We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising utilising your Marketing and Communications Data.

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.

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.

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.

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.

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, 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.

We share your personal data within the ntel 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 Nigeria or 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 Nigeria or your country of residence.

• 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 Nigeria or your country of residence which give personal data the same protection it has in the Nigeria 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 Nigeria or your country of residence.

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.

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 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.

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.

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 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.

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.

Type of data

Lawful basis for processing including basis of legitimate interest

To allow us to contact you

1. (a) Identity;
2. (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

1. (a) Identity;
2. (b) Contact;
3. (c) Marketing and Communications

1. (a) Performance of a contract with you;
2. (b) Necessary to comply with a legal obligation

To authenticate the identity of Clients or End Users and to allow them access to ntel Platform

Identity;

Contact

1. (a) Necessary for our legitimate interests;
2. (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(Know Your Customer) and KYB(Know Your Business)

(a) Necessary to comply with a legal obligation

To administer and protect our business and ntel 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(Know Your Customer) and KYB(Know Your Business) (a) Necessary for our legitimate interests; (b) Necessary to comply with a legal obligation To evaluate and develop new features, services, or improvements to ntel 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(Know Your Customer) and KYB(Know Your Business); 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

Cookies are small pieces of data stored on your device (computer, tablet, or mobile) when you visit a website. These allow us to improve your experience and provide essential functionalities.

• Essential Cookies: These cookies are considered essential as they are necessary for the basic functioning of our website and services. They will typically only be set in response to a request for services, like when you log in or fill out a form. They may assist in ensuring the security of your account.
• Analytical/Performance Cookies: These cookies allow us to measure our website’s performance by analyzing the number of visitors to the website and their activities on the site. This helps us assess how visitors interact with our website and supports us in improving its performance.
• Functionality Cookies: These cookies help us customize your experience based on your preferences. They enhance your journey by remembering choices you make (e.g., language preferences). Functionality cookies allow us to use your interactions with our website to provide enhanced functionality and personalization to you, the user.
• Targeting/Advertising Cookies: These cookies help us provide targeted advertisements. They deliver content more relevant to you and your interests. These cookies, which may be set by our advertising partners, can be used to build a profile of your interests and show you relevant advertisements on other websites.

We may use third-party services that set cookies on our behalf. We do not control these cookies and recommend reviewing their privacy policies.

You can control or delete cookies through your browser settings. However, disabling certain cookies may affect the functionality of our website. When your browsing session ends and the web browser is closed, the session cookies are automatically deleted. Persistent cookies remain stored on your device until their set expiration date or until they are deleted by you.

We may update this Cookie Privacy Policy at our discretion. The update may reflect changes in technology or legal requirements, and users will be notified of any significant updates. Such modified or amended Cookie Notice shall be effective as to you and your information as of that revision date.

We encourage you to periodically review this Cookie Notice to update yourself on how we are using cookies. By using our website and services, you consent to the use of cookies as described in this policy.

Legal Entity: Moment Nigeria Pay 2 Limited

Email: privacy@ntel.com.ng

Address: No 2 Cable Street, behind NeCom House, Marina, Lagos

1. By using, accessing, browsing, framing and/or linking to this site you acknowledge that you have read, understood, and agreed to be bound by these Terms and Conditions.

2. Some pages are only available if you register first but you do not have to register to access most of the pages on the Site. If you do register, we may ask you to provide personal details such as name, address, e-mail address, telephone number and, where appropriate, ntel account number.
3. In such a case you are responsible for the proper use and security of any passwords. ntel does not guarantee the security of the Site against unauthorised or unlawful access or use.
4. ntel may delete a registration (and any associated information or data) without notice if it has not been used for more than six (6) months or at any time if in its absolute discretion it considers that you have abused the use of the site or are in breach of these terms in any way.

