MINT
MINT Platforms (Pty) Ltd · FSP 55118 · NCRCP22892
Version 2.0 · Adopted March 2026 · Next review no later than March 2027
1.1. MINT Platforms (Pty) Ltd (Registration Number 2024/644796/07) (“MINT”, “we”, “us”, or “our”) is a South African fintech company that operates a technology-enabled investment and digital assets platform at www.mymint.co.za. MINT is an authorised Financial Services Provider (FSP Licence Number 55118) registered with the Financial Sector Conduct Authority (“FSCA”) and a registered accountable institution under the Financial Intelligence Centre Act 38 of 2001 (“FIC Act”). MINT is not a bank or deposit-taking institution.
1.2. In the ordinary course of operating the MINT platform and delivering financial and technology services, MINT processes personal information as defined in the Protection of Personal Information Act 4 of 2013 (“POPIA”). MINT is committed to processing personal information lawfully, transparently, and securely, in compliance with POPIA and all other applicable data protection legislation.
1.3. This Privacy Policy (“Policy”) explains how MINT collects, uses, stores, discloses, transfers, and protects personal information in connection with MINT’s websites, including www.mymint.co.za, MINT’s platform, mobile applications, APIs, portals, and other digital interfaces, and MINT’s regulated and non-regulated business operations.
1.4. This Policy applies to all data subjects with whom MINT interacts, including users of the MINT platform, applicants for MINT accounts, representatives of corporate customers, prospective clients, suppliers, partners, service providers, and visitors to MINT’s website.
1.5. By engaging with MINT, whether through the website, platform, communications, products, or regulated financial services, you acknowledge and accept the terms of this Policy.
2.1. In accordance with section 18 of POPIA, MINT provides the following notification when collecting personal information directly from you:
2.1.1. Identity and contact details of the Responsible Party: MINT Platforms (Pty) Ltd, 3 Gwen Lane, Sandown, Sandton, 2031; Email: [email protected]; Telephone: +27 (10) 276-0531;
2.1.2. Identity and contact details of the Information Officer: Lonwabo Damane, Information Officer, Email: [email protected];
2.1.3. Purpose for which personal information is being collected: as set out in clause 7 of this Policy;
2.1.4. Whether the provision of personal information is voluntary or mandatory: certain personal information (such as identity verification documents) is mandatory for purposes of regulatory compliance and account creation. Failure to provide mandatory personal information may result in MINT being unable to open or maintain your account. Other personal information is voluntary, as indicated at the point of collection;
2.1.5. Categories of recipients to whom personal information may be disclosed: as set out in clause 9 of this Policy;
2.1.6. Rights as a data subject: as set out in clause 17 of this Policy; and
2.1.7. Where personal information is collected from a source other than you, MINT will take reasonable steps to bring this notification to your attention as soon as reasonably practicable.
3.1. MINT has appointed the following Information Officer in terms of POPIA:
3.1.1. Information Officer: Lonwabo Damane;
3.1.2. Email: [email protected];
3.1.3. Telephone: +27 (10) 276-0531; and
3.1.4. Physical Address: 3 Gwen Lane, Sandown, Sandton, 2031.
3.2. MINT has also appointed the following Deputy Information Officer to act in the absence or incapacity of the Information Officer:
3.2.1. Deputy Information Officer: Kevin Pillay;
3.2.2. Email: [email protected].
3.3. MINT has registered its Information Officer with the Information Regulator in accordance with POPIA. The Information Officer is responsible for MINT’s compliance with POPIA, including the processing of requests from data subjects, managing POPIA complaints, and reporting to the Information Regulator.
4.1. Terms used in this Policy that are defined in POPIA bear the meanings assigned to them in POPIA. The following additional definitions apply for purposes of this Policy:
4.1.1. “Cookie” means a small text file or similar data element placed on a device when visiting or interacting with MINT’s website or platform, including analogous technologies such as pixels, tags, tracking tools, SDKs, beacons, telemetry identifiers, or similar tools used to support analytics, functionality, security, diagnostics, or user experience;
4.1.2. “Data Subject” means the natural or juristic person to whom personal information relates and whose personal information is processed by MINT;
4.1.3. “Information Officer” means the individual appointed by MINT in terms of POPIA and any Deputy Information Officers authorised to perform the duties and responsibilities assigned to an information officer;
4.1.4. “Operator” means any third party who processes personal information for MINT in terms of a contract or mandate, without coming under MINT’s direct authority;
4.1.5. “Personal Information” has the meaning assigned to it in POPIA and includes, without limitation, information relating to an identifiable, living, natural person or an identifiable existing juristic person, including names, contact details, identification numbers, online identifiers, financial information, transaction data, and any other information that identifies or could reasonably be linked to an identifiable data subject;
4.1.6. “Processing” means any operation or activity concerning personal information, including collection, receipt, recording, organisation, storage, updating, modification, retrieval, dissemination, transmission, distribution, making available, alignment, merging, adaptation, combination, restriction, encryption, archival, retention, destruction, erasure, or de-identification;
4.1.7. “Responsible Party” means the entity that determines the purpose of and means for processing personal information. MINT is the Responsible Party;
4.1.8. “Special Personal Information” means personal information as described in sections 26 to 32 of POPIA, including information relating to religious or philosophical beliefs, race or ethnic origin, trade union membership, political persuasion, health or sex life, biometric information, and criminal behaviour; and
4.1.9. “Website” means any website or digital property owned or operated by MINT, including www.mymint.co.za, sub-domains, portals, web applications, integrated workspaces, linked APIs, dashboards, and platform interfaces provided or maintained by MINT.
5.1. MINT, in its capacity as Responsible Party, processes personal information in compliance with POPIA and accepted information protection principles. This Policy applies to all personal information collected by MINT in connection with the provision of MINT’s platform, investment, and digital asset services; onboarding processes, including those required under the FIC Act and FAIS Act; website and platform interactions; support, sales, and business engagements; contractual relationships; and internal business operations.
5.2. This Policy does not apply to information collected by independent third-party websites, platforms, or applications that are not owned or controlled by MINT.
MINT may collect and process the following categories of personal information:
Full legal name, date of birth, identity number or passport number, nationality, and residential address. Email address, postal address, telephone number, and mobile number. Where the customer is a juristic entity: company name, registration number, registered address, nature of business, and the identity of directors, officers, and beneficial owners.
Information required for KYC and FICA compliance, including identity documentation, proof of address, declarations of source of funds and source of wealth, beneficial ownership information, and suitability and appropriateness information. This information is collected only through secure onboarding workflows and direct regulated engagements, not through the public website.
Information relating to your Legal Tender Account and Digital Currency Wallet, including account balances, transaction histories, deposit and withdrawal records, and the details of Transactions entered into through the platform. Bank account details provided for deposit and withdrawal verification purposes. Tax reference numbers and foreign investment allowance declarations.
IP addresses, device identifiers, browser type, operating system, system logs, and authentication logs. Telemetry, diagnostics, platform usage logs, and session data. Geolocation metadata (where access is enabled on your device). Cookie and analytics data, as further described in clause 15.
Emails, correspondence, support tickets, and other communications with MINT. Information relating to complaints submitted in accordance with MINT’s Complaints Policy.
Information submitted through questionnaires, surveys, feedback forms, or other voluntary mechanisms.
MINT does not intentionally collect Special Personal Information except where required for compliance with applicable law (for example, under the FIC Act) and only through secure, non-public channels. MINT does not collect special personal information through its public website.
7.1. MINT processes personal information for the following lawful purposes:
7.1.1. Provision of Products and Services: to deliver, maintain, secure, and support MINT’s platform, accounts, and investment and digital asset services;
7.1.2. Account and Platform Management: to administer user accounts, Legal Tender Accounts, and Digital Currency Wallets, facilitate access and authentication, maintain platform operability, and enable user functionality;
7.1.3. Regulatory and Legal Compliance: to comply with POPIA, the FIC Act, the FAIS Act, the FSR Act, and other applicable financial services regulations, including AML/CTF/PF obligations, sanctions screening, suitability assessments, and regulatory reporting;
7.1.4. Risk Management and Fraud Prevention: to manage MINT’s operational, financial, and regulatory risks, detect and prevent fraud, money laundering, and other financial crime, and maintain the integrity of MINT’s platform;
7.1.5. Analytics, Development, and Improvement: to analyse system performance, conduct diagnostics, improve product functionality, and enhance user experience, subject to applicable privacy constraints;
7.1.6. Operations and Governance: for governance, audits, risk management, billing, internal controls, IT administration, quality assurance, and business reporting;
7.1.7. Marketing and Communications: to communicate with clients and prospective customers, where permitted under POPIA, regarding MINT’s services, product updates, and relevant events. MINT does not sell, rent, or trade personal information for marketing purposes; and
7.1.8. Automated Decision-Making and Profiling: as further described in clause 16 of this Policy.
8.1. MINT processes personal information only where legally permissible under POPIA. The applicable legal bases are:
8.1.1. Performance of a contract or taking steps prior to entering into a contract: where processing is necessary to open or manage your MINT account, execute your Transactions, or provide the Services you have requested;
8.1.2. Compliance with legal obligations: where processing is required by POPIA, the FIC Act, the FAIS Act, the FSR Act, or any other applicable law, including obligations relating to AML/CTF/PF compliance, sanctions screening, tax reporting, and record-keeping;
8.1.3. Legitimate interests: where processing is necessary to pursue MINT’s legitimate business interests, including enhancing platform security, detecting and preventing fraud, improving MINT’s products and services, and operating the business efficiently, provided that such interests are not overridden by your rights and interests;
8.1.4. Consent: where you have provided explicit consent for specific processing activities. You may withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal; and
8.1.5. Public interest: where processing is required for purposes in the public interest, including the performance of financial sector regulatory functions.
9.1. MINT may disclose personal information to the following categories of recipients:
9.1.1. Service Providers and Operators: including cloud hosting vendors, identity verification providers, KYC and FICA service providers, blockchain analytics providers, payment processors, sanctions screening providers, analytics and diagnostics platforms, cybersecurity vendors, and IT support services. Where such parties process personal information on MINT’s behalf, they are Operators under POPIA and are required to process personal information only on MINT’s documented instructions;
9.1.2. Regulators and Authorities: where required by law, including the Information Regulator, FSCA, FIC, South African Revenue Service (“SARS”), South African Reserve Bank (“SARB”), or pursuant to a lawful order or directive;
9.1.3. Professional Advisers: including auditors, legal advisers, compliance consultants, and insurers engaged in connection with MINT’s business operations;
9.1.4. Corporate Transactions: in the context of mergers, acquisitions, restructuring, or business transfers, subject to appropriate confidentiality obligations and data protection safeguards; and
9.1.5. Counterparties: to the extent necessary to facilitate Transactions entered into through the platform, and subject to applicable data protection safeguards.
9.2. MINT requires all third parties to whom personal information is disclosed to maintain appropriate confidentiality and security safeguards. MINT does not sell, rent, or trade personal information to or with third parties for any commercial purpose.
10.1. MINT may transfer personal information to jurisdictions outside South Africa, including in connection with cloud infrastructure services, sanctions screening, identity verification, and analytics. Such transfers will occur only where the receiving jurisdiction provides an adequate level of protection as contemplated by POPIA, or where MINT has implemented appropriate contractual safeguards aligned with POPIA, such as binding operator agreements that impose equivalent data protection obligations on the recipient.
10.2. MINT ensures that Operators processing personal information internationally do so in accordance with binding written agreements that comply with POPIA’s requirements for cross-border transfers.
11.1. MINT implements appropriate, reasonable technical and organisational measures to safeguard personal information against loss, unauthorised access, destruction, modification, or unlawful processing. These measures include:
11.1.1. encryption of personal information in transit and at rest, where technically feasible;
11.1.2. multi-factor authentication for privileged access to systems containing personal information;
11.1.3. continuous monitoring and logging of access to personal information;
11.1.4. network and infrastructure security controls;
11.1.5. secure software development practices;
11.1.6. regular security testing, vulnerability scanning, and penetration testing;
11.1.7. strict role-based access controls limiting access to personal information to persons who require it for their specific functions; and
11.1.8. ongoing staff training on information security and data protection obligations.
11.2. No information security system is entirely secure. MINT does not guarantee absolute security against all cyber threats. You acknowledge this risk and are responsible for maintaining the security of your own Access Credentials.
11.3. Security Compromise Notification: where MINT reasonably believes that personal information has been accessed or acquired by an unauthorised person (a “Security Compromise”), MINT will:
11.3.1. take all reasonable steps to contain the compromise and prevent further unauthorised access;
11.3.2. notify the Information Regulator as soon as reasonably possible after becoming aware of the compromise, using the prescribed notification form;
11.3.3. notify affected data subjects as soon as reasonably possible where the compromise is likely to adversely affect them, unless the Information Regulator directs otherwise; and
11.3.4. document the compromise, the steps taken to contain it, and all notifications made, and review and update MINT’s security measures to address the cause.
MINT takes reasonable steps to ensure that personal information collected and processed is complete, accurate, not misleading, and up to date. You are encouraged to notify MINT promptly of any changes to your personal information by updating your account profile or contacting MINT’s Information Officer. MINT may periodically request updated information from you to maintain the accuracy of your records.
13.1. MINT retains personal information only for as long as is necessary to achieve the purpose for which it was collected, comply with applicable legal and regulatory obligations, fulfil contractual requirements, or protect MINT’s legitimate interests. The following minimum retention periods apply:
13.1.1. Customer identity and KYC/FICA documentation: at least five years from the termination of the customer relationship, as required by the FIC Act;
13.1.2. Transaction records: at least five years from the date of the relevant transaction, as required by the FIC Act;
13.1.3. Financial and accounting records: at least five years from the end of the relevant financial year, as required by the Companies Act 71 of 2008 and applicable SARS requirements;
13.1.4. POPIA-related documentation, including the PAIA manual, processing records, and consent records: retained indefinitely or until superseded;
13.1.5. Marketing consent records: for the duration of the consent plus three years;
13.1.6. Complaints records: at least three years from the date of resolution of the complaint, or five years for FAIS Complaints; and
13.1.7. Employee records: at least three years after termination of employment.
13.2. At the end of the applicable retention period, personal information is securely deleted, destroyed, or de-identified. Records may not be retained beyond the applicable period without a documented legal justification approved by the Information Officer.
MINT may process technical and aggregated data related to website and platform usage for purposes of analytics, security, and service improvement. MINT’s website may contain links to third-party websites or services. MINT is not responsible for the privacy practices of those third parties. You should review the privacy policies of any third-party websites you access through MINT’s website.
15.1. MINT uses Cookies and similar technologies for:
15.1.1. functionality: to enable core platform features and to remember your preferences;
15.1.2. analytics: to understand how users interact with MINT’s website and platform, so that MINT can improve its products and services;
15.1.3. security: to detect and prevent fraudulent or unauthorised activity; and
15.1.4. performance monitoring: to diagnose technical issues and optimise platform performance.
15.2. MINT’s website will display a Cookie consent notification where required by applicable law. You may manage your Cookie preferences through the Cookie settings interface or through your browser settings. Disabling certain Cookies may affect the functionality of MINT’s website or platform.
15.3. MINT does not use Cookies for targeted advertising or for sharing personal information with third-party advertisers without your consent.
16.1. MINT uses automated processing of personal information, including profiling, in connection with the following activities:
16.1.1. customer risk scoring and AML/CTF/PF risk classification, as required by the FIC Act and MINT’s internal compliance programme;
16.1.2. transaction monitoring and suspicious activity detection;
16.1.3. fraud prevention and identity verification; and
16.1.4. personalisation of platform features and communications.
