For Beam App users in South Africa, the privacy notice which applies to you is available here. This Privacy Notice describes how Beam Money (Pty) Ltd., with its office at 98 Dorp Street, Stellenbosch, Western Cape, South Africa, and its affiliates (collectively, “Beam App”, “we”, and “us”) collect, use, disclose, transfer, store, retain or otherwise process your information when you (“you,” “your”) download Beam App through a relevant app store and sign up for a Beam App account and other services through the app or online at https:/beam.co.za/ (collectively, “Services”).

This Privacy Notice applies to your use of our Services, and covers only information collected in connection with your access to and use of our Services. This Privacy Notice also describes the limited ways we may process the information of individuals who do not use our Services. Please read this Privacy Notice carefully.

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Our Privacy Notice explains:

o   Information we collect about you

o   Sources of information we collect about you

o   How we use your information

o   When and with whom we share your information

o   How long we retain your information

o   Cookies and other similar automated technologies

o   Your Rights

o   International Data Transfers

o   How we secure information

o   How we collect and use the information of non-users

o   Changes to this Privacy Notice

o   Contact

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INFORMATION WE COLLECT ABOUT YOU

We use your data to make Beam App’s products and services work better for you and for others. This describes what data we get about you (which can vary depending on where you live).

We need to collect information about you to provide you with the Services or the support you request. The type of information we collect can vary depending on the country from which you access our Services. Additionally, you can choose to voluntarily provide information to us.

Information You Provide to Access our Services

We use data you put into our systems when you use Beam App, like financial information, information that identifies who you are, transaction information, and any other data you give us.

We collect information you provide when you apply or sign up for a Beam App account, go through our identity or account verification process, authenticate into your account, communicate with us, answer our surveys, participate in contests or promotions offered by us or our partners, or otherwise use our Services.

We collect the following categories of information about you when you use our Services, including:

o   Identification Information, such as: Your name, email address, postal code, phone number, and authentication credentials (for example, information you use to log in to your Beam account), including Internet Protocol (“IP”) address.

o   Additional Identification Information for Verified Users, such as: Your full residential address; date of birth; government-issued identification including passport and driving licence; and photograph if you choose to share such information in order to send and receive larger payment amounts or access other Services.

o   Financial Information, such as: Bank account, payment card numbers and loyalty card information you add to your Beam App account.

o   Contacts Information, In order to provide you with the Service, we will also need to collect information from you about the intended recipient of the payment you request us to make. We will therefore ask you to provide contact details of your intended recipient. You can do this by manually entering a phone number or email address into the Beam App. You can also choose to let us access your phone contacts information, as described below (under Information You Provide to Enhance Your Experience).
Transaction Information. When you use our Services to make, accept, request, or record payments, we collect information such as: when and where the transactions occur, identification information of the transacting parties, a description of the transactions, the payment or transfer amounts, and the devices and payment methods used to complete the transactions.

Information You Provide to Enhance Your Experience

We also use data you give us to make your experience with Beam App better, like contacts you choose to upload to make it easier for you to exchange money with them.

You can choose to provide us with additional information to improve your user experience when using our Services:

o   Contacts Information. You can choose to let us access and upload your phone contacts information to facilitate the entry of payment recipient information or for account verification purposes. You can update your settings to stop sharing your phone contacts with us at any time, although we will always need a recipient’s phone or email address to send money to them as requested by you.

o   Other Information You Provide. We collect information that you voluntarily provide to us, including your photograph, if you choose to upload a picture to the Services; survey responses; participation in contests, or other marketing lead forms or devices; suggestions for improvements; referrals; or any other actions performed on the Services.

Information We Collect From Your Use of our Services

We also get data from the devices you use when you interact with our systems, like your location and information about the device you’re using. We need this data to do things like help protect your account from hackers, combat fraud, check if payments are being made or received legally and by you, and making our products and services better for you and others.

