Privacy Policy

This policy is effective as of 15th April 2024

1. OVERVIEW

Moneta Technology Limited has developed this Privacy Policy to explain how we may collect, retain, process, share and transfer and protect Personal Data from customers, website visitors, when they visit our Sites, Applications or use our Services. This Privacy Statement does not apply to online websites or services that we do not own or control, including third party websites or services of other Moneta Users. This Privacy Statement is designed to help customers obtain information about our privacy practices and to help customers understand their privacy choices when customers use our Sites and Services.

By using or accessing our services, you agree to the collection, use, and disclosure of your personal data as described in this privacy policy, your use of our services is subject to Moneta’s terms. We have defined some terms that we use throughout the Privacy Statement. Customers can find the meaning of a capitalized term in the Definitions section. Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Statement.

2. WHAT PERSONAL DATA DO WE COLLECT?

We may collect information about customers when customers visit our Sites or use our Services, including the following:

  • Registration and Contact information:

    When customers register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfil the Services customers request. Depending on the Services customers choose, we may require customers to provide us with their name, postal address, telephone number, email address and identification information to establish an Account. We may require customers to provide us with additional Personal Data as customers use our Services.

  • Transaction and experience information:

    When customers use our Services or access our Sites, for example, to make purchases from merchants, to receive money, to process payments, or to send money, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information.

  • Participant information:

    When customers use our Services or access our Sites, we collect Personal Data customers provide us about the other participants associated with the transaction.

  • Send or request money:

    When customers send or request money through the Services, we collect Personal Data such as name, postal address, telephone number, and financial account information about the participant who is receiving money from customers or sending money to customers. The extent of Personal Data required about a participant may vary depending on the Services customers are using to send or request money.

  • Pay or request someone else to pay a bill:

    If customers use our Services to pay a bill for the benefit of someone else, or if customers request a User to pay a bill for customers, we collect Personal Data from customers about the account holder such as name, postal address, telephone number, email address, and account number of the bill that customers intend to pay or request to be paid.

  • Add value to their accounts:

    If customers use our Services to add value to their Account or any other account customers may have, or if customers ask a User to add value to any of these accounts, we may collect Personal Data from customers about the other party, or from the other party about customers to facilitate the request. For example, if customers use our Services to reload a mobile phone, or to request value be added to their mobile account, we may collect Personal Data and other information including mobile account number from the other participant.

  • Information about their public profile and their friends and contacts:

    It may be easier for us to help customers transact with their friends and contacts if customers choose to connect their contact list information with their Account or if their Account profile is publicly available. If customers establish an account connection between their device or a social media platform and their Account, we will use their contact list information (such as name, address, email address) to improve their experience when customers use the Services. When their Account profile is public, other users can find their profile to send customers money by searching for customers by name, username, email, or mobile number on Moneta and confirm it’s customers by viewing their photo. Customers can make their Account profile private anytime in their Moneta settings.

  • Information that customers choose to provide us to obtain additional Services or specific online Services:

    If customers request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from customers. We will provide customers with a separate notice at the time of collection, if the use of that information differs from the uses disclosed in this Privacy Statement.

  • Personal Data about customers if customers use unbranded Services:

    certain Services are available without being required to log in to or establish an Account. We will collect Personal Data when customers are interacting with and making payments to merchants using our card payment services that do not carry the Moneta brand and when customers checkout with Moneta without logging into an account. For our unbranded payment services, their interaction is with the merchant, on their platform. If customers are an Account holder, or create an Account at a later date, we may collect information about unbranded transactions and associate them with their Account to improve their customers experience as an Account holder and for compliance and analytics purposes. If customers are not an Account holder, we will collect and store all information customers provide and use such information in accordance with this Privacy Statement.

  • Information about customers from third-party sources:

    We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law.

  • Other information we collect related to their use of our Sites or Services:

    We may collect additional information from or about customers when customers communicate with us, contact our customers support teams or respond to a survey.

  • We may receive additional personal data about you from third parties and other identification and verification services such as your financial institution and payment processor.

3. WHY DO WE RETAIN PERSONAL DATA?

We retain Personal Data to fulfil our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If customer Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal Data in accordance with this Privacy Statement.

4. HOW DO WE PROCESS PERSONAL DATA?

We may Process Customer information for the following reasons:

  • To operate the Sites and provide you with the required Services, including to:

    • Initiate a payment, send or request money, add value to an account, or pay a bill;

    • Authenticate customer access to an Account;

    • Communicate with customers about their Account, the Sites, the Services, or Moneta;

    • Create an account connection between customer Account and a third-party account or platform;

    • Perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes;

    • Keep customer Account and financial information up to date.

  • Verify your identity and the information provide in line with Moneta statutory obligations.

