Privacy Policy

Effective date and last updated: 16 October 2026 (AI providers updated; hosting and email providers named; assistant summary described in full)

The short version

This policy is long because the law asks us to be complete. These are the points that matter most, in plain words. Reading this summary does not replace the full policy below, which governs if anything here is unclear.

We do not sell your data and we do not share your financial data with advertisers.
Some features use AI. Anything that can identify you or describes your money (alerts, statements, names, amounts, receipt images) goes only to Google's Gemini on Google's paid tier, which does not use it to improve Google's products. Only shop names, with every number and name removed by our software first, may go to free AI services (Google, xAI, Cloudflare, OpenRouter, NVIDIA). The one exception is the AI assistant: until we connect a paid account, your questions and a summary of your finances (totals, categories, budgets, goals and your 40 most recent transactions, but not your name, and with names and numbers removed from transaction descriptions) go to those free services, which may use them under their own terms. AI never decides an amount or whether money came in or went out; our rules do, and you confirm. Section 9 has the details.
Bank alerts you choose to send us are read to create transactions. For accuracy, we keep the original text of alerts and statement lines you import and review, together with any corrections you make, unless you turn off “Help improve Automonie” in Settings.
You can see, correct, export and delete your data, and you can delete your account, which deletes your data apart from what the law requires us to keep.
Contact: tobe@automonie.com. You can also complain to the Nigeria Data Protection Commission.

About this policy and who we are
Definitions and interpretation
Scope and application
Personal data we collect
Where your personal data comes from
Bank alerts, notifications, messages and statements
Purposes of processing
Lawful bases for processing
Artificial intelligence and automated processing
Automated decision-making and profiling
Disclosure of personal data to third parties
Transfers of personal data outside Nigeria
Data retention
Security of processing
Personal data breaches
Your rights as a data subject
How to exercise your rights
Marketing and service communications
Cookies, local storage and similar technologies
Device permissions
Children
Beta programme, feedback, campaigns and community
Payments and subscriptions
Third-party websites and services
Changes to this policy
Governing law and disputes
General provisions
Contact us

1. About this policy and who we are

1.1. This Privacy Policy (the “Policy”) is issued by MICADOT-NG LIMITED (RC 9864079), a company incorporated in the Federal Republic of Nigeria, which owns and operates Automonie (“Automonie”, “we”, “us” and “our”). For the purposes of the Nigeria Data Protection Act 2023 (the “NDPA”), any regulations, guidance or directives issued under it by the Nigeria Data Protection Commission (the “Commission”), and any other data protection law that may apply to our processing of your personal data (together, “Data Protection Law”), MICADOT-NG LIMITED is the data controller of the personal data described in this Policy, except where this Policy states otherwise.

1.2. Automonie is a personal finance management service that helps you record, categorise, understand and plan around your money. It is provided through our website and web application, our Android application, and any other channel through which we make it available from time to time (together, the “Service”).

1.3. This Policy explains, in accordance with the transparency and notice obligations of Data Protection Law, what personal data we collect, the sources from which we obtain it, the purposes for which and lawful bases on which we process it, the persons to whom we disclose it, the places to which we transfer it, how long we retain it, how we protect it, and the rights that you have in relation to it, together with how you may exercise those rights.

1.4. This Policy should be read together with our Terms of Service, which govern your use of the Service. Where this Policy and the Terms of Service conflict on a matter concerning personal data, this Policy prevails to the extent of the conflict.

1.5. Automonie does not hold, move, transmit or store your money. It is not a bank, a payment service provider, a lender, an investment adviser or a deposit-taking institution, and nothing in this Policy should be read as suggesting otherwise. Nothing in the Service constitutes financial, investment, tax or legal advice.

2. Definitions and interpretation

2.1. In this Policy, unless the context requires otherwise, the following words and expressions have the meanings given below:

