Privacy Policy - MoMoPSB
INTRODUCTION
MoMo Payment Service Bank (“MoMo PSB”) is a limited liability company registered with the Corporate Affairs Commission (CAC) and licensed by the Central Bank of Nigeria (CBN) to offer financial services with Registration No: 1870676 and principal place of business at 290B, Akin Adesola Street, Victoria Island Lagos. We respect the privacy of our Data Subjects’ Personal Data which should be protected whilst using and interacting with https://momo.ng and all associated MoMo PSB websites, applications, systems, channels, products, and services.
We have prepared this MoMo PSB Privacy Notice (this “Privacy Notice or “Notice”) to notify You about the Personal Data we gather from You, Our Customers, Users, Recruitment Candidates or Applicants, Merchants, Service Providers, Call Center Callers, Visitors and Vendors. This Notice outlines how we handle this Personal Data and the circumstances in which we may share it with third parties.
KEY DEFINITIONS
| The following key terms should be read in conjunction with this Notice: | Definition |
|---|---|
| BVN | Bank Verification Number |
| Consent | Freely given indication of the Data subject’s wishes or a clear affirmative action signifying the Data subject’s agreement to the processing of Personal Data relating to him or her. |
| Contact Center Caller | A person who reaches out to MoMo PSB contact center via telephone to request assistance, seek information, or resolve issues. Contact Center Callers may inquire about services, products, account details, technical support, or other customer-related matters. |
| Customer | A customer is a person (individual or organization) who enters a contract with MoMo PSB by subscribing to MoMo PSB Services or Products. |
| Data Processor | An individual, private entity, public authority, or any other body, who processes personal data on behalf of or at the direction of a data controller or another data processor. |
| Data Subject | The person (natural or juristic) to whom Personal Data relates. In this case, includes but is not limited to the Customer, User, Recruitment Candidate, Vendors, Merchants and Third Parties. |
| Recruitment Candidate/Applicant | A recruitment candidate is a person (individual) who applies for a job at MoMo PSB. |
| Merchant | Any person or organization who provides products and services to their customers via MoMo PSB’s platforms. This includes authorized employees, agents, representatives and sub-contractors of the merchant or service provider. |
| MoMo | MoMo PSB |
| MNO | Mobile Network Operator |
| NDPC | Nigeria Data Protection Commission |
| NDPA | Nigeria Data Protection Act |
| NIN | National Identification Number |
| Personal Data | Information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. This includes but is not limited to, details such as name, identification number phone number, address, age, curriculum vitae, marital status, gender, health details, location information, online identifier, the personal opinions, views, or preferences of the person |
| Processing / Process of Personal Data | Any operation or activity or any set of operations, whether by automatic means, concerning Personal Data, including— (a) the collection, receipt, recording, organization, collation, storage, updating or modification, retrieval, alteration, consultation, or use. (b) dissemination by means of transmission, distribution or making available in any other form; or (c) merging, linking, as well as restriction, degradation, erasure, or destruction of Personal Data. |
| Sensitive Personal Data | Personal data relating to an individual’s — (a) genetic and biometric data, for the purpose of uniquely identifying a natural person, (b) race or ethnic origin, (c) religious or similar beliefs, such as those reflecting conscience or philosophy, (d) health status, (e) sex life, (f) political opinions or affiliations, (g) trade union memberships, etc. |
| Super-Agents/Agents | Any authorized person or organization who sells and/or distributes MoMo PSB’s products and services to MoMo PSB’s customers via Our distribution channels. This shall include the Super-Agents/Agents authorized employees, representatives, and sub-contractors. |
| Third-party Provider | Means and includes, a Merchant, Vendor/Supplier or Super-Agents/Agents |
| “Us”, “We”, “Our” | MoMo Payment Service Bank, MoMo PSB or MoMo. |
| User | A User is a person (individual or Organization) who uses or accesses any of the MoMo PSB channels, which are not limited to MoMo PSB websites; applications; systems, products and services including Unstructured Supplementary Service Data (USSD), and Short Message Service (SMS) |
| Vendor/Supplier | Any person or organization who provides services to or on behalf of MoMo PSB and receives or is entitled to receive fees for such services and any other person who assists the person or organization in carrying out the services. This includes authorized employees, agents, representatives and sub-contractors of the vendor or supplier. |
| Visitor | Anyone who enters the premises of MoMo PSB for a temporary purpose, such as attending a meeting, delivering goods, making an inquiry, or providing services. Visitors typically do not work at the MoMo PSB office and may include clients, customers, vendors, recruitment candidates, contractors, or other guests. |
| “You”, “Your” | The Customer, Vendor or Supplier, Merchant or Service Provider, Recruitment Candidate, Visitor, Call Center Caller or User. |
WHO DOES THIS NOTICE APPLY TO?
This Notice applies to:
- All Customers/Users who are natural persons.
- All Customers/Users who are organizations.
- All Suppliers/Vendors Merchants/Service providers who are natural persons.
- All Suppliers/Vendors, Merchants/Service providers who are organizations.
- All Recruitment Candidates.
- Call center callers.
