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Privacy Policy: Cameroon

Last updated:

This policy reflects what we actually do with your data in Cameroon. It will be reviewed by counsel before launch. Treat the exact wording as provisional until then.

1. Who we are

Kolet is a payment orchestrator that lets you send money, buy airtime, and pay bills through WhatsApp. We are non-custodial. Licensed mobile money operators (MTN MoMo, Orange Money) hold your funds and are subject to their own regulatory oversight.

2. What we collect

  • Identity data you provide during signup: full name, date of birth, and your CNI (national identity card).
  • Phone number from your WhatsApp account, and your MTN MoMo or Orange Money number if different.
  • Transaction data: amount, recipient, time, category, and status reported by your mobile money operator.
  • Conversation context while using the bot: what you typed, what intent we inferred, what flow you chose. We do not store unrelated WhatsApp messages.
  • Device and session data: anonymized identifiers from WhatsApp webhook payloads.

3. How we use it

  • To verify your identity during signup (KYC), including matching your name against your mobile money registration.
  • To process the transactions you initiate.
  • To detect fraud and respond to security incidents.
  • To respond to support requests.
  • To comply with applicable Cameroonian law and lawful requests from regulators or law enforcement.

We do not sell your data. We do not use your data to train AI models visible to other users.

4. How we protect it

  • Your CNI is encrypted at rest with AES-256-GCM using keys held in a dedicated secrets manager.
  • Your transfer PIN is hashed using argon2id. It is never stored in plaintext and we cannot recover it for you.
  • WhatsApp Flows use Meta's end-to-end encryption protocol; data you type is encrypted on your device before Meta sees it.
  • Every account-changing action is logged for forensic investigation.

5. Who we share it with

  • Your mobile money operator: identity fields they need to open and maintain your account.
  • Service providers: companies helping us run the service, bound by confidentiality contracts.
  • Regulators and law enforcement: only when legally required.

6. How long we keep it

Transaction records: 7 years. Identity records: as long as your account is active, then 7 years after closure. Conversation context: 30 days. Logs: 90 days.

7. Your rights

Under applicable Cameroonian data protection law, you have the right to access your data, correct it, restrict its processing, and (subject to legal and regulatory holds) request deletion. Contact privacy@heykolet.com to exercise any of these rights.

8. Changes to this policy

If we change this policy materially, we will notify you via WhatsApp and post the updated version here with a new last updated date.