“Personal data” means any information relating to an identified or identifiable natural person, as more fully defined in the NDPA, and includes, without limitation, a name, an identification number, location data, an online identifier, and one or more factors specific to the physical, physiological, genetic, psychological, cultural, social or economic identity of that person.
“Sensitive personal data” has the meaning given to it in the NDPA. Because the Service is concerned with your finances, we treat all financial information that you provide to or generate through the Service with the care appropriate to sensitive personal data, whether or not Data Protection Law strictly classifies it as such in a given case.
“Processing” means any operation or set of operations performed on personal data, whether or not by automated means, including collection, recording, organisation, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment, combination, restriction, erasure or destruction, and “process” and “processed” are to be construed accordingly.
“Data subject”, “you” and “your” mean the natural person to whom personal data relates, and in particular any person who visits our website, joins our waitlist or newsletter, registers for, or uses, the Service.
“Data processor” means a person or organisation that processes personal data on our behalf and on our documented instructions.
“Third party” means any natural or legal person, public authority, agency or body other than you, us, and persons who, under our direct authority, are authorised to process personal data.
“Bank alert” means any message, notification, email, text message, document or image issued by or on behalf of a bank, payment service provider, wallet operator or other financial institution, or created by you, that records or describes a financial transaction, and that you choose to make available to the Service by any of the means described in this Policy.
“AI provider” means a third party that provides artificial intelligence or machine learning models, including large language models, that we call through an application programming interface in order to provide certain features of the Service.

2.2. Headings are for convenience only and do not affect interpretation. Words in the singular include the plural and vice versa. The words “include”, “including” and “in particular” are illustrative and do not limit the generality of the words preceding them. A reference to a law includes that law as amended, extended, re-enacted or replaced from time to time, and any subordinate legislation made under it.

3. Scope and application

3.1. This Policy applies to all personal data that we process in connection with the Service, our websites (including automonie.com and its subdomains), our waitlist, newsletter, beta programme, community groups we administer, campaigns, quizzes and calculators, customer support, and any correspondence between you and us.

3.2. This Policy applies whether you access the Service as a registered user, as a visitor who has not registered, as a person who has joined our waitlist or newsletter, or as a person whose personal data appears in information that a user provides to us (for example, the name of a person to whom a user sends money, as it appears in a bank alert).

3.3. Where personal data relating to another person (for example, a family member, a friend, a landlord, an employer or a merchant) appears in information you provide to us, you are responsible for ensuring that you are entitled to provide it to us. We process such data only for the purpose of providing the Service to you, such as identifying the counterparty to a transaction, and we do not contact such persons.

3.4. This Policy does not apply to the practices of third parties that we do not own or control, including banks, payment providers, app stores, email providers and other services that you may use alongside the Service. Their handling of your data is governed by their own policies.

4. Personal data we collect

4.1. The categories of personal data that we may collect and process, depending on how you use the Service and which features you choose to enable, are as follows.

4.2. Identity and contact data

Your full name and, where provided, a preferred first name.
Your email address, and your phone number or WhatsApp number where you provide it (for example, when you join the waitlist or beta programme).
If you sign in with Google, the name, email address and profile identifier that Google shares with us with your permission. We do not receive your Google password.

4.3. Account and authentication data

Your password, which we store only as a salted one-way cryptographic hash and which we cannot read or recover.
One-time verification codes, session tokens, the date and time sessions were issued, and records of security events such as sign-ins, password resets and “sign out of all devices” requests.
On mobile, whether you have enabled an app lock with a PIN or with biometrics. Biometric data (such as your fingerprint or face) is handled entirely by your device’s operating system and is never sent to us.
Settings and preferences you choose in the Service, including notification preferences, privacy toggles, and whether you have opted out of having your corrections used to improve the Service.

4.4. Financial data

Transactions, including their date, amount, direction (money in or money out), description, merchant or counterparty, category, the bank or account to which they relate, and how they were recorded (for example, entered manually, imported from a statement, captured from an alert, or shared to the app).
Account identifiers in truncated form only: the name of the bank or wallet and, where available, the last three or four digits of an account number. We do not intentionally store full account numbers, and where a full account number appears in content you provide, we take steps to remove or truncate it before storage.
Budgets, savings goals and the amounts you record against them, bills and reminders, subscriptions (whether entered by you or detected from your transactions), cash records, and notes.
Statements and documents you upload, including PDF, CSV, Excel and Word files and images, and the information extracted from them. Uploaded files are processed to extract transactions and are not retained in their original form after processing, except as described in section 13.
People and businesses you transact with, as derived from transaction descriptions, including any labels or relationships you assign to them (for example, “family” or “landlord”).
Information you tell us about yourself to personalise the Service, such as your stated monthly income, your primary financial goal, or whether you are a student or a corps member.

4.5. Bank alert content

The content of bank alerts you choose to make available to us by any of the channels described in section 6, including the text of emails, notifications and text messages from your bank or wallet provider, and the text visible in receipt images you share.
Metadata about those alerts, such as the time a notification was posted, the name of the app or sender that produced it, and the date an email was sent.

4.6. Content you create and communications

Questions you ask the AI assistant and the replies it gives.
Support requests, feedback, bug reports, survey answers and any other messages you send us, including any attachments.
Corrections you make to information the Service has read or inferred, such as changing a category, an amount, a date or a direction.

