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Anony Balance privacy notice

Version draft-2026-10-15 · draft

Who we are

Anony Balance (pay.anonylabs.com) is run by Anony Labs, a Dutch sole proprietorship (eenmanszaak), Oude Apeldoornseweg 45-067, 7333 NR Apeldoorn, Netherlands, KvK 42189873, VAT number ⟦owner: add when issued⟧. We are the controller for the data described here. Privacy questions: privacy@anonylabs.com.

Data protection officer: none appointed ⟦owner: confirm, as for AnonyVPN⟧.

What Anony Balance is

A euro balance you top up and that the Anony Labs apps you link (AnonyVPN, AnonyMail, AnonyChat Aura+) can use to pay for their plans. You sign in with your AnonyID.

What we store, and for how long

  • Your account here: a random identifier that AnonyID gives this service only (it is different from the one each app gets, so the apps can't match you through it), when the account was made, and your language. Kept while your AnonyID exists.
  • Your e-mail address, from your AnonyID (you see this on the AnonyID consent screen). We use it ONLY for four e-mails about renewals from your balance: your balance is too low for the next renewal, a renewal went through, a renewal failed, and a price change switched automatic renewal off. Refreshed at every sign-in; deleted when your account is closed. A sent e-mail's text is kept 90 days, then deleted.
  • Whether you are 18 or older (yes or no, never your date of birth), for this sign-in only: top-ups, links and vouchers are for adults.
  • Your balance and its history: every top-up, charge, reversal, voucher credit and correction, in euros. Kept 7 years after your account is closed (Dutch tax law requires business records for 7 years); after your AnonyID is deleted the history is no longer linked to it.
  • Each top-up: the amount, the VAT and your country of residence for VAT (two letters, which you choose), the time, the text you agreed to, and how you paid: for Lightning the sats, the exchange rate and its source, and the invoice's payment hash; through Mollie, which way you chose (card, Apple Pay, Google Pay, iDEAL, Bancontact or another bank method), Mollie's payment id and its status. 7 years. We never receive or store card numbers, bank account numbers, your name on the card or account, or your IP address.
  • The apps you linked: which app, when, its daily limit, when you unlinked it, and what it charged. If you link AnonyVPN to your balance, the balance service knows that you use AnonyVPN and which plans you paid for with your balance. The same goes for every app you link. Kept with your balance history.
  • Vouchers: which voucher campaign you redeemed and the credit it gave you, kept while your account exists and deleted with it. We keep only anonymous totals per campaign.
  • Sign-in sessions: a hash of the cookie value and the sign-in's ID token (for signing you out of AnonyID too), 14 days.
  • Server logs: one line per event, without IP addresses, account identifiers, e-mail addresses or amounts. ⟦owner: retention, as AnonyVPN's 30 days?⟧

What the apps you link learn

A linked app gets a random link id (a "mandate"), not your balance account. It learns whether a charge went through and, when it asks, whether your balance covers its next renewal — never your balance itself, your e-mail address, or which other apps you use.

Who else receives data

  • anony-billing, our own bookkeeping service on our own server: for each paid top-up, its reference, amounts, VAT and country, and how it was paid. No account identifier, name or e-mail address.
  • Our bookkeeping provider ⟦Taxmo / Moneybird, as configured⟧: the same anonymous sale ("Anony Balance customer (consumer) – <country>"), as our processor.
  • Mollie B.V. (Amsterdam), only when you pay through Mollie (card, wallet or bank): Mollie processes the payment and is an independent controller for the payment data it collects in its card fields, during 3-D Secure and in the bank step (your card or bank account details, name, IP address and device, for fraud checks), under its own privacy statement (mollie.com/privacy). The card fields on our page are served by Mollie; we receive only a one-time token and the payment's outcome. To show you only the ways that work for your top-up, our server tells Mollie the amount, your VAT country and the page language.
  • Apple (Apple Pay) and Google (Google Pay), only when you choose them: the wallet on your device shows the amount and our name, and hands Mollie an encrypted card token; Apple and Google process this under their own privacy terms (apple.com/legal/privacy, payments.google.com/legaldocument). Google Pay's script is loaded from pay.google.com on the payment page only when Google Pay is offered.
  • Your bank, when you choose a bank method (iDEAL, Bancontact, EPS, Przelewy24, BLIK, TWINT, PayPal and the others shown): you confirm the payment in your bank's (or that provider's) own app or page; it learns that you paid Anony Labs through Mollie, and the amount.
  • Kraken and Bitstamp: only our server asks them for the bitcoin price. Nothing about you is sent.
  • E-mail: the four e-mails are sent through ⟦owner: the Anony Labs notification server (our own mail server) — or Resend while it is used for AnonyID mail⟧.
  • AnonyID (account.anonylabs.com, our own service): signs you in.

Legal bases

  • Contract (GDPR Art. 6(1)(b)): your balance, top-ups, links, charges and the renewal e-mails you asked for by linking an app.
  • Legal obligation (Art. 6(1)(c)): keeping sales records and VAT data for 7 years.
  • Legitimate interests (Art. 6(1)(f)): limits against misuse and fraud (daily limits, the lock after repeated wrong voucher codes, freezing a balance after a chargeback).

Cookies

Only cookies this service needs: the sign-in session, the sign-in state (10 minutes), your language (1 year), a "signed out here" marker (30 days) and the once-a-day age re-check marker (24 hours). No tracking or analytics cookies.

On the payment page, Mollie's card fields are loaded from js.mollie.com, and Google Pay's script from pay.google.com when Google Pay is offered; a bank method opens your bank's own page. ⟦owner: check which cookies or storage Mollie's fields and Google Pay's script set and list them⟧

Your rights

You can ask for access, correction, deletion, restriction or a copy of your data, and object to processing based on legitimate interests: privacy@anonylabs.com. Deleting your AnonyID closes your balance account (see the terms on what happens to an unspent balance). You can complain to the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).