- Super Agents/Agents
WHAT WE COLLECT ABOUT YOU?
| Data Subject Category | Type of Data Collected | Purpose for Processing | Lawful Basis |
|---|---|---|---|
| Customer | Name, Phone Number, Date of Birth, National Identification Number (NIN), Address, Photo, Gender, Alternate Phone Number, Bank Verification Number (BVN), Email, Card Details (including Personal Account Number – PAN, Card Verification Value – CVV, Card Expiry Date), Transaction Data, Spending habit, etc. directly or via our third parties for onboarding purposes. | We use this information for the purpose of:
| It is a regulatory requirement. It is necessary for us to collect this data before entering a MoMo PSB customer’s contract with You. |
| Device and Operating System Information. We collect the following data when You carry out transactions via electronic devices: the name, model and type of Your device (e.g., smartphone, tablet, or computer device, enrolment date of the device and the last successful login date/time of the device; unique device identifiers such as International Mobile Equipment Identity (IMEI); Your device’s Internet Protocol (IP) address and Your device’s operating system (e.g., iOS, Android, Windows) | We use this information for the purpose of:
| It is necessary for us to collect this data in pursuit of MoMo PSB’s legitimate interest of maintaining secure systems and operations. | |
| Geographic information: We collect the location of towns or villages where You carry out transactions with Your electronic device | We use this information to better understand the geographical distribution of our MoMo PSB’s Product and services. | We will obtain Your explicit consent. | |
| Mobile Network Operator (MNO) Information: Your information relating to use of the MNO’s service: Your airtime balance and Data bundle balance. | We display this information to optimize Your experience when You use Our channels e.g. MoMo PSB App | We will obtain Your explicit consent | |
| Website Visitor | Information which we collect from website visitors such as IP address; browser type; operating system; mobile carrier; Your Internet Service Provider (ISP), Uniform Resource Locators (URLs) of sites from which You arrive or leave the MoMo PSB website; and applications and sites that have embedded MoMo PSB platform technology. | We use this information for the purpose of conducting market research and performing statistical analysis of Our Customers’ and/or users’ behavior. | We will obtain Your explicit consent. |
| Cookies | We use this information for the purpose of recognizing You as an existing or registered user of the MoMo PSB website and/or applications. This information helps Us to serve You better. | We will obtain Your explicit consent. | |
| Vendor/Supplier | Information which we collect during the contracting process such as Vendor contact person or directors’ personal data such as name, contact address, phone number, email address, identification numbers and designation within the vendors’ organization, etc. | We use this information for the purposes of:
| It is necessary for us to do so:
|
| Information we collect about vendor financial information such as Bank Account details, payment terms. | We use this information for the purpose of:
| It is necessary for us to collect this data before entering a MoMo PSB Vendor’s contract with You. | |
| Merchant | This includes the Merchant’s contact person’s name, address, phone number, identification number, email address, and other relevant contact details. | We use this information for the purpose of:
| It is a regulatory requirement. It is necessary for us to collect this data before entering a MoMo PSB Merchant’s contract with You. |
| Recruitment Candidate | MoMo PSB may obtain Recruitment Candidate data such as Name, telephone number, address, contact information, date of birth, and other identifying information, CV etc directly or via our third-party partner, MTNN for recruitment purposes. | We use this information for the purposes of:
| It is necessary for us to collect this data in pursuit of MoMo PSB’s legitimate interest of hiring employees to support the business. |
| Further information collected from Your curriculum vitae, application form, and during the interview process or created by us during the recruitment process, including education and qualifications, employment history, interview notes, correspondences | We use this information for the purposes of:
| It is necessary for us to collect this data in pursuit of MoMo PSB’s legitimate interest of hiring employees to support the business. | |
| Information relating to the education or the financial, criminal or employment history of the person. | We and the CBN use this information for background checks. | It is a regulatory requirement. | |
| Sensitive data relating to Your health | We use this information for the purpose of ascertaining Your fitness to work. | We will obtain Your explicit consent | |
| Visitor | Visitor’s name, contact details (e.g., phone number, purpose, and the person the visitor wishes to see), laptop serial number. Image/Video Recording (CCTV footage) | We use this information for the purpose of:
| It is necessary for us to collect this data in pursuit of MoMo PSB’s legitimate interest of securing lives and property. |
| Contact Center Caller | Your voice recording (telephone conversation) when You call our helplines/contact centres | We use this information for Audit and Quality purposes. We require this data as proof that You have authorised Us to carry out your instructions related to Your MoMo PSB wallet. | It is necessary for us to collect this data to comply with Regulatory requirements of recording evidence and in pursuit of MoMo PSB’s legitimate interest of maintaining service quality and mitigating against fraud. |
| Super-Agents/Agents | Information relating to you and your authorized employees, representatives, or contact persons, including name, address, phone number, email address, identification details, Bank Verification Number (BVN), National Identification Number (NIN), bank account details, business registration information, transaction and performance records, onboarding and due diligence documentation, training and compliance records, and other relevant operational or contractual information. | We use this information for conducting onboarding, due diligence, and KYC verification processes; complying with applicable CBN, AML/CFT, fraud prevention, and regulatory requirements; and other business and operational purposes. | It is necessary for us to collect this data:
|
Where Your Personal Data is required other than in respect of the above mentioned, MoMo PSB shall notify You of such other purpose for which Your Personal Data is required to establish a lawful basis for processing.
CHILDREN’S PERSONAL DATA
MoMo PSB’s products and services are generally intended for individuals who meet the minimum age requirements prescribed under applicable law and regulatory requirements.
