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BNA Licence No. 420

Compliance Department · March 2026

Global Data Protection
and Privacy Policy

In force: 06 March 2026 · Next review: 06 March 2027

1. General Considerations

This Data Protection and Privacy Policy (the “Policy”) establishes the principles, rules, responsibilities and control mechanisms intended to ensure that Conectando – Sociedade Prestadora de Serviços de Pagamentos, Lda (hereinafter “Conectando” or the “Institution”) processes personal data lawfully, fairly, transparently and securely, in strict compliance with the applicable legal and regulatory framework.

As a Payment Services Provider integrated into the Angolan Payments System and supervised by the National Bank of Angola, Conectando recognises that protecting personal data and safeguarding privacy are essential pillars of customer trust, institutional integrity and business sustainability.

2. Legal Framework

Among others, this Policy observes the following instruments:

  • Law No. 22/11 of 17 June, Personal Data Protection Act;
  • Law No. 14/21 of 19 May, General Regime of Financial Institutions Act;
  • Law No. 40/20 of 16 December, Angola Payments System Act;
  • Law No. 5/20 of 27 January, Prevention and Combating of ML/TF/PF Act;
  • Notice No. 02/2024 of 22 March – Rules for the Prevention and Combating of Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction;
  • Notice No. 08/20 – Cybersecurity Policy and Adoption of Cloud Computing;
  • Related internal regulations.

3. Scope of Application

This Policy applies to:

  • Shareholders, Directors and Managers;
  • Employees, interns and consultants;
  • Agents, commercial representatives, service providers and critical suppliers;
  • Technology partners and outsourced entities;
  • Any third party acting on behalf of Conectando;
  • All operations, products, channels, digital platforms, payment services, agents, commercial relationships and strategic initiatives.

4. Definitions

For the purposes of this Policy and Law 11/22, the Personal Data Protection Act, the terms used here have the meaning assigned to them in that Law, unless expressly defined otherwise in this document.

  • Personal data: any information, regardless of its nature or medium, including image and sound, relating to an identified or identifiable individual. A person is identifiable when they can be identified directly or indirectly, in particular by reference to an identification number or a combination of elements relating to their physical, physiological, psychological, economic, cultural or social identity.
  • Data subject: an identified or identifiable individual to whom the Personal Data relates.
  • Data subject consent: any freely given, specific, explicit and informed expression of will, regardless of the medium, by which the data subject authorises the processing of their data.
  • Controller: the individual or legal entity, public authority or other body that, alone or jointly with others, determines the purposes and means of processing personal data.
  • Processor: the individual or legal entity, public authority or other body that processes personal data on behalf of the controller under a contractual relationship.

5. Responsibilities

5.1. Board of Directors

The Board of Directors is responsible for:

  • Approving the Policy and its revisions;
  • Ensuring alignment with the applicable legal and regulatory framework;
  • Ensuring adequate resources for implementation;
  • Defining regulatory risk appetite;
  • Ensuring the independence of the Data Protection Officer;
  • Supervising the effectiveness of the data protection governance system.

5.2. Audit and Internal Control Committee (CACI)

The CACI is responsible for:

  • Validating and proposing revisions to the Policy;
  • Monitoring its implementation;
  • Assessing the effectiveness of internal controls related to data protection;
  • Reviewing reports from the Data Protection Officer;
  • Monitoring the management of relevant incidents.

5.3. Data Protection Officer

The Data Protection Officer is responsible for:

  • Ensuring that personal data processing complies with applicable law and this Policy;
  • Monitoring internal compliance with data protection rules;
  • Advising corporate bodies and employees;
  • Monitoring the management of data-subject requests and security incidents;
  • Cooperating with the competent supervisory authority;
  • Promoting awareness and training activities.
  • The Data Protection Officer performs their duties with technical and functional autonomy.

6. Principles of Personal Data Processing

Personal data provided in the context of the relationship with Conectando is processed in strict compliance with the applicable legal provisions, namely:

6.1. Transparency

Personal data is processed transparently, respecting privacy and the fundamental rights, freedoms and guarantees provided for in the Constitution of the Republic of Angola and the Personal Data Protection Act.

6.2. Lawfulness

Personal data is processed lawfully and fairly, in accordance with the principle of good faith.

6.3. Proportionality

The personal data processed is relevant, appropriate and not excessive in relation to the purposes that justified its collection and processing.

6.4. Purpose

Personal data is collected and processed for specific, explicit and legitimate purposes and is not subsequently processed in a manner incompatible with those purposes.

