1 EXECUTIVE SUMMARY

1.1 NetOne Financial Services (Private) Limited, operating under the name "OneMoney," recognizes the importance of information technology in serving all stakeholders. We believe that the development of information technology should occur within the framework of international cooperation. It is our commitment that information technology will not infringe upon human identity, human rights, privacy, or individual and public rights.

1.2 At OneMoney, we are dedicated to safeguarding your privacy, maintaining the security of your information, and ensuring the protection of your personal data. As part of our commitment to delivering efficient products and services, we will collect and process your personal information lawfully, store it securely, and refrain from unlawfully disclosing it to any unauthorized third parties.

1.3 By utilizing our service, you acknowledge and agree to the collection and utilization of information as outlined in this policy. The personal information we gather is employed to provide and enhance the service. We do not disclose or share your information with any third party, except as specified in this Privacy Policy.

2 PERSONAL INFORMATION WE COLLECT?

2.1 Categories of Personal Information collected from you, including from your interactions with us and use of the Services:

2.2 Personal Identifiers: Such as name, Business Name, Address, Phone Number, Email, IP address, Device Information, other information necessary to establish an account or profile.

2.3 Imported Contact Information / Contact Lists: including name, address, phone number, images, email address or usernames associated with the contacts.App allows you to select contacts from your device's contact list to send money or make payments.

2.4 Personal Images: images of your face and national identification card collected for App functionality such as account verification.

2.5 Characteristics of Protected Classifications: including date of birth, national origin

2.6 Information from your device: including, device Id

2.7 Biometric Data: We use your biometric data (with your explicit consent) to provide a more secure and convenient way to authenticate your identity within the App.

3 HOW IS PERSONAL INFORMATION USED?

3.1 Processing of personal data refers to any action or series of actions performed on such data, regardless of the method employed. This includes activities such as obtaining, recording, organizing, retaining, adapting, altering, retrieving, consulting, using, transmitting, disclosing, disseminating, aligning, combining, blocking, deleting, or destroying the data.

3.2 OneMoney gathers and handles your personal information for various business objectives. These objectives encompass, but are not restricted Verifying your identity;

3.3 Completing transactions effectively and billing for products and services;

3.4 Responding to your request for service or assistance

3.5 Manage and improve our Services: for example, to develop new products and features, for customer analysis, to administer our Services, and for internal operations, for example troubleshooting, data analysis, testing, research, and statistical purposes.

3.6 Market our Services: We may use Personal Information to market our Services including where we partner with others to offer similar services to market about our Partners and Merchants. We use Personal Information, including when we Associate information about you, to better understand and cater to your interests.

3.7 Communicate with you: We may contact you when you need us, such as answering a question you sent to our customer service team.

3.8 Comply with Laws: to comply with applicable laws and rules and enforce our agreements with you and other people who use our Services.

3.9 Ensuring compliance with legal and regulatory obligations to prevent and detect fraud and criminal activities.

3.10 OneMoney may maintain a record of your activities on our network and websites using various internet technologies such as web cookies, web beacons, server log files, etc. These records are utilized for analytical purposes, including assessing the effectiveness of different features in compliance with relevant legal obligations. This information may be utilized to enhance your experience on our platforms.

3.11 While you are browsing our websites or using our applications, you have the option to decline the sharing of information by adjusting your browser privacy or mobile application settings. This allows you to opt out of receiving cookies from our site at any time.

3.12 If you do not provide your consent for the usage of personal information, or if you later withdraw your consent for the use of the collected personal information, OneMoney may be unable to provide certain products and services to you.

4 DO WE DISCLOSE PERSONAL INFORMATION, AND WHY?

4.1 We do not sell Personal Information to third parties for money or share your Personal Information for cross context behavioral advertising, including any Sensitive Personal Information.