MoMo PSB does not knowingly collect, process, or solicit Personal Data directly from children or minors below the legally permitted age without appropriate parental, guardian, or other legally authorised consent, where such consent is required under applicable law.
Where MoMo PSB becomes aware that Personal Data relating to a child or minor has been collected or processed without the required lawful basis or appropriate consent, MoMo PSB shall take reasonable steps to:
- verify the processing activity.
- obtain the necessary consent where appropriate; or
- delete, restrict, or otherwise appropriately manage such Personal Data in accordance with applicable law and internal policies.
Parents, guardians, or persons with lawful authority who believe that a child or minor may have provided Personal Data to MoMo PSB without appropriate authorisation may contact MoMo PSB via: dpo@momopsb.com.
AUTOMATED PROCESSING AND PROFILING
MoMo PSB may use automated systems, tools, and processing activities in connection with the provision of its products and services, including for purposes such as:
- fraud detection and prevention;
- transaction monitoring;
- anti-money laundering and counter-terrorism financing (AML/CFT) compliance;
- sanctions and watchlist screening;
- identity verification and onboarding checks;
- cybersecurity and system security monitoring;
- service optimisation; and
- risk management activities.
Such automated processing may involve the analysis of transaction patterns, device information, behavioural indicators, account activity, and other relevant information necessary to protect customers, comply with legal and regulatory obligations, maintain service integrity, and prevent financial crime.
Where required under applicable law, MoMo PSB shall implement appropriate safeguards to protect Data Subjects’ rights in connection with automated decision-making or profiling activities, including the right to request human review of a decision where applicable.
For further information or to exercise any applicable rights relating to automated processing activities, Data Subjects may contact MoMo PSB via: dpo@momopsb.com.
DATA RETENTION
MoMo PSB shall retain Personal Data only for as long as is necessary to fulfil the purposes for which such data was collected, including for the purposes of satisfying legal, regulatory, contractual, accounting, audit, fraud prevention, dispute resolution, operational, and reporting obligations.
The retention period applicable to Personal Data may vary depending on:
- the nature of the Personal Data;
- the purpose for which the Personal Data was collected and processed;
- applicable legal and regulatory requirements;
- contractual obligations; and
- operational or legitimate business needs.
Where Personal Data is no longer required, MoMo PSB shall securely delete, destroy, anonymise, or archive such Personal Data in accordance with applicable laws, regulations, and MoMo PSB’s Records Retention Policy.
Indicative retention periods applicable to certain categories of Personal Data are set out below:
| Data Category | Indicative Retention Period |
|---|---|
| Customer onboarding records, transaction records, and account information | Duration of the customer relationship and a minimum of ten (10) years thereafter, or such longer period as may be required under applicable AML/CFT, CBN, tax, audit, or other regulatory requirements. |
| Vendor/Supplier records | Duration of the contractual relationship plus ten (10) years thereafter |
| Merchant records | Duration of the merchant relationship plus ten (10) years thereafter |
| Recruitment Candidate data (unsuccessful applicants) | Twenty-four (24) months after completion of the recruitment process unless consent is obtained for a longer retention period |
| Employee recruitment and onboarding records (successful applicants) | Retained in accordance with MoMo PSB’s employee records retention requirements |
| Visitor logs and visitor management records | Twenty-four (24) months |
| CCTV footage | Twenty-four (24) months |
| Contact Centre call recordings | Retained for such period as required by applicable law, regulation, audit requirements, fraud investigation purposes, or CBN directives |
| Website cookies and analytics data | Retained in accordance with MoMo PSB’s Cookie and Digital Channels requirements |
For any category of Personal Data not specifically identified in this Notice, MoMo PSB shall retain such Personal Data only for as long as is necessary for the purpose(s) for which it was collected and processed, taking into consideration applicable legal, regulatory, contractual, operational, audit, dispute resolution, fraud prevention, security, and legitimate business requirements. Such retention shall be carried out in accordance with the NDPA 2023, applicable regulatory requirements, and MoMo PSB’s Records Retention Policy as may be updated from time to time.
Where applicable, MoMo PSB may anonymise or archive Personal Data for research, statistical, regulatory, audit, business continuity, or historical record purposes in accordance with applicable laws and internal governance requirements.
MoMo PSB may retain Personal Data for longer periods where:
- required by law or regulation;
- necessary for the establishment, exercise, or defence of legal claims;
- required for ongoing investigations, audits, litigation, fraud monitoring, dispute resolution, or regulatory inquiries; or
- otherwise permitted under applicable data protection laws.
Where retention periods cannot be precisely determined, MoMo PSB shall determine retention periods based on applicable legal, regulatory, operational, and business requirements.
Notwithstanding the foregoing, MoMo PSB may suspend deletion or destruction of Personal Data where such data is subject to an actual or anticipated investigation, regulatory inquiry, litigation hold, court order, audit requirement, or law enforcement request.
THE SAFEGUARDS FOR YOUR PERSONAL DATA
Maintaining the security of Your Personal Data is important to us. Reasonable security safeguards have been implemented to protect Your Personal Data. We use various methods to protect Your data such as:
- Encryption methods when transmitting sensitive data, such as Your Personal Identification Number (PIN).
- Access to Your Personal Data on MoMo PSB websites, applications, systems, USSD, SMS, products, and services or via recruitment platforms will be safeguarded through encryption and/or password/PIN protection.
