Moment Privacy Policy

Last Updated: 17 August 2026

Moment's Privacy Policy at a Glance

This summary explains what information we collect, how we use it, who we share it with, and your rights in simple terms. Our more detailed Privacy Policy can be found below.

What we collect

We collect information that helps us provide safe and reliable payment services, including:

• Your identity and contact details

• Your payment and transaction information

• Verification / KYC details

• Device, browser and usage information

• Business details (for merchant clients)

Why we collect it

We use this information to:

• Create and manage your account

• Process and settle payments

• Verify your identity

• Prevent fraud and financial crime

• Comply with laws and regulations

• Improve our products and security

• Send marketing only with your consent

Who we share it with

We share data only with trusted partners who help us operate, such as:

• Banks and payment partners

• Identity verification providers

• Fraud prevention and security partners

• Cloud hosting and analytics providers

• Regulators and law enforcement

• Business partners (only when necessary)

Your rights

You can ask us to:

• Access your personal data

• Correct or delete it

• Restrict or object to processing

• Withdraw consent

• Get a copy of your data

Email: privacy@momentco.net

Welcome!

At Moment, we provide payment infrastructure services that enable businesses across Africa to accept and manage payments seamlessly. We value your trust and are firmly committed to respecting your privacy and safeguarding your personal data.

This Privacy Policy explains what personal information we collect, how we use it, and the rights you have in relation to your data when you interact with any of our products or services ("Moment Platforms"). Whether you access our platform through our website, applications, or any associated tools, this policy outlines how we protect your information and the measures we take to keep it secure.

We only collect personal data necessary to fulfil our obligations to you and other relevant stakeholders.

Please read this policy together with any additional privacy or fair-processing notices we may provide at specific points where we collect or process personal data. These supplementary notices offer further clarity and do not replace or override this Privacy Policy.

Who are we

Moment is made up of different legal entities that enable our operations (collectively, the "Moment Group"). This privacy policy is issued on behalf of the Moment Group so when we mention "Moment", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Moment Group responsible for processing your data based on where you are located ("Data Controller").

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. Moment Payco Proprietary Limited has registered an Information Officer with the Information Regulator as required by POPIA, and Moment Nigeria Pay 2 Limited has appointed a Data Protection Officer as required by the Nigeria Data Protection Act 2023. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out above.

Scope of Policy

This Privacy Policy applies to:

• Our website(s), mobile applications, and online platforms

• Merchants using Moment for payments

• End-users making payments through Moment

• Prospective client and marketing interactions

• API integrations and SDK usage

• Customer support channels

• Our business operations and compliance processes

It applies whether you access our services directly or via one of our merchants.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

Moment collects personal information from:

• Clients: Individuals or merchants who utilise Moment's Platforms for payment processing or related services, including those merchants' directors, shareholders, or ultimate beneficial owners.

• End-users: Customers of Moment's clients or users of Moment's website.

• Third-parties: Credit bureaus and identity verification partners, banking and payment partners, fraud databases and AML/CFT sources, public business registers, etc.

We may collect, use, store, and transfer different kinds of personal data about you as follows:

From Moment's clients:

• Identity data: First name, maiden name, last name, identity number, username or similar identifier, company registration number, VAT or tax number.

• Know your customer ("KYC") or know your business ("KYB") information: Identification documentation information, address verification information, proof and/or source of funds, relevant regulatory licences and approvals, or tax information.

• Contact information: Email address, telephone or mobile numbers.

• Financial information: Bank and billing account details.

• Transaction information: Details regarding client transactions with end-users such as account details, bank details, payment card information, or other information required for us to process payment transactions.

• Usage data: Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser metadata, session logs and access timestamps, app engagement and usage analytics, error logs and diagnostic information, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access this website, including the cookies installed or utilised on those devices.

• Marketing and communications data: Your communication preferences.

From end-users:

• Identity data: First name, maiden name, last name, identity number, username or similar identifier.

• Payment data: Billing address, payment information, and any information required to process your payment such as card details and the date and time of transactions.

• Usage data: Internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser metadata, session logs and access timestamps, app engagement and usage analytics, error logs and diagnostic information, browser plug-in types and versions, operating system and platform, and other technology on the devices used to access this website, including the cookies installed or utilised on those devices.

