Privacy Policy

Last Update: August 14, 2026

MoneyCoach UG (haftungsbeschränkt)
c/o Volkssolidarität e. V.
Alte Schönhauser Straße 16
10119 Berlin, Deutschland

Privacy Officer: privacy@moneycoach.ai
Legal Representative: Perjan Duro, Managing Director

🛡️ Our Privacy Promise: We built MoneyCoach because we wanted a financial app that respects privacy. As daily users ourselves, we only collect what's absolutely necessary to make the app work well for you.

What You Should Know

We use MoneyCoach ourselves every day, so we care about privacy just as much as you do. Here's what matters most:

🔒 We never sell your data - Your financial information is never sold to anyone, ever.

📱 Local by default, with optional services - Financial data you enter manually is primarily stored on your device. Features you choose to enable, including iCloud, Online Banking, and MCP connections, may transfer specific data as explained below.

🏦 You control bank connections - Only you decide which accounts to connect, and you can disconnect anytime.

🤖 Optional Online Banking categorization - When you enable Online Banking, limited imported transaction information may be processed by the Google Gemini API to suggest a category.

🔌 Optional AI connections are controlled by you - MoneyCoach MCP is off unless you enable it and connect a compatible third-party client yourself.

☁️ Optional cloud sync - You choose whether to sync via iCloud. It's always encrypted.

✋ Easy to leave - Delete the app, delete your data. No questions asked.

1. Who We Are

MoneyCoach UG is a German company that makes personal finance apps. We're based in Berlin and follow German and European data protection law (DSGVO/GDPR).

When you connect your bank accounts, we work with GoCardless (EU-licensed in Latvia) to securely access your banking data. For the optional Online Banking feature, we use Google Firebase infrastructure and the Google Gemini API to process limited transaction information for categorization.

2. What Data We Collect

Financial Data Categories

Transaction Information (Stored Locally) We store your financial transactions including amounts, currencies, dates, and merchant names. This includes payment methods you use (cash, card, or transfer), any personal notes you add, and custom categories you create to organize your spending.

Account Information (When Using Open Banking) When you connect bank accounts, we access account names, identifiers like IBAN numbers, current and historical balances, account types (checking, savings, credit), and currency information.

Budgeting & Planning Data Your budgets include the limits and categories you set, savings goals and targets you're working toward, recurring transaction patterns we identify, and spending forecasts to help you plan ahead.

Technical Data Categories

Device & App Information We collect basic technical information like your device model, iOS version, app version, language settings, screen size, device capabilities, and when you installed or updated the app.

Usage Analytics (Optional) If enabled, we track which features you use most often, app performance metrics, how you interact with the interface, and how long and frequently you use the app.

Diagnostic Data When problems occur, we collect crash reports, error logs, performance monitoring data, network connectivity issues, and steps that help us reproduce and fix bugs.

What We Explicitly DON'T Collect

❌ Banking Credentials: Never your passwords or PINs
❌ Investment Details: No portfolio or trading information
❌ Location Data: No GPS tracking or location services
❌ Contacts: No access to your address book
❌ Photos: No image or document scanning

Data Collection Control:
You can disable analytics anytime in Settings → Privacy → Usage Data.

3. Legal Basis for Processing Your Data (DSGVO/GDPR)

Under Art. 6 Abs. 1 DSGVO/GDPR, we process your personal data based on these legal grounds:

Contract Performance (Art. 6 Abs. 1 lit. b DSGVO/GDPR)

• Purpose: Providing core app functionality, showing transactions and balances
• Data: Financial transactions, account balances, user-created categories
• Why necessary: Essential for delivering the personal finance management service you requested

Legitimate Interest (Art. 6 Abs. 1 lit. f DSGVO/GDPR)

• Purpose: App improvement, analytics, crash reporting, customer support
• Data: Usage statistics, crash logs, device information
• Our interest: Maintaining and improving our service
• Your rights: You can object to this processing at any time

Consent (Art. 6 Abs. 1 lit. a DSGVO/GDPR)

• Purpose: Bank account connections via Open Banking, categorization of imported Online Banking transactions, and optional AI Connections and MCP access
• Data: Banking data; limited imported transaction information sent to Google Gemini; and read-only local MoneyCoach data requested by MCP clients you choose to connect
• Your control: Withdrawable at any time in app settings

4. How We Use Your Data

To Make MoneyCoach Work

• Show your transactions and balances
• Sync across your devices (if you enable iCloud)
• Provide customer support when you need help

To Make It Better With AI

When you enable Online Banking, we may send limited information from newly imported transactions to the Google Gemini API to suggest a MoneyCoach category. Google receives a transaction reference, description, creditor name, debtor name, transaction type, and the available MoneyCoach category and subcategory names or identifiers. We do not send your bank login credentials to Gemini.