We collect information about you and the devices you use to access the Services, such as your computer, mobile phone, or tablet. The information that we collect includes:

o   Geolocation Information. The location of your device, including your IP address, device language, and location of your network provider. For more information and to learn how to disable collection of location information, please see below.

o   Device Information. Information about your device, including your hardware model, operating system and version, device name, unique device identifier, mobile network information, and information about the device’s interaction with our Services.

o   Internet or other electronic network activity information. Information about how you use our Services, including your access time, “log-in” and “log-out” information, browser type and language, country and language setting on your device, IP address, the domain name of your Internet service provider, other attributes about your browser, mobile device and operating system, any specific page you visit on our platform, content you view, features you use, the date and time of your use of the Services, your search terms, and the website you visited before you visited or used the Services, if applicable.

o   Inferences drawn from any of the information we collect to create a profile about you that may reflect, for example, your preferences, characteristics, and behaviour, including for account security purposes or to enhance our Services to you such as to help prevent fraud or misdirected payments.

SOURCES OF INFORMATION WE COLLECT ABOUT YOU

We also need to check that you are using our services legally, that you are eligible for the services you want to use, and we protect your data and our services from fraudsters who may put you and your money at risk. To do this, we may collect data about you from companies that help us verify your identity, do a credit check, prevent fraud or assess risk.

We collect information about you from the following categories of sources:

o   You directly, when you submit information to us or allow us to access information

o   Your devices and how you interact with our Services

o   Our group companies or affiliates

o   Other sources, including:

o   Identity Verification. Information from third-party verification services (e.g., identity verification agencies), and publicly available sources. In some circumstances, where lawful, this information can include your government-issued identification number. We do this identity verification check for the purpose of anti-money laundering, identity verification and fraud prevention.

o   Credit, Compliance, and Fraud. Information about you from third parties for any credit investigation, credit eligibility, identity or account verification process, fraud detection process, or collection procedure, or as may otherwise be required by applicable law. This includes, without limitation, the receipt and exchange of information with governmental agencies, of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies.

Minors’ Information

Our Services are general audience services not directed at individuals under the age of 18. If we obtain actual knowledge that any information we collect has been provided by an individual under the age of 18, we will promptly delete that information where required for compliance with applicable law.

HOW WE USE YOUR INFORMATION

We use your data to do things like make sure the products you are using work, help you log in to your account, verify who you are, secure your data, fight fraud, follow the law, enforce our agreements, figure out what new products we can build, and market and tailor our products to you.

We may collect, use, and share information about you when you request to engage with our Services. For example, we need some of the information we collect from you to deliver the Services to you; sometimes we are required by law and regulations to collect and process this information about you; at other times, we consider it is in our legitimate business interests to collect and process this information, taking into consideration your privacy right. We use information about you for the following reasons:

Providing our Services, in particular:

o   Determining whether the Services are available in your country. We process location information where you have requested use of the Services, but before you agree to the Terms of Service in order to verify if we are able to process your request. Without this information, we cannot confirm whether we are able to offer the Services to you under the Terms of Service.

o   Processing or recording payment transactions or money transfers (as both the recipient or instigator of the payment). We need this information in order to fulfil our obligations arising out of the Terms of Service entered into between you and us. Without this information we would not be able to provide the Services requested by you. Information required for these reasons include: identification information; bank account information; transaction information; and contact information.

o   Providing you with the Beam product and features you choose to use. You have the choice to use certain features of the Services, for example, providing a photo and government identification information where you have qualified to become a Verified User. If you choose to use these features of the product we will need to collect associated information from you either with your consent, for compliance with the law, or where it is in our legitimate business interests to further process your information as described above. You can update your choice to share this information with us at any time.

o   Displaying historical transaction information. As set out in our Terms of Service, we will provide information regarding your transaction history, including monthly account statements. We therefore need to collect and process this information to satisfy our obligations under these terms.

