Moment privacy policy
Updated: 01 March 2024
Introduction
Welcome to Moment’s privacy policy.
Moment respects your privacy and is dedicated to safeguarding your personal data. Accordingly, Moment is committed to only collecting personal data required to meet its obligations to relevant stakeholders. This privacy policy explains how we manage your personal information when you engage with us, regardless of your method of access or usage. The policy details your privacy rights, your legal protections, and covers the utilisation of our products, services, content, features, technologies, or functions offered on our website and all associated sites, applications, and tools collectively referred to as "Moment Platforms."
Please use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. Important information and who we are
Purpose of this privacy policy
This privacy policy aims to give you information on how Moment collects and processes your personal data when you sign up for, access, or use the Moment Platform, including any data you may provide when you contact us.
The Moment Platforms are not intended for children, and we do not knowingly collect data relating to children. If you are below 18 years of age, 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.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Moment is made up of different legal entities, which includes Moment Holdings Limited and certain other Moment group companies listed below (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.
Your Location
Moment Data Controller
South Africa
Moment Payco Proprietary Limited
Nigeria
Moment Nigeria Pay 2 Limited
Rest of World
Moment Holdings UK Limited
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. 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 below.
Contact details
Full name of legal entity: Moment Holdings Limited
Email address: privacy [at] momentco.net
Postal address: c/o Legalinx, 3rd Floor, 207 Regent Street, London, W1B 3HH, United Kingdom
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) being the UK regulator for data protection issues (www.ico.org.uk ) or the relevant regulator in your country where we are licensed. We would, however, appreciate the chance to deal with your concerns before you approach the regulators so please contact us in the first instance.
Changes to the privacy policy and your 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.
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.
2. 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, being individuals or merchants who utilise Moment’s Platforms for payment processing or related services, and includes those merchants’ directors, shareholders, or ultimate beneficial owners; or
End-Users, being customers of Moment’s Clients or users of Moment’s website.
We may collect, use, store and transfer different kinds of personal data about you as follows:
(i) From Moment’s Clients:
Identity Data includes 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 including identification documentation information, address verification information, information around proof and or source of funds details of relevant regulatory licences and approvals, or tax information
Contact Information includes email address, telephone or mobile numbers
Financial Information includes bank and billing account details
Transaction Information including information regarding Client’s 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 includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website, including the cookies installed or utilised on those devices
(ii) From End-Users:
Identity Data includes first name, maiden name, last name, identity number, username or similar identifier
Payment Data includes billing address, payment information, and any information that would be required to process your payment such as card details and the date and time of transactions
Usage Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website, including the cookies installed or utilised on those devices
Marketing and Communications Data includes your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law 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 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 and biometric data). Nor do we ask you to provide any information about criminal convictions and offences.
3. 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.
4. How we use your personal data
We will only use your personal data when the law allows us to. Generally, we do not rely only on consent as a legal basis for processing your personal data. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you.
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.
Where we need to comply with a legal and or a regulatory obligation.
Where required by public interest and legitimate interest.
Purposes for which we will use your personal data
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.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To allow us to contact you | (a) Identity; (b) Contact |
Necessary for our legitimate interests |
| To manage our relationship with you which will include notifying you about changes to our terms or policies | (a) Identity; (b) Contact; (c) Marketing and Communications |
(a) Performance of a contract with you; (b) Necessary to comply with a legal obligation |
| To authenticate the identity of Clients or End Users and to allow them access to the Moment Platform | Identity; Contact |
(a) Necessary for our legitimate interests; (b) Performance of a contract with you |
| To comply with applicable laws and regulations, including by performing compliance checks, and to respond to valid legal processes from regulatory, judicial or supervisory authorities | Identity; Contact; (c) KYC and KYB |
(a) Necessary to comply with a legal obligation |
| To administer and protect our business and the Moment Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting, monitoring, regulatory and risk management obligations and hosting of data) | (a) Identity; (b) Contact; (c) Usage; (d) Payment Data; (e) KYC and KYB |
(a) Necessary for our legitimate interests; (b) Necessary to comply with a legal obligation |
| To evaluate and develop new features, services, or improvements to the Moment Platform | Identity; Usage; Payment Data |
Necessary for our legitimate interests |
| To comply with rules imposed by payment networks or our payment partners and to enforce our contractual rights | KYC and KYB; Usage; Payment data |
Necessary for our legitimate interests |
| To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity; (b) Contact; (c) Usage; (d) Marketing and Communications |
Necessary for our legitimate interests |
| To use data analytics to improve our platforms, customer relationships and experiences | (a) Usage; (b) Payment Data |
Necessary for our legitimate interests |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising utilising your Marketing and Communications Data.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage, Payment Data and Marketing and Communications Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us or by following the unsubscribe options on such communications.
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 law.
5. Disclosures of your personal data
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
External Third Parties as set out in the Glossary.
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, then the new owners may use your personal data in the same way as set out in this privacy policy.
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.
6. International transfers
We share your personal data within the Moment Group. This may involve transferring your data outside your country of residence.
Many of our external third parties may be based outside your country of residence so their processing of your personal data will also involve a transfer of data outside the UK or your country of residence.
Whenever we transfer your personal data out of the UK or your country of residence, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
Where we use certain service providers, we may use specific contracts approved for use in the UK or your country of residence which give personal data the same protection it has in the UK or your country of residence. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or your country of residence.
7. 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 they 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.
8. Data retention
How long will you use my 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 the purposes of 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 to 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.
9. 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 (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
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.
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.
10. Glossary
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and 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 to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
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.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties mean service providers acting as processors who provide IT and system administration services.