Privacy Policy

Effective Date: January 2026
Latest update: 26 September 2026

1. Introduction

This Privacy Policy explains how Conmoji B.V. (“Conmoji”, “we”, “us”) processes personal data in connection with the Conmoji platform.

2. Roles and Responsibilities

Conmoji acts as:

  • Data Controller for account and platform data; and
  • Data Processor for chatbot (Moji) interaction data processed on behalf of Customers.

For payment processing, Mollie B.V. (“Mollie”) acts as an independent Data Controller. As a licensed financial institution, Mollie determines the purposes and means of processing payment data under its own privacy policy, available at https://www.mollie.com/legal/privacy.

3. Legal Basis for Processing

We process personal data on the following legal bases under the GDPR:

  • Contract: to provide and maintain the Service you have subscribed to;
  • Legal obligation: to comply with tax, accounting, and other statutory obligations;
  • Legitimate interest: for fraud prevention, security, and service improvement; and
  • Consent: where required, for example for optional marketing communications and website analytics (Microsoft Clarity, see our Cookie Policy).

4. Payment Data Processing

When you purchase a subscription:

  • payment details are collected and processed by Mollie;
  • Mollie may collect billing name, email, payment method, IBAN or card details, IP address, and related transaction data;
  • Conmoji receives limited metadata from Mollie (such as subscription status, transaction ID, and amount); and
  • we do not store full card or bank account details.

5. Data Sharing with Mollie

We share limited, necessary data with Mollie to:

  • process transactions;
  • verify subscription and payment status; and
  • prevent fraud.

Mollie processes this data under its own privacy framework as an independent controller.

6. Subprocessors

We may use subprocessors for:

  • cloud hosting and infrastructure;
  • AI processing; and
  • email delivery.

All subprocessors operate under Data Processing Agreements. A list of current subprocessors is available upon request via privacy@conmoji.com.

7. International Transfers

Personal data may be processed outside the European Economic Area (EEA). Where this occurs, we implement Standard Contractual Clauses or other appropriate safeguards recognized under the GDPR.

8. Data Retention

Data TypeRetention Period
Account dataDuration of subscription + 6 months
Subscription and financial records7 years, in accordance with Dutch tax law (fiscale bewaarplicht)
Chat session dataDuration of subscription + 30 days, or until deletion is requested by Customer, whichever is earlier
Technical logsUp to 6 months

9. Your Rights

Under the GDPR, you may exercise the right to access, rectify, erase, restrict, or port your personal data, and to object to certain processing.

To exercise these rights, contact: privacy@conmoji.com.

Payment-related data rights may need to be exercised directly with Mollie.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens), www.autoriteitpersoonsgegevens.nl.

10. Contact

Questions about this Privacy Policy can be sent to: privacy@conmoji.com.