Privacy Policy

Last updated: October 9, 2026

Controller:
MoneyCoach UG (haftungsbeschränkt)
c/o Volkssolidarität e. V.
Alte Schönhauser Straße 16
10119 Berlin, Germany
Managing Director: Perjan Duro
Email: privacy@moneycoach.ai

Privacy contact: privacy@moneycoach.ai (see Section 19)

🛡️ Our Privacy Promise: We built MoneyCoach because we wanted a financial app that respects privacy. As daily users ourselves, we only collect the data we need for the app and the purposes set out in this policy.

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.

🇺🇸🇨🇦 Bank linking in the US and Canada - In the United States and Canada, bank connections are provided by Plaid Inc. Plaid receives your bank sign-in directly; we never see your banking password. See Sections 9A, 12A and 12B.

🤖 AI categorization is part of Online Banking - When you use Online Banking, limited information from imported transactions is sent to the Google Gemini API to suggest a category. There is no separate switch for this: if you don't want it, don't use Online Banking.

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

☁️ Optional MoneyCoach Cloud for AI assistants - If you are a Premium Max subscriber, you can choose to upload a read-only copy of selected financial data to our hosting provider in Germany, so AI assistants you approve can answer questions about it. It is off by default and you can delete the copy at any time. See Section 6A.

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

📊 You can switch off analytics - In-app usage analytics is on by default and uses pseudonymous data. You can turn it off at any time in the app's privacy settings.

✋ Easy to leave - Deleting the app removes the data on your device (iCloud copies stay in your iCloud until you delete them there). If you signed in, delete your account in the app under Settings → Manage Account → Delete Account; this also deletes your Online Banking data and any cloud copy on our servers. For any other data, email privacy@moneycoach.ai.

1. Who We Are

MoneyCoach UG (haftungsbeschränkt) is a German company that makes personal finance apps. We're based in Berlin and are the controller within the meaning of Art. 4(7) GDPR for the processing described in this policy, unless stated otherwise.

When you connect bank accounts, we use GoCardless (for banks in the EU/EEA and the UK) or, for banks in the United States and Canada, Plaid Inc. to 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. All service providers are listed in Section 7 (app) and Section 8 (website).

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.

Bank Data from Plaid (US and Canada) When you link a bank in the United States or Canada, Plaid sends us data about the accounts you choose to share: account names and types, the last digits of the account number (not the full number), current and available balances, and the currency. Plaid also sends your transactions (amount, date, merchant or payee name, description, category and pending or booked status), going back up to about two years when the bank provides it. Depending on the account type and your plan, Plaid may also send credit card and loan information (such as statement balance, minimum payment, due date, interest rates and credit limit) and, for investment accounts you link with Premium Max, your holdings (the securities you hold, quantities and values). We send Plaid a pseudonymous user ID so that it can associate your connection with your MoneyCoach account; we do not send it your email address or name. We do not request your full account and routing numbers or your identity details (such as your address or phone number) from Plaid.

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.

Account, Subscription and Support Data

User account: A pseudonymous user ID and, if you sign in, your email address and name.
Subscriptions: Your user ID, email address, name, purchase and subscription history, and, where available, the Apple AdServices attribution token that tells us whether an install came from an Apple Search Ads campaign.
Support and feedback: The content of your message, your email address, and any information you choose to include.

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 (On by Default, Can Be Switched Off) Unless you switch it off, we record which features you use, app performance metrics, how you interact with the interface, and how long and how frequently you use the app.

Diagnostic Data When problems occur, we collect crash reports (including your pseudonymous user ID), error logs, performance monitoring data, and network connectivity issues so we can reproduce and fix bugs.

What We Explicitly DON'T Collect

❌ Banking Credentials: Never your passwords or PINs. You enter them only with your bank or in Plaid's sign-in screen.
❌ Investment Details: No portfolio or trading information, unless you yourself link an investment account (US and Canada, Premium Max); then we receive your holdings from Plaid as described above
❌ Location Data: No GPS tracking or location services
❌ Contacts: No access to your address book
❌ Photos: No image or document scanning

Data Collection Control:
Usage analytics is on by default. You can switch it off at any time in the app's privacy settings.

