2.1. Personal data, or personally identifiable information, means any information about an individual, both natural and juristic entities (i.e. people and companies), from which that entity can be identified. It does not include data where the identity has been removed (anonymous data).

2.2. We may collect, use, store, and transfer (“process”) different kinds of personal data about you which we have grouped together as follows:

2.2.1. Identity Data including full name, username or similar identifier, date of birth, country of residence, copy of identity document or the information about your company such as company registration details, company address and name;

2.2.2. Contact Data including email address, physical/registered addresses, social media contact details and telephone numbers;

2.2.3. Financial Data including bank account details, third-party payment provider information and payment card details (which we do not store but only provide to our authorised third-party payment service provider under contract with us);

2.2.4. Social Media Data including all information accessible on your publicly available profile such as images, photos, photo tags, likes, followers, comments, posts, and stories;

2.2.5. Transaction Data including details about payments to and from you, service or performance contracts, contractual terms, contract fees, signups, invoices and other details of services you have obtained from us, or provide to us;

2.2.6. Profile Data including your Application/Profile username and password, preferences, projects, feedback, ratings and reviews;

2.2.7. Technical Data including internet protocol address/es, your login data, browser type and version, time zone setting and location, cookies, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Application;

2.2.8. Usage Data including information about how you use our company, Application, surveys, events, and Services; and

2.2.9. Marketing and Communications Data including your preferences in receiving notices and marketing from us and our third parties and your communication preferences.

2.3. We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Application feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

2.4. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services or allow you to provide us with your services). In this case, we may have to cancel Application-access or Services you have with us, but we will notify you if this is the case at the time.

3.1. We use different methods to collect data from and about you, including through:

3.1.1. Direct interactions: You may give us your Identity, Contact, Profile, Social Media, Transaction, Usage, Technical, Marketing and Communications and Financial Data by filling in various Bloo Money forms, Application forms or by corresponding with us by phone, email, or otherwise. This includes personal data you provide when you:

3.1.1.1. use our Services;

3.1.1.2. use our Application;

3.1.1.3. use our Website;

3.1.1.4. consult with us;

3.1.1.5. complete forms;

3.1.1.6. interact with us via social media, such as a Facebook™ or Instagram™;

3.1.1.7. provide any contracted services to us as a service provider or independent contractor on contract with us;

3.1.1.8. request information to be sent to you; or

3.1.1.9. give us some feedback.

3.1.2. Automated technologies or interactions: As you interact with our Application, we may automatically collect Technical, Profile and Usage Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other Applications employing our cookies.

3.1.3. Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

3.1.3.1. analytics providers Google Analytics based in the USA;

3.1.3.2. social media websites Facebook, Instagram and LinkedIn based in the USA;

3.1.3.3. survey data providers Typeform and Airtable based in Spain and the USA;

3.1.3.4. marketing platforms Mailerlite based in the USA;

3.1.3.5. search information provider Google based in the USA; and

3.1.3.6. providers of technical and/or payment services being Stitch, Ozow or Paystack based in South Africa.

4.1. We will only use your personal data when the law allows us to and for legitimate reasons, which you hereby expressly understand and consent to. Most commonly, we will use your personal data in the following circumstances:

4.1.1. where we have your express consent to do so;

4.1.2. where we need to consult with you or perform on the Services contract we are about to enter into or have entered into with you;

4.1.3. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or

4.1.4. where we need to comply with a legal or regulatory obligation.

4.2. Purposes for which we will use your personal data:

4.2.1. Providing service via Web Application – “Bloo Money Platform”

4.2.1.1. We provide B2B2C services using our Web Application (https://agency.moya.africa/). This is a financial tool designed to help businesses automate their freelancer management or financial processes in one place (so they can easily onboard, manage and pay freelancers efficiently and at scale.

4.2.1.2. Below is a list of all the ways we plan to use your personal data,

• Provide contracted Services: To provide you with our Services as contracted and maintain Service agreements; we require identity, contact, technical and marketing information

• Customer Care and Support: To engage with you such as Customer Care and support after you have contacted us requesting an engagement via the Application or Website otherwise

• Liaise with Third party integrations to provide contracted Services: To provide it to our authorised third-party service providers who need your personal data to provide their private services to you (such as payment gateway providers)

• Processing Services: To process and service your payment for any services rendered by Bloo Money or its service providers; to manage payments, fees, and charges

• Notification regarding Services: To manage our relationship with you which may include notifying you about changes to our terms or Privacy Policy or Services

• Administration and Protection: To administer and protect our organisation and our Application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

• Monitor quality: To deliver relevant Application content and services to you and measure or understand the effectiveness of the information we serve to you

• Measure and improve: To use data analytics to improve and monitor our Application, Services, user relationships and experiences

• User-specific support or marketing: To provide you with direct and user-specific marketing, make suggestions and recommendations to you about events or services that may be of interest to you

4.2.2. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

4.2.3. Marketing

4.2.3.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. To manifest your rights attached to any marketing sent to you as an existing customer, please use the in-built prompts provided on those communications, or contact us.

4.2.3.2. You will receive marketing communications from us if you are an existing data subject of ours, use our Services/Application (and have accepted this Policy), have requested information from us, have participated in any Bloo Money service or event, or if you provided us with your details when registering for a promotion or event and, in each case, you have not opted-out of receiving that marketing.

4.2.4. Third-Party Marketing

4.2.4.1. Whilst we may use your personal data within our Bloo organisation group, we will get your express opt-in consent before we share your personal data publicly with any entity outside the Bloo group of organisations for public purposes.

