Koodooka Moni — Privacy Policy

Koodooka Moni — Your AI Money Companion

Effective: 3 August 2026

Summary: Koodooka Moni is built with privacy at its core. We do not sell your personal data, we do not use third-party advertising SDKs, product analytics is not currently enabled, and biometric templates never leave your device.

1. Introduction

Koodooka Ltd ("Koodooka", "we", "us", or "our") operates the Koodooka Moni mobile application ("Koodooka Moni" or the "App"). Within the App, "Moni" is the AI-powered financial companion that helps you understand and manage your money through natural conversation.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you use Koodooka Moni. It applies to all users of the App and is designed to comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and the EU General Data Protection Regulation (EU GDPR) where applicable.

By using Koodooka Moni, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use the App.

2. Information We Collect

2.1 Account & Identity Information

When you create an account, we collect:

Phone number — used for account verification and authentication via one-time passcode (OTP)
Name — as provided during registration
Email address — used for account communication
Date of birth — as provided during onboarding for age verification and regulatory purposes
Address — as provided during onboarding for identity and regulatory purposes

Authentication is managed through Firebase Authentication, operated by Google LLC. If you use address autocomplete, the address or postcode text you enter is sent to Google Places API so that Moni can return matching addresses in your selected country. You can instead enter your address manually.

2.2 Biometric Data

Biometric data (Face ID, Touch ID, fingerprint) is processed entirely on your device using your operating system's secure enclave. Koodooka does not receive, transmit, or store your biometric data on any server.

Biometric authentication is optional and used solely to unlock the App on your device. Platform biometrics remain on-device.

2.3 Financial & Profile Data

Depending on the features you use, we may collect financial and profile information you choose to add, including:

Goals, journeys, challenges, rewards and saved preferences
Property and mortgage details you add to Moni
Other money-related context you enter so Moni can help with planning

Open Banking / connected multi-bank feeds are not currently available in the App. If we enable a regulated Open Banking connection in a future release, we will update this policy and obtain any additional consent required before collecting bank-account balances or transaction feeds through that channel. Any future Open Banking access would be read-only — Moni would not initiate payments or modify your bank accounts.

2.4 Voice & Media Data

Microphone: Used when you choose to send voice to Moni. Audio is sent to Microsoft Azure AI Speech for real-time transcription. Koodooka does not store the raw voice audio after the request is processed.
Optional profile photo: If you add a profile photo, the image file is stored using Microsoft Azure Blob Storage. Profile photos are not sent to generative AI services or to Document Intelligence.
Vault documents (camera and files): When you scan or upload a document to your Vault, the document file is stored using Microsoft Azure Blob Storage and may be processed by Microsoft Azure Document Intelligence (document bytes/content) to extract text and suggest details such as dates or reference fields for you to review before they are saved. Vault file bytes stay with Blob Storage and Document Intelligence. Separately, Moni may send bounded extracted document text to generative AI only to classify the document (see section 2.7). Chat features use Vault metadata and labels, not file bytes. Moving Vault storage or document reading to these Microsoft Azure services is a change of processor/processing stack for the same document feature — not a new consumer product category. Files remain available to provide the feature until you delete them or your retention period ends.

2.5 Device & Technical Data

Device type, operating system, and version
Push notification tokens and an app installation identifier used to deliver notifications reliably
App version and crash/diagnostic logs
IP address (logged transiently for security purposes)

2.6 Diagnostics (not product analytics)

We collect crash and related diagnostic data via Firebase Crashlytics to improve reliability and diagnose issues. Crash reports may include a Koodooka Moni account UUID so that we can investigate an affected session; we do not attach your email address to Crashlytics.

Performance monitoring is not currently collected as a live product capability in the current binary/source behaviour (for example, there is no live production performance SDK declared as collecting Apple “Performance Data”). Optional error-monitoring tooling such as Sentry exists in source but is not live unless a non-placeholder production DSN is configured; do not treat Sentry as an active collector while it remains off or placeholder-configured.

Product analytics is not currently enabled in the App. We do not operate a live product-analytics collector (for example Firebase Analytics) in the current binary/source behaviour. We do not use advertising SDKs or cross-app tracking. If we introduce product analytics or performance monitoring later, we will update this policy and obtain consent where required before treating that data as collected.