  • To manage our business needs, such as monitoring, analyzing, and improving the Services and the Sites’ performance and functionality. For example, we analyze User behaviour and perform research about the way customers use our Services.

  • To manage risk and protect the Sites, the Services and customers from fraud by verifying their identity. Moneta’s risk and fraud tools use Personal Data, Device Information, Technical Usage Data and Geolocation Information from our Sites and websites that offer Moneta Services to help detect and prevent fraud and abuse of the Services.

  • To prevent and detect and manage risk against fraud and illegal activities using internal and third-party screening tools.

  • To maintain records which are up to date.

  • To market to customers about Moneta products and Services and the products and services of unaffiliated businesses. We may also Process their Personal Data to uniquely tailor the marketing content and certain Services or Site experiences to better match customer interests on Moneta and other third-party websites.

  • To provide personalized Services offered by Moneta on third-party websites and online services. We may use customer Personal Data and other information collected in accordance with this Privacy Statement to provide a targeted display, feature, Services or offer to customers on third-party websites. We may use cookies and other tracking technologies to provide these online services and/or work with other third-parties such as merchant’s, advertising or analytics companies to provide these online services.

  • To provide customers with location-specific options, functionality or offers if customers elect to share their Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide customers with location-based Services, such as advertising, search results, and other personalized content.

  • To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations.

  • To make it easier for customers to find and connect with others. For instance, if customers let us access their contacts or when their Account profile is public, we can suggest connections with people customers may know and help others connect with customers to send customers money by letting them find customer profile when they search for customers by name, username, email, or mobile number on Moneta. We may also associate information that we learn about customers through their and their contacts’ use of the Services, and information customers and others provide, to suggest people customers may know or may want to transact with through our Services. Social functionality and features designed to simplify customer use of the Services with others vary by Service.

  • To resolve disputes that may arise including investigations by law enforcement or regulatory bodies.

  • To respond to customer requests, for example to contact customers about a question customers submitted to our customers service team.

  • Any other purpose that we disclose to you in the course of providing Moneta Services to you.

5. DO WE SHARE PERSONAL DATA?

Moneta does not, trade, rent or sell Personal data to any one, we will not share or disclose your data to any third party without your consent except as necessary as provided below. We may share customer Personal Data or other information about customers with others in a variety of ways as described in this section of the Privacy Statement.

We may share customer Personal Data or other information for the following reasons:

With other members of the Moneta corporate family: We may share customer Personal Data with members of the Moneta family of entities to, among other things, provide the Services customers have requested or authorized; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements; and to help us manage the availability and connectivity of Moneta products, Services, and communications.

With other companies that provide services to us: We may share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide customers with Services, verify their identity, assist in processing transactions, send customers advertisements for our products and Services, or provide customers support.

With other financial institutions: We may share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to market and offer Moneta-related products, unless customers have given consent for other uses. We may also share Personal Data to process transactions, provide customers with benefits associated with their eligible cards, and keep their financial information up to date.

With the other parties to transactions when customers use the Services, such as other Users, merchants, and their service providers: We may share information about customers and their account with the other parties involved in processing their transactions. This includes other Users customers are sending or receiving funds from merchants, and their service providers when customers use the Services to pay for goods or services. The information includes:

  • Personal Data and Account information necessary to facilitate the transaction;

  • Information to help other participant(s) resolve disputes and detect and prevent fraud;

  • aggregated data and performance analytics to help merchants better understand Users and to help merchants enhance Users’ experiences.

With other third parties for our business purposes or as permitted or required by law: We may share information about customers with other parties for Moneta’s business purposes or as permitted or required by law, including:

  • If we need to do so to comply with a law, legal process or regulations;

  • Law enforcement, regulators, government officials, or other third parties in relation to a subpoena, court order, or other legal process or requirement under Nigerian law or regulation, or the laws and regulations of other jurisdictions that are applicable to Moneta or one of its affiliates; when we need to do so to comply with such law or credit card rules; or when we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss; or to report suspected illegal activity or to investigate violations of a user agreement;

  • To protect the vital interests of a person;

  • To protect our property, Services and legal rights;

  • To facilitate a purchase or sale of all or part of Moneta’s business;

  • In connection with shipping and related services for purchases made using a Service;

  • To help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals and merchants.

  • To banking partners as required by card association rules for inclusion on their list of terminated merchants;

  • To credit reporting and collection agencies;

  • aggregated data and performance analytics to help merchants better understand Users and to help merchants enhance Users’ experiences.

  • To companies that we plan to merge with or be acquired by; and

  • To support our audit, compliance, and corporate governance functions.

With customer consent: We also will share customer Personal Data and other information with their consent or direction, including if customers authorize an account connection with a third-party account or platform.

