Legal

Privacy policy

Last updated

There is no account on this site and one form: the monthly email, which asks for your email address and nothing else. Reading a page asks you for nothing. The server logs each visit for 14 days and visits are counted without cookies; Google Analytics runs only if you switch it on. Momo does not sell personal data and does not share it with any provider.

Who is responsible for your data

Haystack Rock Limited, trading as Momo Finance, is the data controller for the personal data this site involves. It is a company registered in England and Wales under number 07572770, with its registered office at Wimbourne, London Road, Chalfont St. Giles, England, HP8 4NQ. It is registered with the Information Commissioner's Office under reference ZC245152. For anything about your data, email privacy@momofinance.co.uk. This policy covers momofinance.co.uk only; the Momo app at https://app.momofinance.co.uk is a separate service with its own privacy policy.

What the site collects, and what it does not

The site has no account to create, no sign-in and no comment box. It does not ask for your name, your nationality or anything about your finances, and reading it does not identify you. The one thing it does ask for is an email address, and only if you decide to sign up for the monthly email; everything else on this page happens whether you do or not. What a visit involves is set out below, one purpose at a time.

Purpose What is involved Lawful basis Who handles it How long
Sending you the monthly email Your email address, the date you gave consent, and whether you have confirmed it or unsubscribed. Also whether you opened each email and which links you followed. Not your name, and not which page you signed up from. Your consent, given by ticking the box on the form and then confirming the email that follows, which you can withdraw at any time EmailOctopus, a trading name of Three Hearts Digital Ltd, 86-90 Paul Street, London, EC2A 4NE The address is kept until you unsubscribe. It then stays on a do-not-contact list for three years, so it cannot be added again by mistake, and is deleted after that. An address that has not opened an email for 24 months is removed from the list.
Serving the site and keeping it secure Your IP address, browser type, the page requested, the page you came from and the time, written to the web server's log. Legitimate interests in running a reliable, secure site The site's own web server, a DigitalOcean machine in London Deleted after 14 days
Counting visits The page address and title, the page you came from, your screen size and browser language, and the links you follow, including links to a provider's site. The request itself carries your IP address and browser type. Legitimate interests in knowing which pages are useful. You can object by switching visit counting off. Ahrefs Web Analytics, from Ahrefs Pte Ltd, Singapore The raw IP address is not stored; the value behind the daily visitor count is deleted every 24 hours
Google Analytics, only if you switch it on Pages viewed, how you arrived, approximate location, device and browser type, and the identifiers in its two cookies. Your consent, which you can withdraw at any time Google, as a processor Event data deleted after 2 months
Remembering your cookie settings Your choices, the date you made them and the version of the settings you answered, kept as momo-consent. Strictly necessary to honour your choice Your own browser. It is never sent to Momo. Until you clear it
Answering an email you send Your email address and whatever you choose to write. Legitimate interests in replying, or a legal obligation where you are exercising a data protection right Google Workspace, which hosts the momofinance.co.uk mailboxes As long as needed to deal with it, and to keep a record of any request made under data protection law

How visits are counted

Ahrefs Web Analytics sets no cookie and stores nothing on your device. To count unique visitors, Ahrefs turns your IP address and browser type, together with a random value it replaces every 24 hours, into a one-way code, so a visitor can be counted within a day but not followed from one day to the next. Ahrefs states that it never stores the raw IP address. Momo sees only the totals. Switch it off at any time in the cookie settings; "Reject all" switches it off too. It does not respond to a browser's Do Not Track or Global Privacy Control signal, so that setting, or a content blocker, is the way to stop it.

Google Analytics

Google Analytics does not load, and sets no cookie, until you switch it on in the cookie settings. With your consent it records how the site is used, so Momo can see which pages are read and how visitors arrive. Google processes that data on Momo's behalf under its data processing terms, and states that Google Analytics 4 does not log or store IP addresses. Event-level data is deleted after 2 months. Withdrawing consent deletes the cookies straight away and stops it loading; the cookie policy lists both cookies.

The monthly email

Signing up asks for your email address and for you to tick a box saying you want the email. The box starts unticked, and nothing is sent until you tick it yourself. EmailOctopus then sends you an email with a link in it, and you are on the list only once you click that link: an address typed in by somebody else never starts receiving anything. Every email carries an unsubscribe link, which takes one click and no reason. The address is kept until you unsubscribe. It then stays on a do-not-contact list for three years, so it cannot be added again by mistake, and is deleted after that. An address that has not opened an email for 24 months is removed from the list.

EmailOctopus records whether you opened an email and which links you followed, so Momo can see whether the email is read and can drop addresses that have gone quiet. That is the only thing recorded about you beyond the address itself, and it is not joined up with anything you do on this site: reading a page and subscribing are kept apart, and nothing you read here is attached to your address.

The list is never sold, never rented, and never shared with a provider. No provider learns that you read about it or that you subscribed. The email is written by Momo; there is no advertising in it and no third party writes any part of it.

The form itself is built by EmailOctopus, and its code brings Google reCAPTCHA with it to tell a person from a bot. Neither is requested when a page loads: the form's code is fetched only once the form scrolls into view, so a page you do not read to the bottom of contacts neither company. The cookie policy lists everything the form reaches and what each leaves on your device. What you send is handled under EmailOctopus's own privacy policy as well as this one.

Where the data goes

The web server is a DigitalOcean machine in London. DigitalOcean, LLC, a US company, provides it under a data processing agreement that uses the UK Addendum to the standard contractual clauses for any access from outside the UK. Google may process analytics data outside the UK; its data processing terms rely on standard contractual clauses for those transfers. Ahrefs is based in Singapore, and its privacy policy states that it relies on standard contractual clauses for international transfers. Three Hearts Digital Ltd, which trades as EmailOctopus, is a UK company, and states that the list itself is held in Ireland, on Amazon Web Services. That is inside the European Economic Area, which UK law treats as offering adequate protection, so no further safeguard is needed for it.

Momo does not sell personal data or share it with any provider, and no provider learns who has read about it. No one else receives personal data from this site beyond the services named above.

When you follow a link

A link to a provider takes you to that provider's own site, where its own privacy policy applies. Links to providers are set so your browser does not tell the provider which page on Momo you came from. If visit counting is on, Ahrefs records that the link was followed.

Your rights

Under UK data protection law you have the right to ask for a copy of your personal data, to have it corrected, to have it erased, to restrict how it is used, to object to its use, and to receive it in a portable form. Where processing rests on your consent, you can withdraw that consent at any time, as easily as you gave it: from the cookie settings on the cookie policy, which every page links in its footer, and, for the monthly email, from the unsubscribe link in any of them.

To use any of these rights, email privacy@momofinance.co.uk. There is no charge. You will get a reply within one month; if a request is complex or one of several, that can extend by up to two further months, and you will be told why within the first month. If you are on the mailing list, your address is the identifier and there is nothing else to supply. For anything about a visit rather than a subscription, Momo may need some detail from you, such as the date and time, because reading the site does not identify you and there is nothing to look you up by.

If you are unhappy with the answer, you can complain to the Information Commissioner's Office, the UK's supervisory authority for data protection, at ico.org.uk.

Children

The site is written for adults and is not directed at anyone under 18. Momo does not knowingly collect personal data about children.

Changes to this policy

The date at the top shows when this policy last changed, and a material change is described here when it is made. On the site gained its first form, the monthly email, and this policy changed on the day it shipped. If the site ever offers accounts or saves anything more about you, this policy will say what it keeps and for how long before that starts.