• Marketing and communications data: Your communication preferences.

We also collect, use, and share aggregated data such as statistical or demographic data. Aggregated data could be derived from your personal data but is not considered personal data as this data will 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.

We do not collect any special categories of personal data or sensitive data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic data). Nor do we ask you to provide any information about criminal convictions and offences, except where screening against sanctions, politically-exposed-person and adverse-media sources is required under applicable anti-money laundering laws.

Where our identity verification providers carry out facial-image matching or liveness detection as part of KYC, this may involve processing biometric data. We do this only where necessary to comply with our legal obligations under applicable anti-money laundering and counter-terrorist financing laws, or with your explicit consent where required.

How is your personal data collected?

We use different methods to collect data from and about you including through direct interactions. You may give us your identity and contact data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

• Create an account on our website.

• Sign up for and/or utilise any of our products, services, content, features, tools, technologies, or functions offered on any of the Moment Platforms.

• Subscribe to our publications.

• Request marketing to be sent to you.

• Give us feedback or contact us.

We may also obtain information about you from third parties such as credit bureaus and identity verification services.

Basis on which we use your personal data

We are required to have a legal basis for processing your data, besides Consent which we obtain from you, the legal bases for processing your data are:

• Performance of Contract: means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Legitimate Interests: where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. E.g. for fraud prevention or service improvement. This means the interest of our business in conducting our business to enable us to give you the best service/product and most secure experience. We balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).

• Legal Obligations: Where we need to comply with a legal and/or regulatory obligation.

• Public Interest: Where processing is required to support activities that protect the public, uphold the integrity of the financial system, or assist in the prevention and detection of unlawful conduct.

Purposes for which we will use your personal data

We will only use your personal data when the law allows us to. We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

How we share your information

Moment uses trusted External Third Party service providers ("Sub-processors") to support the delivery of our Services and may share your personal data with them for solely this reason and for the Purposes set out in the table above. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

A current list of Moment's authorised data sub-processors is maintained at https://trust.momentco.io/. We may update this list from time to time in accordance with applicable data protection laws.

We may also share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy policy.

We may disclose your Personal Data to government authorities or law enforcement agencies when required to do so by law, including in response to subpoenas, search warrants, court orders, or similar legal processes. We may also permit such access where we believe in good faith that the disclosure is legally necessary or appropriate to investigate, prevent, or address suspected unlawful activity, fraud, security issues, or other wrongdoing.

Sharing information with credit providers

At your request, or that of a credit provider or financial institution you have authorised, we may share payment information about you with that credit provider in connection with your application for credit, a loan, or other financing.

We only do this with your consent, given directly to us or verified as having been given to the credit provider. You may withdraw your consent at any time.

International transfers of your personal data

We share your personal data within the Moment Group and this may involve transferring your data outside your country of residence.

Many of our external third parties may also be based outside your country of residence, so their processing of your personal data will involve a transfer of data outside your country of residence.

Whenever we transfer your personal data out of your country of residence, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• We use specific contracts which give your personal data adequate protection

• We ensure that we follow country specific cross-border transfer requirements or guidelines

• We adopt other safeguards such as encryption, access controls and minimisation

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

Marketing and Promotional Offers

We provide you with choices regarding the use of your personal data for marketing and promotional purposes. To determine which products, services, or offers may be of interest to you, we may process your data. This allows us to assess your preferences and develop communications that are relevant to your needs.

You may receive marketing communications from us where you have given your consent, or where you are an existing customer and we are marketing our own similar products and services, and in each case where you have not subsequently withdrawn that consent or opted out of such communications.

Third-party marketing

We will obtain your explicit opt-in consent before sharing your personal data with any third party for their own marketing purposes.

Opting out

You may withdraw your consent or request that we discontinue sending you marketing communications at any time by contacting us or by using the unsubscribe mechanism included in our communications. Exercising this choice does not affect your ability to continue using our Services.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to help us operate, secure, and improve our services, personalise your experience, and measure the effectiveness of our features and campaigns.