16.2. Where MINT makes decisions that produce legal or similarly significant effects on you through automated processing alone, MINT will implement appropriate safeguards, including:
16.2.1. ensuring that the decision can be reviewed by a suitably qualified human upon your request;
16.2.2. providing you, upon request, with information about the logic involved in the automated processing and the significance of the processing for you; and
16.2.3. allowing you to contest the decision and request human intervention.
16.3. To request information about or a review of an automated decision affecting you, please contact the Information Officer at the contact details set out in clause 3.
17.1. In terms of POPIA, you have the following rights as a data subject. To exercise any of these rights, please contact MINT’s Information Officer at the contact details set out in clause 3.
17.1.1. Right of Access: you have the right to request confirmation of whether MINT holds personal information about you, and to request access to that personal information. Requests for access may be subject to certain fees and grounds for refusal as contemplated by POPIA and the Promotion of Access to Information Act 2 of 2000 (“PAIA”). MINT’s PAIA Manual sets out the procedure for submitting access requests and is available on request.
17.1.2. Right to Correction or Deletion: you have the right to request that MINT correct personal information that is inaccurate, irrelevant, excessive, out of date, incomplete, misleading, or obtained unlawfully, or that MINT delete personal information that MINT is no longer lawfully entitled to retain.
17.1.3. Right to Object: you have the right to object on reasonable grounds to MINT processing your personal information where the processing is not authorised by law or is not necessary for the fulfilment of a contract.
17.1.4. Right to Object to Direct Marketing: you have the right to object at any time, without giving reasons, to the processing of your personal information for purposes of direct marketing. MINT must comply with such an objection at no cost to you and must cease direct marketing communications immediately upon receipt of your objection.
17.1.5. Right to Withdraw Consent: where processing is based solely on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Withdrawal of consent may affect MINT’s ability to provide certain services to you.
17.1.6. Right to Lodge a Complaint: if you believe that MINT has processed your personal information in violation of POPIA, you have the right to lodge a complaint with the Information Regulator.
18.1. MINT may process personal information for direct marketing purposes in accordance with POPIA. MINT will only send marketing communications to you where you have opted in to receive such communications, or where you are an existing client and the communications relate to similar products or services to those already provided to you.
18.2. You may unsubscribe from marketing communications at any time by clicking the unsubscribe link in any marketing email, by updating your communication preferences in your account settings, or by contacting the Information Officer.
18.3. MINT does not share personal information with third parties for their direct marketing purposes without your explicit consent.
19.1. The Information Regulator of South Africa is responsible for monitoring and enforcing compliance with POPIA. If you have a complaint about how MINT has processed your personal information and you are not satisfied with MINT’s response, you may lodge a complaint with the Information Regulator:
19.1.1. Website: https://inforegulator.org.za;
19.1.2. Email: [email protected]; and
19.1.3. Telephone: 010 023 5207.
20.1. MINT may update this Policy from time to time to reflect changes in applicable law, regulatory requirements, MINT’s data processing activities, or changes to MINT’s products and services.
20.2. Where a material amendment is made to this Policy, MINT will notify you through the platform or by email to your registered email address and will publish the updated Policy on MINT’s website. The version with the most recent adoption date published on MINT’s website is the current version. Continued use of MINT’s services after the effective date of an amendment constitutes acceptance of the updated Policy.
20.3. This Policy must be reviewed by the Information Officer at least annually, and a reviewed and, where necessary, updated version must be presented to the Board for approval not later than twelve months after the date of the most recent Board approval.
Version 2.0 · Adopted March 2026 · Next review no later than March 2027
1.1. This Risk Disclosure and Risk Policy Suite ("Policy") forms part of MINT's Terms and Conditions and governs your access to and use of MINT's platform, products, and services ("Services"). By accessing or using the Services, you acknowledge that you have read, understood, and accepted the risks described in this Policy.
1.2. References to "MINT", "we", "us", or "our" mean MINT Platforms (Pty) Ltd (Registration Number 2024/644796/07) and, where applicable, its authorised affiliates and service providers involved in delivering the Services. References to "you" or "your" mean the user, client, customer, or Approved User of the Services.
1.3. You acknowledge that you access and use the Services at your own risk and that you remain responsible for your investment decisions, credit decisions, and transactional instructions, subject to any written advisory mandate expressly agreed with you.
1.4. This Policy must be read together with MINT's Terms and Conditions, Privacy Policy, Complaints Policy, and AML Policy, all of which are incorporated by reference.
2.1. MINT Platforms (Pty) Ltd operates as a regulated financial services business in South Africa and holds the following licences and registrations for the Services it provides:
2.1.1. Financial Services Provider (FSP) licence under the Financial Advisory and Intermediary Services Act 37 of 2002 ("FAIS Act"), FSP Licence Number 55118, authorising MINT to provide financial services in the following categories: Category I and Category II;
2.1.2. registration as an accountable institution under the Financial Intelligence Centre Act 38 of 2001 ("FIC Act");
2.1.3. registration as a Crypto-Asset Service Provider ("CASP") under the applicable FSCA Conduct Standard, CASP Registration Number 55118; and
2.1.4. registration as a credit provider under the National Credit Act 34 of 2005 ("NCA"), NCA Registration Number NCRCP22892, where MINT provides credit products.
2.2. Nothing on the platform constitutes an invitation to the public or a general solicitation to acquire securities or financial products where such invitation would require registration or an approved offer document in any jurisdiction.
2.3. Unless you have entered into a written advisory mandate with MINT, any information, tools, analytics, strategy descriptions, performance information, research, dashboards, risk indicators, or educational material provided on the platform is provided for information and execution enablement purposes only and does not constitute financial advice, a recommendation, or an opinion tailored to your personal circumstances. You remain responsible for determining suitability, affordability, and appropriateness and for seeking independent advice where appropriate.
2.4. Where risk profiling, disclosures, appropriateness checks, or suitability checks are required by law or by product design, you agree to provide complete and accurate information. You acknowledge that inaccurate or incomplete information may result in inappropriate outcomes for which MINT bears no responsibility.
2.5. Certain Services are delivered through third parties, including brokers, custodians, banks, payment service providers, data providers, and other financial institutions. Your use of those components may be subject to additional third-party terms, cut-off times, operational constraints, and regulatory requirements.
3.1. Investments can go down as well as up. You may lose some or all of the capital you invest, and you may not recover your initial investment. MINT does not guarantee returns, capital protection, liquidity, execution outcomes, pricing, credit approval, or the availability of any instrument, market, strategy, feature, or Service.
3.2. Past performance, back-tested performance, simulated performance, and model performance are not reliable indicators of future results. Back tests and simulations are inherently limited and may not reflect actual trading conditions, transaction costs, liquidity constraints, taxes, corporate actions, market impact, latency, partial fills, financing costs, or changes in market structure.
3.3. Where any product, strategy, or configuration introduces leverage, borrowing, or synthetic exposures, losses may be magnified and may exceed the user's initial investment or expectations. You must understand the leverage characteristics of any product before using it.
3.4. Where you gain exposure to foreign instruments or cross-border products, you may face additional risks including currency risk, jurisdictional risk, different settlement cycles, different investor protection regimes, withholding taxes, and market closure or public holiday mismatches.
4.1. MINT may make available strategies, model portfolios, curated allocations, or other investment approaches (each a "Strategy"). Strategies may be discretionary or non-discretionary, may be implemented through periodic rebalancing, and may involve exposures to one or more asset classes, sectors, geographies, factors, or instruments.
4.2. Each Strategy carries risks including market risk, volatility risk, concentration risk, sector risk, style risk, factor rotation risk, drawdown risk, liquidity risk, correlation risk, tail risk, event risk, and regime change risk. Strategies may underperform benchmarks, peers, or cash for extended periods, including during prolonged drawdowns.
4.3. Strategy methodologies, signals, assumptions, parameters, data inputs, optimisation techniques, and portfolio construction rules may be imperfect, may degrade over time, and may fail under certain market conditions. Model risk includes overfitting, survivorship bias, look-ahead bias, data errors, sampling errors, parameter instability, false positives, signal decay, and structural market changes.
4.4. Strategies may require rebalancing or frequent trading. High turnover can increase transaction costs, slippage, and tax consequences and can reduce or eliminate expected returns. Portfolio drift may occur between rebalance events.
4.5. MINT may amend Strategy methodologies, constituents, eligible instruments, risk limits, rebalancing rules, execution methods, or other features to improve risk management, comply with law, respond to market conditions, or meet operational requirements. Changes may alter Strategy risk and return outcomes.
4.6. MINT may suspend subscriptions, redemptions, allocations, switching, rebalancing, withdrawals, or other functionality relating to a Strategy where necessary for risk control, market integrity, liquidity management, operational stability, or regulatory directives. You acknowledge that suspensions may occur without prior notice where required by law, market rules, or risk management.
5.1. Where you choose instruments, construct portfolios, set allocations, configure rules, select strategies, or adjust parameters, you do so at your own risk. MINT is not responsible for losses arising from your choices unless expressly required by law or agreed under a written advisory mandate.
5.2. Self-directed investment decisions may expose you to concentration, leverage, liquidity, correlation, and behavioural risks. You should not implement strategies you do not understand, including short-term, intraday, highly concentrated, or leveraged approaches.
5.3. You are responsible for assessing suitability, risk appetite, time horizon, liquidity needs, affordability, and your ability to absorb losses. You acknowledge that investing while carrying high-cost debt or having insufficient emergency liquidity may increase financial vulnerability.
5.4. If you use any automation features, triggers, recurring allocations, rebalancing rules, or pre-set instructions, you acknowledge that markets may change and that automated instructions may execute at adverse times or prices. You are responsible for monitoring and updating any user-configured automations.
6.1. Markets move continuously. The price you see when you place an order may not be the price at which your order is executed. Prices may move materially between order placement, batching, routing to a broker or execution venue, and execution.
6.2. MINT may batch, aggregate, or net orders across users, strategies, or accounts for operational efficiency, reduced costs, best execution, reduced market impact, or improved fairness. Batching may result in execution at a blended price (including volume-weighted average price), partial fills, delayed fills, or different execution outcomes compared to an individual order executed immediately.
6.3. Your execution price may be adversely affected by slippage, bid-ask spreads, volatility, order book depth, liquidity conditions, market impact, adverse selection, latency, and broker execution algorithms. Slippage can be significant during market stress, auctions, open and close periods, low-liquidity periods, or following news events.
6.4. Market orders may execute at prices substantially different from the last traded or indicative price. Limit orders may not execute. Stop orders may trigger at unfavourable levels and may execute at worse prices in fast markets.
6.5. Orders may be partially executed or not executed at all. Orders may be cancelled, rejected, or amended due to exchange rules, broker controls, compliance controls, risk limits, insufficient funds, corporate actions, instrument halts, erroneous prices, volatility interruptions, or technical reasons.
6.6. Trading in instruments may be halted, suspended, or subjected to volatility interruptions by an exchange, broker, or regulator. During such periods, orders may not execute, and prices may gap materially when trading resumes.
6.7. Where best execution obligations apply, MINT and its execution partners will implement policies and procedures aimed at achieving best execution having regard to price, costs, speed, likelihood of execution and settlement, size and nature of the order, market impact, and other relevant factors. Best execution is not a guarantee of the best possible price in every circumstance.
6.8. Prices displayed may be delayed, indicative, or derived from third-party data sources. Such prices are not guaranteed to be accurate, complete, or suitable for trading decisions.
7.1. Trades settle according to the relevant market settlement cycle. You may not be able to withdraw proceeds, transfer securities, or reuse buying power until settlement is complete and reconciled.
7.2. Settlement may fail due to insufficient securities or cash, corporate actions, restrictions, incorrect instructions, third-party delays, system outages, sanctions screening, banking delays, or other operational issues. Failed settlement can result in penalties, forced buy-ins, delayed ownership transfer, opportunity loss, and additional costs.
7.3. Clearing houses, settlement systems, custodians, brokers, banks, and payment systems are subject to operational and credit risk. Failures can occur and may impact your ability to trade or access assets.
7.4. Withdrawals, transfers, and availability of funds are subject to settlement finality, reconciliation completion, and operational cut-off times. MINT may delay availability to manage settlement and fraud risk.
8.1. Securities may be held in a nominee or custody structure, meaning legal title is held by a nominee entity or custodian while you remain the beneficial owner. Your rights as beneficial owner are exercised through the nominee and are subject to nominee and custodian operational processes and applicable market rules.
8.2. MINT maintains internal records reflecting beneficial ownership, allocations, entitlements, and transaction history. These records must reconcile to broker, custodian, and settlement statements. While MINT implements controls, errors can occur and corrections may be required.
8.3. Where beneficial owner nominee breakdowns or related disclosures are required by market infrastructure participants, regulators, custodians, or issuers, such reporting may be point in time and may reflect holdings and entitlements as at a specific date and time. Intraday trading, batching, and settlement cycles can cause differences between internal positions, executed trades, and settled positions at any moment.
8.4. Entitlements such as dividends, distributions, rights issues, elections, and corporate action participation are determined by record dates and positions held in the nominee at the relevant times. Trading close to record dates may affect entitlements. Processing delays can occur and elections are subject to cut-off times.
8.5. Custody and nominee structures are designed to segregate client assets. However, insolvency of a third party including a broker, custodian, bank, or nominee may result in delays, legal proceedings, administrative processes, restrictions on access, or costs associated with recovery and reconciliation.
8.6. Transfers in and out of the nominee may be restricted or delayed due to market rules, AML screening, sanctions checks, regulatory requirements, reconciliation cycles, or operational constraints.
8.7. MINT may be required to produce audit trails, beneficial ownership registers, or transaction records to brokers, custodians, regulators, Strate, the JSE, issuers, or their agents in accordance with applicable rules and lawful requests.
9.1. Portfolio valuations may rely on last traded prices, bid prices, mid prices, model prices, fair value adjustments, or other methodologies depending on instrument type and market conditions. Valuations may differ from realisable prices.
9.2. Data, charts, analytics, risk metrics, and performance measures may contain errors due to third-party feeds, corporate action processing, instrument mapping, identifier errors, stale data, or calculation assumptions. MINT may correct errors when identified, and such corrections may affect displayed performance and historical metrics.
9.3. Performance calculations may exclude or include certain costs, taxes, or timing assumptions. You should review the disclosure of the calculation methodology where provided.
10.1. Fees, transaction charges, spreads, financing costs, custody costs, taxes, and levies reduce returns. Certain costs vary with market conditions, volatility, liquidity, routing, and order types. The full cost of using MINT's Services is set out in MINT's fee schedule, which is published on the platform.
10.2. Tax treatment depends on your personal circumstances, holding period, instrument type, and applicable law. MINT does not provide tax advice unless expressly mandated. You are responsible for obtaining independent tax advice and for meeting all of your tax obligations, including obligations arising from the acquisition, disposal, and holding of digital assets.
11.1. Private and alternative opportunities may be illiquid and may involve lock-up periods, gating, limited redemption windows, or transfer restrictions. You may not be able to exit when desired.
11.2. Private assets may be valued infrequently and valuations may be subjective. Reported valuations may not reflect realisable values.
11.3. Private opportunities may expose you to issuer risk, manager risk, documentation risk, governance risk, jurisdictional risk, and enforcement risk.
11.4. Certain private opportunities may be available only to qualifying investors under applicable law or platform rules. You are responsible for providing accurate information and acknowledging relevant risk disclosures before accessing such opportunities.
11.5. If and when the platform provides access to alternative assets such as art, collectables, or similar instruments, additional risks may include illiquidity, storage and insurance risk, authenticity and provenance risk, valuation subjectivity, specialist market dependency, fraud risk, and higher transaction and custody costs.
12.1. MINT is registered as a CASP under the applicable FSCA Conduct Standard. The following disclosures apply to MINT's current crypto-asset services. Additional product-specific disclosures are available on the platform.
