V2.1

13 May 2021

PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING THE WWW.MINITMONEY.COM WEBSITE (THE “SITE”) (OWNED AND OPERATED BY CENTBEE (PTY) LTD (2017/014560/07) (“CENTBEE”)) AND THE MINIT MONEY APPLICATION (OWNED AND OPERATED BY CENTBEE), YOU (THE “USER”) ARE INDICATING YOUR ACCEPTANCE TO BE BOUND BY THE PRIVACY POLICY. MINIT MONEY IS A BRAND OWNED AND OPERATED BY CENTBEE (PTY) LTD, AND THEREFORE ANY REFERENCES MADE TO MINIT MONEY SHALL ULTIMATELY POINT TOWARDS THE LEGAL ENTITY TO WHICH THE BRAND BELONGS, WHICH IS CENTBEE (PTY) LTD. MINIT MONEY AND CENTBEE SHALL THEREFORE BE TERMS USED INTERCHANGEABLY, WITH ALL LEGAL RIGHTS AND OBLIGATIONS ULTIMATELY VESTING IN THE LEGAL ENTITY CENTBEE (PTY) LTD

Introduction

This Privacy Policy applies to www.MinitMoney.com and any of its related blogs, applications, websites or platforms (“Website”) owned and operated by Centbee (Pty) Ltd., a limited liability private company registered in accordance with the laws of South Africa (registration number #2017/014560/07).

This Privacy Statement describes how Minit Money (“Centbee”, “Minit Money” “our”, “us” or “we”) collects, uses and discloses the personal information you provide to us or which is collected from you, when you engage with Minit Money in any way, such as when you use the Website, our Services or contract with us. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information.

If you have questions or complaints regarding our privacy policy or practices, please contact our appointed Information Officer using the following information:

• Name or title of data representative: The Chief Executive Officer
• Email address: support@minitmoney.com
• Postal address: 10th floor, 16 Baker Street, Rosebank, Johannesburg, South Africa 2196
• Telephone number: +27 86 076 6960

This Privacy Policy version was last updated on 13 May 2021 and historic versions are archived and can be obtained by contacting us at support@minitmoney.com.

A Special Note About Children’s Information and Special Categories of Information

Users under the age of 18 (eighteen) may not use the Services and provide their personal information to us.

If you are a parent or guardian of a person whose personal data we process pursuant to this Privacy Policy, you warrant that you have read, understood and agree to this Privacy Policy, and hereby expressly consent to Minit Money processing your child’s/ward’s personal data as per this Privacy Policy. You further warrant that any engagement by your child/ward with Minit Money is under our direct supervision and consent.

If a parent or guardian becomes aware that his or her child/ward has provided us with their personal information without his or her consent, he or she should immediately contact us at support@minitmoney.com and we will delete such information from our files.

Further, we do not process Special Categories of Personal Information, including information about your race, sexual orientation, political affiliation, trade union membership, ethnic or cultural origin or religious affiliation, nor do we process any of your biometric information or information concerning your health. As such, do not provide us with such types of information for any reason.

OVERVIEW AND ROLE OF MINIT MONEY

It is important for you to review this Privacy Policy as it applies to all Minit Money Services. Minit Money takes the protection of and privacy of your personal information very seriously and will collect, use and disclose your information only in accordance with the terms of this Privacy Policy or otherwise with your consent or in compliance with the law. In order to operate and provide the Minit Money website, application and services (the “Minit Money Services”) and to reduce the risk of fraud, we must ask you to provide us with information about yourself. This Privacy Policy describes the information we collect and how we use and disclose that information. We will not sell or rent your personal information to third parties for their marketing purposes. However, in order for us to offer our services to our users; enhance the quality of our service from time to time; and protect the interests of our users, we will in limited circumstances share some of your personal information with third parties under strict restrictions, as described in more detail in this Policy. By accepting the Privacy Policy on registration, you expressly consent to our collection, use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy. Further, you also understand and agree that we may lawfully process your personal information due to the legitimate business needs of Minit Money to operate, as well as on the basis that you have contracted with us for the use of our Services.

Minit Money is the Data Controller, as defined by applicable law, and is responsible for your personal data in instances where we decide the processing operations concerning your personal data. Sometimes we also operate as a processor of personal data on behalf of a third-party data controller, where that data controller’s privacy terms will apply, but we will draw your attention to them, when applicable.

If you disagree with the terms of this Privacy Policy, please do not register for or use the Minit Money Services and immediately discontinue your use of the Website and Services.