Firebase Genkit is the software framework MoneyCoach uses to connect this feature to Gemini; the third-party AI recipient is Google LLC. You can avoid this processing by not enabling Online Banking and stop future processing by disconnecting your Online Banking accounts. Google processes these requests under the service configuration and contractual terms applicable to MoneyCoach's Gemini API account.

To Improve the App

• See which features are popular
• Fix bugs and crashes
• Plan new features you'll actually use

5. Automated Decision-Making and AI Processing

MoneyCoach uses automated systems to enhance your experience:

AI Transaction Enhancement

• What it does: Suggests categories for transactions imported through Online Banking
• Technology and recipient: Firebase Genkit connects MoneyCoach to the Google Gemini API, provided by Google LLC
• Data: Transaction reference, description, creditor name, debtor name, transaction type, and available category and subcategory names or identifiers
• When it applies: Only when you choose to enable the optional Online Banking feature
• Your control: Do not enable Online Banking, or disconnect your Online Banking accounts, to prevent future imported transactions from being processed this way
• Manual override: You can edit any AI-suggested category

No Significant Automated Decisions

We do not make automated decisions that significantly affect you (like loan approvals, credit scoring, or account restrictions). All financial decisions remain entirely yours.

Your Rights (Art. 22 DSGVO/GDPR):

• Right to human intervention
• Right to express your point of view
• Right to contest any automated decision
• Right to obtain an explanation

6. Local MCP Server and AI Client Access

MoneyCoach may offer an optional local Model Context Protocol ("MCP") server that allows compatible AI clients selected by you to request access to certain MoneyCoach data on your device.

The MCP server is disabled by default. Before data becomes available through MCP, you must enable Allow AI Connections and confirm the in-app disclosure. If you cancel the confirmation, access remains disabled. You can withdraw permission at any time.

Data Your AI Client May Access

Depending on the permissions you grant, the MCP server may allow your AI client to access selected MoneyCoach data such as:

• Account names and balances
• Transactions, categories, dates, amounts, and currencies
• Budgets, goals, reports, active subscriptions, bills, and related financial metadata
• Payee and merchant names, transaction titles, descriptions, notes, invoice references, and purchase details when the corresponding sharing controls are enabled

MoneyCoach does not operate a remote MCP server or send MCP responses to MoneyCoach servers. The local helper returns requested records to the MCP client you configure. We do not store a separate copy of those responses or use them to train AI models.

Third-Party AI Clients and Model Providers

The recipient is the MCP client you select and configure, such as Claude Desktop, Cursor, Codex, Gemini CLI, Ollama, or another compatible client. When that client requests MoneyCoach data, it receives the requested records. If it uses a cloud-based AI provider, it may then transmit those records outside your device to a provider such as Anthropic, OpenAI, Google, or another provider configured by you.

MoneyCoach does not select or configure the MCP client or AI provider for you and does not control how they process, store, secure, train on, or use data they receive. Their own terms, privacy policies, account settings, logging, retention practices, security measures, training practices, and outputs apply. Review those terms before connecting them.

Where you independently choose a third-party AI or MCP client, that client is not a MoneyCoach subprocessor for the MCP feature. It is a recipient selected by you and may act as its own controller or service provider under its own terms.

Your Controls

You are responsible for choosing which AI client to connect and for reviewing the permissions you grant. Do not connect MoneyCoach to AI clients or model providers unless you understand that permitted MoneyCoach data may be accessed by that client and, depending on the client, may leave your device.

The Connect AI & MCP settings screen includes the main Allow AI Connections toggle plus privacy controls for sharing payee and merchant names and transaction descriptions. If you hide those details, a connected client can still request other permitted data such as balances, amounts, dates, categories, budgets, goals, reports, and financial metadata.

You may immediately block future MCP requests by turning off Allow AI Connections. You should also remove the MoneyCoach configuration from clients you no longer use. Disabling MCP does not delete copies that a client or its AI provider may already have retained under its own policy.

MCP Security Boundaries

The local MCP feature is designed to launch with read-only access. It does not create transactions, edit or delete MoneyCoach data, trigger sync, perform payments or bank transfers, or expose a MoneyCoach-hosted remote MCP server. If these boundaries change in the future, we will update this policy and the product controls.