12.2. Crypto-assets are not legal tender in the Republic of South Africa and are not backed, guaranteed, or insured by any governmental authority, central bank, or regulatory body. Their value is highly volatile and may fluctuate significantly over short periods. Transactions involving crypto-assets may result in substantial financial loss.
12.3. Crypto-asset transactions are generally irreversible once broadcast to and confirmed by the relevant blockchain network. Errors in wallet addresses or instructions may lead to permanent and irrecoverable loss. You are solely responsible for verifying all transaction details before submitting any instruction.
12.4. Crypto-asset services may rely on third-party exchanges, wallets, custodians, market makers, blockchain analytics providers, and other service providers. Failures or insolvencies of those providers can impact access and liquidity.
12.5. The regulatory framework governing crypto-assets in South Africa and internationally is evolving rapidly. Changes in law, regulation, regulatory interpretation, or enforcement practice may adversely affect the availability, legality, or functionality of MINT's crypto-asset services with little or no prior notice.
12.6. Additional crypto-asset-specific risks include extreme volatility; market manipulation risk; protocol risk, including software bugs and hard forks; network congestion and failed transactions; smart contract risk; liquidity fragmentation; and the risk of loss arising from hacking, phishing, SIM-swap attacks, or other cybersecurity incidents.
13.1. Payment, wallet, and card functionality may rely on banks, payment service providers, card schemes, processors, and other third parties. Delays, outages, reversals, chargebacks, failed payments, settlement timing differences, and disputes may occur.
13.2. Transfers and withdrawals are subject to cut-off times, bank processing windows, verification requirements, and compliance screening. Funds may be delayed or held pending verification.
13.3. Certain payment types may be reversible or subject to disputes while others may not. MINT may be required to reverse or withhold funds in accordance with applicable law, scheme rules, bank rules, or court orders.
13.4. You are responsible for safeguarding your credentials and devices. If your account is compromised due to your negligence, social engineering, phishing, SIM swap, malware, or unauthorised access, you may suffer losses. MINT will implement reasonable security measures but cannot eliminate cyber risk.
13.5. MINT is required to comply with the FIC Act and related AML/CTF/PF and sanctions screening obligations. MINT may delay, block, reverse, freeze, restrict, or report transactions where required by law or where suspicious activity is detected, without prior notice where doing so would be unlawful.
13.6. MINT may place holds on accounts or transactions to conduct identity verification, source of funds checks, fraud checks, sanctions screening, dispute handling, or regulatory reporting. You acknowledge that such holds may temporarily restrict your access to funds.
14.1. Any credit offered or facilitated through the platform is subject to affordability assessment, credit policy, verification, and compliance with the NCA and related regulations. Approval is not guaranteed.
14.2. Credit may attract interest, initiation fees, service fees, default interest, collection costs, and legal costs as permitted by law and contract. The total cost of credit may be significant. MINT is required by law to provide you with a pre-agreement statement and quotation before any credit agreement is concluded.
14.3. If you miss payments or default, MINT may take steps including reporting to credit bureaux, restricting platform access, suspending withdrawals, enforcing security, instituting collection action, and taking legal steps, subject to the NCA and due process.
14.4. If credit is secured against your investments or other collateral, market declines may reduce collateral value and may trigger margin calls, top-up requirements, additional security requirements, or forced liquidation to protect the credit exposure. Forced liquidation may occur at unfavourable prices during market stress and may crystallise losses. You remain liable for any shortfall after liquidation.
14.5. Interest rates may be variable and may change due to reference rate changes, risk adjustments, or contractual repricing mechanisms. Your repayments may increase.
14.6. Where applicable, loan performance and credit events may be reported to credit bureaux in accordance with the NCA and applicable industry standards. Disputes may be raised through prescribed dispute resolution processes.
14.7. Where credit is provided by third parties using MINT's infrastructure, additional terms may apply and responsibility for lending decisions, pricing, statements, enforcement, and reporting may rest with the credit provider of record. MINT may act as a platform and servicing provider only, depending on the arrangement.
15.1. The Services may be unavailable due to scheduled or unscheduled maintenance, upgrades, third-party outages, infrastructure failures, cyber incidents, or force majeure events. MINT will use reasonable efforts to provide advance notice of scheduled maintenance and to restore service as promptly as possible following unscheduled outages.
15.2. The Services may depend on external APIs and data feeds. If such integrations fail or degrade, functionality may be impaired. MINT is not responsible for failures attributable to third-party infrastructure outside MINT's reasonable control.
15.3. Operational processes involve manual and automated steps. Errors may occur. MINT maintains internal controls and reconciliation processes but cannot eliminate operational risk entirely.
15.4. Regulatory change may require modification, suspension, or withdrawal of features, products, or markets. MINT may implement changes to comply with regulatory directives and is not liable for losses arising from regulatory-compelled changes.
16.1. You should not rely solely on platform information, marketing materials, dashboards, or illustrative examples when making financial decisions. You are responsible for independently verifying all information and obtaining professional advice where appropriate.
16.2. To the maximum extent permitted by law, MINT will not be liable for losses arising from market movements, execution outcomes, slippage, liquidity constraints, third-party failures, system outages, delays, pricing errors, corporate action processing, settlement failures, or indirect or consequential losses, except to the extent caused by MINT's gross negligence, wilful misconduct, or as otherwise required by applicable law.
16.3. MINT is not responsible for losses resulting from incorrect instructions provided by you, including incorrect beneficiary details, banking details, instrument selection, order parameters, or timing.
16.4. Nothing in this Policy limits or excludes any right, remedy, guarantee, or warranty that cannot lawfully be excluded under the Consumer Protection Act 68 of 2008 or any other applicable legislation to the extent that you qualify as a consumer for purposes of that legislation.
17.1. MINT maintains a formal enterprise risk management framework ("ERMF") that governs the identification, assessment, monitoring, control, and reporting of material risks across MINT's operations. The ERMF is overseen by the Board of Directors, which retains ultimate accountability for MINT's risk appetite and risk tolerance.
17.2. The Board has constituted a Risk and Compliance Committee ("RCC") responsible for reviewing and approving MINT's risk appetite statement at least annually; receiving and reviewing risk and compliance reports from the Compliance Officer and any internal audit function on at least a quarterly basis; overseeing MINT's compliance with applicable regulatory capital and financial soundness requirements; approving material changes to MINT's risk management policies and frameworks; and escalating material risk matters to the full Board.
17.3. MINT's risk appetite statement, risk register, and risk reporting framework are documented in MINT's Internal Risk Policy, which is approved by the Board and reviewed at least annually. The Internal Risk Policy is available to the RCC and to regulatory authorities on request.
17.4. MINT maintains professional indemnity and fidelity guarantee insurance cover as required by the FAIS Act and the applicable Board Notice. Details of this cover are available to clients on request from the Compliance Officer.
17.5. MINT's Conflict of Interest Management Policy governs the identification, disclosure, and management of conflicts of interest between MINT, its employees, and its clients. A summary of the Conflict of Interest Management Policy is available on the platform.
18.1. MINT maintains a Business Continuity Plan ("BCP") and a Disaster Recovery Plan ("DRP") designed to ensure the continued availability of critical platform services and the protection of client assets and data in the event of a material operational disruption. MINT conducts BCP and DRP testing at least annually and following any material change to MINT's technology infrastructure.
18.2. In the event of a material platform outage or operational disruption that affects client access to their accounts, funds, or assets, MINT will publish a service status notification on MINT's website and platform as soon as reasonably practicable, communicate the expected resolution timeline to affected clients as soon as this information is available, and take all reasonable steps to restore normal service promptly.
18.3. MINT's liability for losses arising from platform unavailability is governed by MINT's Terms and Conditions.
MINT will review this Policy at least annually and will update it to reflect changes in law, regulation, market infrastructure, risk practices, or Services. Where a material amendment adversely affects your rights or materially increases the risks to which you are exposed, MINT will provide not less than twenty-one calendar days' advance notice of the change. The effective date of any amendment will be stated on the updated Policy. Continued use of the Services after the effective date of any amendment constitutes acceptance of the updated Policy.
Version 2.0 · Adopted March 2026 · Next review no later than March 2027
1.1. MINT Platforms (Pty) Ltd ("MINT") is a South African fintech business that operates a regulated, technology-enabled investment and digital assets platform. MINT is authorised as a Financial Services Provider under the Financial Advisory and Intermediary Services Act 37 of 2002 and is registered as an accountable institution under the Financial Intelligence Centre Act 38 of 2001 ("FIC Act") and as a Crypto-Asset Service Provider under the applicable Financial Sector Conduct Authority Conduct Standard.
1.2. This Public Statement on Anti-Money Laundering, Counter-Terrorist Financing and Proliferation Financing ("Statement") is issued by the Board of Directors of MINT to communicate MINT's approach, commitments, and obligations in relation to the prevention of money laundering, terrorist financing, and proliferation financing (collectively "ML/TF/PF") to its customers, counterparties, regulators, investors, and the public.
1.3. This Statement is issued in accordance with MINT's obligations as a regulated financial services business and reflects MINT's policy position as at June 2026. It should be read together with MINT's Terms and Conditions, Privacy Policy, and Complaints Policy, all of which are available at www.mymint.co.za.
MINT's AML/CTF/PF framework is governed by, and must be read in the context of, the following principal legislation, regulatory instruments, and international standards:
2.1. The FIC Act and all regulations, directives, guidance notes, and public compliance communications issued thereunder. The FIC Act is the primary South African statute governing the obligations of accountable institutions in relation to ML/TF/PF. MINT is registered with the Financial Intelligence Centre ("FIC") as an accountable institution under the applicable category of Schedule 1 to the FIC Act.
2.2. The Financial Intelligence Centre Amendment Act 1 of 2017, which introduced a risk-based approach to compliance as the governing framework for accountable institutions in South Africa.
2.3. Guidance Note 7A issued by the FIC, which provides the definitive regulatory guidance on the risk-based approach to combating ML/TF/PF and which informs the structure and calibration of MINT's internal compliance programme.
2.4. The Financial Advisory and Intermediary Services Act 37 of 2002 ("FAIS Act") and the General Code of Conduct for Authorised Financial Services Providers and Representatives, under which MINT holds FSP Licence Number 55118.
2.5. The Financial Sector Regulation Act 9 of 2017 ("FSR Act") and any Conduct Standards and directives issued by the Financial Sector Conduct Authority ("FSCA") applicable to MINT's regulated activities, including its crypto-asset services.
2.6. The Protection of Constitutional Democracy against Terrorist and Related Activities Act 33 of 2004 ("POCDATARA") and the Charter of the United Nations Act 69 of 1962, which domesticate the United Nations Security Council Resolutions on targeted financial sanctions and proliferation financing into South African law.
2.7. The Currency and Exchanges Act 9 of 1933 and the Exchange Control Regulations published thereunder, which govern cross-border flows of funds and crypto-assets involving South African resident customers.
2.8. The standards and recommendations of the Financial Action Task Force ("FATF"), of which South Africa is a member. MINT's compliance programme is calibrated to meet FATF standards in addition to domestic legal requirements.
2.9. The Protection of Personal Information Act 4 of 2013 ("POPIA"), which governs the processing of personal information collected by MINT in the course of performing its AML/CTF/PF obligations.
MINT's AML/CTF/PF framework is founded on the following nine commitments, each of which reflects a specific obligation under the FIC Act and applicable regulatory standards. Together, these commitments constitute MINT's public undertaking to its customers, regulators, and the South African financial system:
3.1. MINT maintains a zero-tolerance position toward money laundering, terrorist financing, and proliferation financing across all products, services, and markets in which it operates. No commercial consideration justifies the facilitation of financial crime, and MINT's internal policies, systems, and training programmes are designed to give effect to this position without exception.
3.2. MINT applies a formal risk-based framework calibrated to the specific ML/TF/PF risks presented by its customers, products, delivery channels, and geographic exposure, in accordance with the FIC Act and FATF standards. Controls are applied in proportion to the level of risk identified and are not applied uniformly regardless of risk.
3.3. MINT verifies the identity of every customer before establishing any business relationship or processing any transaction. Verification covers identity, residential address, source of funds, and, where applicable, beneficial ownership. Ongoing monitoring ensures that customer profiles remain current and accurate throughout the duration of the relationship.
3.4. MINT continuously monitors all transactions for indicators of suspicious activity, including unusual patterns, high-risk flows, and behaviours inconsistent with a customer's known profile and stated purpose of the relationship. Automated monitoring systems generate alerts that are reviewed by MINT's compliance function.
3.5. MINT screens all customers, beneficial owners, and counterparties against applicable targeted financial sanctions lists on an ongoing basis, including United Nations Security Council designations, domestic FIC lists, and other applicable international lists. No transaction is processed with or for a designated person or entity.
3.6. MINT files all required reports with the Financial Intelligence Centre, including suspicious transaction reports, unusual transaction reports, cash threshold reports, and terrorist property reports, within the timeframes prescribed by the FIC Act. Reporting is overseen by the Compliance Officer.
3.7. MINT retains customer due diligence records and transaction records for a minimum of five years from the termination of the relationship or the date of the transaction, in compliance with sections 22 and 23 of the FIC Act. All records are stored securely in a manner that permits timely retrieval by regulatory authorities on request.
3.8. All MINT employees, officers, and agents receive mandatory AML/CTF/PF training at onboarding and at least annually thereafter. Training covers the applicable regulatory framework, red-flag indicators, internal reporting obligations, the tipping-off prohibition, and the personal legal consequences of non-compliance.
3.9. MINT's Board of Directors retains ultimate accountability for the AML/CTF/PF framework. The Board-appointed Risk and Compliance Committee provides ongoing oversight and receives quarterly compliance reports from the Compliance Officer. An independent audit of the AML/CTF/PF framework is conducted at least annually.
MINT has established a governance structure that ensures clear accountability for AML/CTF/PF compliance at every level of the organisation:
4.1. The Board of Directors of MINT bears ultimate responsibility for ensuring that MINT maintains an effective AML/CTF/PF compliance framework. The Board approves MINT's Risk Management and Compliance Programme ("RMCP"), applies its mind to the adequacy of the RMCP at least annually, and satisfies itself that sufficient resources, systems, and controls are in place to implement the RMCP effectively. This responsibility cannot be delegated away.
4.2. The Board has constituted a Risk and Compliance Committee ("RCC") as a Board sub-committee. The RCC receives quarterly AML/CTF/PF compliance reports from the Compliance Officer, oversees the adequacy and effectiveness of MINT's compliance framework, reviews the findings of internal and external audits, and escalates material compliance matters to the full Board.
4.3. MINT has appointed a suitably qualified and senior-level Compliance Officer in terms of section 43A of the FIC Act. The Compliance Officer's appointment is registered with the FIC. The Compliance Officer is responsible for the design, implementation, maintenance, and continuous improvement of MINT's AML/CTF/PF framework, for the filing of all required reports with the FIC, and for reporting to the RCC and the Board on all compliance matters. The Compliance Officer's reporting line is independent of MINT's operational and commercial functions.
4.4. MINT has appointed a Deputy Compliance Officer to act in the absence or incapacity of the Compliance Officer, ensuring continuity of the AML/CTF/PF function at all times.
4.5. MINT arranges for an independent review or audit of its AML/CTF/PF framework at least annually. The findings of each review are reported to the RCC and the Board, and all deficiencies identified are remediated within agreed timeframes under the oversight of the RCC.
MINT adopts a risk-based approach to AML/CTF/PF compliance as required by section 42 of the FIC Act and the FIC's Guidance Note 7A. Under this approach, MINT's compliance measures are calibrated to the specific ML/TF/PF risks presented by its business rather than applied uniformly across all customers and transactions:
5.1. MINT conducts a formal institutional ML/TF/PF risk assessment that identifies and assesses the inherent risks to which MINT is exposed across five dimensions: customer risk, product and service risk, delivery channel risk, geographic risk, and emerging risk typologies. The risk assessment is reviewed and updated at least annually and whenever a material change in MINT's business model, product offering, or risk environment occurs. The institutional risk assessment is approved by the Board.
