Finex Money Privacy Policy

1. Introduction

Finex Money (Pty) Ltd (“Finex Money”, “we”, “our”, “us”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains how we collect, use, store, share, and protect personal information when you use:

• the Finex Money mobile application
• Finex Money cards
• Finex Money wallet services
• payment distribution services
• merchant and partner integrations
• website platforms and digital onboarding channels

Finex Money processes personal information in accordance with:

• the Protection of Personal Information Act (POPIA)
• the Financial Intelligence Centre Act (FICA)
• applicable payments-industry regulatory requirements
• obligations imposed by issuing banks and payment schemes

2. Personal Information We Collect

Depending on the services used, Finex Money may collect:

Identity Information
Full name, identity number, passport details, nationality, date of birth

Contact Information
Mobile number, email address, residential address

Biometric Information
Facial verification images, liveness detection data, identity document scans

Financial Information
Wallet identifiers, card information (tokenised where applicable), transaction history, balances

Compliance Information
Sanctions screening results, politically exposed person (PEP) indicators, verification status

Device & Usage Information
IP address, browser type, device identifiers, login activity, app usage behaviour

Location Information
Approximate or verified location data where required for fraud prevention or compliance controls

3. How We Collect Personal Information

Personal information may be collected:

• directly from you during onboarding
• when you use the Finex Money app or website
• during transactions
• from employers or programme sponsors (where applicable)
• from regulated identity verification partners
• from compliance screening providers
• from banking and payment network partners

4. Why We Process Personal Information

We process personal information to:

• verify identity (KYC)
• comply with FICA and AML obligations
• create and maintain accounts
• issue and manage cards
• enable wallet functionality
• process transactions and settlements
• prevent fraud and financial crime
• provide customer support
• improve service performance
• meet regulatory reporting obligations
• support white-label partner programmes
Some processing activities are mandatory for service availability.

5. Legal Basis for Processing

Finex Money processes personal information where necessary to:

• provide contracted services
• comply with legal obligations
• protect legitimate operational interests
• prevent fraud and unlawful activity
• meet regulatory reporting requirements
• obtain consent where applicable

6. Sharing Personal Information

Finex Money may share personal information with trusted service providers including:

Banking Partners
Issuing banks and safeguarding account providers

Payment Networks
Card schemes, switching operators, settlement processors

Compliance Providers
Identity verification, AML screening and sanctions monitoring partners

Technology Infrastructure Providers
Secure hosting and system-processing environments

Retail Payment Networks
Cash-in and cash-out partner networks

Regulators and Authorities
Where required by law
All service providers operate under strict confidentiality and security obligations.

7. Cross-Border Data Transfers

Because Finex Money operates within international payment ecosystems, personal information may be processed outside South Africa where required for:

• card processing
• sanctions screening
• fraud monitoring
• infrastructure hosting
• cross-border payment services

Appropriate safeguards are applied to protect personal information during such transfers.

8. Biometric Identity Verification

Where biometric verification is used:

• facial comparison confirms identity authenticity
• liveness detection prevents impersonation
• document OCR extracts identity data securely

Biometric processing is performed only for verification and compliance purposes.

9. Automated Processing

Automated decision-making may be used to:

• confirm onboarding eligibility
• apply transaction limits
• detect suspicious activity
• enforce compliance controls
• protect customers against fraud

Customers may request manual review where applicable.

10. Data Retention

Personal information is retained:

• for the duration of the customer relationship
• for statutory compliance periods under financial regulations
• for fraud prevention and dispute resolution purposes

Information is securely deleted or anonymised when no longer required.

11. Information Security

Finex Money maintains technical and organisational safeguards including:

• encrypted data storage
• secure communications channels
• access-control management
• monitoring of system activity
• breach detection procedures
• regulated partner security alignment

Security controls are reviewed continuously.

12. Data Breach Notification

If a data breach affects your personal information:

• you will be notified where required
• regulators will be informed where applicable
• corrective action will be implemented promptly

13. Cookies and Website Tracking

Our website and digital platforms may use cookies to:

• improve performance
• enhance user experience
• maintain session security
• analyse usage patterns

• support fraud detection

Users may adjust browser cookie settings where applicable.

14. Processing Information of Minors

Finex Money may process personal information relating to minors where:

• authorised by a parent or legal guardian
• required for designated account structures
• permitted under applicable financial regulations

Guardian consent is required before activation.

15. Your Rights Under POPIA

You may request to:

• access personal information we hold about you
• correct inaccurate information
• object to certain processing activities
• request deletion where legally permitted
• withdraw marketing consent
• request details of third parties who received your information

Requests may be submitted through Finex Money support channels.

16. Complaints

If concerns cannot be resolved directly with Finex Money, complaints may be submitted to:

The Information Regulator (South Africa)

17. Policy Updates

This Privacy Policy may be updated from time to time to reflect:

• regulatory requirements
• product enhancements
• security improvements
• partner-network updates

The latest version will always be available on the Finex Money website.