PRIVACY POLICY
Last Updated: April 16, 2025
Introduction
Monirates Inc., a Delaware corporation with its principal place of business at 2055 Limestone Rd STE 200-C, Wilmington, DE 19808, USA (“Monirates,” “we,” “our,” or “us”) respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile application, and services (collectively, the “Services”).
By accessing or using our Services, you consent to the collection, use, disclosure, and storage of your information as described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services.
JURISDICTIONAL COVERAGE
This Privacy Policy is designed to comply with privacy laws in all jurisdictions where we operate, including but not limited to:
- Nigeria (Nigeria Data Protection Regulation)
- Ghana (Data Protection Act)
- Benin (applicable data protection laws)
- Cameroon (applicable data protection laws)
- Democratic Republic of Congo (applicable data protection laws)
- Kenya (Data Protection Act)
- Malawi (applicable data protection laws)
- Rwanda (Law on the Protection of Personal Data and Privacy)
- Senegal (applicable data protection laws)
- Tanzania (Data Protection regulations)
- Uganda (Data Protection and Privacy Act)
- Zambia (applicable data protection laws)
- United States (various federal and state laws including CCPA/CPRA, VCDPA, CPA, CTDPA, and UCPA)
- United Kingdom (UK GDPR and Data Protection Act)
- European Union (GDPR, where applicable to our operations)
We recognize that different jurisdictions may have varying requirements regarding data protection, and we are committed to meeting or exceeding the legal requirements in each jurisdiction where we operate.
INFORMATION WE COLLECT
We collect several types of information from and about users of our Services:
Personal Information
Information that identifies you as an individual or relates to an identifiable person, including:
- Full name
- Date of birth
- Home or other physical address
- Email address
- Phone number
- Government-issued identification (passport, national ID, driver's license)
- Biometric data (where permitted by law, such as fingerprints for authentication)
- Photographs (for identity verification)
- Nationality
- Tax identification information
- Employment information
Financial Information
Information related to your financial accounts and transactions, including:
- Bank account numbers
- Credit/debit card information
- Transaction history
- Account balances
- Payment history
- Mobile money account details
- Currency exchange transactions
- Transfer records
Identity Verification Information
To comply with anti-money laundering (AML) and know your customer (KYC) regulations across our operating jurisdictions, we collect information to verify your identity, such as:
- Copies of identification documents
- Proof of address documents
- Information about beneficial owners (for business accounts)
- Politically exposed person status
- Sanctions screening information
Device and Usage Information
Information about your device and how you use our Services, including:
- IP address
- Device type and model
- Operating system
- Browser type
- Mobile network information
- Device identifiers
- Location data (with your permission)
- App usage data
- Time and duration of service use
- Pages viewed
- Features used
- Login information
- Access times and dates
Communications Information
When you communicate with us or other users through our platform, we collect:
- Customer service interactions
- Survey responses
- User feedback
- In-app messages
- Communication preferences
HOW WE COLLECT INFORMATION
We collect information in the following ways:
Directly from You
- When you register for an account
- When you complete transactions
- When you upload verification documents
- When you contact customer service
- When you respond to surveys or promotions
- When you provide information through our app or website
Automatically
- Through cookies and similar technologies
- Through our mobile app when you use it
- Through your device when you visit our website
- Through server logs
From Third Parties
- Banks and financial institutions
- Payment processors
- Mobile money providers
- Identity verification services
- Credit bureaus (where permitted by law)
- Public databases
- Marketing partners
- Social media platforms (if you connect your social media accounts)
- Other users (such as when they send money to you)
- Business partners
HOW WE USE YOUR INFORMATION
We use your information for various purposes, including:
Provide Our Services
- Process currency exchange and transfer transactions
- Manage your account and provide customer service
- Verify your identity and prevent fraud
- Enable features such as international transfers, currency exchange, and payments
- Complete KYC and AML checks
- Facilitate communication between users of our platform
Improve Our Services
- Understand how users interact with our Services
- Develop new products and services
- Test and debug features
- Analyze usage patterns and trends
- Conduct research and analysis
Personalize Your Experience
- Remember your preferences
- Customize content and features
- Provide personalized recommendations
- Deliver targeted offers and promotions
Marketing and Communication
- Send promotional communications about products, services, and features
- Deliver updates about our Services
- Measure the effectiveness of our marketing campaigns
- Invite you to events or surveys
Security and Compliance
- Protect our Services against fraud and unauthorized access
- Comply with legal obligations in our countries of operation
- Enforce our terms and policies
- Resolve disputes
- Protect our legal rights and interests
- Respond to legal requests from authorities
- Conduct audits
LEGAL BASES FOR PROCESSING (WHERE APPLICABLE)
Where required by law (such as under GDPR, UK GDPR, or similar laws), we rely on the following legal bases to process your information:
- Contractual Necessity: To fulfill our contract with you.
- Legitimate Interests: To improve services and ensure security.
- Compliance with Legal Obligations: To meet KYC/AML and other statutory requirements.