5.2. MINT applies a documented Customer Risk Scoring Model to every customer at onboarding and on an ongoing basis throughout the relationship. The model assigns a risk score based on a weighted assessment of customer type, jurisdiction, product usage, transaction patterns, source of funds plausibility, delivery channel, and the results of screening processes. Each customer is classified as Low, Medium, or High risk. The risk classification determines the applicable level of customer due diligence, the frequency of ongoing monitoring, and applicable transaction limits.
5.3. Compliance resources and controls are applied in proportion to assessed risk. Low-risk customers are subject to simplified due diligence measures. Customers assessed at standard risk are subject to full customer due diligence. High-risk customers, including all politically exposed persons and their associates, are subject to enhanced due diligence, senior management approval, and more frequent review.
5.4. MINT treats proliferation financing as a distinct risk category requiring specific assessment and controls, separate from money laundering and terrorist financing. MINT's institutional risk assessment includes a standalone proliferation financing component. Screening against all applicable targeted financial sanctions lists extends to proliferation-related designations under the UNSC Resolutions and POCDATARA.
MINT applies a comprehensive customer due diligence framework in accordance with sections 21 to 21E of the FIC Act. The purpose of customer due diligence is to establish and verify the identity of customers and their beneficial owners before a business relationship is established or a transaction is processed, and to maintain a current and accurate understanding of the customer relationship throughout its duration:
6.1. Every customer must be identified and verified before MINT establishes a business relationship or processes any transaction. For individual customers, MINT collects and verifies full legal name, date of birth, identity number or passport number, nationality, and residential address, using reliable and independent sources including, where available, electronic verification against the Department of Home Affairs National Population Register. For juristic entity customers, MINT verifies the entity's registration details, constitutional documents, directorship, and beneficial ownership structure.
6.2. MINT identifies and verifies the natural persons who ultimately own or control every juristic entity, trust, and partnership customer. MINT does not rely solely on a fixed percentage ownership threshold for this purpose. Any natural person who exercises effective control over an entity through ownership, voting rights, contractual arrangements, or other means must be identified as a beneficial owner, regardless of the size of their interest in the entity.
6.3. All individual customers and the beneficial owners of all juristic entity customers are screened against MINT's politically exposed persons ("PEP") database at onboarding and on a continuous basis throughout the relationship. Every PEP relationship is subject to enhanced due diligence, including verification of source of funds and source of wealth, senior management approval before the relationship is established or continued, and more frequent review. No PEP relationship may be established without the approval of the Compliance Officer and a member of MINT's Executive Committee.
6.4. MINT monitors all customer relationships and transactions continuously throughout the duration of the relationship. Monitoring encompasses transaction volumes, values, frequencies, geographic counterparties, and consistency with the customer's known profile, stated purpose, and source of funds. Customer risk classifications are reviewed periodically and updated where circumstances change or where monitoring identifies indicators of heightened risk.
6.5. Where MINT is unable to complete the required identification and verification steps, or where information provided by a customer is false, misleading, or incapable of verification, MINT will decline to establish the business relationship or will terminate an existing relationship in accordance with section 21E of the FIC Act. MINT will not process any further transactions through the relevant account and will assess whether the circumstances give rise to a reportable suspicion.
7.1. MINT operates automated transaction monitoring systems that analyse transaction volumes, values, frequencies, and counterparty geographies against defined risk thresholds and alert parameters. All alerts generated by MINT's monitoring systems are reviewed by MINT's compliance function and escalated to the Compliance Officer where required. Transaction monitoring parameters are reviewed and updated at least annually in line with MINT's institutional risk assessment and current ML/TF/PF typologies.
7.2. MINT screens all customers, beneficial owners, directors, and counterparties against the following sanctions lists at onboarding and on a continuous basis throughout the relationship:
7.2.1. the targeted financial sanctions lists published by the United Nations Security Council pursuant to the Charter of the United Nations Act 69 of 1962;
7.2.2. the domestic targeted financial sanctions lists published by the FIC pursuant to section 26A of the FIC Act;
7.2.3. the OFAC Specially Designated Nationals and Blocked Persons List and the EU Consolidated Financial Sanctions List, to the extent that MINT has exposure to relevant jurisdictions; and
7.2.4. such other lists as may be required by applicable law or as directed by the FIC or FSCA from time to time.
7.3. Where a sanctions screening match is confirmed, MINT will immediately freeze all funds and assets associated with the relevant customer, file the required report with the FIC, and notify the relevant competent authority, all in accordance with the FIC Act and POCDATARA. MINT will not process any transaction that would result in a payment to or from a designated person or entity.
7.4. Given the heightened ML/TF/PF risks presented by crypto-asset transactions, MINT applies enhanced controls to all crypto-asset activities. These include blockchain analytics screening of transaction flows and wallet addresses, risk assessment of external wallet addresses before transfers are permitted, transaction monitoring calibrated to crypto-asset-specific typologies including mixer and tumbler detection, and compliance with the FATF Travel Rule requirements for virtual asset transfers above the applicable reporting threshold.
MINT is subject to the following reporting obligations under the FIC Act and discharges each of them in accordance with the prescribed requirements:
8.1. MINT files a Suspicious Transaction Report ("STR") with the FIC in terms of section 29 of the FIC Act whenever MINT knows or suspects, or has reasonable grounds to know or suspect, that funds involved in a transaction represent the proceeds of unlawful activities, are connected to terrorist financing or proliferation financing, or where information becomes available in the course of MINT's business that may be relevant to an investigation of an unlawful activity.
8.2. MINT files an Unusual Transaction Report ("UTR") with the FIC in terms of section 28A of the FIC Act in respect of transactions that are unusual or appear to have no apparent business or lawful purpose, even in the absence of a specific suspicion of ML/TF/PF.
8.3. MINT files Cash Threshold Reports ("CTRs") with the FIC in terms of section 28 of the FIC Act in respect of all cash transactions above the prescribed reporting threshold.
8.4. MINT files Terrorist Property Reports ("TPRs") with the FIC in terms of section 28A of the FIC Act whenever MINT knows or suspects that it has possession or control of funds or property owned or controlled by, or on behalf of, a person involved in terrorist activities or proliferation financing.
8.5. MINT strictly observes the tipping-off prohibition under section 29(2) of the FIC Act. No employee, officer, director, contractor, or agent of MINT may disclose to any person that a report has been, is being, or will be submitted to the FIC, or that a person is the subject of any such report. Violation of this prohibition constitutes a criminal offence under the FIC Act.
9.1. MINT implements controls to ensure that all cross-border transfers of funds and crypto-assets comply with the Currency and Exchanges Act 9 of 1933 and the Exchange Control Regulations published thereunder. Before facilitating any cross-border transfer or externalisation of funds for a South African resident customer, MINT verifies the applicable exchange control allowance available to that customer, including the Single Discretionary Allowance and the Foreign Investment Allowance, and applies system controls that prevent a transfer from being processed where it would cause a customer to exceed their available allowance without South African Reserve Bank approval.
9.2. All cross-border transfers and crypto-asset externalisation transactions are logged in MINT's cross-border transfer register, which records the customer's identity, the amount, the currency, the destination, the date, the exchange control category applied, and the outcome of MINT's AML/CTF/PF risk review. This register is available to the South African Reserve Bank, FSCA, and FIC on request.
MINT's AML/CTF/PF framework places certain obligations on customers. By opening an account with MINT and using MINT's Services, every customer acknowledges and agrees to the following:
10.1. You must provide accurate, complete, and current information at all times. This includes identity information, proof of residential address, declarations regarding source of funds and source of wealth, and beneficial ownership information. You must promptly notify MINT of any change in your personal or business circumstances that may affect your identity, risk profile, or eligibility to use MINT's Services.
10.2. MINT may at any time request additional documentation or information from you in connection with its customer due diligence, enhanced due diligence, or ongoing monitoring obligations. You must respond to such requests within the timeframe specified by MINT. Failure to respond may result in MINT restricting, suspending, or terminating your account.
10.3. You may not use MINT's platform, directly or indirectly, to launder money, finance terrorism or proliferation financing, evade sanctions, or engage in any other activity that contravenes applicable AML/CTF/PF legislation. MINT reserves the right to restrict, suspend, or terminate any account where prohibited use is detected or reasonably suspected.
10.4. South African resident customers are responsible for ensuring that their use of MINT's Services complies with applicable exchange control requirements. MINT's system controls assist customers in tracking their allowance utilisation but do not substitute for each customer's personal obligation to comply with the Currency and Exchanges Act and the Exchange Control Regulations.
10.5. Where a customer becomes aware of information that may indicate that funds involved in a transaction are connected to unlawful activity, the customer should not process the transaction and should contact MINT's Compliance Officer immediately at [email protected].
MINT takes non-compliance with its AML/CTF/PF obligations seriously and will take decisive action in all cases where a breach is detected or reasonably suspected:
11.1. Where a customer is found to be in breach of MINT's AML/CTF/PF requirements, to have provided false or misleading information, to be the subject of a sanctions designation, or to be using MINT's platform for prohibited purposes, MINT will, without prior notice where required by law or risk management, restrict, suspend, or terminate the account; freeze or block funds and assets in the account; decline to process any transaction; and report the matter to the FIC, FSCA, and other competent authorities as required by applicable law.
11.2. Any employee, officer, director, contractor, or agent of MINT who fails to comply with MINT's AML/CTF/PF framework is subject to disciplinary action up to and including summary dismissal. Violations that constitute criminal offences under the FIC Act or other applicable legislation are reported to the relevant law enforcement and regulatory authorities.
11.3. Non-compliance with the FIC Act may expose MINT as an institution to administrative sanctions under Chapter 7 of the FIC Act, including fines of up to the greater of R10 million or ten per cent of MINT's annual turnover, debarment or suspension of operations, and criminal prosecution of directors, officers, and employees. MINT's AML/CTF/PF framework is designed to ensure that MINT meets its obligations and avoids these outcomes.
12.1. MINT processes personal information collected in the course of its AML/CTF/PF activities strictly in accordance with POPIA and MINT's Privacy Policy. The processing of personal information for AML/CTF/PF purposes is necessary for MINT to comply with its legal obligations under the FIC Act and applicable financial services legislation. MINT minimises the personal information collected to that which is strictly necessary for compliance purposes, implements appropriate technical and organisational security measures to protect that information, and retains it only for the periods required by law.
12.2. Where MINT is required by law to disclose personal information to the FIC, FSCA, SARB, SARS, or other regulatory or law enforcement authorities, it does so in accordance with applicable law. MINT does not disclose personal information collected for AML/CTF/PF purposes to third parties for commercial purposes.
12.3. Data subjects have rights of access, correction, objection, and complaint under POPIA. These rights may be exercised by contacting MINT's Information Officer at [email protected]. Complaints regarding MINT's data processing activities may be referred to the Information Regulator of South Africa at www.inforegulator.org.za.
Customers, counterparties, and other stakeholders who have questions about this Statement or about MINT's AML/CTF/PF obligations and practices are welcome to contact MINT's Legal, Risk and Compliance function using the following contact details:
13.1. Compliance Officer: Kevin Pillay.
13.2. Email: [email protected].
13.3. Telephone: +27 (10) 276-0531.
13.4. Physical Address: 3 Gwen Lane, Sandown, Sandton, 2031.
13.5. Website: www.mymint.co.za.
13.6. If you have information that may indicate that funds on MINT's platform are connected to money laundering, terrorist financing, proliferation financing, or other unlawful activity, please contact the Compliance Officer immediately at [email protected] or call +27 (10) 276-0531. You may also report directly to the Financial Intelligence Centre at www.fic.gov.za.
This Statement will be reviewed by MINT's Compliance Officer at least annually and updated to reflect material changes in applicable law, regulatory requirements, MINT's risk profile, or MINT's business model. Material amendments are approved by the Board of Directors. The current version of this Statement is published on MINT's website at www.mymint.co.za and constitutes the authoritative version.
Version 2.0 · Adopted March 2026 · Next review no later than March 2027
1.1. MINT Platforms (Pty) Ltd (Registration Number 2024/644796/07) ("MINT") is a South African fintech business that operates a regulated, technology-enabled investment and digital assets platform at www.mymint.co.za. MINT is an authorised Financial Services Provider (FSP Licence Number 55118) regulated by the Financial Sector Conduct Authority ("FSCA"), a registered accountable institution under the Financial Intelligence Centre Act 38 of 2001, and a registered Crypto-Asset Service Provider.
1.2. This Public Statement on Advertising and Marketing Standards ("Statement") is issued by the Executive Committee of MINT to communicate clearly and transparently to its customers, partners, influencers, affiliates, regulators, and the general public the standards that govern every advertising and marketing communication produced by or on behalf of MINT.
1.3. This Statement reflects the key principles and commitments in MINT's internal Advertising Policy, which is the binding governance instrument applicable to MINT's employees, agents, and third-party advertising partners. The internal Advertising Policy is available to regulatory authorities on request.
1.4. This Statement should be read together with MINT's Terms and Conditions, Privacy Policy, AML/CTF/PF Public Policy Statement, and Complaints Policy, all of which are published at www.mymint.co.za.
2.1. MINT holds itself to the highest standard of honesty and transparency in every communication it makes to the public. It will not use advertising to mislead, to exploit, or to create unrealistic expectations. Every claim it makes can be substantiated. Every risk it asks its customers to bear will be clearly disclosed. And every person who markets on our behalf is held to the same standard we hold ourselves.
2.2. This commitment is not aspirational. It is operationalised through MINT's internal Advertising Policy, a mandatory pre-publication approval process, a dedicated advertising compliance function within MINT's Legal, Risk and Compliance team, and binding written obligations imposed on every third party that advertises on MINT's behalf.
MINT's advertising and marketing activities are governed by a comprehensive framework of South African legislation and regulatory instruments. The following are the primary instruments to which MINT's advertising must conform:
3.1. The Financial Advisory and Intermediary Services Act 37 of 2002 ("FAIS Act") and the General Code of Conduct for Authorised Financial Services Providers and Representatives. Section 4 of the FAIS Code requires all communications by authorised FSPs with clients to be factually accurate, relevant, balanced, transparent, and not misleading. All advertising by MINT in its capacity as an authorised FSP is subject to these requirements.
3.2. The Financial Sector Regulation Act 9 of 2017 ("FSR Act") and applicable FSCA Conduct Standards. MINT complies with all FSCA Conduct Standards governing the advertising of financial products and services, including any Conduct Standard applicable to crypto-asset service providers.
3.3. The Consumer Protection Act 68 of 2008 ("CPA"). The CPA prohibits false, misleading, deceptive, and unconscionable representations in all advertising directed at consumers. MINT's advertising is designed to comply with the CPA's requirements in full.
3.4. The Protection of Personal Information Act 4 of 2013 ("POPIA") and the Electronic Communications and Transactions Act 25 of 2002 ("ECT Act"). All direct marketing communications by MINT comply with POPIA's consent requirements and the ECT Act's prohibition on unsolicited commercial communications. Every direct marketing communication includes a clear and functional opt-out mechanism.
3.5. The National Credit Act 34 of 2005 ("NCA") (where applicable). Where MINT's advertising relates to credit products, it complies with the NCA's requirements for credit advertising, including prescribed disclosures regarding credit costs and terms.
3.6. The Advertising Regulatory Board Code of Advertising Practice ("ARB Code"). Although the ARB Code is an industry self-regulatory instrument, MINT voluntarily commits to compliance with its standards as a reflection of MINT's commitment to responsible advertising.