4.2 In certain cases, it may be necessary to disclose specific client information to third parties in order to protect our interests. For instance, if a payment fails due to insufficient funds in an account, such information may be shared. Additionally, in situations where it is deemed necessary to safeguard the public interest, details regarding a client's debt may be disclosed to credit bureaus or debt collection agencies. The entities and third parties with whom we may share your information could include:

4.3 Banks and financial institutions

4.4 Regulatory authorities

4.5 The regulator

4.6 Law firms and auditors

4.7 Insurers

4.8 The Zimbabwe Police Service; and other third parties as may be required either contractually, by law, or legitimate interest.

4.9 When we share your information with recipients located in other jurisdictions, we will take measures to ensure that they uphold privacy protection requirements that are similar to our own. This can be achieved through legal obligations or contractual agreements. We do not engage in the sale of your information to third parties, and any marketing activities directed towards you will strictly adhere to our legal obligations and your marketing preferences. Furthermore, we will utilize the communication method that you have chosen.

5 WHO DOES THE POLICY APPLY TO?

5.1 OneMoney's Data Protection and Privacy Policy applies to 'You,' which includes:

5.1.1 All individuals who are customers and/or users, and who are natural persons or living individuals.

5.1.2 All customers and/or users who are organizations or corporate entities.

5.1.3 An individual who can be directly or indirectly identified by an identification number or specific factors linked to their physical, physiological, mental, economic, cultural, or social identity.

5.1.4 All individuals who are employed by OneMoney, including job applicants and prospective employees.

4.1.5 All suppliers, partners, and service providers of OneMoney.

5 WHAT KIND OF PERSONAL INFORMATION DO OUR CUSTOMERS PROVIDE TO US?

5.1 OneMoney, along with its authorized third parties, may gather, retain, and handle Personal Information during the provision of our products and services, as well as when accessing our website and mobile applications.

5.2 information collected and held by us may include:

5.2.1 Names of individuals

5.2.2 Postal or living addresses

5.2.3 Email addresses

5.2.4 Mobile Phone numbers

5.2.5 Identity card and passport

5.2.6 Date and place of birth

5.2.7 Biometric Data

5.2.8 Financial information

5.2.9 Camera and Image information: With your explicit consent, our App may access and collect images stored on your device.

5.2.10 Contact List: With your explicit consent, our App may access and collect information from your contact list stored on your device. This information may include names, phone numbers, and email addresses.

5.2.11 Device Information: We may collect information about your device, including its unique device identifier.

5.2.12 The information present in supporting documents, such as proof of identity or proof of address.

6 PRINCIPLES GOVERNING OUR MANAGEMENT OF YOUR PERSONAL DATA

The OneMoney Data Protection and Privacy Policy incorporates internationally recognized data privacy principles while maintaining compliance with existing national laws. It serves as a supplement to national data privacy laws. We adhere to the following principles when processing your data:6.1 Fairness and Lawfulness

6.1.1 The rights of data subjects are safeguarded when processing personal data. Personal data will be collected and processed in a lawful and equitable manner.

6.1.2 The data collected will be sufficient, pertinent, and not excessive with regard to the purposes for which they are obtained and any subsequent processing.

6.1.3 The processing of individual data should be based on the voluntary consent of the individual involved.

6.2 Limitation to a specific purpose

6.2.1Personal data will only be processed for the purpose that was determined prior to its collection. The gathering of personal data will be conducted for specific, clear, and lawful purposes, and it will not be subsequently processed in a manner that is incompatible with those purposes.

6.3 Transparency

6.3.1 Customers will be provided with information regarding the handling of their data. At the time of data collection, customers will be informed of the purpose for which the data is being processed and any third parties to whom the data may be disclosed.

6.3.2 The processing of personal data is conducted only after obtaining the customer's consent.

6.4 Confidentiality and Data Security

6.4.1 Personal data is protected by data confidentiality measures. It will be handled as confidential on an individual level and safeguarded through appropriate organizational and technical measures to prevent unauthorized access, unlawful processing, or distribution. Additionally, measures will be implemented to prevent accidental loss, alteration, or destruction of the data.

6.4.1 Personal data is protected by data confidentiality measures. It will be handled as confidential on an individual level and safeguarded through appropriate organizational and technical measures to prevent unauthorized access, unlawful processing, or distribution. Additionally, measures will be implemented to prevent accidental loss, alteration, or destruction of the data.