4.2.5. Opting-Out

4.2.5.1. You can ask us or authorised third parties to stop sending you marketing messages at any time by contacting us or the relevant third party at any time and requesting us to cease or change your marketing preferences.

4.2.5.2. Where you opt-out of receiving these marketing messages, this opt-out will not apply to other personal data of yours which we process for another lawful basis.

4.2.6. Change of Purpose

4.2.6.1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

4.2.6.2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

4.2.6.3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5.1. We may have to share your personal data with the parties set out below for the purposes set out above.

5.1.1. Internal Third Parties as set out in the Glossary;

5.1.2. External Third Parties as set out in the Glossary;

5.1.3. Specific third parties listed above; and/or

5.1.4. Third parties to whom we may choose to sell, transfer, or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

5.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions and standards.

6.1. The Application may make use of “cookies” to automatically collect information and data through the standard operation of the Internet servers. “Cookies” are small text files an Application can use (and which we may use) to recognise repeat users, facilitate the user’s on-going access to and use of the Application and allow the Application to track usage behaviour and compile aggregate data that will allow the Application operator to improve the functionality of the Application and its content, and to display more focused advertising to a user by way of third-party tools.

6.2. The type of information collected by cookies is not used to personally identify you. If you do not want information collected through the use of cookies, there is a simple procedure that allows you to deny or accept the cookie feature. Please note that cookies may be necessary to provide you with certain features available on our Application, and thus if you disable the cookies you may not be able to use those features, and your access to our Application will therefore be limited. If you do not disable “cookies”, you are deemed to consent to our use of any personal information collected using those cookies, subject to the provisions of this Policy and our other policies or terms.

7.1. We share your personal data within the Bloo group of organisations and affiliates, and this may involve transferring and processing your data outside of South Africa (such as to Ireland for the purpose of cloud storage).

7.2. Whenever we transfer your personal data out of either territory, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

7.2.1. We will always have a contract concluded between the parties speaking specifically to data protection and the duties of each party related thereto; and

7.2.2. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Regulator’s Office of South Africa; and/or

7.2.3. Where we use certain service providers, we may use specific contracts/clauses which give personal data the same protection it has in South Africa.

7.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of South Africa.

8.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed by using, Multifactor Authentication ("MFA") which is a method that requires a user to provide two or more verification factors to gain access to the Application. This includes One Time Pins ("OTP") via SMS or verification emails to grant a user access to their account and data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a legitimate need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

8.2. We use Amazon Web Services ("AWS") to store customer data. The AWS Region we use is Europe (Ireland). Region code eu-west-1 (rds.eu-west-1.amazonaws.com). AWS provides the capabilities that allow us to encrypt, delete, and monitor the processing of all customer data.

8.3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9.1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purpose of satisfying any legal, accounting, or reporting requirements.

9.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, any other South African applicable law requiring us to retain the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9.3. Details of retention periods for different aspects of your personal data are available from us by contacting us.

9.4. In some circumstances you can ask us to delete your data; see below for further information.

9.5. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data where we are the relevant “Responsible Party” over such personal data. Please contact us to find out more about, or manifest, these rights:

10.1.1. request access to your personal data;

10.1.2. request correction of your personal data;

10.1.3. request erasure of your personal data;

10.1.4. object to the processing of your personal data;

10.1.5. request a restriction of processing your personal data;

10.1.6. request transfer of your personal data; and/or

10.1.7. right to withdraw consent.

10.2. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

10.3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

10.4. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11.1. Lawful Basis

11.1.1. Legitimate Interest means the interest of our organisation in conducting and managing our organisation to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

11.1.2. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

11.1.3. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

11.1.4. Express consent means the confirmed express consent you have provided to our processing of your personal data by actively accepting this Privacy Policy.11.2. Third Parties

11.2.1. Internal Third Parties means other entities or parties in the Bloo group acting as joint responsible parties or operators and who are based in South Africa and provide IT and system administration services and undertake reporting.

11.2.2. External Third Parties means:

11.2.2.1. Authorised third-party service providers under contract with Bloo Money who need your personal information in order to contact and transact with you pursuant to your use of the Services;

11.2.2.2. specific third parties who have been identified above;

11.2.2.3. service providers acting as operators based in South Africa who provide IT and system administration services;

11.2.2.4. South African or other national governments and/or their respective authorities pursuant to our adherence with anti-corruption and crime-fighting legislation; and/or

11.2.2.5. professional advisers acting as operators or joint responsible parties including lawyers, bankers, auditors and insurers based in South Africa who provide consultancy, banking, legal, insurance and accounting services as required.

11.3. Your legal rightsYou have the right to:

11.3.1. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

11.3.2. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

11.3.3. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no valid reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be communicated to you, if applicable, at the time of your request.

11.3.4. Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

11.3.5. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

11.3.5.1. if you want us to establish the data’s accuracy;

11.3.5.2. where our use of the data is unlawful but you do not want us to erase it;

11.3.5.3. where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

11.3.5.4. you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

11.3.6. Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform on a contract with you.

11.3.7. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Application access or Services to you. We will advise you if this is the case at the time you withdraw your consent. Please take note that regardless of your right to withdraw consent under POPI, other South African legislation applies and may require that we continue to process your data in order to comply with anti-corruption, crime-fighting and/or other national legislation, which you expressly understand and agree to.

For more information regarding your personal information lawfully stored or used by Moya Money, please contact hello@bloo.money (with email subject ‘Privacy’) who will gladly assist.