- To protect any data, You store on our servers, our Third-Party server, MoMo PSB regularly audits its systems for possible vulnerabilities and attacks and obligates our Third Parties to put appropriate measures in place to ensure Your personal data is safeguarded where necessary.
- MoMo PSB maintains an Information Security Program internally to ensure that Your Personal Data is protected against unauthorized access, accidental loss, or destruction.
SHARING OF YOUR PERSONAL DATA
MoMo PSB will share Your Personal Data with third parties only where it is necessary to deliver services to You and in compliance with a lawful order or request without recourse to the Data Subject. Disclosure of personal data with third parties for other reasons shall be made with the Data Subject’s consent.
There will be circumstances where we are obliged to disclose Your data by law and are prohibited from informing You when we have received a request for Your Personal Data in relation to any suspected or alleged criminal activity.
In addition, companies employed by MoMo PSB (“Third Parties”) to perform certain functions will be assessed to ensure that they handle Our Data Subject’s data securely.
Some of MoMo PSB Third Parties perform the following functions for MoMo PSB:
- Sale and distribution of MoMo PSB Product and Services, soliciting for customers, receiving payments, supplier onboarding, sending postal mail and email, removing repetitive information from customer lists, customer value management, analyzing data, providing market assistance, customer education and communication and providing customer service.
- Vendor onboarding and management.
- Approved online services on MoMo PSB’s websites, products, and services.
These Third Parties have access to Personal Data needed to perform their functions and for purposes clearly defined by MoMo PSB. The third-party processors are required to do the following:
- process data only based on authorization expressly granted by MoMo PSB through a written agreement that specifies the roles and obligations of each party in respect to data protection.
- ensure there is adequate information security and process measures to protect the Personal Data being processed.
- where requested by the Data Subject, the third-party processor shall rectify or delete such Personal Data on the instruction of MoMo PSB.
MoMo PSB may share the personal data of the Data Subject with third-party processors such as MTN, Nigeria Inter-Bank Settlement System (NIBSS), Central Bank of Nigeria, Anti-Corruption Agencies, Law Enforcement Agencies etc.
Where You use mini-apps, in-app services or card services offered through the MoMo PSB channels , MoMo PSB may share the Personal Data and transaction data reasonably necessary to provide such services with relevant mini-app service providers, card schemes, card-personalisation, production, delivery and processing partners, and other authorised service providers, for purposes including account creation or verification, card issuance and delivery, transaction processing, fraud prevention, service improvement and related operational analytics. Such sharing shall be limited to what is necessary for the relevant service and shall be subject to appropriate contractual, confidentiality, security and data protection obligations.
YOUR RIGHTS AS A DATA SUBJECT
Erasing Your Personal Data (Right to erasure)
You have the right to request that MoMo PSB erases Your Personal Data if it is no longer valid or necessary for the purposes for which it was collected, if it is incomplete or inaccurate and if Your agreement/contract with MoMo PSB has been appropriately terminated.
MoMo PSB will, however, retain and use Your Personal Data in accordance with applicable laws for retention of data, for as long as is necessary to provide You with our services and comply with legal and business obligations, resolution of disputes and enforcement of this Notice among others.
Receiving Your Personal Data (Right to data portability)
You have the right to receive Your Personal Data in a commonly used and machine-readable format and the right to transmit this data to another Data Controller when the processing is based on (explicit) consent or when the processing is necessary for the performance of a contract.
Accessing and Changing Your Personal Data (Right to rectification)
You can review the data You provide to us and make any desired changes to the data You have provided. Please be aware that even after Your request for a change is processed, MoMo PSB may, for a time, retain residual data about You in its backup and/or archival copies of its database. MoMo PSB may be required to verify the information You provided in compliance with existing law or regulation prior to making any changes to Your data.
You have the right to choose whether You receive marketing materials or not. We will send You marketing communication materials on related services, products, and offerings provided by MoMo PSB from time to time if You give us Your consent to do so.
You can opt in or opt out of receiving marketing communication materials when You first sign up, or change this preference at any time through Your MoMo PSB App settings. If You change Your mind after signing up,You can withdraw Your consent at anytime by using the opt-out option (such as the unsubscribe link or a “STOP” reply) included in each marketing message, or by contacting Us using the Contact Details in this Notice.
We do comply with applicable provisions of the Central Bank of Nigeria guidelines, Nigeria Data Protection Act and relevant Consumer Protection regulations on direct marketing.
Where You have consented, MoMo PSB and its authorised partners may analyse data elements such as Your name and contact details, your subscribed products and services, your transaction preferences, service usage patterns, demographic information and device information, in order to identify and send You relevant products, services and offers. MoMo PSB will not process your Personal Data for direct marketing without a lawful basis, and You may opt out at any time.
Yout have a right to object to the processing of Your Personal Data. If You want to exercise this right, please submit Your objection in writing to the contact details as follows: dpo@momopsb.com
MoMo PSB may in certain circumstances comply with such a requirement, and in other circumstances, provide You with reasons for objecting to such a request.
You have a right to withdraw Your consent to the processing of Your Personal Data at any time without affecting the lawfulness of Your data which has been received and processed by MoMo PSB in line with any legal obligation or prior to Your withdrawal of consent.
You have the right not to be subject to a decision based solely on automated processing of personal data, including profiling, which produces legal or similar significant effects concerning You.
Promptly notify MoMo PSB via the Contact Details indicated as follows: dpo@momopsb.com, where You wish to exercise any of Your rights with respect to Your Personal Data.