3.7. Any guidance, direction, or conduct standard issued by the FSCA specifically addressing the advertising of crypto-asset products and services.
The following standards apply to every advertisement and marketing communication produced by or on behalf of MINT, across every channel and medium:
4.1. Every statement, claim, and representation in MINT's advertising is factually accurate and capable of substantiation. Where a claim is based on data or research, that underlying evidence is documented and retained. MINT does not publish claims it cannot verify.
4.2. Where the potential benefits of MINT's products or services are described, the associated risks, limitations, fees, and conditions are disclosed with equivalent prominence. MINT does not present an artificially favourable picture of the risk-reward profile of any product.
4.3. MINT uses language that is clear, plain, and comprehensible to the intended audience. Where technical or regulatory language is unavoidable, it is explained. Disclosures are never designed to be difficult to find, read, or understand.
4.4. MINT clearly identifies itself as the advertiser in every advertisement. Where content is produced by a third party on MINT's behalf, including an influencer or affiliate, the commercial nature of that relationship is disclosed prominently and unambiguously in the content itself.
4.5. MINT does not minimise, qualify away, or obscure the risks associated with its products. Risk disclosures are presented with prominence appropriate to the nature of the risk. For digital asset products, risk disclosures are presented with at least equal prominence to the primary marketing message.
4.6. MINT does not, in any advertisement or marketing communication, directly or indirectly represent or imply that any investment product, crypto-asset, or other financial product guarantees a return, protects capital, or eliminates the risk of loss. This standard applies regardless of the qualifying language used and regardless of the channel.
4.7. Where MINT references historical performance in advertising, the figures are accurate, clearly dated, net of material costs where practicable, and accompanied by the disclosure that past performance is not indicative of future results. MINT does not select only favourable time periods or products for inclusion in advertising.
4.8. MINT accurately represents its regulatory status in all advertising. MINT does not claim to offer services beyond the scope of its regulatory authorisations, does not misrepresent the nature or extent of its licences, and does not create the impression that its products are guaranteed, insured, or government-backed where they are not.
4.9. MINT's advertising is consistent with the principle of treating customers fairly. MINT does not use advertising to exploit cognitive biases, time pressure, financial vulnerability, or emotional states to induce customers to make decisions that are not in their best interests.
4.10. MINT sends direct marketing communications only to persons who have provided their consent in accordance with POPIA, or to existing clients in respect of products or services similar to those they already use, and only where those persons have not opted out. Every direct marketing communication provides a clear and functional opt-out mechanism.
MINT includes the following mandatory disclosures in its advertising, calibrated to the nature of the content:
5.1. Every advertisement that promotes MINT's platform, brand, or general services includes the following disclosure: "MINT Platforms (Pty) Ltd is an authorised Financial Services Provider (FSP 55118) regulated by the Financial Sector Conduct Authority. Digital assets and investments involve risk. The value of your investment may go down as well as up."
5.2. Every advertisement that refers to or promotes any investment product or digital asset available on MINT's platform includes the following additional disclosure: "Investing in digital assets involves a high degree of risk, including the possible loss of the entire amount invested. Digital assets are not legal tender and are not protected by any deposit insurance scheme. Past performance is not indicative of future results. This communication does not constitute financial advice."
5.3. Where any advertisement contains a reference to historical performance or financial returns, the following disclosure is included: "Past performance figures are illustrative only and are not a reliable indicator of future results. Returns are not guaranteed. All investments carry risk."
5.4. Where any advertisement relates to a credit product offered or facilitated through MINT's platform, the following disclosure is included: "MINT Platforms (Pty) Ltd is a registered credit provider (NCRCP22892). Credit is subject to affordability assessment and approval in accordance with the National Credit Act 34 of 2005. Terms and conditions apply."
5.5. Where content is produced or distributed by an influencer, affiliate, or other third party on MINT's behalf, the content includes the disclosure "Paid partnership with MINT Platforms" or equivalent unambiguous language, positioned at the beginning of the content. This disclosure is never buried in hashtags, placed below a read-more threshold, or presented in a manner designed to reduce its visibility.
5.6. All mandatory disclosures are presented in a font size, colour contrast, and position that renders them legible and accessible. Disclosures are never designed or positioned to discourage reading.
The advertising of crypto-asset products and services requires particular care given the volatility of digital assets, the evolving regulatory environment, and the potential for retail investors to misunderstand the nature and risk profile of these products. MINT applies the following additional standards to all crypto-asset advertising:
6.1. Risk disclosures in all crypto-asset advertising are presented with equal or greater prominence than the primary marketing message. Risk information is never relegated to footnotes, end-screens, or secondary pages in crypto-asset content.
6.2. No crypto-asset advertisement presents or implies that any crypto-asset is a stable, low-risk, or capital-protected investment. Where an advertisement references volatility, it does so accurately and without minimising the risk of significant or total loss.
6.3. Every crypto-asset advertisement clearly discloses that crypto-assets are not legal tender in South Africa, are not bank deposits, and are not insured or protected by any governmental deposit protection scheme.
6.4. No crypto-asset advertisement featuring specific digital assets is constructed in a manner that constitutes a recommendation to purchase, hold, or sell any specific crypto-asset. Where specific crypto-assets are featured to illustrate platform functionality, this is stated clearly.
6.5. MINT complies at all times with any guidance, direction, or conduct standard issued by the FSCA specifically governing the advertising of crypto-asset services or products.
MINT bears full regulatory and reputational accountability for all content published about it by third parties acting on its behalf, including influencers, affiliates, and referral partners. The following standards govern every such arrangement.
7.1. No influencer, affiliate, or referral partner may produce or publish any content relating to MINT or its products and services without a formal written agreement with MINT and the prior written approval of MINT's Marketing function for all content before publication.
7.2. All content produced by third parties on MINT's behalf must comply with this Statement and MINT's internal Advertising Policy in full. Third-party advertisers may not make any claim, representation, or statement about MINT, its products, or its performance that has not been approved in writing by MINT.
7.3. The commercial nature of the relationship between MINT and any third-party advertiser must be disclosed clearly and prominently in every piece of content, using unambiguous language positioned at the beginning of the content.
7.4. Third-party advertisers are prohibited from making guaranteed return claims, misrepresenting MINT's regulatory status, making unlicensed financial advice, or creating the false impression that any of MINT's products are risk-free or government-backed.
7.5. Where a third-party advertiser publishes content that has not been approved or that breaches these standards, MINT will direct the immediate removal of the content and will assess whether the arrangement should be terminated.
7.6. Members of the public who become aware of content relating to MINT that appears to breach these standards are encouraged to report it to [email protected].
MINT welcomes feedback on its advertising and marketing communications. If you believe that any MINT advertisement is inaccurate, misleading, inappropriate, or in breach of applicable standards, you may raise a concern through any of the following channels.
8.1. Internal complaints may be submitted to [email protected] or by post to 3 Gwen Lane, Sandown, Sandton, 2031. All advertising complaints are handled in accordance with MINT's Complaints Policy, which is available at www.mymint.co.za.
8.2. If you are not satisfied with MINT's response to your advertising complaint, or if your complaint relates to financial services rendered by MINT as an authorised FSP, you may refer the matter to the FAIS Ombud at www.faisombud.co.za.
8.3. Complaints about the content or standards of advertising may also be referred to the Advertising Regulatory Board at www.arb.org.za.
8.4. Complaints regarding MINT's data processing activities in connection with direct marketing may be referred to the Information Regulator of South Africa at www.inforegulator.org.za.
8.5. Where a complaint relates to MINT's compliance with the Financial Sector Laws, it may be referred to the FSCA at www.fsca.co.za.
This Statement will be reviewed by MINT's Legal, Risk and Compliance function at least quarterly and updated to reflect material changes in applicable law, regulatory requirements, MINT's advertising activities, or MINT's business model. Material amendments are approved by the Board of Directors. The current version of this Statement is published on MINT's website at www.mymint.co.za and constitutes the authoritative version.
Version 2.0 · Adopted March 2026 · Next review no later than March 2027
1.1. The purpose of this Complaints Management Policy ("Policy") is to establish a clear, transparent, fair, and effective framework for the receipt, handling, investigation, resolution, escalation, and reporting of complaints directed at MINT Platforms (Pty) Ltd (Registration Number 2024/644796/07) ("MINT"), its products, services, platforms, personnel, outsourcing partners, and representatives.
1.2. This Policy gives effect to MINT's obligations under the Financial Advisory and Intermediary Services Act 37 of 2002 ("FAIS Act") and the General Code of Conduct for Authorised Financial Services Providers and Representatives ("FAIS Code"), the Financial Sector Regulation Act 9 of 2017 ("FSR Act"), the Consumer Protection Act 68 of 2008 ("CPA"), and accepted principles of corporate governance, including the recommendations of the King IV Report on Corporate Governance for South Africa 2016.
1.3. This Policy is designed to:
1.3.1. promote a culture of accountability, responsiveness, and continuous improvement across MINT's operations;
1.3.2. ensure that complaints are handled lawfully, fairly, timeously, and consistently, and that complainants are treated with respect and dignity throughout the complaints process;
1.3.3. protect the rights and legitimate interests of complainants and of MINT;
1.3.4. comply with all applicable South African legal and regulatory requirements governing the handling of financial services complaints;
1.3.5. mitigate MINT's legal, regulatory, reputational, operational, and technology risks arising from complaints; and
1.3.6. ensure that complaints data is used as a source of risk intelligence to drive continuous improvement in MINT's products, services, systems, and governance arrangements.
2.1. This Policy applies to all complaints received from clients, customers, users, counterparties, suppliers, service providers, employees, contractors, regulators, and other stakeholders, whether those complaints relate to MINT's conduct before, during, or after the provision of any financial or other service.
2.2. This Policy binds all MINT business units, subsidiaries, affiliates, directors, officers, employees, consultants, contractors, and agents, including all persons involved in or responsible for the receipt, handling, investigation, escalation, or oversight of complaints.
2.3. This Policy applies to complaints relating to MINT's technology platforms, algorithms, data processing activities, commercial arrangements, billing, service delivery, conduct, compliance matters, and any other aspect of MINT's business in respect of which a stakeholder has a legitimate interest in raising a concern.
2.4. Where a complaint relates wholly or partially to the conduct, performance, or omission of a third-party service provider or outsourcing partner engaged by MINT, MINT will not decline to investigate or resolve the complaint on the basis that the conduct is attributable to a third party. MINT manages the complaint in accordance with this Policy as if the conduct were MINT's own, except where the third party's independent contractual relationship with the complainant requires a different approach. Where investigation requires information from a third party, MINT will exercise its contractual rights to obtain that information.
3.1. For purposes of this Policy, the following terms bear the meanings assigned to them:
3.1.1. "Complaint" means any expression of dissatisfaction, concern, grievance, or allegation, whether justified or not, relating to MINT's conduct, products, services, systems, decisions, or personnel, where a response or resolution is explicitly or implicitly expected. The expression of dissatisfaction need not be formal or in writing to qualify as a complaint;
3.1.2. "Complainant" means any person or entity who submits a complaint, whether or not that person is a client or customer of MINT;
3.1.3. "FAIS Complaint" means a complaint as defined in the FAIS Act or the FAIS Code, relating to financial advice or intermediary services rendered by MINT as an authorised FSP, and which is subject to the specific complaints handling obligations imposed by the FAIS Code;
3.1.4. "Material Complaint" means a complaint that:
3.1.4.1. alleges unlawful, unethical, fraudulent, discriminatory, or materially negligent conduct;
3.1.4.2. involves potential regulatory non-compliance or systemic risk;
3.1.4.3. exposes MINT to potential litigation, regulatory sanction, or material reputational harm; or
3.1.4.4. involves significant financial exposure or data protection concerns;
3.1.5. "Standard Complaint" means a complaint requiring substantive investigation and resolution that does not meet the threshold for a Material Complaint;
3.1.6. "Low-Risk Operational Complaint" means a routine or isolated complaint with limited impact and no material legal, regulatory, or reputational risk; and
3.1.7. "Working Day" means any day other than a Saturday, Sunday, or public holiday in the Republic of South Africa.
4.1. All complaints must be handled in accordance with the following principles, which reflect MINT's obligations under the FAIS Code, the CPA, and the FSR Act:
4.1.1. Accessibility: complaint channels must be visible, easy to use, and available without unreasonable barriers. MINT must ensure that complaint channels are clearly communicated to all stakeholders and that access is not conditioned on formality or cost.
4.1.2. Fairness and Impartiality: complaints must be assessed objectively, without bias or conflict of interest. The investigator must have no actual or perceived conflict of interest in relation to the subject matter of the complaint.
4.1.3. Confidentiality: information relating to complaints must be handled sensitively and disclosed strictly on a need-to-know basis, consistent with MINT's data protection obligations under POPIA and the FAIS Code.
4.1.4. Transparency: complainants must be informed of the process, expected timeframes, and outcome, subject to applicable legal constraints including legal privilege and confidentiality obligations.
4.1.5. Timeliness: complaints must be acknowledged, investigated, and resolved within the defined timeframes set out in this Policy, and complainants must be kept informed of progress where investigations extend beyond the standard timeframes.
4.1.6. Proportionality: the level of investigation and the resources applied to a complaint must be proportionate to the nature, complexity, and risk profile of the complaint.
4.1.7. Non-Retaliation: no person may be subjected to retaliation, adverse treatment, or discrimination for lodging a complaint in good faith. Any person who subjects a complainant to retaliation is subject to disciplinary action by MINT.
4.1.8. Regulatory Compliance: all complaints handling must comply with applicable legislation and regulatory requirements, including the FAIS Code, the FSR Act, the CPA, and the Protection of Personal Information Act 4 of 2013 ("POPIA").
5.1. MINT maintains multiple, accessible, and secure channels through which complaints may be lodged. MINT must ensure that all complaint channels are clearly communicated to customers and stakeholders in MINT's onboarding documentation, Terms and Conditions, Privacy Policy, website, and mobile application.
5.2. Complaints may be submitted through any of the following channels:
5.2.1. a dedicated complaints email address, being [email protected], which is monitored on every Working Day by MINT's Legal, Risk and Compliance function;
5.2.2. a secure online complaint submission form accessible through MINT's website at www.mymint.co.za and through the MINT mobile application, designed to ensure data integrity, confidentiality, and auditability;
5.2.3. written correspondence, whether delivered electronically or in hard copy, addressed to MINT's Compliance Officer at MINT's registered office at 3 Gwen Lane, Sandown, Sandton, 2031;
5.2.4. verbal complaints, whether made telephonically to +27 10 276 0531 or in person, provided that: such complaints shall, as soon as reasonably practicable, be accurately reduced to writing by an authorised MINT representative; the written record shall, where feasible, be confirmed with the complainant for accuracy; and the written record shall constitute the official complaint for purposes of investigation and record-keeping; and
5.2.5. internal escalation and reporting mechanisms, including whistleblowing and ethics reporting channels, where the nature of the complaint relates to alleged misconduct, unlawful activity, regulatory non-compliance, or other matters warranting protected disclosure.
5.3. Anonymous complaints may be accepted and investigated at MINT's discretion, provided that the information submitted is sufficiently detailed and credible to permit a meaningful assessment and investigation. The absence of the complainant's identity does not preclude MINT from taking remedial action where the complaint discloses a systemic issue.
5.4. The submission of a complaint through any channel shall not, in itself, limit or prejudice any statutory, contractual, or common-law rights that a complainant may have, subject always to applicable law.
5.5. MINT reserves the right to request additional information where a complaint is incomplete, unclear, or incapable of investigation in its current form. Any such request shall not be used to unreasonably delay or frustrate the complaints handling process.