1. WHAT INFORMATION DO WE COLLECT?

Categories of Information

Minit Money may gather and use information about you, including (but not limited to) information in the following categories, which is either provided by you when registering for/using the Services, or is automatically collected from you when using the Website:

• Identification data and contact information (e.g. name, address, telephone number, email address, date of birth);
• Profile information (the information provided by you which is displayed in your Minit Money profile in the Minit Money application);
• Electronic identification data (e.g. IP addresses, cookies);
• Banking and payment information (credit card information, account number) for accounts linked to your Minit Money account;
• Survey results;
• Information about your usage of and interaction with the Minit Money software, our products and websites including computer, platform, device and connection information, device capability, carrier network, bandwidth, statistics on page views, and traffic to and from our websites, operating system or browser type;
• Copies of government-issued identification, such as ID, driver’s license, passport or other documents;
• Information from third parties (as discussed below);
• Products or services ordered and delivered;
• Correspondence between you and Minit Money, including email, telephone logs or recordings, or instant message content, or messages between or to your contacts or other Minit Money users when sent using the Minit Money system

2. REQUIRED INFORMATION FOR REGISTRATION

To open a Minit Money account or use the Minit Money Services, you must provide your mobile phone number. Using certain profile information, we utilize third parties to extract additional information to help verify the authenticity, and any background checks required on your account. In order to make a transaction on your Minit Money account, you must provide additional personal information (which may include a copy of government-issued photo identification, and relevant supporting documentation) necessary to validate your identity for legally-required Anti-Money Laundering & Terrorist Financing purposes, and to comply with relevant laws and regulations. We may also require other commercial and/or identification information if you send or receive certain high-value transactions or high overall payment volumes through the Minit Money Services in order for us to comply with our anti-money laundering or other legal obligations.

3. TRANSACTION INFORMATION

When a user downloads any of Minit Money’s apps or otherwise envisages to use any of Minit Money’s products or services, whether or not such products or services are actually used, the user shall agree to have entered into a business relationship with Minit Money and shall therefore be classified as a customer for all intents and purposes of this Privacy Policy. When you use Minit Money Services, we ask you to provide information related to that transaction, including such information as the amount of the transaction, the type of transaction and payment information. Also, when you send money to another Minit Money user or a remittance recipient, you may be asked to provide personal details of that customer to complete the transaction and your details may also be passed on to us from that customer or our commercial partners. We retain this information for each of your transactions through the Minit Money Services and may add this information to your account profile to be used for future transactions that you may make with us. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to create or access your Minit Money account or use the Minit Money Services, in order to help detect possible instances of unauthorised or fraudulent transactions. Furthermore, Minit Money may transfer your data across national borders, including to jurisdictions where data protection and privacy laws may not exist.

1. INFORMATION ABOUT YOU FROM THIRD PARTIES

In order to protect our customers against potential fraud, we verify the information you provide with identity verification services, payment processors and/or credit reference and fraud agencies. In the course of such verification, we may receive personally identifiable information about you from such services. In particular, if you use a credit card or debit card with Minit Money, we will use card authorization and fraud screening services to verify that your card information and address match the information you supplied to Minit Money, and that the card has not been reported as lost or stolen. If you send or receive high overall payment volumes through the Minit Money Services, in some circumstances we are required to conduct a background check on you by obtaining information about you from a credit reference or fraud agency. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit reference or fraud agency, to the extent permitted by law. Minit Money, at its sole discretion, reserves the right to periodically retrieve and review a consumer credit report supplied by such a credit reference or fraud agency for any account, and reserves the right to close an account based on information obtained during this credit review process.

5. ADDITIONAL VERIFICATION

If we cannot verify the information that you provide, we may ask you to send us additional information (such as your driving license, credit card statement and/or a recent utility bill, or other information linking you to the applicable address), or to answer additional questions online to help verify your information. If you want to change your details or you have recently moved, we will need additional documentation from you.

6. WEBSITE TRAFFIC INFORMATION

Because of the way Internet communication standards work, when you arrive at or leave the Minit Money website, we automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser and operating system you use and the times you access our website. We use this information to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve the Minit Money Services.

Customer Service Correspondence: If you send us correspondence, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from Minit Money to you. We retain these records in order to keep records of our relationship, to measure and improve our customer service, and to investigate potential fraud and violations of our Terms of Service. We retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. You may use our telephone number to contact us for support or assistance with our services. From time to time, we may contact you by telephone for support purposes. If we correspond by telephone, we will typically request certain personal information from you, such as your date of birth, identity number or mobile phone number, in order for us to confirm your identity.

7. NON-USER RECIPIENTS AND REQUEST

When a Minit Money user either sends a payment to, or requests a payment from, an individual who is not a registered member of Minit Money, we will retain the information that the member submits to us for the benefit of the member who is attempting to contact the non-member, so that the member can see a complete record of his or her transactions, including uncompleted transactions. Although this information is retained, we will not market to the non-member in any way at any time using this information.