o   Delivering the information and support you request through the use of our Services. This includes push-notification messages, technical notices, security alerts and support and administrative messages including to resolve disputes, collect fees and provide assistance for problems with our Services or your Beam App account. We may need to communicate with you in our legitimate business interests, or to fulfil our own obligations or meet your requests that arise from the Terms of Service between you and us and we need your identification information in order to deliver this information to you. If you do not provide this information, we will not be able to fulfil our obligations or meet your requests under the Terms of Service.

o   Enforcing our Terms of Service or other applicable agreements or policies. This is necessary in order to fulfil the obligations between you and us under the Terms of Service.

o   Verifying your identity (e.g., through government-issued identification numbers). We need to verify your identity to comply with our contractual obligations, applicable law, and/or for our legitimate interest in protecting the security and integrity of our Services and your account.

o   Otherwise providing you with the products and features you choose to use.

To pursue our legitimate business interest, in particular:

o   Providing, maintaining and improving our Services. It is in our legitimate business interests to continue to maintain our product and service offering to individuals in order to keep running our business.

o   Developing new products and services. It is in our legitimate business interests to continue to improve our product and service offering to individuals in order to develop and grow our business.

o   Improving, personalising and facilitating your use of our Services. For example, when you sign up for a Beam App account, we can associate certain information with your new account, such as information about other Beam App accounts you had or currently have, and prior transactions you made using our Services. We do this in order to ensure in our legitimate interests that content from our Services is presented in the most effective manner for you.

o   Measuring, tracking and analysing trends and usage in connection with your use or the performance of our Services. We want to understand how current products and services, including promotions or discounts offered by us or our partners, are used in order to develop and enhance our products in our legitimate interests. In order to ensure that our legitimate business interests of striving to deliver a consistent, secure and continuous service are met, we need to carry out certain analytics on the performance of our Services.

o   Conducting surveys and collecting feedback about our Services. We do this to pursue our legitimate interests to understand if the Services are helpful to you and to evaluate the effectiveness of any updates we provide.

Protecting our services and complying with our legal obligations:

o   Investigating, detecting, and preventing fraud, security breaches, other potentially prohibited or illegal activities, or to otherwise help protect your account, including to dispute chargebacks on your behalf. We do this as we are required by law to ensure effective fraud prevention processes are in place. We also do this to prevent our Services being misused for fraudulent activities which is in our legitimate interests as a provider of the Services and other payment processing services.

o   Protecting our customers’ rights or property, or the security or integrity of our Services.

o   Complying with any applicable laws or regulations, or in response to lawful requests for information from the government or through legal process.

o   Contacting you to resolve disputes, collect fees, and provide assistance with our Services. We process this information given our legitimate interest to provide you with our Services, to measure the adequate performance of our contract with you and to comply with applicable laws.

o   Verifying or maintaining the quality and safety of our Services.

Processing with your consent:

o   Connecting you with people you already know. For example, you can choose to upload contact information from your device’s address book through the Beam App. With your consent, we will match the contact information you choose to upload this way to the information provided by other users of Beam App in order to provide and improve the Services, including making it easier to find contacts to whom you may send or request payments.

o   Sending you promotional information we think you may find useful or which you have requested from us about our products and services, including future marketing of our Services. We will only send you push notifications regarding promotional information where we have your consent to do so, by selecting your choice in the Notifications section of Beam App. Please see Your Rights section for further information.

o   Communicating with you about opportunities, products, services, contests, promotions, discounts, incentives, surveys and rewards offered by us and select partners. If we send you marketing emails, each email will contain instructions permitting you to “opt out” of receiving future marketing or other communications. We will only process your information for these purposes where we have your consent to do so.

o   For any other purpose disclosed to you in connection with our Services from time to time. If we intend to process your personal data for a purpose other than that set out above, we will provide you with information prior to such processing, and will obtain your consent where necessary.