INTERNATIONAL TRANSFERS
MoMo PSB may host, process, transfer and store Your Personal Data outside Nigeria for lawful business and service-delivery purposes, including but not limited to the provision of cross-border or international remittance and funds-transfer services. Where You use such services, MoMo PSB may share the Personal Data necessary to process the transaction with correspondent banks, international money-transfer operators, payment partners, switches and relevant regulators located outside Nigeria. Any such transfer shall be carried out in accordance with the Nigeria Data Protection Act, 2023 and subject to appropriate safeguards.
Your Personal Data shall in all cases remain subject to the Nigeria Data Protection Act, 2023 (as may be amended from time to time) and any other applicable data protection law or regulation.
REPORTING INCIDENTS
In the event of a privacy breach, MoMo PSB shall report such breach to the relevant authority within 72 hours of being aware of the breach and if necessary, affected individuals of personal data breach (where the personal data breach will likely result in high risks to the freedoms and rights of the data subject) will be notified immediately.
MoMo PSB shall take steps to investigate and recover personal data. MoMo PSB will also ensure that controls are enhanced to prevent a re-occurrence of the breach.
You have a right to lodge a complaint before an appropriate authority for any breach of Your rights.
Kindly notify us:
- If You believe Your account to MoMo PSB products, services, systems, applications, and channels has been compromised.
- If You have been contacted by someone via email, SMS or any other means about Your MoMo PSB application, job applications, products, and services account asking for a password, birth date, or other personal data.
- If You believe Your Personal Data has been used for fraudulent activity.
- If You are a member of the security community and need to report a technical vulnerability.
- If You have any other inquiries relating to information privacy and security.
YOUR OBLIGATIONS
There are certain obligations expected from You as a data subject. Some of these obligations are imposed by applicable laws and regulations, and others have become commonplace for MoMo PSB:
- You must always abide by the terms and conditions of this Notice and any agreement between You and MoMo PSB. This includes respecting all intellectual property rights that may belong to MoMo PSB or Third Parties (such as trademarks or photographs).
- You must not provide MoMo PSB with information that You believe might be false or misleading.
- You must keep Your username, PIN, and password confidential and not share it with others.
RIGHT TO AMEND THIS PRIVACY NOTICE
MoMo PSB may, at any time, change this Privacy Notice by posting the amended version on https://momo.ng Unless otherwise stated, the current version will apply each time You access this website.
CONTACT DETAILS
Attention: Data Protection Officer
Address: MoMo Payment Service Bank
MTN Atlantis Building, 290B Akin Adesola Street,
Victoria Island, Lagos, Nigeria.
Email address: dpo@momopsb.com
INTRODUCTION
MoMo Payment Service Bank (“MoMo PSB”) is a limited liability company registered with the Corporate Affairs Commission (CAC) and licensed by the Central Bank of Nigeria (CBN) to offer financial services with Registration No: 1870676 and principal place of business at 290B, Akin Adesola Street, Victoria Island Lagos. We respect the privacy of our Data Subjects’ Personal Data which should be protected whilst using and interacting with https://momo.ng and all associated MoMo PSB websites, applications, systems, channels, products, and services.
We have prepared this MoMo PSB Privacy Notice (this “Privacy Notice or “Notice”) to notify You about the Personal Data we gather from You, Our Customers, Users, Recruitment Candidates or Applicants, Merchants, Service Providers, Call Center Callers, Visitors and Vendors. This Notice outlines how we handle this Personal Data and the circumstances in which we may share it with third parties.
KEY DEFINITIONS
| The following key terms should be read in conjunction with this Notice: | Definition |
| BVN | Bank Verification Number |
| Consent | Freely given indication of the Data subject’s wishes or a clear affirmative action signifying the Data subject’s agreement to the processing of Personal Data relating to him or her. |
| Contact Center Caller | A person who reaches out to MoMo PSB contact center via telephone to request assistance, seek information, or resolve issues. Contact Center Callers may inquire about services, products, account details, technical support, or other customer-related matters. |
| Customer | A customer is a person (individual or organization) who enters a contract with MoMo PSB by subscribing to MoMo PSB Services or Products. |
| Data Processor | An individual, private entity, public authority, or any other body, who processes personal data on behalf of or at the direction of a data controller or another data processor. |
| Data Subject | The person (natural or juristic) to whom Personal Data relates. In this case, includes but is not limited to the Customer, User, Recruitment Candidate, Vendors, Merchants and Third Parties. |
| Recruitment Candidate/Applicant | A recruitment candidate is a person (individual) who applies for a job at MoMo PSB. |
| Merchant | Any person or organization who provides products and services to their customers via MoMo PSB’s platforms. This includes authorized employees, agents, representatives and sub-contractors of the merchant or service provider. |
| MoMo | MoMo PSB |
| MNO | Mobile Network Operator |
| NDPC | Nigeria Data Protection Commission |
| NDPA | Nigeria Data Protection Act |
| NIN | National Identification Number |
| Personal Data | Information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person. This includes but is not limited to, details such as name, identification number phone number, address, age, curriculum vitae, marital status, gender, health details, location information, online identifier, the personal opinions, views, or preferences of the person |
| Processing / Process of Personal Data | Any operation or activity or any set of operations, whether by automatic means, concerning Personal Data, including— (a) the collection, receipt, recording, organization, collation, storage, updating or modification, retrieval, alteration, consultation, or use. (b) dissemination by means of transmission, distribution or making available in any other form; or (c) merging, linking, as well as restriction, degradation, erasure, or destruction of Personal Data. |
