Afrimobile Money Gambia Limited
Privacy Policy

Introduction

Afri-mobile Money Gambia Limited (“we”, “us” and “Afrimoney”) offers a mobile money solution to all Africell Subscribers. Afrimoney’s mobile money platform is a secure way to store and manage money in an account linked to an Africell sim card, similar to a bank account. These mobile money services include domestic money transfer, collection of international remittances, bill payment, payments for goods and services, purchases of Africell services (Airtime, Data, etc.), and receipt of salary, among others. Like most Mobile Money platforms, Afrimoney operates through a network of Mobile Money agents, who serve as cash-in and cash-out (“CICO”) points for Afrimoney users.

Through a partnership with Opareta Inc (“Opareta”), Afrimoney supports Mobile Money agents (the “users”) as they provide financial services to the general public in The Gambia. Afrimoney provides this support through a mobile application (the “Afrimoney agent app” or “Afrimoney platform”) and whilst we do this, we recognize the importance of protecting the privacy of all the information provided to Afrimoney by users on our platform.

As a user of the Afrimoney agent app, it is important that you read through the following to learn what policies are in place regarding your privacy. We may modify this Privacy Policy from time to time, and if we make material changes to it, we will provide notice to you by updating the Privacy Policy on the Afrimoney agent app, and, if you’ve provided an email address, by sending you an email at that email address.

Afrimoney collects personally identifiable information that we use to profile our users and administer and manage individual Afrimoney accounts, update our databases, and provide user support.

This Privacy Policy will explain how we treat your personal information. Personal Information is information about our users that is personally identifiable, such as your name, nationality, age, address, contact details including your email and phone number, any identifying number assigned to you, and any information relating to transactions in which you have been involved that may not be otherwise publicly available.

What We Collect and How We Collect it.

Afrimoney collects the following personal information from the Opareta app when you register to use the app and apply for financing:

• Your name full legal name (as per government records)
• Your date of birth or age (as per government records)
• Your current residential address
• Your work location / address
• Your primary occupation
• Your starting date as an Afrimoney agent
• Your marital status
• Whether you have a relative or friend working at Africell or Afrimoney
• Whether you are related to a Politically Exposed Person (“PEP”)
• Whether you have been subjected to investigation, prison, convicted of bribery or fraud
• The ID number of a valid ID (See below)
• Your primary registered personal phone number
• Your primary registered Afrimoney mobile money phone number
• Any and all additional registered phone numbers (both personal and business)
• Your next of kin or emergency contact – name, contact & relationship
• Your photo to be taken during the onboarding process
• A photo of your form of identification

You directly provide the data Afrimoney collects when you:

• Open the Afrimoney app
• Sign up and register as a new user
• Voluntarily provide Afrimoney with your email address when you contact us for support

How We Use the Personal Information We Collect

Afrimoney uses the Personal Information for the following purposes:

• Afrimoney uses your information to better understand your needs as a user on our platform and provide you with better services.
• Afrimoney uses your personal information to conduct our own Know Your Agent (KYA) screening and reviews as we are required to do under the law.
• Afrimoney uses your email to send you newsletters, with information we feel would be of interest or importance to you, or to contact you as you’ve requested.
• Afrimoney may collect SMS data from you to enable core functionality for the Afrimoney agent app. Digital records of your transactions are a core feature of the Afrimoney agent app and so Afrimoney may collect your SMS data to confirm and verify the status of these transactions.
• Afrimoney reserves the right to monitor your account usage and perform statistical analyses of user behaviour in order to measure interest and use in the various areas of the Afrimoney agent app, as long as the statistical analyses will not be linked to any registered person by a third party.
• Afrimoney reserves the right to monitor your account usage and may disclose personal information to local law enforcement and investigative agencies or any competent regulatory or governmental agencies to assist in the prevention, detection, or prosecution of money laundering activities, fraud, or other criminal activities as mandated by the law.

Afrimoney does not rent or sell your Personal Information to other people or non-affiliated companies.

Where We Keep Your Personal Information and How We Protect It

Afrimoney stores your Personal Information through our third party partners, such as Opareta. Storage by any third parties will be governed by at least industry standard protections. Afrimoney will only keep the Personal Information you supply for as long as needed to fulfill the purpose for which you have supplied such information.

Afrimoney protects your Personal Information using industry standard security measures. We only allow approved contractors and employees who need to use Personal Information for their work with Afrimoney access to your Personal Information, and third party vendors who store your Personal Information must have adequate security measures in place. It is important to note that the nature of the internet does not allow for 100% security of your Personal Information. Although we take reasonable steps to prevent it, Afrimoney does not warrant that information will not be accessed or disclosed through a breach of any of our security protocol. If we become aware of a security breach involving your Personal Information, as soon as practicable, we will email you at the address you’ve provided, and post to the Afrimoney platform a notice of such security breach.

Afrimoney employees who handle personal information are under an obligation to treat it confidentially and may not disclose it to unauthorized third parties. Afrimoney employees are also responsible for the internal security of the information. Employees who violate Afrimoney’s privacy policies shall be subject to a range of disciplinary actions.

What Rights You Have Regarding Your Personal Information

Every user the Afrimoney platform has the following rights:

• The right to information. You have the right to know what personal information is being collected on you by us.
• The right to access. You have the right to see the personal information you have provided to us.
• The right to rectification and erasure. You may request that Afrimoney correct any of your Personal Information, or you may complete any incomplete information we possess. You have the right to request Afrimoney delete the personal information stored, under certain conditions.
• The right to object to processing or restrict processing. You have the right to request Afrimoney limit the processing of your personal data, or you may object to the processing, under certain conditions.
• The right to information on third parties with access to your data. You may request that Afrimoney disclose the identity of any third party or category of third party who has access to your information.
• The right to data portability. You have the right to request Afrimoney transfer your data to another organization or to you directly, under certain conditions.
• The right to limit direct marketing. You have the right to prevent the processing of your personal data for direct marketing provided you notify us of that in writing (by email or otherwise).

Third Party Privacy Policies

The Afrimoney platform may contain links to other websites. Remember this Privacy Policy only applies on the Afrimoney agent app and platform. If you click a link to another site, be sure to read their privacy policy.

It is Afrimoney’s general policy to be as transparent as possible about your privacy. If you have any questions or concerns about this Privacy Policy, please contact us by email at (AfriMoneyChannel@africell.gm).

The Applicability of Gambian, USA and other International Laws

Please be aware that in using the Afrimoney agent app you are sending Personal Information to the United States where our servers are located. That information, including Personal Information, may be transmitted within the United States of America or to other countries outside of your country of residence. These countries may not have privacy and data protection laws as comprehensive as those in your country of residence. Your Personal Information, however, will at all times remain governed by this Privacy Policy.

Please note that Afrimoney is not intended for children under the age of 18. Having said that, Afrimoney does not control and therefore may not be able to authenticate misrepresentations made by uses on the platform concerning their age (or other personal information). In the event that a user is below the age of 18 (“a minor”) and this is made known to us, Afrimoney shall abide by all data protection laws applicable to it and ensure that participation on the Afrimoney platform is not undertaken by a minor without the prior written consent of a parent or guardian.

This privacy policy is governed by the Laws of The Gambia. Therefore, in being a user on the Afrimoney platform, you consent to the jurisdiction of Gambian courts for any dispute which may arise out of this privacy policy.