4.7. Technical and usage data

Internet Protocol (IP) address, device type and model, operating system and version, browser type and version, app version, language, time zone, and similar technical identifiers.
Logs of requests made to our servers, error reports and diagnostic information, which may include the time of a request and the feature used.
Information about how you use the Service, such as which screens and features you use, how often, and the outcome of actions such as imports.
A record of each calendar day on which you used the Service (the date only, kept for about thirteen months) and which of our apps you signed up in (web, Android or iPhone). We use these to count active users and how many people keep using the Service, in totals only.
If you enable push notifications, a push token that identifies your device to the notification service.

4.8. Payment data

Records of subscription purchases, such as the plan, the amount, the date, the payment reference and the outcome. Card details are entered directly with our payment provider and are never received or stored by us.
If you subscribe through Google Play in the Android app, the purchase token Google Play gives the app, the subscription's status and renewal date as reported to us by Google, and a coded identifier for your account that we pass to Google Play so a purchase can only be used by the account that made it. Google Play's own terms and privacy policy apply to the payment itself.

4.9. Marketing and community data

Your email address and, where provided, your WhatsApp number and how you heard about us, if you join our waitlist, newsletter or beta programme; your subscription status; and whether you have unsubscribed.
Campaign identifiers attached to links or QR codes you used to reach us, for example from a talk at a corps members’ community development service.

4.10. We do not knowingly collect data about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic or biometric data, health, or sex life or sexual orientation. However, such information may be inferable from, or may appear in, transaction descriptions you provide (for example, a payment to a place of worship or a hospital). We do not use transaction data to draw conclusions about these matters, and we process such descriptions only as part of the transaction record.

5. Where your personal data comes from

5.1. We obtain personal data from the following sources:

Directly from you, when you register, enter information, upload documents, forward or share alerts, enable capture features, contact us, or otherwise use the Service.
From your device, when you grant the Service permission to read notifications from approved bank apps or, on builds that offer it, text messages, as described in section 6 and section 20.
From your bank or wallet provider indirectly, through the alerts, statements and emails that they send to you and that you choose to make available to us.
From open-banking providers, where you choose to link an account through such a provider, as described in section 11.
From Google, where you choose to sign in with Google.
Generated by the Service, such as categories, insights, summaries, detected subscriptions, detected duplicates, budget progress and forecasts derived from your data.
From other users of the Service in aggregated, de-identified form, where corrections made by many users improve how the Service categorises a merchant for everyone, as described in section 7.

6. Bank alerts, notifications, messages and statements

6.1. A central feature of the Service is that it can create transaction records from the alerts and statements your bank or wallet provider already sends you, so that you do not have to type them. Each method is optional, each requires an action by you to enable it, and each can be stopped at any time. The methods, and what each involves, are set out below.

6.2. Email forwarding

If you set up forwarding, bank alert emails are sent to a personal address that we create for you. We process emails received at that address to identify bank alerts and extract transactions. We discard emails that do not appear to be from a financial institution. We may also process a one-time verification email from your email provider that is needed to confirm the forwarding rule. You can stop forwarding at any time in your email provider’s settings, and you can ask us to disable your forwarding address.

6.3. Notification capture on Android

If you enable notification capture and grant the Service notification access in your device settings, the Service reads notifications posted by the bank and wallet apps on your list of approved apps. The list starts with well-known Nigerian bank and wallet apps and you can add or remove apps. Notifications from apps that are not on your approved list are not sent to us. Where an app that is not on your list appears to post banking notifications, the Service may suggest it to you on your device so that you can decide whether to approve it; that suggestion is made on your device and the notifications concerned are not sent to us. Notifications from approved apps are sent to us to be read; those that are not transactions, such as one-time passwords, promotions, login notices and balance enquiries, are discarded. You can turn off notification access in your device settings at any time.

6.4. Text messages

Where a version of the Android app offers it and you grant the permission, the Service can read text messages on your device to find bank alerts. The search for bank alerts is carried out on your device. Transactions found, and the text of the alerts from which they were found, are then sent to us when you review and save them. Versions of the app distributed through the Google Play Store may not include this feature.

6.5. Sharing to Automonie

You can share the text of an alert, a receipt image or a PDF to the Service from another app. Shared text is read to prepare a transaction for you to confirm. Shared images may be transcribed using an AI provider, as described in section 9.

