06th February 2020
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.
Users under the age of 18 (eighteen) may use the Services and provide their personal information to us, subject to their parent’s/guardian’s express supervision and consent, which they hereby provide.
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 email@example.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.
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.
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:
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.
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 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.
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.
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, address and email address, in order for us to confirm your identity.
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.
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 firstname.lastname@example.org.
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:
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. ;
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 Minit Money 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:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of South Africa.
Minit Money uses its own cookies for a variety of purposes, including to:
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 your Minit Money PIN or the device security mechanism of your mobile phone (PINpattern/biometric). Do not share your Minit Money PIN with anyone. Minit Money representatives will never ask you for your PIN, so any email or other communication requesting your PIN should be treated as unauthorised and suspicious and forwarded to email@example.com. If you do share your Minit Money PIN with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your PIN. If you believe someone else has obtained access to your PIN, please change it immediately by logging in to your account and changing your PIN and also contact us right away as described below.
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 logging in to your account on the Minit Money website and changing your preferences or by contacting our support firstname.lastname@example.org. 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 email@example.com.
You have the right 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.
You can contact us by email: firstname.lastname@example.org.