Your Account can be accessed using Your Personal Identification Number (PIN) and a One Time Password (for MTN Mobile Money Application Users).

Remember to keep your PIN secret since its required to complete every transaction and change it regularly.

How to deposit money into your account: You can Cash-in through a Mobile money Agent or transfer from your bank account.

How to withdraw money from your account: You can Cash out through a Mobile Money Agent or a Bank Automated Teller Machine.

Inactivity/dormancy: After 9 Months of inactivity, an account will be considered Dormant. You will need to transact or visit our Service Centers to reactivate it. After 15 months of inactivity, the account will be closed, and account balances transferred to Bank of Uganda.

Deposit protection: All customer deposits are protected, and the balances of the customer accounts shall not be attached, assigned, or transferred for the purposes of satisfying any claim.

Account closure: Your Account may be suspended, restricted, or terminated without informing you and without any liability if your PIN is used in an un-authorized, unlawful, improper, or fraudulent manner or for criminal activities.

 How to complain: If you are dissatisfied with our services, contact us through any of our channels.
o Toll free helpline 100
o Social Media pages: Twitter, Facebook, and Instagram
o Website: www.mtn.co.ug
o WhatsApp: +256772123100
o Email: customerservice.ug@mtn.com
o Service Centers

Where can I find out more? If you want more information on the product or terms used in this KFD, please contact us through above channels.

MTN Public Privacy Notice

Effective: 1^st October 2024

Version: 002

We respect your right to privacy, it is very important to us, and we take the protection of your privacy and ensuring the security of your Personal Data very seriously.

We are committed to the fair and transparent Processing of your Personal Data. This Public Privacy Notice describes how we Process your Personal Data, explains your rights in relation to the Personal Data we Process, and states our commitment to Processing your Personal Data in a compliant, ethical, and secure manner.

Who are we?

We are MTN Mobile Money (U) Limited, and we will be referred to as “MTN MoMo”, “we”, “our” and “us” in this Public Privacy Notice.

Who does this Public Privacy Notice apply to?

This Public Privacy Notice applies to individuals that are:

• any person(s) who contracts with us for the provision of products and services, or who purchases a product from us (“customers”), including potential customers to the extent MTN MoMo Processes your Personal Data;
• any person(s) who uses our website, mobile applications or any products or services (“users”);
• all suppliers, contractors, and service providers of MTN MoMo (“suppliers”), including potential suppliers to the extent that MTN MoMo Processes your Personal Data;
• all merchants and partners, including potential merchants and partners to the extent that MTN MoMo Processes your Personal Data;
• resellers such as MTN MoMo distributors, super agents, and agents (“resellers”), including potential resellers to the extent that MTN MoMo Processes your Personal Data; and
• any other persons (save for employees and job applicants) who share Personal Data with MTN MoMo, including beneficiaries, trustees, or donors to MTN MoMo trusts or charitable causes, and MTN MoMo guests.

What are the important terms you need to understand when reading this Public Privacy Notice?

What Personal Data does MTN MoMo collect and use?

To run our business, we may be required to collect, use, store and otherwise Process your Personal Data. The Personal Data that we may collect, and Process can vary depending on the different MTN MoMo products and services that you use, contract for or that you supply to us, how you may be using or delivering those products and services, and the means by which you may be interacting with us.

We will only collect Personal Data that is adequate, relevant, and limited to what is needed in relation to the specific purposes for which we are collecting it, as described in this Public Privacy Notice.

The Personal Data collected and processed by us may include:

• Personal details: we collect information which may include your name, contact information (email address, postal address, residential address, telephone number), gender, date of birth, identifying numbers (identity document number, passport numbers and/or other national identity numbers or social security numbers, as required), family details (which may include Children’s Personal Data), company name, company registration or identifying numbers, or any other information which may be required in terms of regulatory requirements applicable to MTN Fintech and/or our policies during the on-boarding process.
• Account information: we collect information which may include your billing information, financial information, tax information, or any other information required to comply with internal procedures when transacting with MTN MoMo or regulatory requirements.
• Location information: we collect information regarding your physical location / geolocation when you use your device, our products or services and they connect with cellphone towers, Wi-Fi routers, Bluetooth, beacons, GPS satellites and/or other MTN MoMo technologies or infrastructure.
• Network performance: we collect information which inform our network performance such as your use of our products, services, or equipment.
• Financial information: we collect information such as your bank account or credit card details, and financial history (including information to determine your creditworthiness), transactions, remittances, mobile wallet details, micro-loans, micro insurance, and other similar information.
• Usage of your devices, our services, and products: we collect information relating to data usage (including browsing history), financial services that you make use of (i.e., payment, deposit, withdrawal, and other related services).
• Web browsing and application usage: we collect your Personal Data through online identifiers and other technologies when you visit our website, use our mobile applications, through USSD, SMS or any other products and services to which you subscribe. This may include your IP address, browser type, operating system, mobile carrier, your ISP, URLs of sites from which you arrive or leave the website and mobile applications and sites that have our platform technology embedded, time you spend on our website or mobile applications, links, or advertisements you see, purchases made through our website, first party cookies and other web-tracking technologies. We may also collect information identifying or related to equipment accessing our networks including the software, configuration, equipment type and other unique identifiers (such as your username and password). Third party cookies will also be collected from our selected marketing technology partner(s), third party websites and applications.
• Supplier, reseller, and partner information: we collect information which may include financial information, billing information, background checks, employment history, details of your employees or directors, information related to your performance, and any other information which may be required in terms of regulatory requirements applicable to MTN MoMo and/or our policies during the registration process, pre-qualification process, and procurement process.
• Multimedia data: we collect information such as unaltered photographs, audio recordings, or video recordings.
• Social media information: we collect your information related to your interaction with our social media accounts, content and marketing campaigns (including your details when you enter into a competition or interact with an advertisements, your comments, your reactions (i.e. ‘likes’)), Personal Data available from your public profile, and information you have allowed social media platforms to share with us in terms of your privacy preferences on that platform, as well as your social media handles.
• Biometric information: we collect information such as images or video recordings of you, fingerprints, voice recording or voiceprint, scan of your face in order to identify you.
• Demographic information: we collect information related to your gender, race or ethnic origin, age, education, and/or financial status.
• Views, opinions, and interests: we collect information regarding your views, opinions, and preferences (e.g., when you participate in a survey or when you provide feedback regarding our products or services or online based behavior) as well as your interests. In the case of suppliers, resellers, and partners, we will obtain the views and opinions of others regarding your performance (e.g., references).

Where does MTN MoMo collect my Personal Data from?

In most circumstances we collect Personal Data directly from you, for instance, when you buy or use any of our products or services, visit our website, use our mobile application, and/or interact with our customer services departments.

In some cases, however, we will also collect your Personal Data indirectly from third parties, such as from:

• credit check, screening, or vetting agencies.
• financial institutions;
• social media platforms;
• marketing agencies;
• other entities within the MTN Fintech group of companies (e.g., based on the usage of their applications, websites and sharing of Personal Data);
• regulatory bodies (e.g., who share Personal Data in relation to an investigation);
• third parties who provide Personal Data for financial crime detection and prevention;
• resellers or partners in respect of the Personal Data of customers, users, and suppliers; and/or
• commercial entities (e.g., aggregators or integrators who may require verification or validation of Personal Data);
• third parties providing supplier and reseller references.

There may also be instances where Personal Data is collected indirectly from:

• any correspondence or complaints that involve you and us; and
• any other platforms where your Personal Data may be publicly available.

For what purposes does MTN MoMo use my Personal Data?

MTN MoMo will use your Personal Data for purposes of:

• Verification: we Process Personal Data necessary to verify your identity when you are registering for or signing in to our website or our mobile application, using our products and services, when making contact with us, or when we contact you.
• Credit checks: we perform credit checks, including using the services of a credit bureau, where you are applying for products and/or services with us, and to assess your application.
• On-boarding, contracting, and processing orders: we Process your Personal Data in order to on-board and contract with you, to process your request for products and services, to keep you updated with your order progress, and to provide our products and services to you.
• Billing and collection: we Process your Personal Data in order to perform billing of your account for your use of our products and services. We also Process your Personal Data to collect outstanding monies due to us through our collection processes, and where necessary to trace you for these purposes.
• Monitor and improve services: we perform research and statistical analysis on our customers’ and/or users’ behavior for purposes of monitoring the performance of our network, products and services and maintaining or improving our products and services to you.
• Improve value proposition: we analyse our customers and/or users’ preferences and interests based on their use of MTN Fintech’s websites, mobile applications, products, services and/or social media interactions to improve on our services and products, to perform marketing and online behavioral advertising, and to develop new services or products which may be suitable to you.
• Network performance: we Process your Personal Data to protect our network and manage the use of our network. For example, we identify peak periods of use, so we can ensure the network can handle the volume during those times.
• Direct Marketing: we Process your Personal Data to promote and/or market our products and services to you by means of text and voice messaging, email, post, telephone calls, or through social media campaigns which we believe may be of interest to you, but only if this is permitted in terms of our policies, Local Regulatory Requirements, and you have not opted-out from the type of direct marketing communications (e.g., where you have opted-out of certain categories of direct marketing but not all categories of direct marketing).
• Fraud and crime prevention: we Process your Personal Data to detect, prevent or investigate fraud or criminal activity through the use of our products or services.
• Security: we Process your Personal Data to prevent Personal Data Breaches, and to safeguard our IT systems, networks, assets, buildings, and places of work.
• Compliance and reporting: we Process your Personal Data where this is required to comply with any legal obligations imposed on MTN MoMo by Local Regulatory Requirements or in response to directives from law enforcement or court orders (e.g., “know your client” requirements) and to discharge any prescribe reporting obligations.
• Customer service: we Process your Personal Data to provide you with customer services including any administrative services required, or to respond to any question, query, requests, concerns, or complaints you may have about MTN MoMo, including our network, products, services, employees, or our Processing activities.

MTN MoMo will not further Process Personal Data for any purpose that is incompatible with the original purpose that the Personal Data was collected for unless:

• such further Processing is authorised in terms of Applicable Data Protection Law(s);
• we have obtained your consent to the further Processing;
• the further Processing is necessary to comply with an obligation imposed by Local Regulatory Requirements or for conducting proceedings in a court or tribunal; or
• it is for scientific or historical research purposes or statistical purposes.

Is MTN MoMo allowed to Process my Personal Data?

We are allowed to Process your Personal Data, so long as we have a legal basis to do so (i.e., there is a justification to Process your Personal Data in terms of Local Regulatory Requirements applicable to MTN MoMo and/or our policies permit such Processing). When we Process your Personal Data, we will rely on one of the following legal basis, as appropriate, having regard to the purpose of Processing:

• Performance of a contract: the Processing of your Personal Data is necessary to conclude a contract or perform our obligations under a contract entered into with you.
• Legal obligation: this is when we are required to Process your Personal Data to comply with a legal obligation.
• Legitimate interests of MTN MoMo or a third party: we will Process information about you where it is in our or a third party’s legitimate interest provided these interests are not overridden by your interests and fundamental rights and freedom to data privacy.
• Vital interests of the Data Subject or another natural person: the Processing is necessary to protect your vital interests or the vital interests of another natural person.
• Public Interest: the Processing is necessary for the performance of a task carried out in the public interest.
• Your consent: in some cases, we will ask you for specific permission to Process some of your Personal Data. This consent may be withdrawn at any time.

We will not Process your Sensitive Personal Data unless there is a lawful basis to do so as set out above and one of the following grounds applies to the Processing:

• You have given explicit consent to the Processing of your Sensitive Personal Data for one or more specified purposes.
• Processing is necessary to protect your vital interests or the vital interests of another natural person where you are physically or legally incapable of giving consent.
• Processing relates to Sensitive Personal Data which was intentionally made public by you.
• Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.
• Processing is necessary for scientific or historical research purposes or statistical purposes provided such Processing is proportionate to the aim pursued, MTN MoMo respects the essence of the right to data protection and MTN MoMo provides for suitable and specific measures to safeguard your fundamental rights and the interests.
• Processing of Personal Data related to criminal behaviour is obtained and used in accordance with Local Regulatory Requirements.