6.5. Accuracy

Conectando ensures the accuracy of the personal data processed and adopts appropriate measures to allow its correction or deletion whenever it no longer reflects the data subject’s current situation.

6.6. Retention period

Personal data is retained only for the period necessary to pursue the purposes that determined its collection or processing, in accordance with the Personal Data Protection Act.

Without prejudice to the above, where there is a specific legal retention obligation, including under Law No. 5/20 of 27 January on the Prevention and Combating of Money Laundering, Terrorist Financing and the Proliferation of Weapons of Mass Destruction, Conectando will retain legally required data and documents for at least 10 years, counted from the date of the transaction or the end of the business relationship.

After the applicable legal period has expired, data will be securely deleted or anonymised, unless another legitimate legal basis justifies retaining it for an additional period.

7. Data Processing

7.1. Data processed

To provide its payment services, and depending on the category of data subject (customers, users, agents, employees or partners), Conectando may collect and process the following categories of personal data:

  • Data provided by the data subject or collected in the contractual relationship: identification data (name, government-issued identification number, date of birth, nationality and tax identification number, where applicable); contact data (telephone number, email address and physical address); billing and financial data; family status/parentage data; professional data (occupation); and criminal-offence data where processing is necessary to comply with legal obligations, particularly those relating to the prevention of money laundering and terrorist financing.
  • Data collected automatically when using the platform: Device ID, IP address, access logs and activity records, traffic data, and location data when enabled by the user or necessary for security and fraud-prevention purposes.

7.2. Processing of Biometric Data for Identity Verification

Conectando’s Core system may collect personal data through image capture for user registration. As part of identity verification, we collect, use and store biometric data as follows:

  • The system extracts facial-reading information from photographs to compare user photographs in identity documents with one another and with a submitted selfie, to verify identity, conduct anti-fraud checks and improve these processes.
  • We may ask the user to specifically agree to the collection, use and storage of biometric data during verification whenever privacy regulations require this in their jurisdiction. If the user does not consent, we provide alternative identity-verification methods, which may take longer. The same documents and photographs are required for both processes.
  • We will not disclose or share biometric data with third parties except our identity-verification service providers, or where required by law, applicable regulation or a valid court order. We never sell, rent, commercialise or benefit from biometric data.
  • Image-capture data is collected to ensure user security and authenticity and to ensure that only authorised individuals access the system. All data collected is treated with the utmost confidentiality and used exclusively for the purposes described in this privacy policy.
  • Biometric data is retained for the period necessary to complete identity verification, unless the law or legal proceedings require a longer retention period.

7.3. Two-factor authentication and device validation

Conectando’s system collects and stores device-identification data through the UDID (Unique Device Identifier) exclusively to enable two-factor authentication (OTP – One Time Password) for validating the user’s identity when logging in on another device.

7.4. Lawful bases

Conectando processes personal data only when based on one of the following lawful bases:

  • Performance of a contract or pre-contractual steps;
  • Compliance with a legal obligation to which Conectando is subject;
  • Protection of the data subject’s vital interests where they are physically or legally unable to express their will;
  • Performance of a task carried out in the public interest or in the exercise of public authority;
  • Conectando’s legitimate interests, provided they do not override the data subject’s fundamental rights, freedoms and guarantees;
  • The data subject’s freely given, specific, informed and explicit consent, which may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

7.5. Processing purposes

Personal data processed by Conectando will not be used for purposes different from or incompatible with those that motivated its initial collection, except where:

  • The data subject has given consent for the new purpose;
  • Processing is for statistical or historical purposes, provided the data is previously anonymised;
  • Processing is necessary for the prevention, investigation or prosecution of crime, or for safeguarding national security, as provided by applicable law, provided the data subjects’ rights, freedoms and guarantees do not prevail.

7.6. Retention period

The period for which Conectando retains personal data varies according to the underlying processing purpose and lawful basis. Conectando observes the principle of storage limitation and keeps data only for the period strictly necessary, in accordance with legal obligations and operational needs.

Once the defined retention period ends, personal data is securely deleted in accordance with internal retention policies.

Retention for longer than the defined period for historical, statistical, criminal-investigation or national-security purposes may be authorised by the Data Protection Agency upon a reasoned application submitted by Conectando.