7. Who We Share Data With

Financial Data Sharing

We do not sell your financial data. Your banking information, transactions, and budgets are shared only when needed for services you enable or with recipients you choose, including:

Service Providers Selected by MoneyCoach

We require service providers acting on our behalf to protect personal data consistently with this policy, our contractual requirements, and applicable data protection law. They may process data only for the services described here:

For Bank Connections:

• GoCardless, an EU-licensed payment service provider, for secure Open Banking connections
• Your data is processed within the European Union
• Bank-level security standards

For App Functionality:

• Cloud services for app analytics and crash reporting
• Google Firebase infrastructure for optional Online Banking functionality
• Google Gemini API, provided by Google LLC, to categorize transactions imported through optional Online Banking
• All processing follows European data protection standards

Optional Services:

• Apple iCloud for device synchronization (only if you enable it)

Recipients You Select and Direct

MCP clients and the AI providers configured inside them are selected and directed by you, not by MoneyCoach. MoneyCoach makes data available only after you enable MCP, confirm the disclosure, and configure a client. The identity of the AI provider therefore depends on your client configuration. See Section 6 for the data involved and the controls available to you.

8. Open Banking: How It Works

The Simple Version

1. You tap "Connect Bank" in MoneyCoach
2. We send you to your bank's website
3. You log in with your normal bank credentials
4. Your bank asks what data you want to share
5. You say yes, and data flows securely to MoneyCoach

Your Rights

• Connect and disconnect anytime - No penalties, no questions
• Choose which accounts - Connect checking but not savings, your choice
• Consent expires - After up to 180 days, you'll need to reconnect
• See everything - All connected accounts shown in app settings

Security

• Your bank login stays with your bank (we never see it)
• All data is encrypted during transfer and at rest
• Your data processed in secure, certified data centers

9. Data Retention Periods

We only keep your data as long as necessary. Here's exactly how long:

Personal & Financial Data

Technical Data

AI Processing Data

Your selected MCP client or AI provider may retain prompts, responses, or logs under its own policy and account settings. MoneyCoach does not control that retention.

Your Control:

• Immediate deletion: Disconnect bank accounts, disable features
• Complete removal: Delete app + contact us for server data
• Partial control: Turn off specific features anytime

10. Your Rights Under DSGVO/GDPR

You have comprehensive rights over your personal data:

🔍 Right to Access (Art. 15 DSGVO/GDPR)

What it means: Get a copy of all data we have about you
How to use it: Email us - we'll send a complete data export
Response time: Within 1 month, free of charge
Real example: "Show me all my support emails and any analytics data you have"

✏️ Right to Rectification (Art. 16 DSGVO/GDPR)

What it means: Correct any wrong or incomplete data
How to use it: Tell us what's incorrect
Response time: Fixed within 1 month
Real example: "My support email address is wrong in your system"

🗑️ Right to Erasure (Art. 17 DSGVO/GDPR)

What it means: Delete your data when no longer needed
How to use it: Request deletion via email
Response time: Within 1 month
Real example: "Delete all my support conversations and any server data"

📦 Right to Data Portability (Art. 20 DSGVO/GDPR)

What it means: Take your data to another service
How to use it: Request a structured data export
Format: JSON, CSV, or other machine-readable format
Real example: "I want to move my financial data to another app"

⏸️ Right to Restrict Processing (Art. 18 DSGVO/GDPR)

What it means: Pause data processing while resolving issues
How to use it: Email us with your concern
Real example: "Stop processing my data while we resolve this dispute"

🚫 Right to Object (Art. 21 DSGVO/GDPR)

What it means: Say no to data processing
How to use it: Object via email or app settings
Real example: "I don't want my usage data used for analytics"

🛡️ Rights Related to Automated Decision-Making (Art. 22 DSGVO/GDPR)

What it means: Control over AI/automated systems
How to use it: Manually edit any AI suggestions
Real example: "Change the category AI suggested for this transaction"

To Exercise Your Rights: 📧 Email: privacy@moneycoach.ai
🕰️ Response Time: Within 5 business days (acknowledgment), 1 month (completion)
🌍 Available in: All EU languages

11. Managing Your Consent

You have full control over what data we process and how:

Current Consent Status

Check what you've agreed to anytime in Settings → Privacy → Data Consent:

• 🟢 Required: Core app functionality (cannot be disabled)
• 🔵 Optional: Bank connections, AI enhancements, analytics
• ⚪ Disabled: Features you've turned off

How to Change Your Mind

Bank Account Connections

• Enable: Settings → Bank Accounts → Connect New Account
• Disable: Settings → Bank Accounts → Disconnect (instant)
• Effect: We immediately stop accessing your accounts

Usage Analytics

• Enable: Settings → Privacy → Usage Data → Share Data
• Disable: Settings → Privacy → Usage Data → Don't Share
• Effect: We stop collecting app usage statistics

iCloud Sync

• Enable: iOS Settings → [Your Name] → iCloud → MoneyCoach
• Disable: Same location, toggle off
• Effect: Data stops syncing between devices

AI Connections and MCP

• Enable: MoneyCoach for Mac → Settings → Connect AI & MCP → Allow AI Connections, then confirm the disclosure
• Disable: Turn off Allow AI Connections and remove the MoneyCoach MCP config from any third-party client you connected
• Effect: The local MCP helper immediately blocks future requests for MoneyCoach data. Disabling access does not delete information already retained by a client or provider.

Withdrawal Effects

What happens when you withdraw consent:

✅ Immediate: Processing stops within 24 hours
✅ No penalties: Full app functionality remains
✅ Data cleanup: Related data deleted per retention policy
✅ Re-consent: You can always change your mind later

Consent Records

We keep a record of your consent choices for legal compliance:

• When you gave consent
• What you consented to
• When you withdrew consent (if applicable)
• Method used (app settings, email, etc.)

12. International Data Transfers

We prioritize keeping your data within the EU:

🇪🇺 EU-Based Processing:

• Primary data storage: European Union
• Bank connections: EU-licensed provider (Latvia)
• Core app functions: Germany/EU infrastructure

🌍 Limited International Transfers: Only for specific technical services with full GDPR protection:

• AI enhancement services: US providers with Standard Contractual Clauses
• Analytics services: Global infrastructure with EU data residency options

Your Protection:

• ✅ Standard Contractual Clauses (Art. 46 GDPR)
• ✅ Adequacy decisions where available
• ✅ Additional safeguards for sensitive financial data
• ✅ Right to object to international transfers

All transfers comply with DSGVO/GDPR requirements.

13. Security Measures

Technical Protection

• All data encrypted during transfer and storage
• Multi-factor authentication for our systems
• Regular security audits
• Automatic security updates

What You Can Do

• Keep your phone updated
• Use strong banking passwords
• Don't share your MoneyCoach with others
• Contact us immediately if something seems wrong

14. Cookies and Tracking

In the App

The app uses some analytics tools (Firebase, Adjust) that create device identifiers. You can turn these off in Settings.

On Our Website

We don't use any cookies on our website. It works perfectly without them.

15. Changes to This Policy

We sometimes update this policy when we add new features or when laws change.

If we make important changes that affect how we handle your data, we'll let you know by:

• Sending you an email (if we have your email address)

For big changes, you'll have at least 30 days to review them before they take effect. If you don't like the changes, you can always delete your account or stop using the new features.

16. Data Protection Officer (DPO)

Our Data Protection Officer is your direct contact for all privacy matters:

📧 Email: privacy@moneycoach.ai
Address: MoneyCoach UG, c/o Volkssolidarität e. V., Alte Schönhauser Straße 16, 10119 Berlin

What our DPO can help you with:

• Exercise your DSGVO/GDPR rights (access, deletion, correction, etc.)
• Privacy concerns or complaints
• Data processing questions
• Consent management issues
• Data breach reports

Response times:

• Initial acknowledgment: Within 72 hours
• Full response: Within 30 days (as required by DSGVO/GDPR)
• Urgent matters: Within 24 hours

17. Contact Us

For General Privacy Questions

Email: privacy@moneycoach.ai
Response Time: Within 5 business days

For App Support

Email: support@moneycoach.ai
In-App: Settings → Support

For Regulatory Complaints

If you're not satisfied with our response, you can complain to the German data protection authority:

Der Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI)
Graurheindorfer Str. 153
53117 Bonn, Germany
📧 Email: poststelle@bfdi.bund.de
🌐 Website: bfdi.bund.de

18. Children's Privacy

MoneyCoach is for users 16 and older. We don't knowingly collect data from younger children. If you think we have, please contact us immediately.

This version: May 2026
Questions? We're here to help at privacy@moneycoach.ai