2.7 Information Processed by AI Services

Koodooka Moni is an AI-native service. After you give permission in the App, Koodooka sends only the information needed for the feature you use to Google LLC and Microsoft Corporation generative AI and speech services. This may include:

Your messages and relevant chat history, including information you choose to share in chat
Relevant profile and money context you have added — such as goals, journeys, rewards or challenges, property and mortgage details you supply (which may include mortgage figures on a journey you use), preferences, approximate location text, and related summaries Moni keeps to personalise replies
Vault document metadata and labels used in chat (for example document type, title, or renewal dates). Chat-path Vault facts are metadata-only — not file bytes
Extracted Vault document text for classification when you scan or upload: Azure Document Intelligence extracts text first; Moni may then send that extracted text (within a configured size limit) to Vertex Gemini or Azure OpenAI only to classify the document. Vault file bytes remain with Azure Blob Storage and Document Intelligence
Voice audio and transcripts when you choose to use voice (audio is transcribed by Microsoft Azure AI Speech before chat AI runs)
Moni reply text when you choose to have a response spoken aloud

Not sent to generative AI under current behaviour: connected Open Banking account names, bank balances, or transaction feeds (Open Banking is not currently available); Vault document file bytes (those stay with Azure Blob Storage and, when you scan or upload, Azure Document Intelligence); or profile photo image bytes.

We use the generative AI and speech categories above to provide Moni's chat, voice, insights, profile, rewards and Vault classification features. Document file storage and Document Intelligence extraction of bytes are described in sections 2.4 and 4 and are not the same as generative AI. Moni asks for your explicit permission before personal data in this section is sent to a third-party generative AI or speech service.

This permission is collected once for the current data-use policy version (in-app version identifier aligned with this policy pack) and recorded with the date and policy version. We ask again only if you withdraw permission or we materially change the AI providers, information shared or purpose.

3. How We Use Your Information

| Purpose | Legal Basis (UK/EU GDPR) | |---|---| | Provide and operate the App | Performance of contract (Art. 6(1)(b)) | | Authenticate your identity | Performance of contract (Art. 6(1)(b)) | | Display and organise your financial and profile data | Performance of contract (Art. 6(1)(b)) | | Return address suggestions while you enter an address | Performance of contract (Art. 6(1)(b)) | | Send relevant personal data to named AI services to provide Moni's AI and voice features | Your explicit consent (Art. 6(1)(a)) | | Process document scans and files you choose to upload | Performance of contract (Art. 6(1)(b)) | | Send push notifications (account alerts, insights) | Consent (Art. 6(1)(a)) | | Prevent fraud and ensure security | Legitimate interest (Art. 6(1)(f)) | | Improve and develop the App | Legitimate interest (Art. 6(1)(f)) | | Comply with legal and regulatory obligations | Legal obligation (Art. 6(1)(c)) |

4. Data Sharing & Third Parties

We do not sell, rent, or trade your personal data to any third party.

We share data only with the following categories of service providers, who process data on our behalf under appropriate contractual safeguards:

| Provider | Purpose | Data Shared | |---|---|---| | Firebase Authentication and Firebase Cloud Messaging (Google LLC) | Phone verification, authentication and push notifications | Phone number, authentication and device-token data | | Firebase Crashlytics (Google LLC) | Crash and diagnostic reporting | Crash logs, device/app metadata, and optional account UUID | | Google Places API — Google LLC | Address autocomplete | The address or postcode search text you enter | | Microsoft Azure (infrastructure) | Cloud infrastructure and application hosting | Encrypted application data | | Microsoft Azure Blob Storage — Microsoft Corporation | Secure storage of optional profile photos and Vault document files | Profile photo image files you choose to add; Vault document and media files you upload or scan | | Microsoft Azure Document Intelligence — Microsoft Corporation | Reading Vault documents (bytes/content) to extract text and suggest fields for your review | Document images/PDFs you choose to scan or upload — file bytes only; not generative chat AI | | Google Cloud Vertex AI (Gemini) — Google LLC | AI chat, natural-language processing, and Vault document classification | Messages, relevant chat history, profile/goals/journeys/rewards/property context, preferences/location text, Vault metadata/labels for chat, and bounded extracted Vault text for classification (not file bytes) | | Microsoft Azure OpenAI Service — Microsoft Corporation | Customer-specific insights, profile analysis, rewards features, and Vault document classification | Relevant profile and money context and the prompt needed for the selected feature (same generative categories as above, including bounded extracted Vault text for classification; not Vault file bytes) | | Microsoft Azure AI Speech — Microsoft Corporation | Voice transcription and speech generation | Voice audio for transcription, and Moni reply text for speech generation |

Google and Microsoft process this information on Koodooka's behalf under contractual and technical safeguards as service providers / processors. We require them to provide the same or an equivalent level of protection described in this policy and required by applicable data-protection law. How store "data shared with third parties" questionnaires classify enterprise AI and cloud processors can differ from controller/processor language under UK/EU GDPR; treat store-console sharing toggles as a legal-review item rather than an automatic "shared with third parties for their own purposes" statement.

