Privacy Policy
This notice explains how Digital Money S.r.l. processes personal data
when you use the Digital Money Internal Tools application — the MCP server at
https://mcp.digitalmoney.ai and the Google OAuth client that authenticates its users and that
Digital Money's internal systems use to reach the Google Ads API. It is provided under
Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).
- 1. Data controller
- 2. Scope of this notice
- 3. Data we process
- 4. Purposes and legal bases
- 5. Google user data and Limited Use
- 6. AI assistants and MCP clients
- 7. Recipients and processors
- 8. International transfers
- 9. Retention
- 10. Security
- 11. Your rights
- 12. Cookies, automated decisions, minors
- 13. Changes to this notice
1. Data controller
The controller is Digital Money S.r.l., Via Brera 16, 20121 Milan, Italy, VAT number IT12577680015 (“Digital Money”, “we”). For any privacy matter, including exercising your rights, write to marketing@digitalmoney.ai. If you are an employee or collaborator, the internal privacy notice you received when joining Digital Money also applies to you.
2. Scope of this notice
This notice covers only the Internal Tools application. It does not cover:
- the corporate website digitalmoney.ai, governed by its own privacy policy;
- the consumer comparison websites operated by Digital Money (for example Digital Pecunia, BestBroker, Finprospekt, Scegli Conti), each governed by the policy published on that site;
- the underlying company databases and advertising accounts the tools read from. The application does not introduce new purposes for that data: it gives authorized staff an additional, controlled way to consult data that Digital Money already processes under the notices published to the respective data subjects.
3. Data we process
| Category | Details | Source |
|---|---|---|
| Google account identity | E-mail address, Google account identifier (sub), hosted domain
(hd) and the fact that the address is verified. We do not request your
name, picture, calendar, mail or any other Google data. |
Google Sign-In, at the moment you authorize the application (scopes
openid, email) |
| Authorization and session data | MCP client registration (client name, redirect URI), one-time authorization codes, the opaque access and refresh tokens issued by this server, their creation and expiry times and the e-mail address they belong to. | Generated by the application |
| Usage and security logs | Timestamp, request path and method, HTTP status, latency, a trace identifier, the name of the tool invoked, a truncated preview of the query text, the e-mail address of the authenticated user and, in the hosting platform's request logs, the client IP address. | Generated by the application and by Google Cloud Run |
| Google Ads data | Campaign, ad group, keyword, search term, geographic, cost and conversion statistics of the advertising accounts owned by Digital Money, retrieved on demand through the Google Ads API with Digital Money's own credentials. This is business data about our advertising and does not include your personal Google Ads information. | Google Ads API |
| Company database records | Records from Digital Money's tracking platform and website databases, which may include contact details of business partners and pseudonymous conversion-tracking identifiers (for example click identifiers). API credentials stored in those databases are masked before being shown. | Digital Money systems |
| Application logs | Log entries of Digital Money's websites and platform (errors, HTTP request lines, stack traces), read only on an authorized user's request to investigate a malfunction. They may contain requested URLs, user agents and pseudonymous identifiers (for example click identifiers); client IP addresses are dropped and credentials and e-mail addresses are masked before being shown. | Google Cloud Logging |
We do not process special categories of personal data (Art. 9 GDPR) or data relating to criminal convictions through this application.
4. Purposes and legal bases
| Purpose | Legal basis (Art. 6(1) GDPR) |
|---|---|
Authenticating you and restricting access to Digital Money personnel
(verification of the @digitalmoney.ai domain) |
(f) our legitimate interest in securing our information systems; for employees, the processing is also necessary in the context of the employment relationship (b) |
| Providing the tools' functionality — running the queries and reports you request and returning the results to your MCP client | (b) performance of the employment or collaboration contract; (f) legitimate interest in operating our business efficiently |
| Security monitoring, troubleshooting, abuse prevention and auditing of access to company data and advertising accounts | (f) legitimate interest in the security and integrity of our systems and data; (c) compliance with legal obligations, including accountability under the GDPR |
| Establishing, exercising or defending legal claims | (f) legitimate interest |
Where we rely on legitimate interest we have assessed that the processing is limited to what a member of staff would reasonably expect when using an internal work tool, and does not override your rights and freedoms. We do not use the data for marketing, profiling or to make decisions about you.