3. Legal Basis for Processing Your Data (GDPR)

Under Art. 6(1) GDPR, we process your personal data based on these legal grounds:

Contract Performance (Art. 6(1)(b) GDPR)

• Purpose: Providing core app functionality, your user account, subscriptions, sync you enable, Online Banking (connecting your bank accounts via GoCardless or, in the United States and Canada, Plaid, keeping them in sync, and suggesting categories for imported transactions via Google Gemini), and answering your support requests
• Data: Financial transactions, account balances, user-created categories, banking data you authorize (in the United States and Canada, including credit, loan and investment holdings data from Plaid), limited imported transaction information sent to Google Gemini, account and subscription data, support messages
• Why necessary: Essential for delivering the personal finance management service you requested

Legitimate Interest (Art. 6(1)(f) GDPR)

• Purpose: Security and access logs for the optional cloud copy (Section 6A), crash reporting and stability, protecting our backend against abuse (App Check), improving merchant recognition, operating and securing our website, cookieless website statistics, processing names of other people (such as payees or payers) contained in your imported bank transactions, measuring how our subscription offers perform, attributing app installs to our Apple Search Ads campaigns, in-app usage analytics
• Data: Crash logs, device information, pseudonymous identifiers, usage analytics, pseudonymized transaction data (names removed, IBANs replaced by a keyed hash), server log data
• Our interest: Running a stable, secure service and improving its quality; for names of other people in your transactions, providing the Online Banking feature you use; for install attribution, measuring the effectiveness of our advertising
• Your rights: You can object to this processing at any time (see Section 13)

Consent (Art. 6(1)(a) GDPR)

• Purpose: The newsletter, playing embedded YouTube videos after you click them, email notifications about the country leaderboard, and optional AI Connections and MCP access, and the optional MoneyCoach Cloud for AI assistants (Section 6A)
• Data: Your email address for the newsletter; and read-only local MoneyCoach data requested by MCP clients you choose to connect
• Special-category risk (Art. 9(2)(a) GDPR): Payee, merchant and description text that you choose to include in the cloud copy can be free text and may reveal, for example, health or religious information. We upload this text only if you separately switch it on, and we ask for your explicit consent for it.
• Your control: You can withdraw your consent at any time with effect for the future (Art. 7(3) GDPR). Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

4. How We Use Your Data

To Make MoneyCoach Work

• Show your transactions and balances
• Sync across your devices (if you enable iCloud)
• Manage your subscription
• 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. This also applies to transactions imported through Plaid in the United States and Canada. 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.

Legal basis: Art. 6(1)(b) GDPR, because category suggestions are part of the Online Banking feature (see our Terms of Use). Names of other people in your transactions (such as payees or payers) are processed on the basis of Art. 6(1)(f) GDPR; the legitimate interest is providing the Online Banking feature you use. You can object (Section 13).

To Improve the App

• Fix bugs and crashes
• Improve how we recognize merchants in imported transactions
• Unless you switch off analytics: see which features are popular and 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
• Legal basis: Art. 6(1)(b) GDPR; names of other people Art. 6(1)(f) GDPR (see Section 4)
• 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.

As we make no decisions within the meaning of Art. 22 GDPR, the rights under Art. 22 do not apply. You can change any AI-suggested category at any time.

6. Local MCP Server and AI Client Access

This Section 6 describes the local MCP server on your Mac. The separate, optional cloud copy for AI assistants is described in Section 6A.

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

The local MCP server does not send MCP responses to MoneyCoach servers. (If you separately switch on MoneyCoach Cloud for AI assistants, Section 6A applies.) 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 AI Tools 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, or perform payments or bank transfers. The optional MoneyCoach Cloud for AI assistants in Section 6A is a separate feature with its own boundaries. If these boundaries change in the future, we will update this policy and the product controls.