6.6. iPhone Shortcuts

If you set up an automation on an iPhone, your device forwards text messages from the senders you choose to the Service using a private capture key. You control which senders are forwarded and can delete the automation at any time.

6.7. Statements

You can upload bank statements. Password-protected statements require you to provide the password, which is used only to open the file at that moment and is not stored. We extract the transactions in the statement and check them against the balances printed in it where possible.

6.8. What we keep

From every alert or statement, we keep the transaction record we create. In addition, unless you turn off “Help improve Automonie” in Settings, we keep the original text of imported alerts and statement lines that you review, together with what the Service read and what you changed, so that we can measure and improve accuracy. Uploaded statement files and shared images are not kept after they have been processed. Capture keys are stored only in hashed form.

6.9. Your responsibility

The alerts and statements you make available to us may contain the personal data of other people, such as the names of people who sent you money. You confirm that you are entitled to make them available to us for the purpose of managing your own finances.

7. Purposes of processing

7.1. We process personal data for the following purposes and for no purpose incompatible with them:

Providing the Service: creating and maintaining your account; recording, reading, categorising and de-duplicating transactions; recognising your accounts; detecting subscriptions and recurring charges; calculating budgets, goals, summaries, reports, recaps and forecasts; and showing you insights about your money.
Accuracy and quality: checking imported transactions against statement balances; asking you to confirm items we are unsure about; learning from the corrections you make so that the Service categorises your future transactions the way you prefer; and, using corrections from many users in aggregated and de-identified form, improving how merchants are categorised for all users.
AI features: answering your questions in the AI assistant, reading statements, alerts and receipt images that our own rules cannot read, and suggesting the purpose of a transfer, as described in section 9.
Communications: sending service messages such as verification codes, password resets, security alerts, reminders you set, budget alerts, digests and notices about changes to the Service or this Policy; and, where you have agreed, newsletters and updates.
Support: responding to your requests, investigating problems you report, and improving our help materials.
Payments: processing subscriptions and keeping records of them.
Security and integrity: authenticating you; preventing, detecting and investigating fraud, abuse, security incidents and breaches of our Terms of Service; rate limiting; and keeping logs.
Product development: understanding how the Service is used, diagnosing errors, and planning and testing improvements, using aggregated or de-identified data wherever practicable.
Legal and regulatory: complying with legal obligations, responding to lawful requests from authorities, establishing, exercising or defending legal claims, and keeping records required by law, including tax and accounting records.

7.2. Should we wish to process personal data for a new purpose that is not compatible with the purposes above, we will inform you before doing so and, where required by Data Protection Law, seek your consent.

8. Lawful bases for processing

8.1. Data Protection Law requires us to have a lawful basis for each processing activity. We rely on the following:

Performance of a contract: processing that is necessary to provide the Service to you under our Terms of Service, or to take steps at your request before entering into that contract. This covers most of the processing described in section 7.1 under “Providing the Service”, “Communications” (service messages), “Support” and “Payments”.
Consent: processing that you have specifically agreed to, including notification capture, text message reading, email forwarding, iPhone Shortcuts capture, linking an account through an open-banking provider, sending content to an AI provider when you use an AI feature, push notifications, newsletters and marketing messages, and the processing of financial information to the extent that it constitutes sensitive personal data. You may withdraw consent at any time, as described in section 17. Withdrawal does not affect the lawfulness of processing carried out before it.
Legitimate interests: processing that is necessary for our legitimate interests, or those of a third party, provided those interests are not overridden by your interests, rights and freedoms. Our legitimate interests include keeping the Service secure, preventing fraud and abuse, improving accuracy and quality through corrections, understanding how the Service is used, and defending legal claims. Where we rely on legitimate interests, you have the right to object, as described in section 16.
Legal obligation: processing that is necessary to comply with a legal obligation to which we are subject, such as keeping financial records, responding to lawful orders, and notifying breaches.
Vital interests and public interest: in rare cases, processing necessary to protect someone’s life, or to perform a task carried out in the public interest or in the exercise of official authority vested in us.

9. Artificial intelligence and automated processing

9.1. Our approach. Most of what the Service does, including reading amounts, dates and whether money came in or went out, is done by fixed rules that we write and control, on our own servers, without any AI provider. We use an AI provider only for the features listed in this section, and only where those features are used.