5. Google user data and Limited Use
The application's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. In particular:
- Google Sign-In data (your e-mail address and account identifier) is used solely to authenticate you, to enforce the domain restriction and to attribute your actions in our logs. It is not used for advertising, sold, or shared with third parties for their own purposes.
- Google Ads API data is retrieved only from advertising accounts owned by Digital Money, only in response to a request you make, and is returned to you (and to the MCP client you use, see section 6). It is not stored by the application beyond the time needed to serve the request.
- Humans at Digital Money do not read Google user data obtained through the application except where you have asked for support, where it is necessary for security purposes (such as investigating abuse), to comply with applicable law, or for internal operations where the data has been aggregated or anonymised.
- We do not use data obtained through Google APIs to develop, improve or train generalised artificial intelligence or machine-learning models.
You can review or withdraw the authorization granted to the application at any time from your Google account at myaccount.google.com/permissions.
6. AI assistants and MCP clients
The application is designed to be used from an MCP-compatible client, typically an AI assistant in its desktop, web or command-line editions. When you invoke a tool, the results — which may include the data described in section 3 — are transmitted to that client and processed by its provider under the agreement in place between Digital Money and the provider and the provider's own privacy terms. Digital Money selects and configures the assistants it authorizes for work use; you should use only those. The application itself does not use your data to train any AI model.
7. Recipients and processors
Personal data is accessed by Digital Money staff who need it for the purposes above and by the following categories of processors acting on our instructions under Art. 28 GDPR:
- Google Cloud EMEA Ltd / Google LLC — hosting of the application (Google
Cloud Run, region
europe-west1, Belgium), managed databases and cache, request logging; Google Sign-In; Google Ads API. - AI assistant / MCP client providers authorized by Digital Money — processing of the tool results you request.
- Database and infrastructure hosting providers used for the company platforms the tools read from.
We may also disclose data where required by law, to competent authorities, or to professional advisers bound by confidentiality. We do not sell personal data.
8. International transfers
The application and its data are hosted in the European Union. Some providers listed above (in particular Google LLC and the providers of the authorized AI assistants) are established in the United States and may process data there. Such transfers rely on an adequacy decision of the European Commission — including the EU-U.S. Data Privacy Framework for certified organisations — or on the Standard Contractual Clauses adopted by the Commission under Art. 46(2)(c) GDPR, together with supplementary measures where needed. You can request a copy of the relevant safeguards by contacting us.
9. Retention
| Data | Retention |
|---|---|
| Pending sign-in state (between redirect to Google and callback) | 10 minutes |
| Authorization codes | 60 seconds |
| Access tokens issued by the application | 24 hours |
| Refresh tokens issued by the application | 30 days from issue, or earlier if revoked |
| MCP client registrations | Until revoked or no longer used |
| Application and platform logs | 30 days, unless a specific event must be kept longer for security investigations or legal claims |
| Google Ads data and database query results | Not stored: held in memory only for the duration of the request |
Data in the underlying company platforms follows the retention rules of those platforms.
10. Security
We apply technical and organisational measures appropriate to the risk, including: transport encryption (TLS) for every connection; OAuth 2.1 with PKCE and Google-federated sign-in restricted to the company domain; short-lived tokens; read-only database roles for analytics tools and a single, confirmation-gated write operation; masking of credentials in query results; least-privilege service accounts; encryption at rest provided by the hosting platform; and logging of access for audit purposes.
11. Your rights
Under Articles 15–22 GDPR you have the right to access your personal data, to obtain its rectification or erasure, to restrict or object to its processing (including, on grounds relating to your particular situation, where we rely on legitimate interest), and to data portability where applicable. You can exercise these rights by writing to marketing@digitalmoney.ai; we will respond within one month. You can also withdraw the Google authorization at any time (see section 5), which prevents further sign-ins.
You have the right to lodge a complaint with a supervisory authority, in particular the Italian Garante per la protezione dei dati personali or the authority of the EU Member State where you live or work.
12. Cookies, automated decisions, minors
- The application sets no cookies and uses no analytics or tracking technologies. The Google sign-in pages you are redirected to are operated by Google under its own policies.
- We do not make decisions based solely on automated processing that produce legal or similarly significant effects on you (Art. 22 GDPR).
- The application is intended for adults working for Digital Money and is not directed at minors.
13. Changes to this notice
We may update this notice when the application or the applicable law changes. The current
version is always published at https://mcp.digitalmoney.ai/privacy; material changes will be
communicated to users through the usual internal channels.