6A. MoneyCoach Cloud for AI Assistants (Optional, Premium Max)

MoneyCoach Cloud for AI assistants lets AI assistants that you approve (ChatGPT, Claude, Gemini, Muse or Grok) answer questions about your finances without your Mac being on. To do this, MoneyCoach uploads a read-only copy of selected data to a hosting provider in Germany. It is off by default. It is available only with Premium Max, and nothing is uploaded until you turn it on in the app (Settings, "MCP & AI") and confirm the disclosure.

What is uploaded

• Accounts and balances
• Transactions: amount, date, category and account name
• Budgets and goals
• Recurring costs and bills
• Payee and merchant names, and transaction notes (for example invoice references or memo text), only if you separately switch on "Share Payee & Merchant Names" and "Share Transaction Descriptions". Both are off by default.

If you have linked bank accounts, transactions imported from them (including through Plaid in the United States and Canada) are part of the transactions that are uploaded.

We also store your Premium Max status and its expiry date, which we take from our own subscription records, so that the service can check your plan.

What never leaves your device

Account numbers (such as IBANs) and account owner names. Attachments and photos are not uploaded. Transaction notes stay on your device unless you switch on "Share Transaction Descriptions".

Where it is stored and who can read it

The copy is stored with a hosting provider in Germany that acts as our processor under a data processing agreement (Art. 28 GDPR). It is encrypted in transit and encrypted at rest. Each user's data is separated from other users' data in the database. As a rule, our staff do not look at the content of your cloud copy. Access is limited to what is strictly needed, and only in these cases: to fix a technical problem or restore the service, when you ask our support for help with your cloud copy, or when the law requires it.

You sign in to MoneyCoach with our authentication provider. Assistants never receive your sign-in details. When you connect an assistant, you approve it on a consent screen, and it receives a read-only access token that expires after one hour. The assistant can renew it while you keep using it. The connection ends when you delete the copy, or after 90 days without use. An assistant can only read; it cannot create, change or delete anything, move money or contact your bank.

Who receives data from the copy

When you ask a question, the assistant you approved requests the relevant records from the copy and receives them. The company behind that assistant (see the table below) processes the data under its own terms and privacy policy and acts as an independent controller once it has retrieved the data. MoneyCoach does not control how it stores, uses or trains on that data. Check its settings before you connect the assistant. Deleting the cloud copy does not delete data an assistant has already retrieved.

Transfers outside the EU

Only the assistants in this table can connect to the cloud copy. When you connect one, the consent screen names the company that receives the data.

Grok: SpaceXAI LLC has no company in the EU that receives your data, and it is not certified under the EU-U.S. Data Privacy Framework. There is no EU adequacy decision for it, and MoneyCoach has no data transfer contract with it. US authorities may be able to access the data, and it may be harder for you to enforce your rights in the USA. We tell you this on the consent screen, and Grok can connect only if you tick the box to agree. You can withdraw this consent at any time: disconnect the assistant or delete the cloud copy. We keep a record of your consent and of the version of the text you agreed to.

If you use an assistant with a business or team account, your organization's agreement with the provider can also apply.

Retention and deletion

• Until you delete it. In the app, choose "Delete Shared Data and Disconnect". This erases the copy and disconnects all connected assistants at once.
• When you delete your MoneyCoach account, the copy is erased as part of account deletion.
• After 90 days without activity (no upload, no sync status check and no assistant use), the copy is erased automatically.
• When you disconnect a bank, the accounts, details and transactions from that connection are removed from the copy.
• Backups of the hosted database are encrypted and are deleted within 15 days.
• Access and security logs (which assistant accessed what kind of data and when; never the data itself) are kept as long as we need them to secure the service and to investigate misuse.
• Erasure records. To prove that an erasure happened and to stop a stale device from re-uploading deleted data, we keep a minimal record of each erasure: pseudonymous IDs of your account and of the deleted records, the time and the reason. We keep these records as long as we need them for these purposes.