Some of our processes for how we use your information may involve automated processing and automated decisions. We need to do this to meet our own contractual obligations, to comply with applicable law, and as it is in our legitimate business interests to carry out such checks for fraud prevention purposes or where we are under a legal or regulatory obligation to do so (or we believe we are required to do so under such legal or regulatory obligation).

For example:

o   Identity verification processing. We use third party identification verification services to automatically verify your identity, so we know you are who you say you are. We set out more information on this above and how this affects you. If we cannot identify you, we may not be able to provide the Services to you. This identity verification check will be based on the information you provide to us and the results we get for the third party verification services (which is limited to the result of the check).

o   Fraud and crime prevention processing. We have developed processes, for the purposes set out above, to check that our Services are not being used for fraudulent purposes. We will consider information you provide to access our Services, information you provide to enhance your experience, information we automatically collect from your use of our Services, and information we collect from other sources. We regularly check that our processes are up to date and implemented robustly and fairly to ensure that we can deliver the Services to you and that they are safe to use. If we feel that our fraud and crime prevention processing detects activities or use of our Services which could be used for fraudulent or criminal activities, we may not be able to provide the Services to you.

o   Product development and creation. We can process the information you provide to us, the information we collect from your use of our Services, and the information we obtain from third parties automatically to improve our product and develop new products. The information we use will help us to understand what is important to our users, and how we can create better products and services.

o   Product marketing. With your consent, we can process the information you provide to us, the information we collect from your use of our Services and the information we obtain from third parties to market new products to you by delivering notifications, including in our applications or on our websites.

WHEN AND WITH WHOM WE SHARE YOUR INFORMATION

We share your information with others in the circumstances described in this section. For example, with other people with whom you interact when you use our services; within our ecosystem of companies, who may offer services that we think could be useful to you; with service providers who help us run our services; or if we need to share your information to comply with the law.

We may share the information described in the “Information We Collect About You” section with the following categories of service providers and third parties:

With Other Users of our Services

o   With other users of our Services. This is necessary to provide our Services to you and to fulfil our obligations in our Terms of Service. For example, we may share information with the person(s) with whom you transact when you make or accept a payment or money transfer using our Services. This helps them know they’re getting money from you (or that you requested a payment from them). We may also make certain information available to other Beam App customers to help them know they’re making a payment to the right person, such as when you joined Beam App, whether you appear in their contacts, and the number of people in their contacts who have also transacted with you. If you choose, we may also allow you to share additional information about you and your use of our Services with other Beam App customers.

With our Affiliates and Group Companies

o   With our group companies and corporate affiliates, including Paytec Services (Pty) Ltd for provision of electronic money and payment services in South Africa, GKPOS and FlooID for point-of-sale checkout, MoneyGram for international remittances, for the reasons outlined above, and as it is necessary to provide our Services to you and fulfil our obligations in our Terms of Service. For example, we may share your information internally with Paytec Services (Pty) Ltd if you use Beam App to make a payment from a South African Bank, through the BankTech Platform, or pay an account of a BankTech Platform Corporate customer, in order to complete your transaction, or for our legitimate business interests to provide you with enhanced services from Beam App, to understand how you engage with Beam Money company products to help make our Services better for you, and to help us provide Services tailored to your preferences, such as the ability to track rewards in Beam App if you are a member of any of the Beam Merchant network’s loyalty program(s).

With Third Parties

o   With service providers who help us provide, maintain, and improve our Services (e.g., vendors who help us with fraud prevention, identity verification and fee collection services), as well as financial institutions, payment networks, payment card associations, credit bureaus, and other entities in connection with your payment, money transfer process, or otherwise to help us provide the Services;

o   With service providers that run advertising campaigns, contests, special offers, or other events or activities in connection with our Services.

Business Transfers and Corporate Changes

o   To a subsequent owner, co-owner, or operator of one or more of the Services; or

o   If we do or try to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these); the sale of substantially all of our stock and/or assets; the financing, acquisition, divestiture, or dissolution of all or a portion of our business; or other corporate change.