5. It is technically impracticable to provide a fault-free site and ntel does not undertake to do so. In the event of a fault, ntel will take steps to restore the Site as soon as is reasonably practicable.
6. Access to the Site may occasionally be suspended or restricted for operational reasons such as maintenance or the introduction of new facilities or products.
7. ntel reserves the right at any time and without notice to modify, edit, delete, suspend, discontinue, temporarily or permanently, any content, including any products available through the Site or any part of it.
8. Content provided by ntel including information, data, material, text, designs, graphics, pictures, video, photographs, applications, software, audio and other files, and their selection and presentation, is owned by ntel or licensed to ntel by third parties. It is protected by copyright, trademark and other intellectual property rights as applicable and provided solely for your own use. Republication or redistribution of the content, including by framing or similar means, is prohibited.
9. You must not permit or make any attempt to disassemble, deconstruct, break down, hack or otherwise interfere with the Site.
10. You may not use the content or services we make available here in ways that might violate our intellectual property rights, harm our systems, or abuse other users of the site.

11. You will indemnify, keep harmless and defend ntel against any claims, losses, costs and liabilities arising from any claims by you or any third party, in connection with the use or misuse of the Site.
12. All the materials on the Site are provided “as is”, without any conditions, warranties or other terms of any kind. Unless otherwise expressly specified ntel excludes all representations, warranties, conditions and other terms (including, without limitation, the conditions implied by law relating to satisfactory quality, and fitness for purpose) which, but for this clause, might have effect in relation to the Site.
13. ntel is not liable whether in contract, tort, under statute, for misrepresentation or otherwise (including in each case negligence) and whether or not the party concerned was advised in advance of the possibility of such loss or damage, whether direct, indirect or consequential howsoever arising under or loss of profit, loss of revenue, loss of anticipated savings, loss of opportunity, loss of business, wasted expenditure, loss from business interruption, loss or corruption or destruction of data, loss of contracts, loss from expenditure of time by managers and employees, liability to third parties, pecuniary losses arising from goodwill, or loss of or damage to goodwill; or any indirect or consequential loss or damage whatsoever, resulting from your use of or inability to use the Site, or from your relying on the accuracy or completeness of the Site content.
14. You may not transfer any of your rights or obligations under the Terms to another party.
15. The delay of ntel to exercise any of its rights or act upon a breach of these terms shall not be deemed a waiver of any subsequent breach of the same or any other term or provision of these Terms and Conditions.
16. We will not be liable to you for any matter or circumstances beyond ntel’s reasonable control.

17. ntel will not disclose any information of a confidential nature obtained as a result of the use of the Site to any person other than their employees, employees or officers of its affiliated company, professional advisers and suppliers. Information of a confidential nature excludes: (a) Any information which became available to the public other than through a breach of the Terms; (b) Information lawfully in the possession of the recipient before the disclosure took place; (c) Information for which disclosure is required by law, by an order of court or by any government authority.
18. In no circumstances shall ntel be liable to you whether based on contract, tort (including negligence or breach of statutory duty) or otherwise for loss (whether direct or indirect) of profits, opportunity, business, or anticipated savings or for any indirect or consequential loss whatever resulting from your access to, or use of, or inability to use the Site and the Content, whether based on warranty, contract, tort, negligence or any other legal theory, and whether or not we know of the possibility of such damage.
19. ntel will comply with its obligations under applicable data protection legislation and maintain all relevant registrations and notifications, for the purposes of operating the Site.
20. You shall take all reasonable steps to ensure that any software used with or in connection with the Site are free from viruses or any other harmful components.

21. The invalidity of any provision shall not affect the enforceability of the remaining Terms.
22. These Terms are governed by the laws of the Federal Republic of Nigeria.
23. Disputes shall be submitted to Arbitration under the Arbitration and Conciliation Act, Cap A18, Laws of the Federation of Nigeria, 2004. Venue: Lagos, Nigeria.
24. Any action related to these Terms shall be subject to the jurisdiction of the Nigerian courts.