9.2. Two kinds of AI use. We separate what we send to AI providers by what it contains:

Content that can identify you or describes your money (for example the text of an alert or statement, the names of people you pay, amounts, or a receipt image) is sent only to Google's Gemini models on Google's paid service tier, provided by Google LLC and its affiliates ("Google"). We never send this kind of content to a free or unpaid AI service.
Stripped shop names (the name of a shop or merchant, with every number, amount, account number, phone number, email address and person's name removed by our own software before anything is sent, and never the name of a person you transferred money to) may be sent to free service tiers of the following providers, tried in this order until one answers: Google (Gemini, unpaid tier); X.AI LLC (Grok); Cloudflare, Inc. (Workers AI); OpenRouter, Inc., which passes the request to one of the model providers it works with; and NVIDIA Corporation (NVIDIA NIM). Our software refuses to send anything to these providers that still contains a digit or an email address.

9.3. Paid tier terms. Under Google's terms for its paid Gemini services, as they stand on the date of this Policy, Google processes the content we send to provide the service to us and does not use it to improve its products. You can read Google's current terms at ai.google.dev/gemini-api/terms. Until we have connected a paid account, the features that need it are switched off and the Service relies on its own rules.

9.4. Free tier terms. The terms of the free tiers listed in section 9.2 may allow those providers to keep, review, or use what we send to improve their products. That is why only stripped shop names are ever sent to them. A stripped shop name on its own does not identify you, and the answers (the spending category for that shop) are stored by us without any link to you, so that the same shop is not asked about again.

9.5. Features that use AI, and what is sent.

Ask about your money (the assistant), on the paid tier: your question, the conversation so far, and a summary of your finances that includes your first name, your stated monthly income and goal where provided, your income and spending totals, your top spending categories, and your budgets and goals.
Ask about your money (the assistant), until a paid account is connected: the same question, conversation and summary go to the free service tiers listed in 9.2, tried in the same order, except that we leave out your name and remove every number, name and email address from transaction descriptions before sending. Free tiers may keep and use what they receive under their own terms, including to improve their services. The assistant shows a notice when it is running this way. Do not type passwords, card numbers or other secrets into it.
Receipt and screenshot images you share, on the paid tier: the image, so that the text in it can be transcribed. The transcribed text is then read by our own rules.
Receipts you scan in the app: the image is not sent to us or to any AI provider. The text in it is read on your device and sent to us, and our own rules read the total and the date. Where our rules cannot tell the shop or the category, the receipt's words are stripped as described in section 9.2 and may be sent to the free tiers; the AI may only suggest the shop name and the category, and you confirm every field before anything is saved.
Suggested categories for shops, on the free tiers: when you ask for suggestions for spending marked "Other", the stripped names of the shops involved. You confirm each suggestion before it is applied.
Statements our rules cannot read, on the paid tier: the text of the statement, which may include your name, the names of counterparties, transaction descriptions, amounts, dates and balances. Where possible we remove account numbers first. A statement read this way is accepted only if its opening balance plus credits minus debits equals its closing balance exactly; otherwise it is not imported.
Alerts our rules cannot read, on the paid tier, only when you are reviewing them before saving: the text of the alert, with account numbers removed where possible. The AI may only point to where the amount is written; our rules check it and decide whether money came in or went out, and you confirm it before it is saved. Alerts forwarded by email or captured automatically are never read this way.
Transfer purpose suggestions, on the paid tier, where offered: a description of the transfer pattern (the payee's name with account numbers removed, the amounts and how often), which you confirm before it is applied.

9.6. Your choice. You can avoid sending content to any AI provider by not using the features in section 9.5 and entering or correcting transactions yourself where an upload cannot be read by our rules. Using these features is not required to use the core Service.

9.7. Accuracy of AI output. AI output may be incomplete or wrong. The AI assistant provides general information about your own data and is not financial, investment, tax or legal advice. Where the Service uses AI to read a document, the result is checked by our rules and, where we are not confident, shown to you to confirm before it is relied on.

10. Automated decision-making and profiling

10.1. The Service automatically categorises transactions, detects recurring charges, flags possible duplicates, estimates spending trends, and produces insights and summaries about your finances. This is a form of profiling in the sense that it evaluates aspects of your financial situation.

10.2. These evaluations are produced for your own information and to help you manage your money. We do not make any decision based solely on automated processing that produces legal effects concerning you or similarly significantly affects you, such as a decision about credit, insurance, employment or eligibility for a service. We do not sell or provide these evaluations to lenders, insurers, employers or any other third party.

10.3. You can correct any automated categorisation or detection at any time, and the Service learns from your corrections for your own account.

11.1. We do not sell personal data, rent it, or share financial data with advertisers or data brokers. We disclose personal data only as described in this section, and only to the extent necessary for the purpose concerned.

