Privacy Policy

1. Introduction

MOMONEYO LIMITED BY GUARANTEE ("MOMONEYO," "we," "our," or "us"), a licensed National Non-Profit Organisation in the Republic of Ghana, is committed to the highest standards of data protection. This Privacy Policy describes how we collect, use, and protect your personal data when you use our platform to start campaigns, make donations, or interact with our community services.

By using the MOMONEYO platform, you acknowledge and agree to the practices described in this policy. We operate in full compliance with the Data Protection Act, 2012 (Act 843) of the Republic of Ghana.

2. Data Controller

MOMONEYO acts as the data controller for the personal information processed through the platform. Our headquarters are located in Accra, Ghana. We have appointed a Data Protection Officer (DPO) to oversee compliance and handle inquiries related to your personal information.

3. Data We Collect

We collect information that allows us to verify identities, process financial transactions, and maintain a secure environment for communal giving.

4. NIA Compliance Statement

5. Legal Basis for Processing

We process your data under the following legal foundations provided by Act 843:

• Consent: You have given clear consent for us to process your data for a specific purpose (e.g., subscribing to a newsletter).
• Contract: Processing is necessary for a contract we have with you (e.g., disbursing funds you raised).
• Legal Obligation: Processing is necessary for us to comply with Ghanaian law (e.g., the Anti-Money Laundering Act, 2020).

6. How We Use Your Data

We use the collected data for the following essential purposes:

• Verification: To confirm the identity of campaign creators and the legitimacy of their needs to prevent platform fraud.
• Financial Processing: To facilitate the flow of funds from donors to creators via pawaPay and Mobile Money networks.
• Audit & Compliance: To monitor for suspicious transaction patterns and report to the Financial Intelligence Centre (FIC) where required by law.
• Communication: To send transaction receipts, verification updates, and support responses.

7. Data Sharing & Disclosure

MOMONEYO does not sell, rent, or trade your personal data to third-party marketers. Data is only shared with:

• Payment Processors: We share transaction details with pawaPay to execute Mobile Money prompts.
• Service Providers: Cloud hosting (Firebase) and communication services (Resend) that process data strictly on our behalf.
• Legal Authorities: If required by the Anti-Money Laundering Act, 2020 (Act 1044), we are legally bound to share suspicious transaction reports with the Financial Intelligence Centre.

8. Data Retention

In compliance with the Anti-Money Laundering Act, 2008 (Act 749), MOMONEYO is required to retain all transaction records and identity verification data for a minimum of seven (7) years.

Inactive accounts or deleted campaigns are moved to a restricted archive where they remain for the duration of the legal retention period before being permanently purged or anonymized.

9. Data Security

We employ enterprise-grade security measures to protect your information, including 256-bit TLS/SSL encryption for all data in transit. Access to sensitive verification data is strictly limited to authorized compliance staff through multi-factor authentication (MFA).

10. Your Rights (Act 843)

Under the Data Protection Act, 2012, you have the following rights:

• Right of Access: You can request a copy of the personal data we hold about you.
• Right to Rectification: You can request that we correct inaccurate or incomplete information.
• Right to Erasure: You can request the deletion of your data, subject to the 7-year legal retention requirements for financial records.
• Right to Object: You can object to the processing of your data for direct marketing purposes.