In addition, Moneta may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify customers or provide information about their use of the Sites or Services. We do not share their Personal Data with third parties for their marketing purposes without their consent.

6. HOW DO WE WORK WITH OTHER SERVICES AND PLATFORMS?

A significant benefit and innovation of Moneta’s Services is that customers can connect their Account with a third-party account or platform. For the purposes of this Privacy Statement, an “account connection” with such a third-party is a connection customers authorize or enable between their Account and a non-Moneta account, payment instrument, or platform that customers lawfully control or own. When customers authorize such a connection, Moneta and the third-party will exchange their Personal Data and other information directly. Examples of account connections include:

  • Linking their Account to a social media account or social messaging service;

  • Connecting their Account to a third-party data aggregation or financial services company, if customers provide such company with their Account log-in credentials; or

  • Using their Account to make payments to a merchant or allowing a merchant to charge their Account.

If customers choose to create an account connection, we may receive information from the third-party about customers and their use of the third-party’s service. For example, if customers connect their Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If customers connect their Account to other financial accounts, directly or through a third-party service provider, we may have access to their account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement.

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, customers should review the privacy notice of any third-party that will gain access to their Personal Data as part of the account connection. For example, Personal Data that Moneta shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the accounts or platform’s privacy practices.

7. HOW DO WE USE COOKIES AND TRACKING TECHNOLOGIES?

When customers visit our Sites, use our Services, or visit a third-party website for which we provide online Services, we and our partners may use cookies and other tracking technologies (collectively, “Cookies”) to recognize customers as a User and to customize their online experiences, the Services customers use, and other online content and advertising, measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if customers choose to disable or decline Cookies, their use of the Sites and Services may be limited or not possible.

8. GROUNDS FOR PROCESSING OF PERSONAL DATA?

Processing of Personal information by Moneta shall be lawful if at least one of the following applies.

  • The Data Subject has given consent to the processing of his/ her personal information for one or more specific purposes.

  • Processing is necessary for the performance of an agreement which the Data Subject is party.

  • Where Processing of User Data is necessary for compliance with a legal obligation Moneta is Subject to.

  • Where processing is necessary to protect the Vital interests of a user

  • Where the processing of user data is necessary for the performance of a task that is done in public interest or in exercise of a public mandate vested on Moneta.

WHAT PRIVACY CHOICES AND RIGHTS ARE AVAILABLE TO CUSTOMERS?

Customers have choices and rights when it comes to the privacy practices and communications described in this Privacy Statement. Many of their choices may be explained at the time customers sign up for or use a Service or in the context of their use of a Site. Customers may be provided with instructions and prompts within the experiences as customers navigate the Services.

Choices Relating to the Personal Data We Collect:

  • Personal Data. Customers may decline to provide Personal Data when it is requested by Moneta, but certain Services or all of the Services may be unavailable to customers.

  • Location and other device-level information. The device customers use to access the Sites or Services may collect information about customers, including Geolocation Information and User usage data that Moneta may then collect and use. For information about their ability to restrict the collection and use of such information, please use the settings available in the device.

  • Right to request deletion of data

  • Right to request for and access any Personal Information collected and stored by Moneta

  • Right to be informed regarding your Personal data

  • Right to be informed about appropriate safeguards in place where data is transferred abroad;

  • Right to object to automated decision making and processing;

  • Right to request rectification and modification of Personal Information which Moneta keeps;

  • Right to request the movement of data from Moneta to a third party - this is the right to the portability of data;

  • Right to revoke consent;

  • Right to object to direct marketing, and to request that Moneta restricts the processing of their information; and

Choices Relating to Our Use of customer Personal Data:

  • Personalized Services offered by Moneta on third-party websites and services. Customers may manage their preferences for other Moneta Services that are personalized and offered to customers on third-party websites from their Account. We may also provide customers with instructions and prompts on how to manage their preferences within the Service experience.

  • Finding and connecting with others. If available, customers may manage their preferences for finding and connecting with others from their account of the Service customers use.

Choices Relating to Account Connections

  • If customers authorize an account connection to a third-party account or platform, such as a social media account, customers may be able to manage their connection preferences from their Account or the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices customers may have.

Choices Relating to Cookies:

  • Customers may have options available to manage their cookies preferences. For example, customer browser or internet device may allow customers delete, disable, or block certain cookies and other tracking technologies. Customers may choose to enable these options, but doing so may prevent customers from using many of the core features and functions available on a Service or Site.

  • Customers may have an option regarding the use of cookies and other tracking technologies when customers use a Service or visit parts of a Site. For example, customers may be asked if customers want the Service or Site to “remember” certain things about customers, and we will use cookies and other tracking technologies to the extent that customers permit them.