11.2. Service providers acting as data processors. We use carefully selected providers to operate the Service. They process personal data on our instructions and are bound by obligations of confidentiality and security. They include providers of:

application hosting and server infrastructure (including Render and Vercel);
database hosting (MongoDB Atlas);
transactional and marketing email delivery (Brevo), and the receipt of forwarded emails (Postmark);
mobile app builds, over-the-air updates and push notification delivery (Expo);
website content management (Sanity), which holds the content of our public website and not your financial data;
artificial intelligence, as described in section 9 (Google on its paid tier for personal content; Google, xAI, Cloudflare, OpenRouter and NVIDIA for stripped shop names and, until a paid account is connected, the AI assistant);
payments, including Google Play for subscriptions bought in the Android app;
airtime, data, TV and electricity purchases, where that feature is available: VTpass (VTPass Technologies Limited) receives the phone, smartcard or meter number and the amount needed to make the purchase, and the card payment is taken by Paystack. Card details go directly to Paystack and are never received or stored by us.

11.3. Independent providers you choose to use. Some providers process personal data under their own terms and policies, as controllers in their own right, when you choose to use a feature that relies on them:

Google, for the AI features described in section 9, and for sign-in if you choose to sign in with Google.
Open-banking providers (Mono), once bank linking launches (coming soon), if you choose to link an account. Access is read-only and cannot be used to move money. You enter your bank credentials with the provider and your bank, never with us, and we never see or store them.
Paystack, to process subscription payments. We never receive your card details.
App stores (such as Google Play), when you download the app.

11.4. Legal and protective disclosures. We may disclose personal data where we believe in good faith that it is required by law, regulation, court order or other valid legal process; to respond to lawful requests from public authorities, including to meet national security or law enforcement requirements; to enforce our Terms of Service; or to protect the rights, property or safety of MICADOT-NG LIMITED, our users or the public. Where permitted, we will tell you about such a request.

11.5. Business transfers. If MICADOT-NG LIMITED is involved in a merger, acquisition, reorganisation, sale of assets, financing or insolvency, personal data may be transferred to the successor or acquirer, subject to its continued protection on terms no less protective than this Policy. We will notify you before your personal data becomes subject to a different privacy policy.

11.6. With your instruction. We disclose personal data to any other person where you ask us to, for example when you export a report and choose to send it to someone.

11.7. Aggregated and de-identified data. We may use and share information that has been aggregated or de-identified so that it no longer identifies you, for example statistics about how many users imported a statement in a month. We take reasonable measures to ensure such information cannot be re-identified.

12. Transfers of personal data outside Nigeria

12.1. Several of our providers, including our hosting providers, our email provider and Google, process data in countries outside Nigeria, which may include the United States, member states of the European Union and other countries.

12.2. Where we transfer personal data outside Nigeria, we do so in accordance with the NDPA, relying on one or more of the grounds it provides, including that the recipient is subject to a law, binding corporate rules, contractual clauses, code of conduct or certification mechanism that affords an adequate level of protection; that you have consented to the transfer after being informed of the possible risks; or that the transfer is necessary for the performance of a contract between you and us or for the implementation of pre-contractual measures taken at your request.

12.3. In particular, by using the AI features described in section 9 you consent to the transfer of the content described in that section to the providers named there, outside Nigeria, having been informed in sections 9.3 and 9.4 of the terms on which they may use it.

13. Data retention

13.1. We retain personal data only for as long as is necessary for the purposes for which it was collected, including the purpose of meeting any legal, accounting or reporting requirements. In determining the appropriate period, we consider the amount, nature and sensitivity of the data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, whether we can achieve those purposes by other means, and applicable legal requirements.

13.2. Subject to sections 13.3 and 13.4, our standard retention periods are:

Account, financial and content data: for as long as your account remains open. When you delete your account, we delete this data, including your transactions, budgets, goals, bills, subscriptions, accounts, contacts, notifications and correction records, promptly and in any event within thirty (30) days, save for copies in routine backups, which are overwritten in the ordinary course within a further period not exceeding ninety (90) days.
Uploaded statement files and shared images: not retained after processing.
Original alert and statement text kept for accuracy: while your account is open, unless you turn off “Help improve Automonie”, in which case we stop keeping new text.
Waitlist and newsletter data: until you unsubscribe or ask us to delete it, or until it is no longer needed for the purpose for which it was collected.
Support and feedback correspondence: for up to two (2) years after the matter is closed, unless it is needed for longer to resolve a dispute.
Payment records: for the period required by tax and accounting law, which may be up to six (6) years after the transaction or longer where the law requires.
Security logs: for a limited period, generally not more than twelve (12) months, unless needed to investigate an incident.

