MannyPay Privacy Notice

Consent

By using the MannyPay Wallet and providing us your Personal Data, you are deemed to have permitted the collection, use, and processing of your Personal Data and accepted the policies and practices in this Privacy Notice.

If you do not allow the collection, use, and processing of your Personal Data, please do not use our platform or contact us for assistance.

Definition of Terms

1. Personal Information – any information, whether recorded or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual.
2. Data Subject / User – an individual whose Personal, Sensitive, or Privileged information is processed.
3. Consent of the Data Subject – any freely given, specific, informed indication of will whereby the Data Subject agrees to the processing of his/her personal, sensitive personal, or privileged information. It may be given by a lawful representative or an agent specifically authorized by the Data Subject.
4. Outsourcing – disclosure or transfer of Personal Data by the Parties to their Personal Information Processor(s) (PIP/s) for processing under this Notice or other agreements.
5. Processing – any operation performed upon Personal Data including collection, recording, organization, storage, updating, retrieval, consultation, use, consolidation, blocking, erasure, or destruction, whether automated or manual if in a filing system.
6. Personal Data Breach – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data transmitted, stored, or otherwise processed.
7. Sensitive Personal Information – personal information about an individual’s marital status, age, birthdate, sex, gender, and information contained in government-issued IDs.

Why We Collect & What We Collect

For MannyPay Wallet Registration

We request the following to set up your account:

• Mobile Number
• First and Last Name
• Username
• Password
• Mobile Personal Identification Number

For MannyPay Wallet Verification

After registration, we may request further personal and sensitive personal information to verify your identity and enable features (e.g., add money, pay bills, buy load/credits/vouchers, withdraw, send money):

• Personal particulars (contact details, residence, gender, birthdate, place of birth, civil status, nationality, mother’s maiden name)
• Financial information (e.g., income source)
• Employment/business details
• Government ID(s) and data contained therein
• Selfie

Account verification is optional but unverified users will have limited access. You may also enable biometric login (facial or fingerprint recognition) on your device; this is optional and requires your device permission.

For Marketing and Advertising

We may assess your preferences and activities to recommend MannyPay or third-party services, promotions, products, offers, and discounts we believe may suit your interests.

For Product and Market Research

Your data may be used to analyze trends and patterns to improve and innovate financial products and services.

For Customer Service

We collect information necessary to address and resolve your queries and concerns.

For Legal Compliance

We collect information to comply with legal obligations, regulatory/reportorial requirements, and other lawful purposes.

If we request data for a purpose not covered above, we will explain the purpose and lawful basis. If we later process your data for a new purpose, we will provide a clear explanation and relevant information before doing so.

How We Collect

1. Direct input during account creation, registration, and verification via our app or website.
2. Your use of MannyPay Wallet products and services through electronic channels.
3. Your browsing or transactions on the MannyPay website.
4. When you contact customer support (website, telephone, email).
5. When you enable biometric login (facial/fingerprint recognition).
6. From third parties for transactions you direct to us, or from law enforcement/regulators during complaints or investigations.

How We Use Your Data

• Know-Your-Customer (KYC) and client identification activities required by law.
• Assessing and/or processing applications or transactions (e.g., account opening, fund transfer, withdrawal, bills payment, load, game credits/vouchers).
• Responding to inquiries, requests, concerns, or complaints.
• Managing your accounts and performing necessary audit, administrative, and operational tasks.
• Detecting, preventing, investigating, and prosecuting fraud or crime.
• Detecting and preventing violations of our Community Guidelines.
• Performing activities for which you have provided consent.
• Other activities permitted by law.

Data Sharing / Outsourcing

Within MannyPay, data is accessible only to authorized backend developers, admin, support, and finance personnel on a need-to-know basis.

Data collected for KYC may be disclosed to our partner processors, ZOLOZ and Netbank. Technology partners receive only limited data necessary to provide their services within the application and may not store information beyond that purpose. No data collected by the application will be disclosed to other third parties unless required by law or with your consent.

Retention of User Data

MannyPay and Netbank retain user data for five (5) years upon account closure. Data will not be deleted while a wallet retains a balance. You may request deletion at any time; once the retention period expires or data is no longer needed, we will securely delete it.

How We Protect Your Information

We implement reasonable and appropriate physical, technical, and organizational safeguards, including secured servers behind firewalls, encryption, and access controls, to protect against loss, destruction, misuse, or alteration. In line with our retention policy, MannyPay and Netbank securely delete data upon expiry of the retention period or when no longer necessary.

Your Rights as a Data Subject

1. Right to be Informed whether Personal Data pertaining to you shall be, are being, or have been processed.
2. Right to Reasonable Access to Personal Data collected and processed.
3. Right to Object or withhold consent to the collection and processing of Personal Data.
4. Right to Erasure/Blocking to suspend, withdraw, or order the blocking, removal, or destruction of Personal Data from relevant filing systems.
5. Right to Rectification to dispute inaccuracies or errors and have them corrected without delay unless the request is vexatious or unreasonable.
6. Right to Data Portability to obtain a copy of your data in a commonly used, structured, and machine-readable format.
7. Right to File a Complaint before the National Privacy Commission for violations of your data privacy rights, and to claim damages when applicable.

Changes to this Privacy Notice

This Privacy Notice may be updated or amended to reflect platform changes or legal/regulatory updates. Where required, we will notify you and seek renewed consent. Otherwise, updates take effect upon posting.