We will not Process Children’s Personal Data unless there is a lawful basis to do so as set out above and one of the following exceptions apply to the Processing:

• The Child’s Guardian has given explicit Consent to the Processing of the Child’s Personal Data for one or more specified purposes.
• Processing is necessary to protect the vital interests of the Child.
• Processing relates to Personal Data which was intentionally made public by the Child with the Consent of their Guardian.
• Processing is necessary for the establishment, exercise or defence of legal claims;
• Processing is necessary for reasons of substantial public interest, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and the interests of the Child.
• Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes provided such Processing is proportionate to the aim pursued, MTN MoMo respects the essence of the right to data protection and MTN MoMo provides for suitable and specific measures to safeguard the fundamental rights and the interests of the Child.

Is it mandatory to provide MTN MoMo the Personal Data asked for?

It is not mandatory for you to provide any Personal Data to us. However, failing to provide certain Personal Data to us, particularly where that Personal Data has been requested by us may impact our ability to, amongst other things:

• provide our products or services to you;
• to support you with and manage our products and services;
• provide you full functionality to all our webpages;
• on-board you as supplier, reseller, contractor, or service provider; and
• to allow you access to our premises or buildings.

Does MTN MoMo Process my Personal Data automatically?

MTN MoMo does not perform any automated decision making (including profiling) which results in legal consequences for you and/or which affects you in a similarly significant manner. Should this change in the future, we will notify you and update this Public Privacy Notice accordingly.

How long does MTN MoMo keep my Personal Data for?

We will not retain your Personal Data for any longer than is necessary for achieving the purpose(s) for which the Personal Data is Processed, unless:

• retention of the Personal Data is required or authorised by any Regulatory Requirements;
• you have consented to the retention of the Personal Data; or
• the Personal Data is required for historical, statistical or research purposes and provided that we have established appropriate safeguards against the Personal Data being used for any other purposes.

We will ensure that Personal Data, which is no longer required, or which we are no longer authorised to retain, is as soon as reasonably practicable, de-identified or destroyed through secure means, alternatively through permanent erasure by appropriate and effective mechanisms in accordance with consistent with Local Regulatory Requirements and MTN MoMo’s internal policies.

Does MTN MoMo transfer my Personal Data to third parties?

Yes, we do share Personal Data with affiliated third parties, as necessary for our legitimate business needs, to carry out your requests, and/or as required or permitted by any Regulatory Requirements. This would include:

• Our service providers: we transfer your Personal Data to our third-party service providers, such as payment network processors, financial institutions, Value Added Service Providers, aggregators, (IT) systems providers, hosting providers, consultants (such as legal advisers) and other goods and services providers. These providers Process your Personal Data on behalf of MTN MoMo in terms of a binding agreement with appropriate security safeguards. MTN MoMo will only transfer Personal Data to such a service provider when they meet our strict standards on the Processing of data and security. We only share Personal Data that allows our service providers to provide their services and they are not allowed to Process your Personal Data for any other purpose.
• Our partners: we transfer your Personal Data to our partners such as our partner financial institutions to jointly provide our services to customers. These partners Process your Personal Data on behalf of or jointly with MTN MoMo in terms of a binding agreement with appropriate security safeguards. We only share the minimum Personal Data with partners that is necessary for the provision of services.
• If we are reorganized or sold to another organization: we may disclose Personal Data in connection with the sale, assignment, or other transfer of the business to which the data relates.
• Courts, tribunals, law enforcement, or regulatory bodies: we may disclose Personal Data in order to respond to requests of courts, tribunals, government, or law enforcement agencies or where it is necessary or prudent to comply with Local Regulatory Requirements, court or tribunal orders or rules, or government regulations.
• Audits: disclosures of Personal Data may also be needed by our auditors including to perform financial audits, data privacy or security audits and/or to investigate or respond to a complaint or security threat.
• Insurers: our business requirements mean that we carry significant insurance cover in respect of business activities. There are several different participants in the insurance market (e.g., brokers, insurers, and reinsurers, as well as their professional advisors and other third parties involved should there be a claim). Some of these insurance market participants will require that we disclose Personal Data about you to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance products, where there is a claim that you are relevant to and to allow the insurance market participants to comply with their legal and regulatory obligations. Some of these insurance market participants will handle this information on our behalf (like our service providers described above), but others will want to Process information about you independent of us.
• Other third parties: we may share information with research agencies or other third parties who use MTN MoMo platforms / systems to advertise their product. However, the Personal Data collected is anonymised and/or aggregated prior to sharing with such third parties.

Does MTN MoMo transfer my Personal Data internationally?