- Consent: When you have explicitly agreed to the processing.
DATA SHARING AND DISCLOSURE
We may share your personal information with:
Service Providers
- Payment processors (such as banking partners in Nigeria, Ghana, Kenya, and other operating countries)
- Mobile money operators (such as MTN, Vodafone, Airtel, Orange, M-Pesa, and others across our markets)
- Identity verification services
- Cloud hosting providers
- Analytics providers
- Customer support tools
- Marketing and advertising partners
- Professional advisors (legal, accounting, etc.)
Financial Partners
- Banking institutions
- Mobile money providers
- Card networks
- Money transfer networks
- Currency exchange services
Business Transfers
If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of company assets, your information may be transferred as part of that transaction.
Legal Requirements
We may disclose your information when we believe in good faith that disclosure is necessary to:
- Comply with laws, regulations, or legal processes
- Enforce our terms and agreements
- Protect our rights, property, or safety
- Prevent fraud or unauthorized activity
- Respond to government requests, including from regulatory authorities in Nigeria, other African countries, the US, UK, and EU
With Your Consent
We may share your information with third parties when you have given us your consent to do so.
SALE OR SHARING OF PERSONAL INFORMATION
Monirates does not sell personal information for monetary consideration. However, under laws like the CCPA/CPRA, certain sharing of personal information may be considered a “sale” or “sharing” even without monetary exchange.
We may share certain information (such as device identifiers, browsing activity, and transaction patterns) with advertising partners and analytics providers who may use this information for targeted advertising or analytical purposes. This may constitute “sharing” under certain privacy laws.
INTERNATIONAL DATA TRANSFERS
Monirates operates in multiple countries, primarily across Africa, with connections to global financial systems. As a result, your information may be transferred to, stored, and processed in countries outside of your country of residence, including countries that may not have the same data protection laws as your jurisdiction.
When we transfer personal information from one jurisdiction to another, we implement appropriate safeguards in accordance with applicable laws, which may include:
- Data transfer agreements incorporating standard contractual clauses approved by relevant regulatory authorities
- Implementing appropriate technical and organizational measures to ensure an adequate level of protection
- Obtaining your explicit consent for certain transfers
- Relying on adequacy decisions where available (such as for transfers to and from the UK and EU)
For users in the European Economic Area (EEA), UK, and other jurisdictions with similar requirements: When we transfer your personal information outside of these regions, we ensure that appropriate safeguards are in place to provide an adequate level of data protection.
DATA SECURITY
We implement appropriate technical and organizational measures to protect your personal information, including:
- Encryption of sensitive data in transit and at rest
- Access controls and authentication procedures
- Regular security assessments and penetration testing
- Staff training on data protection and security
- Monitoring for suspicious activities
- Secure data centers and cloud infrastructure
- Compliance with industry security standards
However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
DATA RETENTION
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law, including:
- To provide our Services to you
- To comply with legal obligations (such as AML recordkeeping requirements, which may be 5-10 years depending on the jurisdiction)
- To resolve disputes
- To enforce our agreements
- For legitimate business purposes
When personal information is no longer needed, we will securely delete or anonymize it.
YOUR PRIVACY RIGHTS
Depending on your jurisdiction, you may have certain rights regarding your personal information:
For All Users
- Access: You can request access to the personal information we have about you.
- Correction: You can request that we correct inaccuracies in your personal information.
- Account Information: You can access and update certain information through your account settings.
For Users in Nigeria and African Countries with Similar Rights
Under the Nigeria Data Protection Regulation and similar laws in other African countries where we operate, you may have rights to:
- Request information about the processing of your personal data
- Request restriction of processing
- Object to processing in certain circumstances
- Request deletion of your data in certain circumstances
For Users in the United States
Depending on your state of residence, you may have rights to:
- Request deletion of your personal information
- Request disclosure of categories of personal information collected
- Request correction of inaccurate personal information
- Opt out of the sale or sharing of personal information
- Limit the use of sensitive personal information
- Data portability (receiving your data in a structured format)
- Non-discrimination for exercising your rights
For Users in the UK and EU
You may have rights to:
- Data portability (receiving your data in a structured, commonly used format)
- Restriction of processing
- Objection to processing
- Erasure (the “right to be forgotten”)
- Withdrawal of consent
- Lodge a complaint with a supervisory authority
AUTOMATED DECISION-MAKING
We use automated processes for purposes such as fraud detection, identity verification, and transaction risk scoring. These automated processes may include:
- Anti-fraud systems that analyze transaction patterns
- Identity verification systems that match submitted documents to verify authenticity
- Risk assessment systems that evaluate transaction risk
- Compliance screening systems that check against regulatory watchlists
Your Rights Regarding Automated Decisions
Where applicable law provides (such as under GDPR or similar laws), you have the right to:
- Obtain human intervention in the decision-making process
- Express your point of view about the decision
- Contest the decision
For U.S. residents, you may have rights under state privacy laws to opt out of certain profiling activities. Please contact us to exercise these rights.