13.3. We may retain personal data for longer where required or permitted by law, where it is necessary to establish, exercise or defend legal claims, or where you have asked us to.

13.4. Aggregated or de-identified information that can no longer identify you may be retained indefinitely.

14. Security of processing

14.1. We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data, having regard to the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing as well as the risks to your rights and freedoms. These measures include:

encryption of data in transit between your device and our servers using HTTPS and Transport Layer Security;
storage of passwords and capture keys only as one-way cryptographic hashes;
truncation of account numbers, and the removal of full account numbers from content where practicable before storage or transmission to an AI provider;
access controls that limit access to personal data to authorised personnel who need it, and authentication for every request to your data;
rate limiting and monitoring to detect and prevent abuse;
optional two-step verification and, on mobile, an app lock using a PIN or your device’s biometrics;
read-only access where you link an account through an open-banking provider (bank linking is coming soon); and
contractual obligations of confidentiality and security on our providers.

14.2. No method of transmission over the internet and no method of electronic storage is completely secure. While we work to protect your personal data, we cannot guarantee its absolute security. You are responsible for keeping your password, PIN and devices secure, and for telling us promptly if you believe your account has been compromised.

15. Personal data breaches

15.1. If a personal data breach occurs that is likely to result in a risk to your rights and freedoms, we will notify the Commission within seventy-two (72) hours of becoming aware of it, or as otherwise required by the NDPA, and, where the breach is likely to result in a high risk to your rights and freedoms, we will inform you without undue delay in plain language, describing the nature of the breach, its likely consequences, the measures we have taken or propose to take, and the steps you can take to protect yourself.

16. Your rights as a data subject

16.1. Subject to the conditions, limitations and exceptions set out in Data Protection Law, you have the following rights in relation to your personal data:

Right to be informed: to receive clear information about how we process your personal data, which this Policy provides.
Right of access: to obtain confirmation of whether we process your personal data and, if so, a copy of it together with information about the processing.
Right to rectification: to have inaccurate personal data corrected and incomplete data completed. Most of your data can be corrected by you directly in the Service.
Right to erasure: to have your personal data deleted where it is no longer necessary, where you withdraw consent on which processing is based, where you object and there are no overriding legitimate grounds, or where it has been processed unlawfully. You can delete your account in the Service, or request deletion on our delete your account page.
Right to restriction: to ask us to restrict processing while the accuracy of data or the lawfulness of processing is being checked, or in other circumstances set out in Data Protection Law.
Right to data portability: to receive personal data you have provided to us in a structured, commonly used and machine-readable format, and to have it transmitted to another controller where technically feasible. You can export your transactions from the Service.
Right to object: to object at any time to processing based on our legitimate interests, and absolutely to processing for direct marketing.
Right to withdraw consent: at any time, where processing is based on consent, without affecting the lawfulness of processing before withdrawal.
Rights relating to automated decision-making: not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects, as described in section 10.
Right to complain: to lodge a complaint with the Nigeria Data Protection Commission, or with the supervisory authority where you live or work if outside Nigeria. We would appreciate the opportunity to address your concern first.

17. How to exercise your rights

17.1. Many rights can be exercised directly in the Service: you can edit and delete transactions and other records, export your data, change your settings, turn off “Help improve Automonie”, turn off capture features, unsubscribe from newsletters, and delete your account (also possible without the app on our delete your account page). For anything else, email tobe@automonie.com from the email address associated with your account.

17.2. To protect your data, we may need to verify your identity before acting on a request, and we may ask for further information for that purpose. We will not use that information for any other purpose.

17.3. We will respond to requests within thirty (30) days of receipt or such other period as Data Protection Law permits. Where a request is complex or we receive many requests, we may extend that period as permitted by law and will tell you why.

17.4. Exercising your rights is free of charge. However, where a request is manifestly unfounded or excessive, in particular because of its repetitive character, we may charge a reasonable fee reflecting our administrative costs, or refuse to act on it, and we will explain our reasons.

17.5. To withdraw consent for specific features: turn off notification access in your device settings; revoke the text message permission in your device settings; remove the email forwarding rule in your email provider; delete the iPhone Shortcuts automation; disconnect a linked account in the Service or with the open-banking provider; stop using the AI features; turn off push notifications in your device settings; or use the unsubscribe link in any marketing email.