We also use analytics tools (such as Google Analytics) to understand how users interact with our Services. You can learn more about how Google collects and processes data at www.google.com/policies/privacy/partners/ and opt out of Google Analytics at https://tools.google.com/dlpage/gaoptout.

Please note that clearing your cookies, switching devices, or using a new browser may require you to repeat your opt-out settings.

Please see Moment's full Cookie Policy at https://momentco.net/legal

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed in an unauthorised way. In addition to having a PCI DSS-compliant environment, Moment employs various security and access management tools to ensure maximum security of data whether at rest or in motion. Sensitive payment card details are stored in secured vaults and encrypted or tokenized to replace these sensitive data, reducing the risk of data breaches.

In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Automated Decision Making

We use automated tools to support our compliance and security processes. These tools support activities such as:

• Fraud detection

• KYC/KYB verification

• Identifying unusual or suspicious activity

These tools collect and evaluate the Personal Data you provide, compare it with public records or trusted databases, and assess whether it meets the standards required by law and our internal compliance policies. It may automatically approve or decline an application. We carry out this automated processing because it is necessary for the performance of our contract with you and to comply with our legal obligations under applicable anti-money laundering, counter-terrorist financing and sanctions laws. When the automated checks cannot reach a clear conclusion, the case is referred to our compliance team for manual review.

If you believe an automated decision about your application was incorrect, you have the right to:

• Request human intervention

• Receive an explanation of an automated decision

• Contest a decision you believe was incorrect

If you would like to exercise these rights, you may contact us at privacy@momentco.net.

How long will we use your personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you or where required by regulation to do so.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

In some circumstances, you can ask us to delete your data: see your legal rights below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

• Request access to your personal data: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• 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. Please note that 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 good reason for us to continue 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 notified to you, if applicable, at the time of your request.

• 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 the grounds that you feel it impacts on your fundamental rights and freedoms, you have the right to do so. 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.

• 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:

  • If you want us to establish the data's accuracy.

  • Where our use of the data is unlawful but you do not want us to erase it.

  • 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.

  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• 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 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 products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Object to solely automated decision-making: where a decision about you is made solely by automated means and has legal or similarly significant effects, you may request human intervention, an explanation of the decision, and reconsideration of it, as described under Automated Decision Making above.

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 could 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 could 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.

Children's Privacy

The Moment Platforms are not intended for children, and we do not knowingly collect data relating to children.

If you are below the age of majority (as defined by the applicable laws in your country), you may only utilise our platforms with the involvement of a parent or guardian. We do not have any intention to conclude contractual arrangements or collect data relating to individuals who do not have legal capacity.

If you believe a child has provided data, contact us immediately.

Changes to this Policy

We review our policy periodically and we will let you know if there are significant changes. We will notify you through:

• Email;

• In-app notifications; and/or

• Website banners.

The "Last Updated" date at the top of this Policy reflects the latest version.

Third-party links

Our platforms may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins, and applications and are not responsible for their privacy statements. When you leave the Moment Platform, we encourage you to read the privacy policy of every third-party website you visit.

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 explain the legal basis which allows us to do so. Where required by law, we will request your consent before processing your Personal Data for a new purpose.

Duty to inform us of changes

We review our policy periodically and we will let you know if there are significant changes to the policy practice.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Complaints and Regulatory Contact

You have the right to lodge a complaint with the relevant data protection authority in your country if you believe that we have not complied with applicable data protection laws.

However, we would welcome the opportunity to address your concerns directly before you contact a regulator, so we encourage you to reach out to us in the first instance at privacy@momentco.net. We will make every effort to resolve your complaint promptly and fairly.

For users in different jurisdictions, the appropriate supervisory authorities include:

United Kingdom (UK GDPR)
Information Commissioner's Office (ICO)
Website: www.ico.org.uk

Nigeria (NDPA)
Nigeria Data Protection Commission (NDPC)
Website: www.ndpc.gov.ng
(Or any successor agency established under Nigerian law.)

South Africa (POPIA)
Information Regulator (South Africa)
Website: www.justice.gov.za/inforeg/

If you reside in another jurisdiction in which we operate, you may contact your local supervisory authority in accordance with applicable law.

We will make every effort to resolve your complaint promptly and fairly.