Koodooka configures these Google and Microsoft services as enterprise/API processors for providing Moni features, not as consumer products you use directly. Legal verification required: whether each provider's current enterprise contractual terms and our tenant configuration prohibit use of Koodooka Moni customer content to train their general-purpose foundation models must be confirmed against the signed agreements and admin settings in force — this policy does not invent or restate unaudited contract wording. Provider processing may still include limited security or abuse monitoring and short-lived operational caching as described in their enterprise service terms. Microsoft's public Azure AI Speech documentation states that real-time speech audio is not stored at rest after processing; confirm against the SKU and terms you actually use.

Open Banking providers are not current recipients while connected-bank features remain unavailable. If that changes, this table will be updated before the feature is offered.

We may also disclose personal data if required to do so by law, regulation, or valid legal process (e.g., a court order or regulatory request).

5. Data Storage & Security

Koodooka's application data is stored on Microsoft Azure infrastructure in the UK South region. Optional profile photos and Vault document bytes are stored with Microsoft Azure Blob Storage. Document reading for Vault uses Microsoft Azure Document Intelligence (document content/bytes for extraction only). Generative AI providers receive the categories in section 2.7 (including Vault metadata/labels for chat and bounded extracted Vault text for classification where relevant), not Vault file bytes. Data sent to the named AI providers is processed as described in sections 2 and 4. We implement industry-standard security measures, including:

Encryption in transit (TLS 1.2+) and at rest (AES-256)
Role-based access controls and the principle of least privilege
Regular security assessments and vulnerability scanning
Secure key management via Azure Key Vault
Audit logging and monitoring

While we take all reasonable precautions, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security.

6. International Data Transfers

Google and Microsoft may process data outside the UK and EEA. Where an international transfer occurs, we use appropriate safeguards, such as:

Standard Contractual Clauses (SCCs) approved by the UK ICO or European Commission
UK International Data Transfer Agreement (IDTA)
Adequacy decisions where applicable

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this policy, unless a longer retention period is required by law.

Account, profile and financial data: Retained while your account is active. After the 30-day account-deletion grace period, we delete or anonymise personal data unless limited information must be retained to satisfy legal, regulatory or compliance requirements.
Chat history and saved memories: Retained in your Koodooka Moni account to provide conversation history and personalisation, then handled under the same account-deletion process.
Voice audio: Not stored by Koodooka after the real-time transcription request is processed.
Profile photos: Retained in Azure Blob Storage while associated with your account, until you remove the photo or your account deletion process completes.
Vault documents: Retained in Azure Blob Storage while needed to provide the Vault feature, until you delete them or the applicable retention period ends. Document Intelligence processing is used to produce review candidates from document content and is not a separate long-term store of your files beyond what is required to provide that processing.
Technical and diagnostic logs: Retained only as long as reasonably needed for security, reliability and troubleshooting.

When data is no longer needed, it is securely deleted or anonymised.

8. Your Rights (UK & EU GDPR)

Under data protection law, you have the following rights:

Right of access — Request a copy of the personal data we hold about you
Right to rectification — Request correction of inaccurate or incomplete data
Right to erasure — Request deletion of your personal data ("right to be forgotten")
Right to restrict processing — Request that we limit how we use your data
Right to data portability — Receive your data in a structured, machine-readable format
Right to object — Object to processing based on legitimate interests
Right to withdraw consent — Where processing is based on consent, you may withdraw it at any time
Rights related to automated decision-making — You have the right not to be subject to decisions based solely on automated processing that produce legal or similarly significant effects

To exercise any of these rights, contact us at [email protected]. We will respond within one month as required by law.

You may withdraw permission for third-party AI processing in the App under Settings > Privacy > Data Usage for AI Services, by deleting your Moni account, or by contacting us. Because Moni is an AI-native service and the named AI services are required to provide it, withdrawing permission signs you out and disables access to Moni until you grant permission again. Withdrawal does not delete your account or stored data; the withdrawal screen also provides a separate option to start account deletion.

You also have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or your local supervisory authority.

9. Children's Privacy

Koodooka Moni is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us at [email protected] and we will take steps to delete such information promptly.

10. Cookies & Tracking

Koodooka Moni is a native mobile application and does not use browser cookies. We do not employ any third-party advertising trackers or SDKs. Product analytics is not currently enabled. If we introduce product-analytics tools in the future, we will update this policy and obtain consent where required before declaring that collection as live.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the App or by email before the changes take effect. The "Effective" date at the top of this page indicates when this policy was last revised.

We encourage you to review this policy periodically.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Company: Koodooka Ltd
Email: [email protected]