Yes, MTN MoMo may transfer Personal Data outside of Uganda but only if such transfers are permitted in terms of Local Regulatory Requirements and Applicable Data Protection Law(s).

MTN MoMo may transfer your Personal Data to other entities within the MTN group of companies. All MTN entities are bound by the MTN Binding Corporate Rules which ensures that the MTN entity receiving your Personal Data protects your Personal Data in accordance with those binding corporate rules.

MTN MoMo may also transfer certain Personal Data outside of Uganda to third parties working with us or on our behalf for the purposes described in this Public Privacy Notice. When transferring Personal Data internationally to third parties we ensure your Personal Data will continue to be protected for example, by entering to binding data transfer agreements or by ensuring there are adequate data privacy and protection laws, which requires the relevant third party to adhere to the data handling and data protection requirements, acceptable to MTN MoMo.

How does MTN MoMo secure my Personal Data?

MTN MoMo secures the integrity and confidentiality of the Personal Data in its possession or under its control by implementing appropriate, reasonable technical, physical, and organisational measures to prevent:

• accidental loss of, damage to, or unauthorised destruction of your Personal Data;
• unlawful or unauthorised access to / dissemination of your Personal Data; and
• unlawful or unauthorised Processing of your Personal Data.

As part of its processes, MTN MoMo takes reasonable measures to regularly identify and assess all reasonably foreseeable internal and external risks to Personal Data in its possession or under its control and implements reasonable and appropriate technical, physical, and organisational security measures to protect against the identified risks.

How does MTN MoMo handle Personal Data Breaches?

While MTN MoMo implements reasonable measures to prevent or reduce the likelihood and impact of Personal Data Breaches, this risk can’t be completely eliminated. If MTN MoMo becomes aware of or reasonably suspects a Personal Data Breach has occurred or that the integrity or confidentiality of Personal Data has been compromised, MTN MoMo adheres to its incident management policies, procedures and supporting documents governing the handling and reporting of Personal Data Breaches.

What are my rights?

If MTN MoMo Processes Personal Data about you, you have the following rights:

• Access and correction: you have the right to access the Personal Data retained by MTN MoMo. This is sometimes called a ‘Data Subject Access Request’. If we are obliged to provide Personal Data to you, we will provide it to you free of charge. Before providing Personal Data to you, we may ask for proof of identity and sufficient information about your interactions with us in order to locate your Personal Data. If the Personal Data we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the Personal Data.
• Object to Processing: you have the right to object to us Processing your Personal Data, on grounds relating to your particular situation, under certain circumstances. For example, if we are Processing your Personal Data on the basis that is necessary for purposes of our or a third party’s legitimate interest. You may also object if you believe there is no legal basis for us to Process your Personal Data anymore.
• Withhold consent: you have the right to withhold your consent without any fear of negative repercussions in circumstances that we seek your consent to Process your Personal Data. If you experience any intimidation or negative repercussions for withholding your consent, you should report this to your local whistleblower hotline at anonymous@tip-offs.com and Telephone number: 0800 212 800.
• Withdraw consent: you also have the right to withdraw your consent at any time and we will cease Processing your Personal Data unless there is an alternative legal basis to continue Processing your Personal Data. We will advise you if we intend to continue Processing your Personal Data in these circumstances.
• Disposal / Restrictions: in addition, you may have rights to have your information deleted / destroyed if we are keeping it too long or have no legal basis to Process it. You may also request that the Processing of your Personal Data is restricted in certain circumstances.
• Lodge complaints: you have the right to lodge a complaint regarding the way your Personal Data is being Processed with MTN MoMo or if you believe there has been a breach of MTN MoMo privacy policies and/or Applicable Data Protection Law(s).

You can make a request or exercise these rights by contacting MTN MoMo at dataprotectionofficeUG@mtn.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with any Regulatory Requirements, Applicable Data Protection Law(s) and MTN MoMo’s internal policies.

Finally, you always have the right to lodge a complaint with the supervisory authority in charge of protecting Personal Data, the Personal Data Protection Office, Uganda, whose contact details are:

[Postal Address:] Plot 7A, Rotary Avenue, Rotary Avenue

[Email Address:] info@pdpo.go.ug

[Telephone number:] 0417801008/9

[Website:] www.pdpo.go.ug