| Sensitive Personal Data | Personal data relating to an individual’s — (a) genetic and biometric data, for the purpose of uniquely identifying a natural person, (b) race or ethnic origin, (c) religious or similar beliefs, such as those reflecting conscience or philosophy, (d) health status, (e) sex life, (f) political opinions or affiliations, (g) trade union memberships, etc. |
| Super-Agents/Agents | Any authorized person or organization who sells and/or distributes MoMo PSB’s products and services to MoMo PSB’s customers via Our distribution channels. This shall include the Super-Agents/Agents authorized employees, representatives, and sub-contractors. |
| Third-party Provider | Means and includes, a Merchant, Vendor/Supplier or Super-Agents/Agents |
| “Us”, “We”, “Our” | MoMo Payment Service Bank, MoMo PSB or MoMo. |
| User | A User is a person (individual or Organization) who uses or accesses any of the MoMo PSB channels, which are not limited to MoMo PSB websites; applications; systems, products and services including Unstructured Supplementary Service Data (USSD), and Short Message Service (SMS) |
| Vendor/Supplier | Any person or organization who provides services to or on behalf of MoMo PSB and receives or is entitled to receive fees for such services and any other person who assists the person or organization in carrying out the services. This includes authorized employees, agents, representatives and sub-contractors of the vendor or supplier. |
| Visitor | Anyone who enters the premises of MoMo PSB for a temporary purpose, such as attending a meeting, delivering goods, making an inquiry, or providing services. Visitors typically do not work at the MoMo PSB office and may include clients, customers, vendors, recruitment candidates, contractors, or other guests. |
| “You”, “Your” | The Customer, Vendor or Supplier, Merchant or Service Provider, Recruitment Candidate, Visitor, Call Center Caller or User. |
WHO DOES THIS NOTICE APPLY TO?
This Notice applies to:
- All Customers/Users who are natural persons.
- All Customers/Users who are organizations.
- All Suppliers/Vendors Merchants/Service providers who are natural persons.
- All Suppliers/Vendors, Merchants/Service providers who are organizations.
- All Recruitment Candidates.
- Visitors.
- Call center callers.
WHAT WE COLLECT ABOUT YOU?
| Data Subject Category | Type of Data Collected | Purpose for Processing
| Lawful Basis |
| Customer | Name, Phone Number, Date of Birth, National Identification Number (NIN), Address, Photo, Gender, Alternate Phone Number, Bank Verification Number (BVN), email, etc. directly or via our third parties for onboarding purposes. | We use this information for the purpose of: · Ensuring we adhere to all CBN rules for opening a PSB account · Opening the MoMo PSB account and creating access to the services offered via the account. · Processing the products and services You have subscribed to or bought from Us. · Contacting You about changes to the service, product or to obtain information required for You to use or continue to use Your MoMo PSB account. · Billing You for using Our products or services · Sharing information with MoMo PSB third parties within our operations and Service Providers, including those third parties to whom You have subscribed for their services and consented to Our provision of Your personal data to them. · Sending you marketing materials. | It is a regulatory requirement.
It is necessary for us to collect this data before entering a MoMo PSB customer’s contract with You. |
| Device and Operating System Information. We collect the following data when You carry out transactions via electronic devices: the name, model and type of Your device (e.g., smartphone, tablet, or computer device, enrolment date of the device and the last successful login date/time of the device;unique device identifiers such as International Mobile Equipment Identity (IMEI); Your device’s Internet Protocol (IP) address and Your device’s operating system (e.g., iOS, Android, Windows)
| We use this information for the purpose of: • Ensuring the security of our systems and to mitigate against fraud. | It is necessary for us to collect this data in pursuit of MoMo PSB’s legitimate interest of maintaining secure systems and operations. | |
| Geographic information: We collect the location of towns or villages where You carry out transactions with Your electronic. device
| We use this information to better understand the geographical distribution of our MoMo PSB’s Product and services. | We will obtain Your explicit consent. | |
| Mobile Network Operator (MNO) Information: Your information relating to use of the MNO’s service:Your airtime balance and Data bundle balance. | We display this information to optimize Your experience when You use Our channels e.g. MoMo PSB App | We will obtain Your explicit consent | |
| Website Visitor | Information which we collect from website visitors such as IP address; browser type; operating system; mobile carrier; Your Internet Service Provider (ISP), Uniform Resource Locators (URLs) of sites from which You arrive or leave the MoMo PSB website; and applications and sites that have embedded MoMo PSB platform technology. | We use this information for the purpose of conducting market research and performing statistical analysis of Our Customers’ and/or users’ behavior. | We will obtain Your explicit consent. |
| Cookies | We use this information for the purpose of recognizing You as an existing or registered user of the MoMo PSB website and/or applications. This information helps Us to serve You better.
| We will obtain Your explicit consent. | |
| Vendor/Supplier | Information which we collect during the contracting process such as Vendor contact person or directors’ personal data such as name, contact address, phone number, email address, identification numbers and designation within the vendors’ organization, etc. | We use this information for the purposes of: · Correspondence · Due Diligence and to Know our vendors. · Fulfilling the contractual agreement(s). · Prevent and detect fraud, information security and privacy incidents, and other crimes, recover debts, or trace those who owe us money.
