The purpose of this Privacy Policy is to inform you, in accordance with the applicable data protection regulations, about the processing of personal data that may be collected through the "ONA Wealth Mentor" application (hereinafter, the "App" or the "Application").
Downloading and using the App grants you the status of user (hereinafter, the "User" or the "Users") and implies your knowledge and acceptance of the terms contained in this Privacy Policy.
| Identity: | MENTORONA, S.L. (hereinafter, "ONA WEALTH MENTOR") NIF B 22942833 |
| Address: | Calle Prim, 12 Pt. 01, 28004 Madrid, España |
| Email address: | support@onawealthmentor.com |
ONA WEALTH MENTOR obtains information from Users when they make use of the different functionalities available in the App that require the provision of personal data. In particular, we may record the following information:
Account creation / User registration: The personal data requested in the registration and account management forms, such as (without limitation): first name, surname(s), email address, mobile phone number, login credentials, preferred language and, where applicable, data necessary to subscribe to paid versions.
Use of the App and interactions with the AI: Data derived from the use of the App, including:
The content of queries, questions and messages entered by the User in the App.
The responses generated by the AI system.
Information about financial learning preferences (for example, declared level of financial knowledge, topics of interest, general educational objectives), insofar as the User provides such information voluntarily.
Contact and user support forms / emails: The personal data that the User voluntarily provides when contacting us through the App or by email to request information or support (including, without limitation, name, email address and any other information that the User includes in their message).
Payment and billing management: To manage the payment of subscriptions or paid services in the App, the User must provide the data necessary for payment processing and billing (for example, first name and surname(s), tax identification number, billing address, bank details or credit/debit card details). Payments are normally processed through payment service providers (payment gateways).
Technical and usage data: Technical information generated or collected automatically when using the App, such as:
Device identifiers, operating system, App version, session identifiers.
IP address, date and time of accesses, activity logs, application errors.
Data on the use of functionalities (screens visited, time of use, clicks), generally in an aggregated or pseudonymised form.
Informational and marketing communications: Identification and contact data (for example, name and email address) that we use to send informational and, where applicable, marketing communications related to ONA WEALTH MENTOR, provided that the User has expressly authorised this.
Some data indicated as mandatory in the forms will be necessary in order for us to provide certain services. If the User does not provide such data, ONA WEALTH MENTOR may not be able to process the registration, provide the service or respond to the User's request.
The personal data provided by the User, or generated as a result of using the App, will be processed for the following purposes and on the following legal bases:
Consent of the data subject (Art. 6.1(a) GDPR)
To send electronic communications about news, educational content, App features or services related to ONA WEALTH MENTOR, provided that the User has given their explicit consent for this and until such consent is withdrawn.
Performance of the legal relationship established between ONA WEALTH MENTOR and registered Users (Art. 6.1(b) GDPR):
To enable access to and management of the account and/or functionalities for registered Users in the App.
To provide the functionalities of the App, including the generation of informational and educational responses through artificial intelligence systems.
To provide technical support and user assistance through the available channels.
To manage subscriptions and paid services, including billing and collection of payments.
Compliance with the legal obligations applicable to ONA WEALTH MENTOR as a result of the processing activities described above (Art. 6.1(c) GDPR).
As a general rule, Users' personal data will not be disclosed to third parties except:
In addition, ONA WEALTH MENTOR may engage third parties to provide the infrastructure and/or services necessary for the proper functioning of the App and the provision of the services offered (for example, cloud hosting services, AI technology providers, IT maintenance, analytics tools, consent-based marketing tools, etc.), which will act as data processors.
In all such cases, ONA WEALTH MENTOR undertakes to:
In all cases, data are hosted and processed within the European Union, and no international transfers of data are made outside the European Economic Area.
Personal data will be retained by ONA WEALTH MENTOR for the following periods:
User registration and account data: For the entire duration of the contractual relationship (for as long as the User keeps their account active in the App) and, once the account has been cancelled or deactivated, for the time necessary for the statute of limitations of any potential legal liabilities.
Data derived from the use of the App and interactions with the AI: For the time necessary to provide the service, ensure the security and proper functioning of the App and, where applicable, for as long as the consent given for additional purposes remains in force. After these periods, the data may be blocked or anonymized.
Contact and user support data: For the time strictly necessary to handle and manage each specific request or incident raised by the User, and subsequently for the limitation periods of any potential liabilities.
Billing and payment data: For the periods established by the applicable regulations (for example, tax and accounting obligations), and in general for up to 6 years from the issuance of each invoice or accounting document.
Once the retention periods have expired, personal data may be kept duly blocked solely for the purpose of responding to legal or contractual liabilities. Once those periods have finally elapsed, the data will be deleted or, where appropriate, irreversibly anonymised.
The User guarantees that the personal data provided to ONA WEALTH MENTOR through the App are true, accurate, current and complete. The User is responsible for informing ONA WEALTH MENTOR of any modification or update to such data.
Updates may be made, where possible, through the options enabled in the User's profile within the App or, failing that, by sending a communication to the addresses indicated in the section ` What are your rights?`, following the instructions set out therein.
As a general rule, Users are not allowed to provide personal data relating to third parties through the App. In the event that, exceptionally, the User provides personal data of third parties, the User undertakes to:
The User shall be liable towards ONA WEALTH MENTOR and towards the third parties concerned for any damage or liability that may arise from the breach of these obligations.
Users have the right to withdraw at any time the consent they may have given for the processing of their data. Likewise, Users may exercise against ONA WEALTH MENTOR their rights of access, rectification, erasure and portability of their data, restriction of processing and objection to processing, as well as the right not to be subject to decisions based solely on the automated processing of their data, where applicable.
For these purposes, the User may use the following channels, always enclosing a copy of their ID card or any other document that allows their identity to be verified:
Finally, if the User becomes aware of or considers that an event may constitute a breach of the applicable data protection regulations, they may lodge a complaint with the Spanish Data Protection Agency (Agencia Española de Protección de Datos).
ONA WEALTH MENTOR reserves the right to unilaterally amend this Privacy Policy whenever necessary, for example, in order to adapt it to legislative changes, case law criteria, new features in the App or changes in the personal data processing activities carried out.