8. PERSONAL DATA OF FRIENDS

You may be interested in inviting your friends or contacts to join Minit Money. In the event you wish to use Minit Money’s referral service, you will provide contact information about these friends or contacts. This information will only be used for the purposes of automatically generating a message to these potential Minit Money users. By entering your friend’s contact details you are confirming that your friend has consented to the supply of their details and that you consent to Minit Money identifying you as the person who has made the referral in the invitation sent to your friend and including your name and details in such invitation. Further, you hereby indemnify Minit Money against any liability it may accrue by virtue of your provision of a third-party’s information to us. You may request to remove this third-party information by emailing us at support@minitmoney.com.

9. Aggregated Data

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

9. HOW DO WE USE AND DISCLOSE YOUR INFORMATION AND FOR WHAT PURPOSES?

Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience when using our Services and to properly perform on our contractual duties with you.

Internal Uses: We collect, store and process your personal information on servers located in various jurisdictions where Minit Money facilities are located. Minit Money collects and uses, or has third party service providers acting on Minit Money’s behalf collecting and using, personal data relating to you, as permitted or necessary for the following purposes, which are all done on the lawful grounds of your express consent, our legitimate business interests, and our contractual engagement with you:

• Provide the Minit Money Services and members services you request including without limitation processing transactions and communicating with you about your transactions;
• Verify your identity and the information provided to us;
• Resolve disputes, collect fees, and troubleshoot problems;
• Inform you about service updates and faults;
• Investigate and prevent potentially prohibited or illegal activities, and enforce our Terms of Service;
• Customise, measure, and improve our services and the content and layout of our website;
• Deliver targeted marketing and advertising, service updates, and promotional offers based on the communications preferences you have defined for your Minit Money account;
• To improve our search functionality and help you find contacts more easily;
• Compare information for accuracy, and verify it with third parties;
• For our internal purposes, to associate relationships amongst our users through such attributes as address, phone number or device information, for example where more than one Minit Money account is set up under one household or last name;
• Protect your and Minit Money’s interests, including in particular to enforce our Terms of Service and investigate, prevent and fight against fraud; and
• Comply with legal and regulatory requirements,

Your payment card number, bank account and other financial information will never be revealed to or be visible to other Minit Money users, including anyone who you have paid or who has paid you through the Minit Money Services or third parties that use Minit Money Services, except with your express permission or if we are required to do so pursuant to payment card rules, a court order or other legal process. By accepting this Privacy Policy, you expressly agree and consent that each time you use your Minit Money account for transactional purposes, Minit Money may transfer the aforementioned relevant data to such Minit Money customer in order to process, execute or otherwise deal and provide information about the payment.

Disclosure to Third Parties: Other Than Minit Money Users, Minit Money will not sell or rent any of your personal information to third parties for their marketing purposes, and will only disclose this information in the limited circumstances and for the purposes described in this Policy. In certain situations, Minit Money may be required to disclose personal data in response to lawful requests by public authorities, including meeting national security or law enforcement requirements. Specifically, you consent to and direct Minit Money (and third party service providers acting strictly on Minit Money’s behalf) to do any and all of the following:

Disclose information including, without limitation, transaction information, account information, personal information and the contents of communications to: the police; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies (other than tax related authorities), departments, regulatory authorities, self-regulatory authorities or organizations; and other third parties that we in good faith believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations of violations of our Terms of Service (including without limitation, your funding source or credit or debit card provider). If you provide false or inaccurate information and fraud is identified, we may pass details to fraud prevention agencies and law enforcement agencies may access and use that information. We and other organizations may also access and use this information (including information from other countries) to prevent fraud and money laundering;

• Disclose information in response to the requirements of the payment card associations or a civil or criminal legal process.
• Disclose necessary information to the payment processors, banks, payment card associations, or other service providers necessary to provide the Minit Money Services you request (these third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information was shared).
• Disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian legally appointed for you).
• Disclose aggregated statistical data with our business partners. For example, we may disclose that a specific percentage of our users live in particular geographies. However, this aggregated information is not tied to personal information.
• As with any other business, it is possible that in the future Minit Money could merge with, or be acquired by, another company. If such an acquisition occurs, you consent to the successor company having access to the information maintained by Minit Money, including customer account information, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended. You will be notified via email and/or a prominent notice on our website of any material change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Change of Purpose: We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by applicable national law.

International Transfers: We share your personal data within the Centbee group of organisations and affiliates, and this may involve transferring and processing your data outside of South Africa. Whenever we transfer your personal data out of the country, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
2. Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of South Africa.