Safety and Compliance with Law

o   If we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, exercise or defend our legal rights; (iii) to enforce or comply with our Terms of Service or other applicable agreements or policies; (iv) to protect our or our customers’ rights or property, or the security or integrity of our Services; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect us, users of our Services or the public from harm, fraud, or potentially prohibited or illegal activities.

With Your Consent

o   With your consent. For example:

o   At your direction or as described at the time you agree to share;

o   When you authorize a third party application or website to access your information.

Aggregated and Anonymized Information

o   We also may share (within our group of companies or affiliates, or with service providers or other third parties) aggregated and/or anonymized information that does not specifically identify you or any individual user of our Services.

HOW LONG WE RETAIN YOUR INFORMATION

We keep your information as long as you keep using our products and services. After that, we keep it for as long as we need it to do things like fight fraud, collect fees you owe, resolve disputes with (or involving) you, follow the law, enforce our agreements and defend our rights in court.

We generally retain your information only as long as reasonably necessary to provide you the Services or to comply with applicable law. However, even after you deactivate your Beam App account (see below for more information), we can retain copies of information about you and any transactions or Services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, to enforce our Terms of Service or other applicable agreements or policies, or to take any other actions consistent with applicable law.

COOKIES AND OTHER SIMILAR AUTOMATED TECHNOLOGIES

Digital cookies and similar technologies help us make our services better to use by doing things like recognizing when you’ve signed in, helping us process your payments, and preventing fraud.

When you interact with our online services through your web browser, we obtain certain information using automated technologies, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our websites or emails.

We use these automated technologies to collect your device information, internet activity information, and inferences as described above. These technologies help us to, among other things, support the integrity of our registration process.

When you visit our browser site, we use cookies that are essential to the functioning of our Services. These are cookies that enable you to navigate and use all the features in the Services provided by us. For example, without these, you would not be able to navigate between pages on the website. If we use additional types of cookies, we will first request your consent to the extent required by applicable law. For more information on the types of cookies we use, please see below:

Type

Purpose

Duration

Strictly necessary

Used to track privacy consents.

Forever.

Strictly necessary

Used to prevent fraud by identifying bad actors that use the same browser to login to multiple accounts.

1 year

Strictly necessary

Used to track progress in a single user flow in order to, for example, create a payment.

Session

Strictly necessary

Used to authenticate and authorize each of a user’s actions.

7 years

Strictly necessary

Used to identify a user’s language, country, software, and device to provide compatibility.

Session

Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device. You can learn more about cookies and how to manage your preferences by visiting http://www.allaboutcookies.org.

To the extent we process your personal data through the placement of strictly necessary cookies, we do so in accordance with this Privacy Notice.

YOUR RIGHTS

Personal Data

If you reside in South Africa, you have the right under certain circumstances:

o   To be provided with access to your personal data held by us;

o   To request that your data be transferred to a third party (data portability);

o   To request the rectification or erasure of your personal data held by us;

o   To request that we cease or restrict processing your data;

o   To object to profiling activities based on our own legitimate interests;

o   To object to solely automated processing; and

o   In addition, where you have provided your consent to our processing of your personal data you can withdraw this at any time. If we process your information on the basis of your consent and you withdraw your consent, this does not affect the lawfulness of the processing prior to your withdrawal.

In order to exercise your rights (including the right to withdraw your consent), you can go to https://beam.co.za/support. We may need to verify your identity before granting access or otherwise changing or correcting your information. POPIA may provide for certain exceptions to the rights described above, and we reserve the right to avail ourselves of these exceptions where applicable.

Deactivating Your Account

If you wish to deactivate your account, you can do so at any time by logging into your Beam App account and visiting https://beam.co.za/support.

If you would like to have your account closed permanently, please contact us at https://beam.co.za/support.