Legal basis

Your consent (Art. 6(1)(a) GDPR) for the cloud copy and, for payee, merchant and description text, your explicit consent (Art. 9(2)(a) GDPR). If you connect Grok: your explicit consent to the transfer to the USA (Art. 49(1)(a) GDPR). You can withdraw consent at any time by deleting the copy; this does not affect earlier processing. Security and access logs: our legitimate interest in securing the service (Art. 6(1)(f) GDPR). You can object (Section 13).

Limits

The cloud copy is a read-only convenience feature. AI-generated answers can be wrong and are not financial advice (see our Terms of Use). We do not use the cloud copy to train AI models.

7. Who We Share Data With (App)

We do not sell your data. We share personal data only with the recipients listed below, and only to the extent needed for the stated purpose. Where a recipient acts as our processor, we have concluded a data processing agreement under Art. 28 GDPR. Apple acts as an independent controller for the App Store and iCloud.

Recipients You Select and Direct

MCP clients and the AI providers configured inside them are selected and directed by you, not by MoneyCoach. The same applies to AI assistants you approve for the cloud copy in Section 6A (ChatGPT, Claude, Gemini, Muse or Grok). Section 6A says which company receives the data and which safeguard applies. 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.

Other Recipients

We disclose personal data to authorities only where we are legally required to do so (Art. 6(1)(c) GDPR).

8. Our Website (moneycoach.ai)

Server log files. When you visit the website, our hosting provider automatically processes the data listed above to deliver the pages and protect the site against attacks. Vercel deletes these logs automatically after 1 day.

Web analytics. Our analytics tool is self-hosted and cookieless. It does not set cookies or store any identifier on your device, and it does not create cross-site profiles.

Newsletter. We use the double opt-in procedure: you receive a confirmation email and are only subscribed after you confirm. You can unsubscribe at any time using the link in every email.

Embedded videos. YouTube videos are only loaded after you click them. Before that, no data is sent to YouTube. After the click, Google receives the data listed above and may set cookies. For more information, see Google's privacy policy at policies.google.com/privacy.

9. Open Banking: How It Works

The Simple Version (EU/EEA and UK, via GoCardless)

1. You tap "Connect Bank" in MoneyCoach
2. We send you to your bank's website (via GoCardless)
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
• Bank authorization 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
• Online Banking data is stored and processed on servers in the EU

9A. Bank Linking in the United States and Canada (Plaid)

The Simple Version

1. You tap "Connect Bank" in MoneyCoach and choose your bank.
2. Plaid's sign-in screen opens inside the app. You sign in with your bank and allow access to your accounts. Where your bank and Plaid offer it, you choose which accounts to share.
3. Plaid sends us the data for those accounts. We never see your bank password.

What Plaid sends us, and why

We do not use this data to sell or advertise to you, to decide whether you qualify for credit, or for any purpose other than providing and securing MoneyCoach.

What we send Plaid

We send Plaid a pseudonymous user ID, the country and language of your session, and the products we request. We do not send Plaid your email address or name.

Plaid's own privacy policy

When you use Plaid's sign-in screen, Plaid collects and uses information about you as described in Plaid's End User Privacy Policy. Plaid may retain and use data under that policy independently of us. In Plaid Portal at my.plaid.com, you can see which apps are connected, end a connection and ask Plaid to delete the data it holds.

Your control

• Connect and disconnect anytime in the app (Settings, Bank Accounts).
• Choose which accounts you share in Plaid's screen, where your bank and Plaid offer this.
• Reconnect if your bank asks you to renew access.