SENSITIVE PERSONAL INFORMATION
We collect sensitive personal information, such as government identification numbers, financial account details, and biometric data (where permitted by law), solely for legitimate business purposes, including identity verification, fraud prevention, and compliance with financial regulations.
For U.S. residents: Under applicable state privacy laws, you may have the right to limit the use and disclosure of sensitive personal information. You can exercise this right through your account settings or by contacting us.
CHILDREN'S PRIVACY
Our Services are not directed at or intended for children. We do not knowingly collect personal information from children under 13 years of age. If you are under 13, please do not provide any personal information to us.
If we learn that we have collected personal information from a child under 13 without parental consent where required by law (such as under the Children's Online Privacy Protection Act in the U.S.), we will take steps to delete that information promptly.
For users between 13 and 18 years of age, we may collect limited information as permitted by applicable law, but certain features and services may be restricted.
COOKIES AND SIMILAR TECHNOLOGIES
We use cookies, web beacons, pixels, and similar technologies to collect information about how you use our Services.
Types of Cookies We Use
- Essential Cookies: Necessary for the operation of our website.
- Analytical/Performance Cookies: Allow us to recognize and count the number of visitors.
- Functionality Cookies: Used to recognize you when you return to our website.
- Targeting Cookies: Record your visit to our website and the pages you have followed.
Cookie Consent and Choices
When you first visit our website, you will be presented with a cookie consent banner that allows you to:
- Accept all cookies
- Decline non-essential cookies
- Manage your cookie preferences
- Access our Cookie Policy for more detailed information
You can also control cookies through your browser settings and other tools. However, if you block certain cookies, you may not be able to use some features of our Services. To change your cookie preferences at any time, click on “Cookie Settings” in the footer of our website.
THIRD-PARTY LINKS AND SERVICES
Our Services may contain links to third-party websites, apps, or services that are not operated by us. If you click on these links, you will be directed to that third party's site. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
MARKETING COMMUNICATIONS
We may send you marketing communications about our products and services. You can opt out of receiving marketing communications from us by:
- Following the unsubscribe instructions in any marketing email
- Adjusting your communication preferences in your account settings
- Contacting customer support
Even if you opt out of marketing communications, we will still send you service-related communications, such as transaction confirmations and account notices.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by:
- Posting the updated policy on our website
- Sending an email or in-app notification
- Providing notice through our Services
The date at the top of this Privacy Policy indicates when it was last updated. We encourage you to review this Privacy Policy periodically.
CONTACT US
If you have questions or concerns about this Privacy Policy or our data practices, please contact us at:
Privacy Team
Email: privacy@monirates.com
Address: 2055 Limestone Rd STE 200-C, Wilmington, DE 19808, USA
Data Protection Officer
Email: dpo@monirates.com
For Users in Specific Regions:
- Nigeria: nigeria-privacy@monirates.com
- UK/EU: gdpr@monirates.com
- US: us-privacy@monirates.com
REGIONAL SUPPLEMENTS
NIGERIA SUPPLEMENT
In compliance with the Nigeria Data Protection Regulation (NDPR), we provide the following additional information:
- Data Controller: Information about the data controller.
- Categories of Personal Data: Specific categories collected.
- Purpose of Processing: Explicit purposes.
- Technical Methods Used for Processing: Description of methods.
- Third-Country Transfer Safeguards: Safeguards used.
- Retention Period: Specific timelines.
You have the right to request access to, rectification, or deletion of your personal data, and to lodge a complaint with the National Information Technology Development Agency (NITDA) if you believe your rights have been violated.
GHANA SUPPLEMENT
In compliance with Ghana's Data Protection Act, we inform you that:
- Data Controller: Information about the data controller.
- You have the right to request access to your personal data, object to processing, and request rectification or erasure in certain circumstances.
- You may lodge a complaint with the Data Protection Commission of Ghana.
UNITED STATES SUPPLEMENT
This U.S. Privacy Policy Supplement is provided pursuant to applicable U.S. state privacy laws including, but not limited to, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), Connecticut Data Privacy Act (CTDPA), and Utah Consumer Privacy Act (UCPA).
Data Controller: Information about the data controller.
California Residents
Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have specific rights regarding their personal information:
- Right to Know: Information about collection and use.
- Right to Delete: Request deletion of data.
- Right to Correct: Correct inaccurate information.
- Right to Opt-Out: Opt-out of sale or sharing.
- Right to Limit Use of Sensitive Personal Information: Restrict use of sensitive data.
UK AND EU SUPPLEMENT
In compliance with UK GDPR and EU GDPR (where applicable), we provide the following additional information:
- Data Controller: Information about the data controller.
- Legal Bases for Processing: Contractual necessity, legitimate interests, compliance, consent.
- Automated Decision-Making: Details on human intervention.
- Data Protection Officer: Contact information.
To exercise your rights under GDPR or to lodge a complaint with a supervisory authority, please contact us using the information in the “Contact Us” section.
Let’s get you
Started
Join the fintech revolution that’s connecting Africa to the world.