| It is necessary for us to do so: · Before entering a contract with You. · To pursue our legitimate interest. |
| Information we collect about vendor financial information such as Bank Account details, payment terms. | We use this information for the purpose of: · Processing payments · To Conduct vendor due diligence
| It is necessary for us to collect this data before entering a MoMo PSB Vendor’s contract with You. | |
| Merchant | This includes the Merchant’s contact person’s name, address, phone number, identification number, email address, and other relevant contact details. | We use this information for the purpose of: · Ensuring we adhere to all CBN rules for establishing a business account with Us · Creating access for You to use our MoMo PSB Platform · Processing the products and services You offer through Us · Contacting You about changes to the service, product or to obtain information required for You to use or continue to use Your MoMo PSB Merchant account and services · Processing Your bill or Your share of the revenue for using Our platform. · Sharing information with third parties within our operations and Service Providers, including those third parties to whom You have subscribed for their services and consented to Our provision of Your personal data to them. · Sending you marketing materials. | It is a regulatory requirement. It is necessary for us to collect this data before entering a MoMo PSB Merchant’s contract with You. |
| Recruitment Candidate | MoMo PSB may obtain Recruitment Candidate data such as Name, telephone number, address, contact information, date of birth, and other identifying information, CV etc directly or via our third-party partner, MTNN for recruitment purposes. | We use this information for the purposes of: · Communicating with You during the recruitment process · Onboarding You as an employee should we hire You. | It is necessary for us to collect this data in pursuit of MoMo PSB’s legitimate interest of hiring employees to support the business.
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| Further information collected from Your curriculum vitae, application form, and during the interview process or created by us during the recruitment process, including education and qualifications, employment history, interview notes, correspondences | We use this information for the purposes of: · Progressing the recruitment process, including assessing, and making decisions about Your suitability for a role · Verifying compliance with our policies and procedures regarding recruitment. | It is necessary for us to collect this data in pursuit of MoMo PSB’s legitimate interest of hiring employees to support the business.
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| Information relating to the education or the financial, criminal or employment history of the person. | We and the CBN use this information for background checks. | It is a regulatory requirement.
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| Sensitive data relating to Your health | We use this information for the purpose of ascertaining Your fitness to work. | We will obtain Your explicit consent | |
| Visitor | Visitor’s name, contact details (e.g., phone number, purpose, and the person the visitor wishes to see), laptop serial number.
Image/Video Recording (CCTV footage) | We use this information for the purpose of: • Knowing the number of people in the building in case of an incident. • Validating the identity of visitors, audit and security of lives and property. • Ensuring our premises are safe and secure. | It is necessary for us to collect this data in pursuit of MoMo PSB’s legitimate interest of securing lives and property.
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| Contact Center Caller | Your voice recording (telephone conversation) when You call our helplines/contact centres | We use this information for Audit and Quality purposes. We require this data as proof that You have authorised Us to carry out your instructions related to Your MoMo PSB wallet.
| It is necessary for us to collect this data to comply with Regulatory requirements of recording evidence and in pursuit of MoMo PSB’s legitimate interest of maintaining service quality and mitigating against fraud.
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Where Your Personal Data is required other than in respect of the above mentioned, MoMo PSB shall notify You of such other purpose for which Your Personal Data is required to establish a lawful basis for processing.
THE SAFEGUARDS FOR YOUR PERSONAL DATA
Maintaining the security of your Personal Data is important to us. Reasonable security safeguards have been implemented to protect your Personal Data. We use various methods to protect your data such as:
- Encryption methods when transmitting sensitive data, such as your Personal Identification Number (PIN).
- Access to your Personal Data on MoMo websites, applications, systems, USSD, SMS, products, and services or via recruitment platforms will be safeguarded through encryption and/or password/PIN protection.
- To protect any data, you store on our servers, our Third-Party server, MoMo regularly audits its systems for possible vulnerabilities and attacks and obligates our Third Parties to put appropriate measures in place to ensure your personal data is safeguarded where necessary.
- MoMo maintains an Information Security Program internally to ensure that your Personal Data is protected against unauthorized access, accidental loss, or destruction.
SHARING OF YOUR PERSONAL DATA
MoMo PSB will share Your Personal Data with third parties only where it is necessary to deliver services to You and in compliance with a lawful order or request without recourse to the Data Subject. Disclosure of personal data with third parties for other reasons shall be made with the Data Subject’s consent.
There will be circumstances where we are obliged to disclose Your data by law and are prohibited from informing You when we have received a request for Your Personal Data in relation to any suspected or alleged criminal activity.
In addition, companies employed by MoMo PSB (“Third Parties”) to perform certain functions will be assessed to ensure that they handle Our Data Subject’s data securely.
Some of MoMo PSB Third Parties perform the following functions for MoMo PSB:
- Sale and distribution of MoMo PSB Product and Services, soliciting for customers, receiving payments, supplier onboarding, sending postal mail and email, removing repetitive information from customer lists, customer value management, analyzing data, providing market assistance, customer education and communication and providing customer service.
- Vendor onboarding and management.
- Approved online services on MoMo PSB’s websites, products, and services.
These Third Parties have access to Personal Data needed to perform their functions and for purposes clearly defined by MoMo PSB. The third-party processors are required to do the following:
- process data only based on authorization expressly granted by MoMo PSB through a written agreement that specifies the roles and obligations of each party in respect to data protection.