Retention and deletion of Plaid-sourced data

• When you disconnect a bank: we ask Plaid to end the connection and stop receiving data. We then delete the accounts, balances, transactions, liability and holdings data we stored for that connection. Our connection to the bank through Plaid cannot be used again after this.
• When you delete your MoneyCoach account: we end every bank connection with Plaid, and delete all Plaid-sourced data we hold, together with the rest of your account data.
• If you stop using MoneyCoach without a Premium plan: once a day, we delete the bank connections of users who have not used the app for 14 days and who do not have an active Premium plan. This also ends the connection with Plaid. You can connect your bank again whenever you like. Users with an active Premium plan are not affected. If we cannot confirm that your Premium plan is active, we do not run this deletion for you that day.
• What may remain: a minimal record that a connection existed (connection ID, your user ID, bank provider, bank ID and country, status, dates and the reason it ended; no account or transaction data) is kept for 12 months after a connection ends for troubleshooting and dispute handling, unless you delete your account, in which case it is deleted with the account. Cached category suggestions for your transactions are removed when you disconnect your last bank.
• Plaid may keep data under its own policy (see above). We cannot delete data that Plaid holds as an independent controller.
• Cloud copy: if you switched on the cloud copy (Section 6A), data from a bank you disconnect is removed from it as well.

10. Data Retention Periods

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

Personal & Financial Data

Technical Data

Account, Subscription and Communication Data

AI Processing Data

Your selected MCP client or AI provider (including any assistant you approve for the cloud copy) 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, delete the cloud copy
• Complete removal: Delete your account in the app (Settings → Manage Account → Delete Account), delete the app, and email us for any remaining data
• Partial control: Turn off specific features anytime

11. Are You Required to Provide Your Data?

You are not legally or contractually obliged to provide personal data. However, some features cannot work without certain data:

• Manual budgeting works without an account and without bank data.
• Online Banking requires a bank connection. Without it, you cannot import transactions automatically. In the United States and Canada, this requires Plaid's sign-in screen.
• Cloud copy for AI assistants requires Premium Max and your opt-in.
• Subscriptions require a purchase through the App Store. Without it, you cannot use paid features.
• Support requires an email address so that we can reply to you.
• Newsletter requires an email address.
• Analytics is optional. If you switch it off, the app works the same.

12. Your Rights Under the GDPR

You have comprehensive rights over your personal data:

🔍 Right to Access (Art. 15 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 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 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 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 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 Withdraw Consent (Art. 7(3) GDPR)

What it means: Withdraw any consent you gave, with effect for the future
How to use it: In the app settings (see Section 14) or by email

🛡️ AI Suggestions

We make no decisions within the meaning of Art. 22 GDPR (see Section 5). You can change any AI-suggested category at any time.

⚖️ Right to Lodge a Complaint (Art. 77 GDPR)

You can complain to a data protection supervisory authority (see Section 20).

To Exercise Your Rights: 📧 Email: privacy@moneycoach.ai
🕰️ Response Time: Within 1 month

12A. Notice for US Residents (CCPA/CPRA and other state privacy laws)

This section supplements the rest of this policy for residents of California and other US states with consumer privacy laws.

Categories of personal information we collect, in the last 12 months, and their sources

Why we use it: to provide and secure MoneyCoach, process subscriptions, answer support requests, improve the app, and comply with law (details in Sections 3 and 4).

We do not sell or share your personal information. We do not sell personal information, and we never sell or share your financial information. We do not "share" personal information for cross-context behavioral advertising: the app contains no advertising SDK and does not use your device's advertising identifier. To measure our advertising campaigns, we use Apple's install attribution (AdServices and SKAdNetwork), through which Apple reports installs and some in-app milestones only in aggregated form that does not identify you. We do not knowingly sell or share the personal information of consumers under 16.

We do not use or disclose sensitive personal information for purposes other than those permitted by law (providing the service, security, and similar).

Retention: see Section 10 and Section 9A.

Your rights: You may ask us to

• tell you what personal information we collect, use, disclose and the categories of sources and recipients (right to know);
• give you a copy (right to access and portability);
• delete your personal information (right to delete);
• correct inaccurate personal information (right to correct);
• limit use of sensitive personal information (we only use it as permitted, so there is nothing further to limit);
• not discriminate against you for exercising these rights. We will not deny you the service, charge different prices or give a lower quality of service for exercising your rights.