18. Marketing and service communications

18.1. We send service communications that are necessary to provide the Service and to keep your account secure, such as verification codes, password resets, security notices, reminders you have set, and notices of material changes. You cannot opt out of essential service communications while you have an account, but you can control many reminders and alerts in Settings.

18.2. We send newsletters and promotional messages only where you have agreed, or where otherwise permitted by law. Each marketing email contains an unsubscribe link, and you can opt out at any time. If you join our community groups on third-party platforms such as WhatsApp, your participation is also governed by that platform’s terms and policies, and other members of the group may be able to see your name and number.

19. Cookies, local storage and similar technologies

19.1. Our web application uses your browser’s local storage to keep you signed in and to remember preferences such as your theme and the account you are viewing. These are strictly necessary for the Service to work as you request.

19.2. We do not use advertising cookies or third-party advertising trackers. Our hosting and website providers may set technical cookies or collect technical data needed to deliver pages securely and reliably.

19.3. You can clear local storage and cookies in your browser settings. If you do, you will be signed out and your preferences will be reset.

20. Device permissions

20.1. The mobile app may ask for the following permissions. Each is requested only when you use the feature that needs it, and each can be refused or revoked in your device settings:

Notification access: to read notifications from approved bank and wallet apps, as described in section 6.3.
Text messages: on builds that offer it, to find bank alerts in your messages, as described in section 6.4.
Notifications: to send you reminders and alerts.
Microphone: if you use voice logging, to turn what you say into a transaction. Speech recognition is performed by your device.
Camera and photos: if you choose to capture or select an image of a receipt. A scanned receipt is read on your device and the app deletes its copy of the photo afterwards; a photo you pick from your gallery stays in your gallery.
Biometrics: if you enable app lock with a fingerprint or face, handled entirely by your device.

21. Children

21.1. The Service is intended for persons aged eighteen (18) years and above. We do not knowingly collect personal data from children. If you are a parent or guardian and believe that a child has provided us with personal data, please contact us and we will take steps to delete it. Where a student plan or similar offering is made available, it is intended for students who are aged eighteen or above.

22. Beta programme, feedback, campaigns and community

22.1. If you join our beta programme, we process your contact details and the feedback you send to improve the Service, and we may invite you to a community group. Beta versions may contain features not yet available generally and may be less stable; the same protections in this Policy apply to them.

22.2. If you reach us through a campaign link or QR code, we record which campaign brought you to us so that we can understand which activities are effective. We record this against the campaign, not to build a profile of you.

22.3. Quizzes and calculators on our website may be used without an account. Answers are processed to show you a result and, where you choose to share them, to send them to the destination you pick.

23. Payments and subscriptions

23.1. Paid plans are processed by our payment provider. You enter your card or payment details directly with that provider, and we receive only confirmation of the payment, its reference, amount, date and status. We do not receive or store full card numbers, card security codes or bank login details.

24. Third-party websites and services

24.1. The Service may contain links to, or integrations with, third-party websites, apps and services, such as your bank, your email provider, app stores, community platforms and the guides we provide for cancelling subscriptions. We are not responsible for the privacy practices of those third parties, and we encourage you to read their policies.

25. Changes to this policy

25.1. We may amend this Policy from time to time to reflect changes in our processing, the Service, or the law. The date at the top of this Policy shows when it was last updated. Where we make a material change, including a change of AI provider or of the terms on which we use one, we will notify you in the Service or by email before the change takes effect, and where Data Protection Law requires, we will seek your consent. Your continued use of the Service after a change takes effect signifies that you have read the updated Policy; it does not signify consent where consent is separately required.

26. Governing law and disputes

26.1. This Policy is governed by the laws of the Federal Republic of Nigeria, including the NDPA. Without prejudice to your right to complain to the Commission or to any other authority, any dispute arising out of or in connection with this Policy shall be subject to the dispute resolution provisions of our Terms of Service.

27. General provisions

27.1. If any provision of this Policy is held to be invalid or unenforceable, that provision shall be enforced to the maximum extent permissible and the remaining provisions shall continue in full force and effect.

27.2. Nothing in this Policy limits any right you have under Data Protection Law that cannot be limited by agreement.

27.3. This Policy is written in English. Where we provide a translation, the English version prevails in the event of inconsistency.

28. Contact us

28.1. For any question about this Policy, to exercise any of your rights, or to make a complaint, contact us at tobe@automonie.com, with the subject line “Data protection”. We will acknowledge your message and respond within the period set out in section 17.3.

28.2. If you are not satisfied with our response, you may contact the Nigeria Data Protection Commission through its official channels.