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 unauthorized access to any information we hold, we also implement technical measures such as encryption and access controls. The Visma Security Program ensures high standards of security and confidentiality.
In addition, we ensure legal obligations in contracts with our data processors, requiring them to implement organizational 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 list of the personal data we process about you.
- Rectification: You also have the right to request the correction of inaccurate personal data concerning you.
- Erasure: You can request the deletion of personal data concerning you.
- Restriction: You can ask us to restrict the processing of your personal data.
- Data portability: You can ask us to provide you or third parties 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, or based on legitimate interests.
Please note that exceptions or limitations to the above-mentioned rights may apply 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 in accordance with applicable laws and regulations.
If you wish to exercise any of your data protection rights, please submit a support request on the Moloni website or send an email to dpo@moloni.com.
Finally, you also have the right to lodge a complaint with the 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 via email at geral@cnpd.pt.