How to submit a request: Email privacy@moneycoach.ai. If you have a MoneyCoach account, send the request from the email address on the account, so that we can verify you. We may ask for information that matches our records. We respond within 45 days (we may extend once by another 45 days and will tell you why). Many rights can be used directly in the app: delete your account (Settings, Manage Account, Delete Account), disconnect a bank, delete the cloud copy.

Authorized agents: You may use an authorized agent. The agent must send a written authorization signed by you, and we may ask you to verify your identity with us directly.

Appeals: Depending on the state you live in, if we refuse a request, you may appeal by replying to our decision or by writing to privacy@moneycoach.ai with the subject "Appeal". If you are still not satisfied, you may contact your state attorney general.

Scope: This notice applies to all personal information we hold about you, including the financial information we receive from your bank through Plaid.

Do-Not-Track and Global Privacy Control: Our website does not set tracking cookies. Because we do not sell or share personal information, there is nothing to opt out of. If your browser sends a Global Privacy Control signal, we treat it as a request to opt out where the law requires this.

Children: MoneyCoach is not directed to children under 16 and we do not knowingly collect personal information from children under 13.

12B. Notice for Canadian Residents (PIPEDA and provincial law)

If you link a bank in Canada, the following applies in addition to the rest of this policy.

• Accountability: MoneyCoach UG (haftungsbeschränkt) is responsible for the personal information described in this policy. Our Privacy Officer is accountable for our compliance and can be reached at privacy@moneycoach.ai.
• Purposes and consent: We collect Plaid-sourced data only to provide the bank-linking features you ask for (Section 9A). You consent when you connect your bank. You can withdraw consent at any time by disconnecting the bank, subject to legal and contractual restrictions. If you withdraw consent, some features will no longer work.
• Processing outside Canada: Your information is processed by Plaid (a US company) and on our servers in the European Union (for our backend; see Sections 7 and 15). It may also be processed by our service providers in the United States and other countries. Where data is processed outside Canada, it is subject to the laws of those places, and courts, law enforcement and other authorities there may be able to access it. We use contracts and security measures to protect it.
• Access and correction: You may ask for access to, and correction of, your personal information at privacy@moneycoach.ai. We respond within 30 days (we may extend as the law allows and will tell you why).
• Retention: see Sections 9A and 10. We keep personal information only as long as needed for the stated purposes or as required by law.
• Breach notification: If a breach of security safeguards creates a real risk of significant harm to you, we will notify you and the Office of the Privacy Commissioner of Canada as the law requires.
• Quebec: If you live in Quebec, you may also have the rights to data portability and to have your information de-indexed or ceased to be disseminated, and to withdraw consent. Our Privacy Officer is the person in charge of the protection of personal information and can be reached at privacy@moneycoach.ai.
• Complaints: You can contact us first. You may also complain to the Office of the Privacy Commissioner of Canada (priv.gc.ca) or your provincial regulator.

13. Right to Object (Art. 21 GDPR)

Right to object on grounds relating to your particular situation

Where we process your personal data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you have the right to object to this processing at any time, on grounds relating to your particular situation. This applies in particular to in-app usage analytics, crash reporting, improving merchant recognition, names of other people in imported bank transactions, paywall performance measurement, Apple Search Ads install attribution, website server logs and website statistics. If you object, we will no longer process your personal data for these purposes unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing serves the establishment, exercise or defence of legal claims.

Right to object to direct marketing

Where we process your personal data for direct marketing purposes, you have the right to object at any time, without giving reasons. We will then no longer process your personal data for these purposes.

How to object: Send an informal message to privacy@moneycoach.ai.

14. Managing Your Consent and Optional Features

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

Bank Account Connections (EU/EEA, UK, United States and Canada)

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

Usage Analytics

• Enable or disable: In the app's privacy settings, using the analytics switch
• 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 → AI Tools → 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.

MoneyCoach Cloud for AI Assistants

• Enable: Settings, "MCP & AI", then follow the opt-in and confirm the disclosure (Premium Max)
• Disable and delete: Settings, "MCP & AI", "Delete Shared Data and Disconnect"
• Effect: The cloud copy is erased and all connected assistants are disconnected. Disabling does not delete information an assistant has already retrieved.