  • Customers can learn more about our cookies and tracking technologies by visiting the Statement on Cookies and Tracking Technologies page.

Choices Relating to Their Registration and Account Information:

  • If customers have an Account, customers generally may review and edit Personal Data by logging in and updating the information directly or by contacting us. Contact us if customers do not have an Account or if customers have questions about their Account information or other Personal Data.

Choices Relating to Communication:

  • Notices, Alerts and Updates from Us:

    • Marketing: We may send customers marketing content about our Sites, Services, products, products we jointly offer with financial institutions, as well as the products and services of unaffiliated third parties and members of the Moneta corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. Customers may opt out of these marketing communications by following the instructions in the communications customers receive. If customers have an Account with us, customers may also adjust their communication preferences in their Account settings. For messages sent via push notifications, customers may manage their preferences in their device.

    • Informational and Other: We will send communications to customers that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that customers request from us. Customers may not opt out of receiving these communications. However, customers may be able to adjust the media and format through which customers receive these notices.

9. HOW DO WE PROTECT CUSTOMER PERSONAL DATA?

We maintain technical, physical, and administrative security measures designed to provide reasonable protection for customer Personal Data against loss, misuse, unauthorized access, disclosure, and alteration. The security measures include firewalls, data encryption, access controls and information access authorization controls. While we are dedicated to securing our systems and Services, customers are responsible for securing and maintaining the privacy of their password(s) and Account/profile registration information and verifying that the Personal Data we maintain about customers is accurate and current.

In Compliance with Payment Card Industry Data Security Standard (PCI DSS requirements) we implement security protocols and standards including but not limited to encryption, firewall, to ensure your information is safe and secure. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that customers have authorized.

10. CAN CHILDREN USE OUR SERVICES?

The Sites and Services are not directed to children under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Customers are advised to contact us if they believe that we have mistakenly or unintentionally collected information from a child under the age of 18.

11. WHAT ELSE SHOULD CUSTOMERS KNOW?

Changes to This Privacy Statement.

We may revise this Privacy Statement from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Statement will be effective as of the published effective date. If the revised version includes a substantial change, we will provide customers with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means.

Transfers of Their Personal Data to Other Countries

Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party servers which constitutes the transfer of your personal data to computer or servers. Moneta shall take steps to ensure that any transfer of data outside Nigeria from data subjects under this privacy policy is processed and protectable according to the applicable data protection regulations. Where personal data is to be transferred outside Nigeria, Moneta shall protect customer information and put adequate measures to ensure security of such data. By using our Sites and Services, customers consent to their Personal Data being transferred, including countries that have different data protection rules than their country.

12. CONTACT US

Customers may contact us if they have any questions about our Privacy Statement and practices or questions about their Account information or Personal Data via email. dpo@moneta.com

13. WHAT ELSE SHOULD CUSTOMERS KNOW?

Account means a Moneta member account.

Device Information

means data that can be automatically collected from any device used to access the Sites or Services. Such information may include, but is not limited to, customer device type; customer device’s network connections; customer device’s name; customer device’s IP address; information about customer device’s web browser and the internet connection being used to access the Site or Services; Geolocation Information; information about apps downloaded to customer device; and biometric data (e.g., Touch ID/Fingerprint to verify their identity).

Geolocation Information

means information that identifies with reasonable specificity their location by using, for instance, longitude and latitude coordinates obtained through GPS, Wi-Fi, or cell site triangulation. Some of our Services may ask customers for permission to share their current location. Some of the Sites and Services require this information to provide a specific product or online Service. If customers do not agree to our collection of the geolocation information, our Sites or Services may not function properly when customers try to use them.

Moneta

means Moneta Ltd. and subsidiaries or affiliates. In this Privacy Statement, Moneta is sometimes referred to as “we,” “us,” or “our,” depending on the context.

Personal Data

means personal information that can be associated with an identified or identifiable person. “Personal Data” can include name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport, Social Security number and Taxpayer ID). Personal Data does not include information that does not identify a specific User.

Process

means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, disseminating or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

Services

means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to customers by Moneta.

Sites

means the websites, mobile apps, official social media platforms, or other online properties through which Moneta offers the Services and which has posted or linked to this Privacy Statement.

Technical Usage Data

means information we collect from customer phone, computer or other device that customers use to access the Sites or Services. Technical Usage Data tells us how customers use the Sites and Services, such as what customers have searched for and viewed on the Sites and the way customers use our Services, including their IP address, statistics regarding how pages are loaded or viewed, the websites customers visited before coming to the Sites and other usage and browsing information collected through Cookies.

User

means an individual who uses the Services or accesses the Sites.