Privacy and Data Protection Policy

I. Introduction

Kwattel S.A. respects your privacy and is committed to protecting it. This policy aligns with Law No. 22/11 on Data Protection and other internal regulations.

II. Objectives

This policy governs the collection and processing of personal data provided by users through forms, documents, or other contact methods. All data is handled confidentially and in accordance with applicable laws.

III. Data Controller

Kwattel – Payment Services S.A., headquartered in Luanda, Angola, is responsible for data collection and processing.

IV. Data Processing Principles

• Lawful, fair, and transparent
• Specific and legitimate purposes
• Data minimization and relevance
• Accuracy and timely updates
• Retention only as necessary

V. Data Subjects

Includes clients, suppliers, and potential clients who voluntarily provide data or do so upon request.

VI. Categories of Personal Data

VII. Legal Basis, Purpose, and Retention

VII.1 Legal Basis

• Consent
• Contract execution
• Legal obligation
• Legitimate interest

Location data is used only to support service functionality and is not stored or shared unless legally required.

VII.2 Purposes

• Marketing
• Client and supplier management
• Accounting and tax management
• Legal dispute management
• Physical security (video surveillance)

VII.3 Retention Periods

10 years for tax data, 7 years for anti-money laundering, 30 days for video surveillance. Other data may be retained based on consent or legitimate interest.

VIII. Data Collection Timing and Methods

Data is collected with consent when acquiring or providing services/products, orally, in writing, or via the website. Agents may also collect data.

IX. Data Subject Rights

• Access
• Rectification
• Erasure ("Right to be Forgotten")
• Portability
• Withdrawal of Consent/Opposition
• Restriction
• Complaint

Requests are free unless excessive. Contact: geral@kwattel.com or visit the company’s headquarters. Response within 30 days.

X. Data Sharing

With consent, data may be shared with partners, subcontractors, auditors, or authorities. Data may be processed inside or outside Angola.

XI. Data Security and Confidentiality

Kwattel S.A. applies security measures and does not sell or distribute personal data. Confidentiality is strictly maintained.

XII. Data Breach Notification

Any breach posing risk will be reported to authorities and affected individuals immediately.

XIII. Policy Changes

Kwattel S.A. may update this policy at any time. Changes will be published on the website.

XIV. Reference Documents

• Code of Conduct
• Penal Code

XV. Implementation

Reviewed annually by the responsible department and approved by the Board of Directors. Compliance monitored by HR.

XVI. Review

Policy is revised upon internal or external changes. All revisions require board approval.

XVII. Approval

Approval is the responsibility of the Board of Directors under corporate governance.

XVIII. Final Considerations

Violations are subject to legal or disciplinary action. HR handles dissemination; Compliance provides training. Effective from February 2025.