10. WHAT ARE COOKIES AND HOW DO WE USE THEM?

Minit Money and its partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use cookies or similar technologies in order to provide you advertising based upon your browsing activities and interests. We use analytics software to allow us to better understand the functionality of our software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile app. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website. We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes.

Minit Money uses its own cookies for a variety of purposes, including to:

• Recognize you when you sign in and understand how you arrived at our website, so we can make sure that we provide you with relevant customer content and information;
• Recognize your time zone so that your transaction histories and other account information are accurately displayed;
• Present customized content, if, for example, your cookie was set a long time ago, we know you are not a new user and we will not show you content intended for new users, such as ‘how to use Minit Money’ pages;
• Remember your chosen preferences, such as the language you choose to see our website in or default currencies;
• Fight against fraud;
• Inform Minit Money about the version of the Minit Money software client you are using so that we can provide you with new software updates and direct you to the relevant help sections;
• Enable you to access your account and account services through the Minit Money software client;
• Provide internal and customer analytics and gain statistics and metrics about our websites, such as total number of visitors and page views;
• Monitor the effectiveness and performance of our advertising and marketing campaigns and carry out research in order to help us to improve our products and websites;
• Initiate security measures such as ‘time-out’ when you have not logged into your account service area for a period of time; and
• Populate your Minit Money client with one of your Minit Money contacts’ information, where this contact invited you to join Minit Money.

11. HOW LONG IS YOUR INFORMATION RETAINED?

Minit Money will retain your information (including geo-location data) for as long as is reasonably necessary to: (1) fulfil any of its intended purposes (as described in this Privacy Policy) or (2) comply with applicable legislation, regulatory requests and relevant orders from competent courts or our regulators.

12. HOW DOES MINIT MONEY PROTECT YOUR INFORMATION?

Minit Money is committed to handling your customer information with high standards of information security. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfil their job responsibilities. Minit Money will take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation. We encrypt all transmission of information using secure socket layer technology (SSL). Your personal and traffic data can only be accessed by authorized employees of Minit Money or its affiliates, subsidiaries or service providers who need to have access to this data in order to be able to fulfil their given duties. The security of your Minit Money account also relies on your protection of the device security mechanism of your mobile phone (PIN pattern/biometric). Minit Money representatives will never ask you for your mobile phone PIN, so any email or other communication requesting your PIN should be treated as unauthorised and suspicious and forwarded to support@minitmoney.com. 

13. ACCESSING OR CHANGING YOUR INFORMATION

You can review the personal information you provided us and make any desired changes or deletions to such information, or to the settings for your Minit Money account, at any time by contacting our support support@minitmoney.com. Upon request, Minit Money will provide you with information about whether we hold any of your personal information. You have a right to ask for a copy of your information and to ask us to correct any inaccuracies in your personal information or delete your personal information. A fee may be charged depending on the work required to obtain and provide the requested access. We will respond to your request within a reasonable time frame. If you choose to close your Minit Money account, you will need to contact Minit Money to request this closure. We will mark your account in our database as “Closed,” but will keep your account information in our database for as long as reasonably necessary to comply with our legal and regulatory requirements. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law. If you wish to subscribe to our newsletter(s) or marketing communications we will use your name and email address to send communication to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at support@minitmoney.com.

14. YOUR RIGHTS RELATING TO YOUR PERSONAL INFORMATION

You have the right to:

1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no valid reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be communicated to you, if applicable, at the time of your request.

1. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
2. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
   1. if you want us to establish the data’s accuracy;
   2. where our use of the data is unlawful but you do not want us to erase it;
   3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
   4. you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
3. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform on a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Website access or Services to you. We will advise you if this is the case at the time you withdraw your consent. Please take note that regardless of your right to withdraw consent under data privacy laws, other South African legislation applies and may require that we continue to process your data in order to comply with anti-corruption, crime-fighting or other legislation, which you expressly understand and agree to.

No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

14. POLICY ACCOUNTABILITY

Minit Money is responsible for ensuring that our day-to-day procedures comply with this Privacy Policy. If you want to exercise your right to access your information or have any questions about this policy, Minit Money’s information practices, or your dealings with Minit Money, you can contact us by emailing support@minitmoney.com.

15. THIRD PARTY SITES

Our site includes links to other websites whose privacy practices may differ from those of Minit Money. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

16. POLICY UPDATES AND NOTIFICATIONS

All future changes to this Privacy Policy as already published on the Minit Money website(s) and application at the time you register for the Services are incorporated by reference into this Privacy Policy. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. If you disagree with the terms of this Privacy Policy, you may close your account at any time.

You can contact us by email: support@minitmoney.com.