Privacy Policy

MTN and data privacy

The operational affiliates of MTN Group Fintech Proprietary Limited as well as all other operational entities which directly or indirectly (whether through one or more intermediaries or otherwise) control, or are controlled by, or are under common control with, MTN Group Fintech Proprietary Limited or MTN Group Limited (collectively "MTN Fintech") are committed to protecting and respecting your privacy.

This privacy statement sets out the basis on which we will process any personal information that we may collect about you as a visitor to momodeveloper.mtn.com (the "Developer Site"), a user (through an account) of the MTN Fintech API (a "User"), or a contact at one of our customers, suppliers or other business partners.

The information that we may process about you

We may collect and process the following information about you:

1. 1. Information that you give us: This is information about you that you give to us by filling in forms on the Developer Site (or other forms that we ask you to complete), giving us a business card (or similar), while attending one of our events or corresponding with us by telephone, post, email or otherwise.
   
   

   When you sign up for an account, it may include:

   • First Name, Last Name

   • Email

   • Username

2. 2. Information that you transmit through the MTN Fintech API: This is information that you transmit using the MTN Fintech API, which our systems will process in accordance with our terms and conditions.
3. 3. Information that the Developer Site and other systems collect about you:
   • • If you visit the Developer Site, it will automatically connect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information such as your browser type and version and the pages on the sites that you visit.
   • • The Developer Site may also download "cookies" to your device – this is described in our separate cookie statement.
   • • If you exchange emails, telephone conversations or other electronic communications with our employees and other staff members, our information technology systems will record details of those conversations, sometimes including their content.
4. 4. Information that the MTN Fintech API collects about you: This may include information relating to your location (based on where you access the MTN Fintech API from, and any information that has been provided by you when you used our existing mobile money service).
5. 5. Other information: We may also collect some information from other sources. For example:
   • • If we have a business relationship with the organisation that you represent, your colleagues or other business contacts may give us information about you such as your contact details or details of your role in the relationship.
   • • We sometimes collect information from third party data providers or publicly available sources for anti-money-laundering, background checking and similar purposes, and to protect our business and comply with our legal and regulatory obligations.

The uses that we make of your information

We may use your information for the following purposes:

1. 1. To create a user account for you;
2. 2. to operate, manage, develop and administer your account for you;
3. 3. to operate, manage and develop the MTN Fintech API for you;
4. 4. to send payments to you;
5. 5. to send you emails about your account and the Developer Site, including emails containing marketing information which we believe you will find relevant and interesting;
6. 6. to operate, manage, develop and promote the Developer Site and our business and, in particular, our relationship with you or the organisation you represent (if any) and related transactions;
7. 7. to communicate with you to inform you about service interruptions and new capabilities or functionalities;
8. 8. to protect the security of the Developer Site;
9. 9. to protect the Developer Site and our business from fraud, money-laundering, breach of confidence, theft of proprietary materials and other financial or business crimes; and
10. 10. to comply with our legal and regulatory obligations and bring and defend legal claims.

We may from time to time review information about you held in our systems – including the contents of and other information related to your email and other communications with us – for compliance and business-protection purposes as described above. This may include reviews for the purposes of disclosure of information relevant to litigation and/or reviews of records relevant to internal or external regulatory or criminal investigations.

• 1. To the extent permitted by applicable law these reviews will be conducted in a reasonable and proportionate way and approved at an appropriate level of management. They may ultimately involve disclosure of your information to governmental agencies and litigation counterparties as described below.
• 2. Your emails and other communications may also occasionally be accessed by persons other than the member of staff with whom they are exchanged for ordinary business management purposes (for example, where necessary when a staff member is out of the office or has left MTN Fintech).

We will only process your personal information as necessary so that we can pursue the purposes described above, and then only where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest in pursuing those purposes. In exceptional circumstances we may also be required by law to disclose or otherwise process your personal information.

We will tell you, when we ask you to provide information about yourself, if provision of the requested information is necessary for compliance with a legal obligation or, on the other hand, if it is purely voluntary and there will be no implications if you decline to provide the information. Otherwise you should assume that we need the information for our business or compliance purposes (as described above). If you are uncertain as to MTN Fintech's need for information that we request from you, please contact the MTN Fintech representative asking for the information, or Contact us (see below), with your query.

Storage of your information

Your personal information will be securely stored by us either on third party systems (see named third party service providers, listed below) or on our own systems.

Disclosure and international transfer of your information

We may disclose personal information about you, where reasonably necessary for the various purposes set out above:

• 1. to the other members of the MTN Fintech group of companies;
• 2. to your colleagues within the organisation that you represent;
• 3. to information technology service providers, including (i) our service provider based in Sweden which assists us in the context of MTN Fintech API calls and (ii) our service provider based in the United States of America that hosts the MTN Fintech API, documentation related thereto and user credentials;
• 4. to partners who run any events that you sign up to through the Developer Site;
• 5. to a person who takes over our business and assets, or relevant parts of them; or
• 6. in exceptional circumstances:
• • to competent regulatory, prosecuting and other governmental agencies, or litigation counterparties, in any country or territory; or
• • to where we are required by law to disclose.

Retention and deletion of your information

We will delete the information that we hold about you when we no longer need it.

Note that we may retain some limited information about you even when we know that you have left the organisation that you represent, so that we can maintain a continuous relationship with you if and when we are in contact with you again, representing a different organisation.

Your rights

You may:

1. 1. have a right of access to the personal information that we hold about you, and to some related information, under applicable data protection law;
2. 2. require any inaccurate personal information to be corrected or deleted;
3. 3. have the right to ask us to erase your personal information and to ask us to restrict the processing of your personal information, in certain circumstances;
4. 4. object to our use of your personal information for direct marketing purposes at any time and you may have the right to object to our processing of some or all of your personal information (and require them to be deleted) in some other circumstances;
5. 5. and have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

If you wish to exercise any of these rights, please Contact us as set out below.

You can also lodge a complaint about our processing of your personal information with the body regulating data protection in your country, where you live or work, or the location where the data protection issue arose.

Contact Us

We welcome questions, comments and requests regarding this privacy statement and our processing of personal information. Please send them to MTN Group Limited, Innovation Centre, 216 14th Avenue, Fairland, Gauteng, 2195, South Africa.

Change to the Policy

Any changes we make to this privacy statement in the future will be posted to our Developer Site (at momodeveloper.mtn.com) and also available if you Contact us. Please check back frequently to see any changes.