6.1. Upon receipt, every complaint must be promptly recorded in MINT's centralised Complaints Register, which constitutes the official record for governance, risk management, audit, and regulatory reporting purposes. The Complaints Register must be maintained by the Legal, Risk and Compliance function and must be accessible at all times to the Compliance Officer and the relevant members of MINT's governance structures.
6.2. The Complaints Register must, at a minimum, record:
6.2.1. the date, time, and method of receipt;
6.2.2. the identity of the complainant, where disclosed;
6.2.3. a summary of the complaint and the issues raised;
6.2.4. the unique reference number assigned to the complaint;
6.2.5. the classification of the complaint in accordance with clause 7;
6.2.6. the internal owner or function responsible for handling the complaint;
6.2.7. all key milestones, including the date of acknowledgement, the date of any extension notices, and the date of resolution; and
6.2.8. the outcome of the complaint and any remedial actions taken.
6.3. MINT must acknowledge receipt of every complaint in writing within five Working Days of receipt, or within two Working Days in respect of a FAIS Complaint.
6.4. The written acknowledgement must:
6.4.1. confirm receipt of the complaint;
6.4.2. provide the complainant with the unique reference number assigned to the complaint for tracking purposes;
6.4.3. identify the person or function responsible for managing the complaint and provide contact details for that person or function;
6.4.4. outline the complaints handling process, including the classification that has been assigned to the complaint, the anticipated steps to be taken, and the indicative timeframe for resolution; and
6.4.5. inform the complainant of any information that must be provided to enable the complaint to be progressed.
6.5. The acknowledgement of receipt does not constitute an admission of liability, fault, or wrongdoing by MINT, and shall not prejudice MINT's rights or defences.
7.1. Every complaint recorded in the Complaints Register must, as soon as reasonably practicable after acknowledgement, undergo an initial assessment conducted by an appropriately authorised and suitably qualified person within MINT's Legal, Risk and Compliance function.
7.2. The purpose of the initial assessment is to:
7.2.1. determine whether the complaint falls within MINT's jurisdiction, mandate, and control, and whether it is relevant for handling under this Policy;
7.2.2. identify and classify the nature of the complaint, including whether it relates to service delivery or operational matters, contractual or commercial arrangements, technical or platform performance, conduct or ethics, data protection or information security, or legal, regulatory, or compliance matters;
7.2.3. assess the materiality, severity, and risk profile of the complaint, having regard to potential financial exposure, legal or regulatory implications, reputational impact, operational or systemic risk, and potential impact on clients or other stakeholders; and
7.2.4. identify any immediate remedial, containment, or risk-mitigation actions required to prevent ongoing harm, preserve evidence, or ensure regulatory compliance, including the imposition of interim controls or legal holds where appropriate.
7.3. Following the initial assessment, every complaint must be classified into one of the following categories:
7.3.1. Low-Risk Operational Complaint: a routine or isolated complaint with limited impact and no material legal, regulatory, or reputational risk;
7.3.2. Standard Complaint: a complaint requiring substantive investigation and resolution that does not meet the threshold for a Material Complaint; or
7.3.3. Material Complaint: a complaint that, individually or in combination with related complaints, alleges unlawful, unethical, fraudulent, discriminatory, or grossly negligent conduct, raises potential breaches of law, regulation, or internal policy, involves significant financial exposure or systemic failure, or poses a material risk to MINT's reputation, business continuity, or stakeholder trust.
7.4. The outcome of the initial assessment and classification must be recorded in the Complaints Register and must be used to determine the applicable investigation methodology, escalation level, resolution timeframe, and governance oversight for the complaint.
7.5. The classification of a complaint may be reviewed and upgraded at any stage of the process if new information emerges or the risk profile changes.
8.1. Every complaint requiring investigation must be investigated by a suitably qualified, competent, and independent person or team. Independence requires that the investigator has no actual or perceived conflict of interest in relation to the subject matter and is not directly implicated in, or responsible for, the conduct or decision under investigation.
8.2. The scope and methodology of the investigation must be proportionate to the classification of the complaint and must be designed to ensure factual accuracy, fairness, and completeness. An investigation may include one or more of the following, as appropriate:
8.2.1. the review and analysis of relevant documents, records, correspondence, contracts, policies, system logs, and data sets;
8.2.2. the conduct of interviews with the complainant, affected persons, witnesses, and relevant MINT personnel;
8.2.3. consultation with, or referral to, internal specialists including the legal, risk, compliance, information security, data protection, or technology functions;
8.2.4. forensic, technical, or data-driven analysis, including system audits, access reviews, or algorithmic assessments, where the complaint raises issues of fraud, data integrity, cybersecurity, or systemic failure; and
8.2.5. the imposition of interim measures, safeguards, or controls where necessary to prevent ongoing harm or preserve evidence.
8.3. MINT may, at its discretion and where appropriate, appoint external independent advisors, including legal counsel, forensic investigators, auditors, or technical experts, particularly in relation to Material Complaints.
8.4. All investigations must be conducted in accordance with applicable law, ethically and in good faith, with due regard to procedural fairness and the rights of all affected parties, and in a manner that preserves confidentiality, legal privilege, and the integrity of the investigative process.
8.5. The findings, conclusions, and recommendations arising from an investigation must be appropriately documented, supported by evidence, and retained in accordance with MINT's records retention obligations. Investigation files must be maintained on a confidential basis and access must be limited to those with a legitimate need to know.
9.1. MINT applies the following resolution timeframes, measured from the date of acknowledgement in accordance with clause 6.3:
9.1.1. Low-Risk Operational Complaints: MINT will use reasonable endeavours to communicate a final outcome within five Working Days of acknowledgement;
9.1.2. Standard Complaints: MINT will use reasonable endeavours to communicate a final outcome within fifteen Working Days of acknowledgement; and
9.1.3. Material Complaints and FAIS Complaints: MINT will use reasonable endeavours to communicate a final outcome within thirty Working Days of acknowledgement.
9.2. These timeframes do not constitute fixed or guaranteed service levels and may be extended where the complaint involves complex factual, technical, forensic, or legal analysis, depends on information or cooperation from third parties, raises issues subject to regulatory or parallel internal processes, or is otherwise incapable of resolution within the ordinary timeframe despite reasonable efforts.
9.3. Where MINT reasonably determines that a complaint cannot be resolved within the applicable timeframe, MINT must notify the complainant in writing without undue delay, setting out the reasons for the delay at an appropriate level of detail and providing an updated indicative timeframe for resolution or, where that is not reasonably practicable, periodic progress updates at reasonable intervals of not less than every ten Working Days.
9.4. Any extension of time and the reasons therefor must be recorded in the Complaints Register.
10.1. Upon completion of the investigation, MINT will determine an appropriate outcome having regard to the findings, the evidence available, the applicable legal and contractual framework, and the risk profile of the complaint.
10.2. Possible outcomes include:
10.2.1. acceptance of the complaint, in whole or in part, together with the implementation of appropriate remedial or corrective action;
10.2.2. partial acceptance, where certain aspects of the complaint are substantiated and others are not, with reasons provided;
10.2.3. rejection of the complaint, in whole or in part, where the complaint is not substantiated, accompanied by a clear explanation of the basis for the decision; or
10.2.4. negotiated, alternative, or consensual resolution, including settlement, corrective undertakings, or other agreed measures, where this is appropriate and lawful.
10.3. Where a complaint is upheld in whole or in part, remedial actions may include:
10.3.1. corrective service or operational measures designed to address the specific issue raised;
10.3.2. enhancements to systems, processes, platforms, algorithms, or controls to prevent recurrence;
10.3.3. refunds, credits, fee adjustments, or other financial remedies, where contractually, legally, or commercially appropriate;
10.3.4. disciplinary or corrective action in accordance with applicable employment, contractor, or governance frameworks; and
10.3.5. amendments to policies, procedures, training programmes, or governance arrangements.
10.4. The selected outcome and any remedial actions must be proportionate to the nature and severity of the complaint, consistent with MINT's legal obligations and internal policies, and approved at an appropriate level of authority having regard to the classification of the complaint.
10.5. The outcome of the complaint, together with reasons, must be communicated to the complainant clearly and in writing, subject to applicable legal privilege, confidentiality obligations, and data protection requirements.
10.6. The determination of an outcome under this clause does not constitute an admission of liability, fault, or wrongdoing by MINT unless expressly stated otherwise. All outcomes and remedial actions must be documented and recorded in the Complaints Register.
11.1. A complainant who is dissatisfied with the outcome of a complaint may request escalation for further review, subject to the procedures in this clause.
11.2. An escalation request must be submitted in writing, must set out the grounds on which the complainant remains dissatisfied, and must be lodged within a reasonable period following the communication of the outcome.
11.3. Escalation under this Policy does not constitute a re-investigation as of right. It constitutes a review of whether the complaint was handled in accordance with this Policy, whether the investigation process was fair and proportionate, and whether the outcome was reasonable having regard to the information available at the time.
11.4. Depending on the nature, classification, and risk profile of the complaint, escalation may be directed to:
11.4.1. senior management, where the complaint relates to operational or service delivery matters;
11.4.2. the Legal, Risk and Compliance function, where the complaint raises legal, regulatory, ethical, or control-related issues;
11.4.3. the Executive Committee, where the complaint involves cross-functional risk, material financial exposure, or reputational impact; or
11.4.4. the Board of Directors or a duly constituted Board Committee, where the complaint constitutes a Material Complaint, involves senior management or executive-level conduct, or presents material legal, regulatory, or strategic risk to MINT.
11.5. Material Complaints must be escalated without delay to the Legal, Risk and Compliance function, irrespective of whether the complainant has requested escalation.
11.6. The outcome of any escalation or review must be documented, approved at the appropriate level of authority, and recorded in the Complaints Register.
11.7. The decision taken following escalation shall, subject to applicable law, constitute MINT's final internal position on the complaint.
12.1. Where required by law, regulation, or contractual obligation, or where otherwise reasonably appropriate, MINT may notify, engage with, or make disclosures to relevant regulators, supervisory authorities, or law enforcement agencies, and will cooperate fully with any external investigation, inquiry, inspection, or audit.
12.2. Any regulatory or external referral must be assessed and approved at an appropriate level of authority, coordinated through the Legal, Risk and Compliance function, and conducted in a manner that preserves confidentiality, legal privilege, and MINT's rights and defences.
12.3. Where a complaint gives rise to a reasonable prospect of litigation, regulatory enforcement, or formal investigation, MINT may issue legal hold notices, restrict communications, and engage external legal or forensic advisors.
12.4. Nothing in this Policy:
12.4.1. restricts or limits any person's right to refer a matter to an external dispute resolution body, regulator, ombud, or court of competent jurisdiction; or
12.4.2. obliges a complainant to exhaust internal complaint procedures before exercising any statutory or legal rights.
12.5. Where a complainant has lodged a FAIS Complaint and remains dissatisfied after receiving MINT's final internal response, or where MINT has not resolved the complaint within the timeframe required by the FAIS Code, MINT must inform the complainant of their right to refer the matter to the FAIS Ombud. The FAIS Ombud can be contacted as follows:
12.5.1. Website: www.faisombud.co.za;
12.5.2. Email: [email protected]; and
12.5.3. Telephone: 012 762 5000.
12.6. Where a complaint relates to MINT's compliance with the Financial Sector Laws, the complainant may also refer the matter to the FSCA. Where a complaint relates to MINT's data processing activities, the complainant may refer the matter to the Information Regulator in accordance with POPIA.
13.1. MINT must maintain complete, accurate, and up-to-date records of all complaints, investigations, outcomes, and related correspondence in the centralised Complaints Register.
13.2. All complaints and related documentation must be retained in accordance with MINT's Records Retention Policy and applicable legal and regulatory requirements. For FAIS Complaints, records must be retained for a minimum of five years from the date of resolution. For all other complaints, records must be retained for a minimum of three years from the date of resolution.
13.3. Complaint records must be protected against unauthorised access, alteration, or destruction, and must be preserved in accordance with any applicable legal hold or evidence-preservation obligations.
13.4. The Compliance Officer must prepare and submit complaint-handling reports to management at least quarterly. Each quarterly report must include, at a minimum:
13.4.1. the number, type, and classification of complaints received during the reporting period;
13.4.2. analysis of root causes, recurring themes, and emerging trends;
13.4.3. average and outlier resolution timeframes, including any material delays;
13.4.4. identification of systemic, structural, or control-related issues; and
13.4.5. remediation measures implemented or proposed, together with progress against such measures.
13.5. The Compliance Officer must table a semi-annual complaints report to the Board Risk and Compliance Committee or such other Board sub-committee as the Board may designate. An immediate report must be submitted to senior management and the Board where any single complaint or cluster of complaints indicates a material systemic risk, regulatory breach, or potential class action.
13.6. MINT must submit complaints statistics to the FSCA as required by the FAIS Code and applicable FSCA Conduct Standards.
13.7. Complaints data may be aggregated and anonymised for purposes of risk management, reporting, training, and continuous improvement, subject to applicable data protection and confidentiality obligations.
14.1. Where a complaint constitutes a FAIS Complaint, the following additional requirements apply in addition to the general requirements of this Policy:
14.1.1. MINT must acknowledge the FAIS Complaint within two Working Days of receipt;
14.1.2. MINT must resolve the FAIS Complaint within the timeframes prescribed by the FAIS Code and any applicable FSCA Conduct Standard or directive;
14.1.3. MINT must keep records of all FAIS Complaints for a minimum of five years from the date of resolution;
14.1.4. MINT must include FAIS Complaints in MINT's complaints statistics reported to the FSCA as required by the applicable reporting obligations; and
14.1.5. MINT must cooperate fully with any investigation by the FAIS Ombud and must respond to requests for information or documentation within the prescribed timeframes.
15.1. MINT treats complaints as a critical source of risk intelligence and continuous improvement. MINT must implement processes to ensure that insights derived from complaints inform strategic, operational, and governance decision-making.
15.2. MINT must systematically analyse complaint data, trends, and root causes to identify systemic or recurring risks, weaknesses in products, services, platforms, algorithms, processes, or controls, and gaps in training, communication, or governance arrangements.
15.3. MINT must use the insights derived from complaint analysis to implement targeted corrective and preventive actions, enhance products, services, systems, and technological solutions, strengthen internal controls, compliance frameworks, and risk management practices, and inform policy development, training programmes, and operational standards.
15.4. Where complaint trends indicate material or systemic risk, MINT must escalate those risks to the appropriate governance forum and address them through documented remediation plans with defined ownership, timelines, and accountability.
15.5. Continuous improvement initiatives arising from complaints must be monitored, tracked, and reviewed to assess effectiveness and sustainability. Progress must be reported to the RCC at each quarterly meeting.
16.1. MINT must ensure that all personnel who are involved in, or may reasonably be expected to be involved in, the receipt, handling, investigation, escalation, or oversight of complaints receive appropriate, role-specific training before commencing such duties and at least annually thereafter.
16.2. Training must cover obligations relating to the receipt, handling, investigation, and resolution of complaints in accordance with this Policy and applicable law; confidentiality, data protection, and information security requirements; escalation pathways, decision-making thresholds, and governance structures applicable to different categories of complaints; and the consequences of non-compliance with this Policy.
16.3. MINT must maintain appropriate records of training undertaken for purposes of audit, compliance monitoring, and continuous improvement.
17.1. This Policy is approved by the Board of Directors of MINT, which retains ultimate accountability for the effectiveness, adequacy, and oversight of MINT's complaints management framework.
17.2. The Board may delegate aspects of oversight under this Policy to the Risk and Compliance Committee or another duly constituted Board sub-committee, provided that such delegation does not dilute the Board's overall responsibility.
17.3. The Executive Committee is responsible for the implementation, administration, and day-to-day oversight of this Policy; ensuring that appropriate procedures, controls, and resources are in place to support effective complaint handling; monitoring compliance with this Policy and applicable legal and regulatory requirements; and escalating Material Complaints, systemic issues, and material breaches of this Policy to the appropriate governance forum.
