1. Data Controller
Monize LLC ("Monize", "we", "us") operates the Monize RE-COMEX platform. We are registered in Ulaanbaatar, Mongolia and serve as the data controller for personal data processed through this platform.
Contact: [email protected]
2. Data We Collect
2.1 Account Information
When your brokerage administrator creates your account, we collect your full name, email address, and assigned role (admin, manager, trader, or viewer).
2.2 Trading Activity
We record bids placed in MSE COMEX auctions, trade settlement records, deposit balances, and buyer registration details. This data is essential for operating the auction platform and meeting regulatory requirements.
2.3 Audit Logs
For compliance purposes, we log administrative actions including the user ID, action performed, IP address, and user agent. These logs are immutable and retained for regulatory compliance.
2.4 Analytics Data
With your consent, we collect anonymous page-view analytics using self-hosted Umami analytics. This data contains no personally identifiable information and is used solely to improve the platform. No data is shared with third parties.
3. Legal Basis for Processing
- Contract performance: Account data, trading activity, and audit logs are necessary to provide the auction platform services agreed upon with your brokerage.
- Legal obligation: Audit logs and trade records are required by Mongolian securities regulations and MSE compliance requirements.
- Legitimate interest: Platform security measures (IP logging, session management) protect all users.
- Consent: Analytics data collection is optional and requires your explicit consent via our cookie consent banner.
4. Data Sharing
We do not sell personal data. We share data only with:
- Mongolian Stock Exchange (MSE): Trading data is transmitted to MSE COMEX as required for auction participation.
- Your brokerage: Administrators within your tenant organization can view user accounts and trading activity for their brokerage.
- Regulatory authorities: When required by Mongolian law or regulatory orders.
5. Data Retention
- Account data: Retained while your account is active, deleted within 30 days of account deactivation.
- Trading records: Retained for the period required by Mongolian securities regulations (minimum 5 years).
- Audit logs: Retained indefinitely for compliance purposes.
- Analytics data: Aggregated, anonymous data retained for up to 24 months.
6. Data Security
We protect your data using encryption at rest and in transit (TLS 1.2+), AES-256-GCM encryption for sensitive credentials, PostgreSQL Row-Level Security for tenant isolation, httpOnly secure cookies for authentication, and CSRF protection.
7. Your Rights
Under the Law on Personal Data Protection of Mongolia and applicable regulations, you have the right to:
- Access your personal data
- Request correction of inaccurate data
- Request deletion of your data (subject to regulatory retention requirements)
- Withdraw consent for analytics at any time via the cookie settings
- Lodge a complaint with the relevant data protection authority
To exercise these rights, contact your brokerage administrator or email us at [email protected].
8. Cookies
We use cookies for essential platform functionality and, with your consent, for analytics. See our Cookie Policy for full details.
9. Changes to This Policy
We may update this policy to reflect changes in our practices or legal requirements. We will notify users of material changes via in-app notification.