8. Data Subject Rights

Under applicable law, the data subject has the following rights, which may be exercised by submitting a request to Conectando:

  • Right of access: to obtain confirmation of whether personal data relating to them is being processed and access information about the conditions under which it is processed;
  • Right to rectification: to request correction of inaccurate personal data or updating of outdated data;
  • Right to completion: to obtain completion of incomplete personal data, including through a corrective statement;
  • Right to erasure (“right to be forgotten”): to request deletion of personal data in the situations provided for by law;
  • Right to restriction of processing: to obtain restriction of processing where the legally prescribed circumstances apply;
  • Right to withdraw consent: to withdraw consent at any time where processing is based exclusively on consent, without affecting the lawfulness of prior processing;
  • Right to object: to object, on grounds relating to their particular situation, to processing based on the controller’s legitimate interest;
  • Right to data portability: to receive personal data provided to Conectando in a structured, commonly used and machine-readable format and request direct transmission to another controller where technically feasible.

Exercising rights

A request to exercise rights must be made in writing to Conectando’s Data Protection Officer through the following channels:

Email: p.rodrigues@paypayafrica.com

Registered letter: Rua Joaquim Fernandes Boavida, Prédio Palácio Real, 5.º andar C, Ingombota, Luanda, Angola.

The communication must include a photocopy of an identity document so that the data subject’s identity can be confirmed.

Except where obtaining proof would require disproportionate effort or is effectively impossible, Conectando undertakes to provide proof that the right was exercised upon the data subject’s request.

These rights may not be feasible where national security or criminal-investigation prevention applies, where the data subject cannot be identified, or where other laws take precedence.

9. Sharing Data with Third Parties

Conectando may transmit data subjects’ personal data to processors acting on its behalf and under its direction for specific processing purposes or parts of those purposes.

Conectando only shares data with processors with whom it has a formal contractual relationship imposing a duty of confidentiality regarding the information, in accordance with this Policy. Such entities must also provide sufficient technical and organisational guarantees to protect the data as required by applicable law.

In addition to sharing with processors, Conectando may, where duly justified, be required to disclose personal data to public entities, national or foreign, in compliance with legal obligations or an order from a competent authority.

9.1. Data communication within the KWiK Arrangement

For operations integrated into the KWiK Arrangement, and in compliance with regulatory provisions issued by the National Bank of Angola, certain user data may be communicated to EMIS – Empresa Interbancária de Serviços, S.A., the entity responsible for the technical and operational management of that arrangement.

Depending on the operation, communicated data may include user identifiers, mobile telephone number, email address, tax identification number, IBAN and other elements strictly necessary to execute the operation.

The communication is based on a legal and regulatory obligation applicable to the payment system and does not depend on the data subject’s consent.

EMIS will act as Controller for data processed within the KWiK Arrangement, and its processing will be governed by its own privacy policy.

9.2. Data communication for international payment partnerships and complementary services

For partnerships established to provide international transfer and foreign-exchange services on the PayPay Africa platform, and in compliance with legal and regulatory provisions issued by the National Bank of Angola, certain user data may be communicated to international payment-scheme partners, transfer and remittance service providers, and entities authorised by the National Bank of Angola to provide services complementary to Conectando’s services, including entities responsible for the technical, operational or regulatory management of the relevant partnered services.

Depending on the operation, communicated data may include user identifiers, mobile telephone number, email address, tax identification number, IBAN and other elements strictly necessary to execute the operation, including beneficiary identification, compliance checks, fraud prevention and the prevention of money laundering and terrorist financing.

The communication is based on legal and regulatory obligations applicable to payment and foreign-exchange operations, as well as the performance of established partnerships, and does not depend on the data subject’s consent.

Those partners will act as Controllers for data processed in connection with their services, and their processing will be governed by their own privacy policies.

10. Information Security Commitment

Conectando is committed to ensuring the security of the personal data it processes, ensuring its confidentiality, integrity and availability in line with good privacy and data-protection practices. The objective is to prevent the accidental or unlawful destruction, in whole or in part, accidental loss, alteration, disclosure or unauthorised access to data subjects’ information.

In this context, Conectando has established security rules and procedures applicable to personal-data processing, defining the required security levels, the resources to be protected, and the functions and responsibilities of each employee or third party who, in the course of their activity, has access to the data.

11. Right to Lodge a Complaint

If a data subject has concerns about personal-data breaches or other privacy matters, they may contact Conectando through the contacts indicated in section 8 of this Policy. They also have the right to lodge a complaint with the Data Protection Agency (APD) or the supervisory authority in their country of residence.

12. Questions and Omissions

Questions and omissions arising from the interpretation and application of this Policy are resolved by the Board of Directors.

13. Approval and Review of the Policy

This Policy is approved by Conectando’s Board of Directors and periodically reviewed by the Compliance Department, at the initiative of the Board of Directors or whenever internal or external changes may affect its content.