6.5 Data Retention

6.5.1 Personal data will be stored in a manner that allows for the identification of individuals only as long as it is necessary for the purposes for which the data was collected and processed. When it is time to dispose of your personal information, we take appropriate measures to ensure its erasure or render it unreadable/anonymized, using reasonable procedures.

6.6 Data Integrity

6.6.1 The personal data held must be accurate, complete, and kept up to date. Appropriate measures are implemented to ensure that any inaccurate or incomplete data is promptly updated.

6.7 Consent to Data Processing

6.7.1 Processing of an individual's personal data will take place only upon obtaining the consent of the concerned person. Declarations of consent must be provided voluntarily. The transfer of personal data to recipients, whether within or outside of OneMoney, is governed by the authorization requirements for processing personal data and necessitates the consent of the customer.

6.8 Processing Security

6.8.1 Personal data will be protected against unauthorized access, unlawful processing, and disclosure, as well as accidental loss, alteration, or destruction.

7 PROCESSING PERSONAL INFORMATION OF MINORS

7.1 The collection and processing of personal information pertaining to a child will only be carried out with the consent of their parents or legal guardian.

7.2 In certain circumstances, it may be necessary for us to process the information of a child. This could include cases where such processing is required to exercise or defend a legal right or obligation, or when the child has made their personal information public with the consent of their parents or legal guardian.

8 WHAT ARE YOUR RIGHTS?

8.1 Right to be informed that we are collecting personal data about you

8.2 Right to access personal information

8.2.1 You have the right, as permitted by law, to request a copy of the personal information that OneMoney holds about you, which includes advertising audience categories and inferred information.

8.3 Right to correct personal information

8.3.1 You possess the right to rectify any information that is held about you to guarantee its accuracy, relevance, completeness, and appropriateness, ensuring that it is not excessive.

8.4 Right to object to use of personal information

8.4.1 You have the right to request the erasure of your personal data in specific circumstances as allowed by law. However, please note that if there is a legal obligation for us to retain the data, you may not be able to exercise your right to request deletion.

8.4.2 You have the right to withdraw your consent or to object to the processing of your personal information by OneMoney, as permitted by applicable law. However, it is important to note that in cases where the processing of your personal information is based on a legal obligation, you may not be able to exercise your right to object.

8.5 Right to opt-out of marketing messages

8.5.1 OneMoney will refrain from providing targeted marketing to you unless you have explicitly given us your consent to do so. If you decide that you no longer wish to receive marketing messages from OneMoney, you have the option to opt out at any time using the available methods provided to you. Additionally, if you had previously opted in to receive personalized content based on your usage of our services, you can also opt out at any time.

9 SECURITY PRACTICES

Your data is transmitted securely through a protected connection.

10 CONTACT US

If you have any inquiries regarding the topics covered in this privacy policy or if you wish to exercise any of the aforementioned rights, please feel free to reach out to our Data Protection Office at onemoney@netone.co.zw. Our dedicated privacy team will promptly respond to your email.

In order to verify your identity and uphold your right to access your personal data (or exercise any other rights), we may need to ask you for specific information. This is a security measure implemented to prevent the disclosure of personal data to unauthorized individuals. Additionally, we may reach out to you to request additional information related to your request, which can help expedite our response.

We make every effort to address all valid requests in a timely manner. However, if your request is particularly complex or if you have submitted multiple requests, it may take us longer to respond. If such a situation arises, we will notify you and provide regular updates on the progress of your request.

11 CHANGES TO POLICY

12.1 OneMoney reserves the right to modify this Data Protection and Privacy Policy as and when required.

12.2 Any changes to our Data Protection and Privacy Policy will be published on our website

12.3 We encourage you to regularly review the up-to-date Data Protection and Privacy Policy to stay informed about OneMoney's dedication to safeguarding your information and enhancing your experience by offering improved products and services.

12.4 Any amendment or modification to this policy will take effect from the date of notification on the OneMoney website

STATEMENT EFFECTIVE DATE

1 January 2024