- ensure there is adequate information security and process measures to protect the Personal Data being processed.
- where requested by the Data Subject, the third-party processor shall rectify or delete such Personal Data on the instruction of MoMo PSB.
MoMo PSB may share the personal data of the Data Subject with third-party processors such as MTN, Nigeria Inter-Bank Settlement System (NIBSS), Central Bank of Nigeria, Anti-Corruption Agencies, Law Enforcement Agencies etc.
YOUR RIGHTS AS A DATA SUBJECT
Erasing Your Personal Data (Right to erasure)
You have the right to request that MoMo PSB erases Your Personal Data if it is no longer valid or necessary for the purposes for which it was collected, if it is incomplete or inaccurate and if Your agreement/contract with MoMo PSB has been appropriately terminated.
MoMo PSB will, however, retain and use Your Personal Data in accordance with applicable laws for retention of data, for as long as is necessary to provide You with our services and comply with legal and business obligations, resolution of disputes and enforcement of this Notice among others.
Receiving Your Personal Data (Right to data portability)
You have the right to receive Your Personal Data in a commonly used and machine-readable format and the right to transmit this data to another Data Controller when the processing is based on (explicit) consent or when the processing is necessary for the performance of a contract.
Accessing and Changing Your Personal Data (Right to rectification)
You can review the data You provide to us and make any desired changes to the data You have provided. Please be aware that even after Your request for a change is processed, MoMo PSB may, for a time, retain residual data about You in its backup and/or archival copies of its database. MoMo PSB may be required to verify the information You provided in compliance with existing law or regulation prior to making any changes to Your data.
Direct Marketing
You have the right to choose whether You receive marketing materials or not. We will send You marketing materials on related services, products, and offerings provided by MoMo PSB from time to time if You give us Your consent to do so. If You change Your mind at any time, You are always able to opt out.
We do comply with applicable provisions of the Central Bank of Nigeria guidelines, Nigeria Data Protection Act and relevant Consumer Protection regulations on direct marketing.
Right to object to processing
A data subject has a right to object to the processing of their Personal Data. Data Subjects who want to exercise this right must submit their objection in writing to the contact details as follows: dpo@momopsb.com
MoMo PSB may in certain circumstances comply with such a requirement, and in other circumstances, provide the data subject with reasons for objecting to such a request.
Right to withdraw consent
You have a right to withdraw Your consent at any time without affecting the lawfulness of Your data which has been received and processed by MoMo PSB in line with any legal obligation or prior to Your withdrawal of consent.
Automated decision making
You have the right not to be subject to a decision based solely on automated processing of personal data, including profiling, which produces legal or similar significant effects concerning You.
Promptly notify MoMo PSB via the Contact Details indicated as follows: dpo@momopsb.com, where You wish to exercise any of Your rights with respect to Your Personal Data.
INTERNATIONAL TRANSFERS
You understand that MoMo PSB may be required to host, process, transfer and store Your Personal Data in other countries for business purposes which could include entering a contract with a third-party for Your sole benefit.
MoMo PSB shall ensure that the countries have adequate data protection laws, corporate security policies, procedures, and standards to adequately protect Your Personal Data as prescribed by NDPA.
Your Personal Data shall be subject to the Nigeria Data Protection Act, 2023 (as may be amended from time to time) and any other applicable Data Protection Regulation.
REPORTING INCIDENTS
In the event of a privacy breach, MoMo PSB shall report such breach to the relevant authority within 72 hours of being aware of the breach and if necessary, affected individuals of personal data breach (where the personal data breach will likely result in high risks to the freedoms and rights of the data subject) will be notified immediately.
MoMo PSB shall take steps to investigate and recover personal data. MoMo PSB will also ensure that controls are enhanced to prevent a re-occurrence of the breach.
You have a right to lodge a complaint before an appropriate authority for any breach of Your rights.
Kindly notify us:
- If You believe Your account to MoMo PSB products, services, systems, applications, and channels has been compromised.
- If You have been contacted by someone via email, SMS or any other means about Your MoMo PSB application, job applications, products, and services account asking for a password, birth date, or other personal data.
- If You believe Your Personal Data has been used for fraudulent activity.
- If You are a member of the security community and need to report a technical vulnerability.
- If You have any other inquiries relating to information privacy and security.
YOUR OBLIGATIONS
There are certain obligations expected from You as a data subject. Some of these obligations are imposed by applicable laws and regulations, and others have become commonplace for MoMo PSB:
- You must always abide by the terms and conditions of this Notice and any agreement between You and MoMo PSB. This includes respecting all intellectual property rights that may belong to MoMo PSB or Third Parties (such as trademarks or photographs).
- You must not provide MoMo PSB with information that You believe might be false or misleading.
- You must keep Your username, PIN, and password confidential and not share it with others.
RIGHT TO AMEND THIS PRIVACY NOTICE
MoMo PSB may, at any time, change this Privacy Notice by posting the amended version on https://momo.ng Unless otherwise stated, the current version will apply each time You access this website.
CONTACT DETAILS
Attention: Data Protection Officer
Address: MoMo Payment Service Bank
MTN Atlantis Building, 290B Akin Adesola Street,
Victoria Island, Lagos, Nigeria.
Email address: dpo@momopsb.com