Newsletter

• Disable: Use the unsubscribe link in any newsletter email

Withdrawal Effects

What happens when you withdraw consent:

✅ For the future: Processing based on that consent stops
✅ No penalties: All other app functionality remains
✅ Data cleanup: Related data deleted per retention policy
✅ Re-consent: You can always change your mind later

15. International Data Transfers

Some of our service providers are located in the United States or may access data from there. For each recipient, Sections 6A, 7 and 8 state the country and the safeguard we rely on. Transfers to third countries take place only on the basis of:

• an adequacy decision of the European Commission (Art. 45 GDPR), including the EU-U.S. Data Privacy Framework for certified companies,
• Standard Contractual Clauses adopted by the European Commission (Art. 46(2)(c) GDPR), or
• your explicit consent to the transfer after we have told you about the risks (Art. 49(1)(a) GDPR). We use this only when you connect an AI assistant whose provider has no company in the EU and is not certified under the EU-U.S. Data Privacy Framework (at the moment, Grok; see Section 6A).

You can request a copy of the relevant safeguards from privacy@moneycoach.ai.

If you live in the United States or Canada, your data is transferred to and processed in the European Union (Germany and other EU member states) and by service providers in the United States. EU data protection law gives your data a high level of protection there. See Sections 12A and 12B.

16. Security Measures

Technical Protection

• All data encrypted during transfer and storage
• Bank sign-in details are entered only with your bank or in Plaid's sign-in screen. We store the connection token Plaid gives us (not your password) and remove it when you disconnect.
• The optional cloud copy is encrypted in transit and at rest, separated per user, and accessed only through read-only access tokens that expire after one hour.
• Multi-factor authentication for our systems
• 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

17. Cookies and Similar Technologies

In the App

Firebase Analytics and Mixpanel use an app-instance identifier. They are on by default on the basis of our legitimate interest in improving the app (Art. 6(1)(f) GDPR). You can switch them off in the app's privacy settings and object at any time (Section 13). Crash reports are linked to your pseudonymous user ID so that we can find and fix problems you run into (Art. 6(1)(f) GDPR). You can object (Section 13). Superwall uses a pseudonymous identifier to show subscription offers and measure how they perform (offers: Art. 6(1)(b) GDPR; measurement: Art. 6(1)(f) GDPR; you can object, Section 13).

On Our Website

We do not use cookies for analytics or advertising, and our web analytics does not store anything on your device. Some free tools save your inputs in your browser's local storage so they aren't lost when you reload the page. This data stays on your device and is not sent to us (§ 25(2) no. 2 TDDDG). YouTube may set cookies only after you click an embedded video (see Section 8).

18. Changes to This Policy

We sometimes update this policy when we add new features or when laws change. We will publish the updated version here with a new "last updated" date.

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)

Where a change requires your consent, we will ask for it before the change applies to you.

19. Privacy Contact

For all privacy matters, contact us at:

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

We can help you with:

• Exercising your GDPR rights (access, deletion, correction, etc.) and your US state and Canadian privacy rights
• Privacy concerns or complaints
• Data processing questions
• Consent management issues
• Data breach reports

Response time: Within 1 month (Art. 12(3) GDPR)

20. Contact Us

For General Privacy Questions

Email: privacy@moneycoach.ai

For App Support

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

For Regulatory Complaints

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the EU member state of your habitual residence, place of work or place of the alleged infringement. The authority responsible for us is:

Berliner Beauftragte für Datenschutz und Informationsfreiheit (BlnBDI)
Alt-Moabit 59-61
10555 Berlin, Germany
📧 Email: mailbox@datenschutz-berlin.de
🌐 Website: datenschutz-berlin.de

21. 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.

22. Language Versions

This policy is available in English, German and Italian. The German and Italian versions are translations provided for your convenience. If the versions differ, the English version prevails, unless mandatory law requires otherwise.

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