17.4. Compliance with this Policy forms an integral part of MINT's enterprise risk management framework, internal control environment, and governance processes. Material non-compliance with this Policy may result in disciplinary action and may be escalated to senior management, the Executive Committee, or the Board, as appropriate.
18.1. The current version of this Policy must be:
18.1.1. published on MINT's website at www.mymint.co.za and made easily accessible to customers through the MINT platform;
18.1.2. provided to any customer upon request at no cost;
18.1.3. communicated to all employees and representatives involved in complaint handling at the time of appointment and following any material amendment; and
18.1.4. referenced in MINT's Terms and Conditions, Privacy Policy, and onboarding documentation.
19.1. This Policy must be reviewed by the Compliance Officer at least annually. A reviewed and, where necessary, updated version must be presented to the Board for approval no later than twelve months after the date of the most recent Board approval.
19.2. An earlier review is required where there are changes in applicable law, regulation, or regulatory guidance; material changes to MINT's business model, technology, or risk profile; findings arising from complaints, audits, or regulatory reviews; or identified deficiencies in the operation or effectiveness of this Policy.
19.3. Any material amendment to this Policy must be approved by the Board. The current version number, date of adoption, and Board resolution number must be reflected on the face of this Policy at all times.
Version 2.0 · Adopted March 2026 · Next review no later than March 2027
1.1. Purpose and Scope These terms and conditions ("Terms") constitute a legally binding agreement governing all access to, interaction with, and use of the MINT website at www.mymint.co.za, including any associated webpages, sub-domains, mobile applications, application programming interfaces ("APIs"), dashboards, portals, and other digital interfaces operated or made available by MINT from time to time (collectively, the "Site"), and all products, services, functionalities, tools, features, content, information, transaction facilities, and ancillary services made available through or in connection with the Site, whether accessed by desktop, mobile device, or otherwise (collectively, the "Services").
1.2. Operator The Site and the Services are operated and made available by MINT Platforms (Pty) Ltd, a private company duly incorporated in accordance with the laws of the Republic of South Africa (Registration Number 2024/644796/07), an authorised Financial Services Provider (FSP Licence Number 55118), and a registered accountable institution under the Financial Intelligence Centre Act 38 of 2001 ("MINT", "we", "us", or "our"). No other person is authorised to bind MINT unless explicitly indicated in writing.
1.3. Binding Effect
1.3.1. These Terms apply to and are binding on every person who accesses the Site or uses any of the Services, whether as a registered user or otherwise. By accessing the Site, creating or maintaining a user account, clicking an acceptance mechanism, or using any part of the Services, you acknowledge that you have read, understood, and accepted these Terms in full, you agree to be legally bound by these Terms as if you had signed them, and you agree that MINT's Privacy Policy, Complaints Policy, Risk Policy, together with any other policies, schedules, notices, or rules referenced in these Terms (as amended from time to time), are incorporated into and form an integral part of these Terms.
1.3.2. If you do not agree, or cease to agree, with any provision of these Terms, you must immediately refrain from accessing the Site and discontinue all use of the Services. Continued access or use constitutes conclusive proof of acceptance.
1.4. Condition to Access Your continued access to the Site and use of the Services is conditional upon your ongoing compliance with these Terms and all applicable laws. MINT reserves the right to restrict, suspend, or terminate access where these Terms are not complied with.
1.5. No Obligation to Provide Access Nothing in these Terms obliges MINT to make the Site or any Services available to any person, or to continue providing the Site or Services for any period of time. Access is granted at MINT's discretion and may be withdrawn in accordance with these Terms and applicable law.
2.1. Regulatory Status and FAIS Disclosure
2.1.1. MINT Platforms (Pty) Ltd is an authorised Financial Services Provider under the Financial Advisory and Intermediary Services Act 37 of 2002 ("FAIS Act"), holding FSP Licence Number 55118. MINT is authorised to provide financial services in the following categories: Category I and Category II. MINT is also registered as an accountable institution under the Financial Intelligence Centre Act 38 of 2001 and as a crypto-asset service provider under the applicable FSCA Conduct Standard.
2.1.2. In accordance with the requirements of the FAIS Act and the General Code of Conduct for Authorised Financial Services Providers and Representatives ("FAIS Code"), MINT makes the following pre-contractual disclosures:
2.1.2.1. MINT's registered name is MINT Platforms (Pty) Ltd, Registration Number 2024/644796/07;
2.1.2.2. MINT's FSP Licence Number is 55118;
2.1.2.3. MINT does not provide financial advice as defined in the FAIS Act unless you have entered into a separate written advisory mandate with MINT;
2.1.2.4. MINT holds professional indemnity and fidelity insurance cover as required by the FAIS Act and the applicable Board Notice. Details of this cover are available from the Compliance Officer on request;
2.1.2.5. MINT's Conflict of Interest Management Policy is available on the Site;
2.1.2.6. where MINT acts as a juristic representative or is associated with any product supplier, this will be disclosed in the relevant product documentation; and
2.1.2.7. if you have a complaint about financial services rendered by MINT, you have the right to refer your complaint to the FAIS Ombud at www.faisombud.co.za after receiving MINT's final internal response.
2.2. Execution Only and Information Only Platform
2.2.1. The Site and the Services are provided on an execution only and information only basis, subject to these Terms. Unless you have concluded a separate written advisory mandate with MINT, MINT does not provide financial, investment, trading, legal, tax, accounting, or other professional advice of any nature; does not assess the suitability, appropriateness, or merits of any Digital Currency, Transaction, or strategy for your individual circumstances; and does not act as your agent, fiduciary, representative, or advisor.
2.2.2. All decisions to access the Site, use the Services, or enter into Transactions are taken by you independently and at your sole risk. You acknowledge that you are solely responsible for obtaining independent legal, financial, tax, accounting, and other professional advice prior to using the Services or entering into any Transaction.
2.3. Conflict of Interest Disclosure MINT discloses the following material conflict of interest in accordance with its obligations under the FAIS Code: funds deposited by you into your Legal Tender Account are held in pooled bank accounts operated by MINT. MINT earns interest on funds held in those pooled accounts. You will not receive any portion of this interest, and you irrevocably waive any entitlement to interest on funds held in your Legal Tender Account. This arrangement constitutes a material conflict of interest, which MINT hereby discloses. If you require further information regarding this arrangement, please contact MINT's Compliance Officer at [email protected].
2.4. Digital Currency Risk Acknowledgements
2.4.1. You expressly acknowledge, understand, and accept that:
2.4.1.1. Digital Currencies are not legal tender in the Republic of South Africa and are not backed, guaranteed, or insured by any governmental authority, central bank, or regulatory body;
2.4.1.2. the value of Digital Currencies is highly volatile and may fluctuate significantly over short periods of time;
2.4.1.3. Digital Currencies are speculative and high-risk assets, and transactions involving Digital Currencies may result in substantial financial loss;
2.4.1.4. you may lose some or all of the Digital Currencies or funds associated with your use of the Services;
2.4.1.5. the regulatory treatment of Digital Currencies and digital asset-related services in South Africa and other jurisdictions is evolving and uncertain, and changes in law, regulation, or regulatory interpretation may adversely affect the availability, functionality, or legality of the Services; and
2.4.1.6. past performance of any Digital Currency is not indicative of future performance.
3.1. Approved User Requirement Access to the Services is strictly limited to persons who have been approved by MINT as authorised users of the platform ("Approved Users"). No person may access or use any part of the Services unless and until such person has been accepted by MINT as an Approved User in accordance with these Terms.
3.2. Eligibility Criteria By applying for Approved User status, creating or maintaining a User Account, or using any part of the Services, you represent, warrant, and undertake on an ongoing basis that you are a natural person who is at least eighteen (18) years of age and have full legal capacity to enter into and be bound by these Terms; where you access the Services on behalf of a juristic person, you are duly authorised to do so and to bind that entity to these Terms; you are not subject to any legal, regulatory, or contractual restriction that would prevent you from lawfully accessing or using the Services; all information, documentation, and declarations provided to MINT are true, accurate, complete, current, and not misleading; and MINT has, to its satisfaction, completed all identity verification, AML/CTF/PF compliance, sanctions screening, source of funds, risk assessment, and related checks required under applicable law or MINT's internal policies.
3.3. Ongoing Obligation to Update You undertake to promptly notify MINT in writing of any change in circumstances that may affect your eligibility, risk profile, or Approved User status, including any change to your personal details, beneficial ownership, authorisation, regulatory status, or source of funds.
3.4. No Entitlement to Approval Approval as an Approved User is not a right and remains at all times subject to MINT's discretion. MINT is under no obligation to provide reasons for refusing an application, except to the extent required by applicable law.
3.5. Suspension and Revocation MINT may at any time refuse, suspend, restrict, or revoke your Approved User status if you no longer satisfy the eligibility requirements; any information provided by you is or becomes false, inaccurate, incomplete, or misleading; continued access may expose MINT to legal, regulatory, reputational, or operational risk; or such action is required or advisable to comply with applicable law, regulatory guidance, court orders, or internal risk management policies.
4.1. Requirement for a User Account Access to certain Services is conditional upon the creation and maintenance of a registered user account ("User Account"). You may not access or use Services requiring registration unless and until a User Account has been successfully created, verified, and approved by MINT in accordance with these Terms.
4.2. Account Creation and Verification To create a User Account, you must provide such information, documentation, and confirmations as MINT may require, including for identity verification, compliance, security, and risk management purposes. MINT may refuse to create, activate, or maintain a User Account where the information provided is incomplete, inaccurate, misleading, or unsatisfactory, or where required by applicable law or internal policy. MINT may subject any User Account to ongoing monitoring, periodic review, and re-verification.
4.3. Single Account Restriction Unless expressly authorised in writing by MINT, you may maintain only one User Account. MINT may suspend or terminate any additional or duplicate accounts created in breach of this clause.
4.4. Account Credentials and Security
4.4.1. You are solely responsible for maintaining the confidentiality and security of all credentials associated with your User Account, including usernames, passwords, personal identification numbers, authentication codes, private keys (where applicable), recovery phrases, and any multi-factor authentication mechanisms ("Access Credentials"). You must ensure that your password is unique and not reused across other platforms, that your Access Credentials are not disclosed or shared with any third party, and that all reasonable security measures are implemented to prevent unauthorised access to your User Account.
4.4.2. MINT may require the use of multi-factor or enhanced authentication mechanisms as a condition of access to certain Services or for the execution of certain Transactions. Failure to maintain or correctly use such mechanisms may result in restricted access or suspension.
4.5. Responsibility for Account Activity You are fully and exclusively responsible for all activity conducted through your User Account, whether authorised by you or not. MINT is entitled to assume, without further enquiry, that any instruction, request, or Transaction initiated through your User Account has been validly authorised by you. MINT has no obligation to verify the identity or authority of any person accessing your User Account.
4.6. Security Incidents
4.6.1. You must immediately notify MINT in writing upon becoming aware of, or reasonably suspecting, any unauthorised access to or use of your User Account, any compromise of your Access Credentials, or any security breach, cyber incident, or suspicious activity relating to your User Account. Failure to provide prompt notice may materially prejudice MINT's ability to mitigate loss.
4.6.2. To the maximum extent permitted by law, MINT shall not be liable for any loss arising from your failure to comply with these security obligations, compromise of your Access Credentials due to your negligence or breach, or unauthorised access that could reasonably have been prevented by industry-standard security practices.
5.1. General Prohibition You may access and use the Site, the Services, and any User Account solely for lawful purposes and in strict accordance with these Terms. Any use outside the scope expressly permitted is prohibited.
5.2. Prohibited Conduct Without limiting clause 5.1, you may not, directly or indirectly, use the Site, the Services, or any User Account to engage in any activity that is unlawful, fraudulent, deceptive, or misleading; conceal, convert, transfer, or otherwise deal with the proceeds of unlawful activity, including ML/TF/PF or sanctions evasion; engage in market manipulation, wash trading, spoofing, layering, front-running, or any activity intended to distort market prices or order book integrity; infringe or violate any intellectual property, proprietary, confidentiality, or privacy rights of MINT or any third party; introduce malware, viruses, or other malicious code, or attempt to gain unauthorised access to the Site, the Services, or any connected systems; reverse engineer, decompile, or disassemble any software or technology underlying the Site or Services, except to the extent permitted by law; circumvent, disable, or interfere with any security-related features, access controls, transaction limits, or monitoring mechanisms; impersonate any person or provide false or misleading information to MINT; use the Services for the benefit of any third party without MINT's prior written consent; access or use the Services if you are not, or cease to be, an Approved User; or engage in any conduct that MINT reasonably considers may expose it or its users to legal, regulatory, reputational, operational, or financial risk.
5.3. Enforcement Powers If MINT reasonably believes that you have engaged, or are engaging, in prohibited conduct, MINT may, without prior notice and without prejudice to any other rights or remedies, refuse, suspend, or terminate your access to the Site, Services, or User Account; suspend, cancel, delay, reverse, or refuse to process any Transaction; impose transaction limits, freezes, or other restrictions on your accounts; report relevant information to regulators, law enforcement authorities, or other competent bodies; and retain records relating to you and your use of the Services as required by law.
6.1. Provision of Hosted Wallet Services MINT provides Approved Users with access to a hosted digital asset wallet service (each, a "Digital Currency Wallet") for the holding, receipt, transmission, and administration of supported Digital Currencies through the platform, strictly in accordance with these Terms.
6.2. Nature and Scope of Custody
6.2.1. Unless expressly stated otherwise in writing, MINT provides Digital Currency Wallets on a custodial, hosted basis, whereby MINT (or its appointed service providers) retains possession or control of the private cryptographic keys associated with the relevant Digital Currencies. Digital Currencies credited to a Digital Currency Wallet are recorded on MINT's internal ledger and may be pooled or commingled at a technical or operational level, notwithstanding internal attribution to individual users.
6.2.2. You acknowledge that Digital Currencies reflected in a Digital Currency Wallet may not be held in a uniquely identifiable blockchain address in your name.
6.3. Legal Character of Holdings Your interest in Digital Currencies credited to a Digital Currency Wallet constitutes a personal contractual claim against MINT, subject to these Terms and applicable law. Except to the extent expressly required by applicable law or any regulatory determination applicable to MINT's crypto-asset services, no trust, fiduciary, nominee, agency, or bailment relationship is created solely by the operation of these Terms or any Digital Currency Wallet. This clause does not limit any rights you may have under applicable law. You acknowledge and accept the risk that, in the event of MINT's insolvency, business rescue, or liquidation, your rights in respect of Digital Currencies may be subject to applicable insolvency laws and may not be immediately recoverable.
6.4. No Deposit Protection or Insurance Digital Currencies held in Digital Currency Wallets are not legal tender, are not deposits for purposes of any banking or financial services legislation, and are not insured, guaranteed, or protected by any deposit insurance scheme, governmental authority, or regulator.
6.5. Supported Digital Currencies MINT supports only those Digital Currencies expressly identified on the platform from time to time. MINT may discontinue support for any Digital Currency, protocol, or network without liability, including as a result of forks, protocol changes, security vulnerabilities, or regulatory requirements. MINT does not support derivative, enhanced, wrapped, or forked versions of Digital Currencies unless expressly stated otherwise.
6.6. Transactions All Transactions are executed strictly in accordance with your instructions as received through your User Account. Blockchain transactions are irreversible once broadcast to and confirmed by the relevant network. You bear sole responsibility for verifying transaction details, including wallet addresses, networks, amounts, and fees.
6.7. Safeguarding Measures MINT implements reasonable administrative, technical, and organisational measures designed to safeguard Digital Currencies under its control, including layered security protocols and restricted access controls. You acknowledge that such measures do not eliminate all risks inherent in digital asset custody.