Location Information

In order to provide certain Services, we may require access to location information, including precise geolocation information collected from your device. If you do not consent to collection of this information, certain Services will not function properly and you will not be able to use those Services. You can stop our collection of location information at any time by changing the preferences on your mobile device. If you do so, some of our mobile applications will no longer function. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove Beam mobile applications from your device.

INTERNATIONAL DATA TRANSFERS

Beam App operates internationally and many of our systems are based in the European Union, which has different data protection standards to South Africa. When we transfer your personal data to- and from our affiliates outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission.

We also use standard contractual clauses when we transfer your personal data to third parties outside the EEA or we adopt other means to ensure that adequate safeguards are applied to your personal data, such as a relevant third party’s binding corporate rules (approved by EU data protection authorities and put in place to protect your personal data). Master Card (https://www.mastercard.co.uk/en-gb/about-mastercard/what-we-do/privacy.html) has implemented binding corporate rules.

You may obtain a copy of any of the documents we use to protect your personal data when it is transferred outside the EEA by contacting us at privacy@beam.co.za.

HOW WE SECURE INFORMATION

We do a lot to keep your data safe. While we think we have strong defences in place, no one can ever guarantee that hackers won’t be able to break into our sites or steal your data while it is stored or flowing from you to us or vice versa.

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, and misuse, and unauthorized access, disclosure, alteration, and destruction. Nevertheless, the internet is not a 100% secure environment, and we cannot guarantee absolute security of the transmission or storage of your information. We hold information about you both at our own premises and with the assistance of third-party service providers.

For more information about our security practices, please visit https://beam.co.za/security.

HOW WE COLLECT AND USE THE INFORMATION OF NON-USERS

When customers provide us access to their phone contact book, we collect certain information regarding individuals who do not use our Services. We only use this information for certain limited purposes, we do not maintain it in a form that identifies individuals, and we never share it with third parties.

Even if you do not use the Services, we may collect your information from our customers for certain limited purposes. As described above, customers may grant us access to their phone contacts information to make it easier to find the people they want to send money to or for account verification purposes.

When a customer grants us access to their phone contacts information, we may collect, in pseudonymized form, email addresses and phone numbers of non-users, as well as other information associated with the customer’s contact book. We never re-identify this data to identify specific non-users, and we never share it with third parties for any reason. Because we do not maintain this non-user information in a form that allows us to identify individuals, we are unable to process access or deletion requests from non-users.

CHANGES TO THIS PRIVACY NOTICE

We can change this privacy notice. When the changes impact your rights or how we use your data in important ways, we’ll tell you first, which may be through our app, website, or by email.

We may amend this Privacy Notice from time to time by posting a revised version and updating the “Effective Date” above. The revised version will be effective on the “Effective Date” listed. We will provide you with reasonable prior notice of material changes in how we use your information, which may include notification in Cash App through our app or website, or by email, if you have provided one. If you disagree with these changes, you may cancel your account at any time. If you keep using our Services, you consent to any amendment of this Privacy Notice.

CONTACT

You can contact our privacy team with any questions or concerns as described below.

Please contact our privacy team with any questions or concerns regarding this Privacy Notice. Please mark your questions or concerns to:

Attention: Data Protection Officer

Postnet Suite 001

Private Bag X5071

Stellenbosch 7599

South Africa

Or log into your Beam App account and visit https://beam.co.za/support.

If you have any questions or concerns regarding our privacy notice, or if you believe our privacy notice or applicable laws relating to the protection of your personal information have not been respected, you may file a complaint with our privacy team listed above. We will respond to let you know when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We may keep records of your request and any resolution.

If you have any questions or concerns regarding our notice, or if you believe our notice or applicable laws relating to the protection of your personal information have not been respected, you can file a complaint with our privacy team listed above, and we will respond to let you know who will be handling your matter and when you can expect a further response. We can request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.

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