Privacy, Data Use and Retention Policy

Updated: May 12, 2025

1. WHO WE ARE

This data privacy, use and retention notice (the "Privacy Notice") applies to all personal information collection and processing activities carried out by OntaPay and the Onta Network group (together, "Onta Network"). Onta Network is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide through the Onta Network app). In this notice, references to "we", "us" or "our" are references to Onta Network. Different Onta Network companies may control and process your data depending on where you are ordinarily resident. The Onta Network company that provides you with access to the Onta Network Service and your Onta Network Profile, as identified in the Onta Network General Terms of Service ("Onta Network", or "we", "our", or "us") is the Onta Network company directly responsible for handling your personal data.

Legal Entity Information: Onta Network Ltd is a company incorporated in the British Virgin Islands with company number 2164530. Our registered address is Craigmuir Chambers, Road Town, Tortola, VG 1110, British Virgin Islands.

Our support email address is [email protected]. We respect individuals' rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. "Personal information" means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Notice from time to time. When we do we will communicate any changes to you and publish the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.

2. THE INFORMATION WE PROCESS

We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this notice. Personal information may include:

  • A. Basic personal information, including name and address, date of birth and contact details;
  • B. Financial information, including account and transactional information and history;
  • C. Goods and services we provide to you;
  • D. Visual images and personal appearance (such as copies of passports or real-time biometric facial scans); and
  • E. Online profile and social media information and activity, based on your interaction with us and our websites and applications, including, for example, your login information, Internet Protocol (IP) address, smart device information, location coordinates, online and mobile app security authentication, mobile phone network information, searches, site visits and spending patterns; and
  • F. Anonymized personal data from your contact book if you choose to enable the Send Money to Contacts Feature.

We may also process certain special categories of information for specific and limited purposes, such as detecting and preventing financial crime or to make our services accessible to customers. We will only process special categories of information where we've obtained your explicit consent or are otherwise lawfully permitted to do so. This may include biometric information, relating to the physical, physiological or behavioral characteristics of a person, including, for example, fingerprint or facial recognition or similar technologies to help us prevent fraud and money laundering.

3. HOW WE OBTAIN INFORMATION

Your information is made up of all the financial and personal information we collect and hold about you/your business and the proprietors, officers and beneficial owners of that business and your transactions. It may include:

  • A. Information you give to us;
  • B. Information that we receive from third parties – including other Onta Network group companies, third parties who provide services to you or us, credit reference, fraud prevention or government agencies, and other financial institutions (where permitted by law);
  • C. Information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts;
  • D. Information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition). This includes information from the contact book stored on your device, if you enable the Send Money to Contacts Feature; and
  • E. Information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.

4. YOUR RIGHTS

We want to make sure you are aware of your rights in relation to the personal information we process about you. These include rights to:

  • Access your personal information
  • Rectify inaccurate personal information
  • Request erasure of your personal information
  • Restrict processing of your personal information
  • Data portability
  • Object to processing of your personal information
  • Withdraw consent
  • Lodge complaints with the regulator

If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain to our Data Protection team, please contact us at[email protected].

5. CHANGES TO THE WAY WE USE YOUR INFORMATION

From time to time, we may change the way we use your information. Where we believe you may not reasonably expect such a change, we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes, it may not be possible for us to continue to operate your account and/or provide certain products and services to you through the Onta Network app.

6. HOW WE USE AND SHARE YOUR INFORMATION

We will only use and share your information where it is necessary for us to lawfully carry out our business activities. Your information may be shared with and processed by other Onta Network group companies to:

  • Provide and administer products and services
  • Verify your identity and prevent fraud
  • Comply with legal and regulatory obligations
  • Improve our products and services
  • Communicate with you about your account
  • Enable faster and more secure payments
  • Analyze transaction patterns for improved security

7. SHARING WITH THIRD PARTIES

We will not share your information with anyone outside of the Onta Network group except:

  • A. Where we have your permission;
  • B. Where required to provide your product(s) or service(s);
  • C. Where we are required by law and by law enforcement agencies, judicial bodies, government entities, tax authorities or regulatory bodies;
  • D. With other financial institutions to help recover funds from misdirected payments;
  • E. With third parties providing services to us, such as market analysis and benchmarking;
  • F. With other financial institutions to help trace funds where financial crime is suspected;
  • G. With debt collection agencies;
  • H. With credit reference and fraud prevention agencies;
  • I. With third-party guarantors or other companies that provide you with benefits or services associated with your product or service;
  • J. Where required for a proposed sale, reorganization, transfer, or other transaction relating to our business;
  • K. In anonymized form as part of statistics or other aggregated data shared with third parties; or
  • L. Where permitted by law, it is necessary for our legitimate interests or those of a third party, and it is not inconsistent with the purposes listed above.

8. TRANSFERRING INFORMATION OVERSEAS

We may transfer your information to organizations in other countries on the basis that anyone to whom we pass it protects it in the same way we would and in accordance with applicable laws. We will only transfer your information to countries that have been deemed to provide an adequate level of protection or where we have put in place appropriate safeguards to ensure your information is protected.

9. MARKETING INFORMATION

Upon signing up to and continued use of Onta Network's services, you agree to receive marketing updates and targeted marketing materials. You can change your preferences at any time by:

  • Clicking "unsubscribe" in any marketing emails
  • Texting "STOP" to our marketing text messages
  • Contacting us at [email protected]

10. COMMUNICATIONS ABOUT YOUR ACCOUNT

We will contact you with information relevant to the operation and maintenance of your Onta Network account by a variety of means including via email, text message, and in-app notifications. We may monitor or record communications in accordance with applicable laws.

11. FRAUD PREVENTION

We may access and use information from fraud prevention agencies when you open your account and periodically to:

  • A. Manage and make decisions about your accounts;
  • B. Prevent criminal activity, fraud and money laundering; and
  • C. Check your identity and verify the accuracy of information you provide.

We use automated decision-making processes as part of our verification and risk assessment procedures. You have rights regarding these automated decisions, including the right to request manual review.

12. HOW LONG WE KEEP YOUR INFORMATION

We retain your personal data:

  • To fulfill the original purpose for which it was collected for as long as you are an Onta Network user
  • To comply with relevant legal and regulatory requirements, which may require retention for up to ten years after your relationship with us ends
  • For longer periods when required to comply with court orders, investigations by law enforcement or regulatory authorities, or other legal obligations

If you want more information about how long we keep your personal data, please contact us at [email protected].

For more detailed information about your rights, our legitimate interests, and our specific processing purposes, please contact our privacy team or refer to our full policy document.

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