6.8. Suspension and Withdrawal Restrictions MINT may suspend, restrict, or delay withdrawals from Digital Currency Wallets where reasonably necessary to comply with applicable law or regulatory directives, address security incidents or system integrity risks, or investigate suspected prohibited use.
7.1. MINT may, subject to these Terms, establish and maintain for each Approved User a South African Rand-denominated account ("Legal Tender Account") for the limited purpose of facilitating permitted Transactions through the platform. The Legal Tender Account may be used solely to deposit South African Rand ("ZAR") for use in Transactions and to receive ZAR proceeds arising from completed Transactions, withdrawals, or other amounts credited in accordance with these Terms.
7.2. All deposits into a Legal Tender Account must originate from a bank account held in your own name (or, where applicable, in the name of the entity on whose behalf you are acting), maintained with a bank authorised under the Banks Act 94 of 1990. MINT may refuse, delay, or reverse any deposit or withdrawal where the source or destination of funds cannot be satisfactorily verified, or where required for compliance, fraud prevention, or risk management purposes.
7.3. The Legal Tender Account does not constitute a bank account, deposit account, or similar regulated account. MINT is not a bank or deposit-taking institution. Funds credited to a Legal Tender Account are held solely for transactional purposes in connection with the Services and do not attract the protections applicable to bank deposits.
7.4. Amounts credited to a Legal Tender Account do not earn interest, yield, or any other return. MINT earns interest on funds held in pooled accounts, and you irrevocably waive any entitlement to claim interest or similar amounts in respect of such funds. This arrangement constitutes a material conflict of interest, which is disclosed in clause
7.5. MINT will use reasonable measures to safeguard funds credited to Legal Tender Accounts, which may include holding such funds in one or more designated bank accounts. You acknowledge that such funds may be pooled or commingled at an operational level, subject to internal attribution and record-keeping.
7.6. Withdrawals from a Legal Tender Account are subject to completion of applicable verification checks, applicable withdrawal limits, processing times and fees, and the absence of any suspension, freeze, or restriction imposed under these Terms.
7.7. In the event of MINT's insolvency, business rescue, or similar proceedings, your rights in respect of funds held in a Legal Tender Account may be subject to applicable insolvency laws and may not be immediately recoverable. To the maximum extent permitted by law, you bear all risks associated with holding funds in a Legal Tender Account, including operational, legal, and regulatory risks, other than risks arising from MINT's wilful misconduct or gross negligence.
8.1. Subject to these Terms, MINT facilitates access for Approved Users to transaction functionality enabling the purchase of supported Digital Currencies using ZAR or other permitted consideration ("Buy Transactions") and the sale of supported Digital Currencies in exchange for ZAR or other permitted consideration ("Sell Transactions"), in each case strictly on a pre-funded basis and subject to applicable transaction limits, fees, and controls.
8.2. All Transactions are facilitated on an execution only basis. MINT does not provide advice, recommendations, or opinions in relation to any Transaction and does not assess the suitability, appropriateness, or merits of any Transaction, pricing level, or trading strategy.
8.3. Buy Transactions may only be initiated where sufficient cleared funds are available in the relevant Legal Tender Account. Sell Transactions may only be initiated where sufficient supported Digital Currencies are available in the relevant Digital Currency Wallet.
8.4. MINT may impose, amend, or remove limits, thresholds, or conditions on Transactions from time to time, including limits based on value, volume, frequency, asset type, or user risk profile.
8.5. MINT may delay, suspend, cancel, refuse, or reverse the processing of any Transaction where reasonably necessary to comply with applicable law, regulatory requirements, or court or governmental orders; implement fraud prevention, AML, sanctions, cybersecurity, or risk management controls; or address system integrity, operational, or market-disruption concerns.
8.6. You expressly acknowledge and agree that MINT does not warrant the availability of liquidity at any time, that any Transaction will be executed at a particular price or within any particular time, that prices displayed on the platform reflect prevailing market prices on external venues, or the performance, solvency, or conduct of any counterparty.
8.7. You bear all risks associated with market volatility, price movements, slippage, spreads, partial fills, or unfilled Transactions. MINT's records of Transactions shall, in the absence of manifest error, constitute prima facie evidence of the Transactions conducted through the platform.
9.1. You agree to pay all fees, charges, and costs applicable to your use of the Services, including in connection with the opening, maintenance, and operation of your User Account, Legal Tender Account, Digital Currency Wallet, and the execution of Transactions (collectively, "Fees").
9.2. Applicable Fees will be disclosed through the platform, a fee schedule, pricing page, transaction confirmation screen, or other written notice made available by MINT from time to time. Fees may be expressed as fixed amounts, percentages, spreads, tiered rates, or combinations thereof.
9.3. You authorise MINT to deduct applicable Fees automatically from your Legal Tender Account, Digital Currency Wallet, or transaction proceeds, as applicable.
9.4. Certain Transactions may incur fees charged by third parties, including blockchain network fees, validator or miner fees, payment processors, or banking institutions ("Third-Party Fees"). Third-Party Fees are not set or controlled by MINT and may fluctuate. MINT bears no responsibility for the amount, calculation, or collection of Third-Party Fees.
9.5. MINT may amend Fees from time to time to reflect changes in costs, market conditions, regulatory requirements, risk considerations, or business operations. Where a Fee change materially and adversely affects you, MINT will, where reasonably practicable, provide not less than twenty-one calendar days' advance written notice through the platform or by other reasonable means. Continued use of the Services after the effective date constitutes acceptance of the revised Fees.
9.6. Except where required by applicable law, Fees are non-refundable. All Fees are exclusive of VAT and other applicable taxes, duties, or levies, unless expressly stated otherwise. 10. TAXES
10.1. You are solely responsible for determining, declaring, and paying all taxes, duties, levies, assessments, or similar governmental charges that may arise in connection with your access to or use of the Services, any Transactions entered into through the platform, and the acquisition, holding, transfer, disposal, or valuation of Digital Currencies.
10.2. MINT does not provide tax, accounting, or legal advice. Nothing on the Site, through the Services, or in any communication by MINT constitutes tax advice or a representation regarding the tax treatment or consequences of any Transaction or Digital Currency.
10.3. MINT may be required by law, regulation, court order, or request from a competent authority to disclose information relating to your identity, accounts, or Transactions to tax authorities or other regulators, and you consent to such disclosure where lawfully required.
10.4. To the maximum extent permitted by law, you indemnify MINT against any loss, cost, liability, penalty, interest, or expense arising from your failure to comply with applicable tax laws or any claim by a tax authority relating to your use of the Services, except to the extent caused by MINT's wilful misconduct or gross negligence.
11.1. MINT may suspend, restrict, or terminate your access to the Site, the Services, any User Account, Legal Tender Account, and/or Digital Currency Wallet where MINT reasonably considers that such action is required or advisable to comply with applicable law, regulatory requirements, directives, or court orders; a security, integrity, operational, or cyber risk has arisen or is reasonably suspected; you have breached, or MINT reasonably suspects you have breached, these Terms; or continued access may expose MINT to legal, regulatory, financial, operational, or reputational risk.
11.2. MINT may take immediate action without prior notice where advance notice would be impracticable, unlawful, or would reasonably undermine the purpose of the suspension, including in cases involving suspected fraud, financial crime, security incidents, or regulatory intervention.
11.3. Where reasonably practicable and lawful, MINT will notify you of the fact of the suspension or termination and the general reasons for such action, provided that MINT shall not be required to disclose information where doing so would breach law, regulatory obligations, confidentiality duties, or prejudice investigations.
11.4. Suspension or termination does not affect any rights or remedies accrued prior to suspension or termination, or any provisions of these Terms intended by their nature to survive termination.
11.5. To the maximum extent permitted by law, MINT shall not be liable for any loss suffered as a result of any suspension or termination carried out in accordance with these Terms, other than where such loss arises from MINT's wilful misconduct or gross negligence.
12.1. MINT processes personal information relating to users and other data subjects strictly in accordance with the Protection of Personal Information Act 4 of 2013 ("POPIA") and MINT's Privacy Policy, which is available on the Site and is incorporated into and forms part of these Terms.
12.2. By using the Services, you acknowledge and agree that MINT may collect, use, store, record, disclose, and otherwise process personal information for lawful purposes, including to perform or conclude a contract with you, to comply with legal or regulatory obligations, to pursue MINT's legitimate business interests, or with your consent where required by applicable law.
12.3. You retain the rights afforded to you under POPIA, including rights of access, correction, objection, and complaint, which may be exercised in the manner described in the Privacy Policy.
13.1. All intellectual property rights of whatever nature, including copyright, trade marks, designs, patents, trade secrets, know-how, database rights, and rights in software, algorithms, interfaces, content, and documentation ("Intellectual Property") subsisting in or relating to the Site and the Services vest in, or are lawfully licensed to, MINT and/or its licensors.
13.2. Subject to your ongoing compliance with these Terms, MINT grants you a limited, non-exclusive, non-transferable, non-sublicensable, and revocable licence to access and use the Site and the Services solely for your internal, lawful, and permitted purposes. You may not copy, reproduce, modify, adapt, distribute, reverse engineer, scrape, or remove any proprietary notices from any part of the Site or Services.
13.3. All rights not expressly granted are reserved by MINT and its licensors.
14.1. All Transactions and transfers are subject to compliance with the Currency and Exchanges Act 9 of 1933 and the Exchange Control Regulations published thereunder. MINT implements controls to ensure that cross-border transfers and crypto-asset externalisation comply with applicable exchange control requirements.
14.2. By using the Services for cross-border transfers or transfers to external crypto-asset addresses or exchanges, you confirm that such transfers are within your applicable exchange control allowances or are supported by SARB approval, that the transfer complies with all applicable South African exchange control laws and regulations, and that you have made all required disclosures to SARS and the SARB.
14.3. MINT will decline to process any transfer that would cause you to exceed your applicable exchange control allowance without SARB approval. MINT bears no responsibility for the tax or exchange control consequences of your Transactions.
15.1. An account will be treated as dormant where no instructions or transactions have been initiated by the account holder for a continuous period of twelve months. In respect of dormant accounts, MINT will attempt to contact the account holder using registered contact details and may restrict trading and withdrawal functionality pending re-verification of the account holder's identity.
15.2. MINT will not charge additional fees solely on account of dormancy except as disclosed in MINT's fee schedule. Where an account remains dormant for three years and MINT is unable to contact the account holder after reasonable efforts, MINT will report and deal with unclaimed funds in accordance with applicable law.
16.1. You expressly acknowledge, understand, and accept that access to and use of the Site and the Services, and any Transactions entered into through the platform, involve significant risks. You confirm that you have carefully considered these risks and the Risk Policy, which forms part of these Terms, and elect to use the Services notwithstanding such risks.
16.2. You acknowledge and accept that you rely on your own judgment and, where appropriate, independent professional advice in deciding whether to access the Services or enter into any Transaction.
17.1. To the maximum extent permitted by applicable law, MINT shall not be liable to you or any third party for any indirect, incidental, special, consequential, or economic loss or damage of any nature whatsoever, including loss of profit, revenue, business opportunity, goodwill, anticipated savings, or data, whether arising in contract, delict (including negligence), statute, or otherwise, even if MINT has been advised of the possibility of such loss.
17.2. Nothing in these Terms is intended to exclude, restrict, or limit any right, remedy, guarantee, or warranty that cannot lawfully be excluded or limited under the Consumer Protection Act 68 of 2008 ("CPA") or any other applicable law to the extent that you qualify as a consumer for purposes of the CPA.
17.3. To the extent that MINT is found to be liable to you, MINT's total aggregate liability arising out of or in connection with the Services, these Terms, or any Transaction shall be limited to the total Fees actually paid by you to MINT in the twelve months immediately preceding the event giving rise to the claim, provided that this limitation shall not apply to any claim arising from MINT's wilful misconduct or fraud, any claim that cannot lawfully be excluded or limited under the CPA or the FAIS Act, or any claim in respect of which MINT is required by applicable regulatory determination to maintain unlimited or prescribed minimum liability.
17.4. MINT shall not be liable for any loss arising from the acts or omissions of third parties, including blockchain networks, validators, miners, payment processors, banks, or other service providers outside MINT's reasonable control.
18.1. You indemnify, defend, and hold harmless MINT, its directors, officers, employees, agents, and service providers from and against any and all losses, damages, liabilities, penalties, costs, and expenses (including reasonable legal fees) arising out of or in connection with your breach of these Terms or any representation or warranty, any prohibited use or unlawful activity conducted through your User Account, your misuse of the Site or Services, or any claim by a third party arising from your acts or omissions.
18.2. This indemnity applies irrespective of whether the relevant loss was foreseeable and survives the suspension or termination of your User Account.
19.1. MINT is committed to providing a high standard of service. If you wish to submit a complaint, you may do so in accordance with MINT's Complaints Policy, which is published on the Site. Complaints may be submitted through the dedicated complaints channel at [email protected]. The Complaints Policy explains MINT's procedures for receipt, handling, investigation, and resolution of complaints, and explains your right to refer a complaint to external dispute resolution bodies, including the FAIS Ombud.
19.2. The parties shall use reasonable efforts to resolve any dispute arising out of or in connection with these Terms amicably and in good faith before initiating formal dispute resolution proceedings.
19.3. Any dispute which is not resolved amicably shall be finally resolved by arbitration in the Republic of South Africa, conducted in accordance with the rules of the Arbitration Foundation of Southern Africa ("AFSA"), by an arbitrator appointed in accordance with those rules.
19.4. Nothing in this clause prevents either party from approaching a court of competent jurisdiction for urgent interim or injunctive relief. Nothing in this clause limits a complainant's right to refer a matter to the FAIS Ombud, the FSCA, the National Consumer Commission, or any other competent external dispute resolution body.
20.1. MINT may amend these Terms from time to time to reflect changes in applicable law or regulatory requirements, enhancements or modifications to the Services, or risk, security, or operational considerations.
20.2. Where an amendment materially and adversely affects your rights, MINT will provide you with not less than twenty-one calendar days' advance written notice of the proposed amendment through the platform, by email to the address registered to your User Account, or by other written means. You may close your User Account and withdraw your funds within the notice period if you do not accept the proposed amendment, in which case MINT will not apply the amended Terms to you. Continued access to or use of the Services after the expiry of the notice period constitutes acceptance of the amended Terms.
21.1. These Terms are governed by and construed in accordance with the laws of the Republic of South Africa.
21.2. Subject to clause 19, the courts of the Republic of South Africa shall have jurisdiction to hear any matter arising out of or in connection with these Terms.
22.1. Nothing in these Terms creates any partnership, joint venture, agency, or fiduciary relationship between you and MINT, and neither party has authority to bind the other.
22.2. Neither party shall be liable for any failure or delay caused by events beyond its reasonable control, including acts of God, war, terrorism, civil unrest, labour disputes, regulatory or governmental actions, failure of utilities or telecommunications, cyber incidents, blockchain network failures, or changes in law.
22.3. If any provision of these Terms is held invalid, unlawful, or unenforceable, that provision shall be severed and the remaining provisions shall remain in full force and effect.
22.4. These Terms, together with the Privacy Policy, Complaints Policy, Risk Policy, and any documents expressly incorporated by reference, constitute the entire agreement between you and MINT in relation to the Site and the Services and supersede all prior agreements, understandings, or representations.
22.5. Any failure or delay by MINT to exercise any right or remedy shall not constitute a waiver.
22.6. You may not assign or transfer your rights or obligations under these Terms without MINT's prior written consent. MINT may assign its rights and obligations in connection with a restructuring, sale of business, or similar transaction.
22.7. Provisions that by their nature are intended to survive termination shall survive, including clauses relating to liability, indemnity, dispute resolution, intellectual property, and data protection.