Privacy Policy Politique de Confidentialite

FiapPay ("we", "us", "our"), operated by Los Bebes Inc., is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect your data when you use our escrow platform for online commerce across social media channels including WhatsApp, Instagram, TikTok, and Facebook, via Mobile Money (MTN MoMo and Orange Money). By using FiapPay, you consent to the data practices described in this policy.

We collect the following categories of information to facilitate secure escrow transactions:

Information You Provide Directly:

• Phone Number: Your Mobile Money-registered phone number, used as your primary account identifier and for transaction processing.
• Transaction Details: Bill amounts, item descriptions, buyer/seller phone numbers, and transaction timestamps.
• Dispute Evidence: Photos, videos, screenshots, shipping receipts, and text descriptions you submit during a dispute.
• Communication Data: Messages exchanged with the FiapPay WhatsApp bot, including commands and responses.

Information Collected Automatically:

• Transaction Metadata: Timestamps, transaction statuses, payment confirmation codes from Mobile Money networks, and escrow lifecycle events (creation, locking, release, dispute).
• Device Information: Basic device identifiers provided by WhatsApp (e.g., WhatsApp Business API metadata).

Information We Do NOT Collect:

• Mobile Money PIN codes or passwords.
• Bank account details or credit/debit card numbers.
• Location data, contacts, or media from your device.
• Browsing history or cookies (this website is static and does not use tracking cookies).

We use the collected information strictly for the following purposes:

• Transaction Processing: To create bills, process Mobile Money payments, manage escrow holds, generate Release PINs, and execute fund disbursements.
• Fraud Prevention: To detect and prevent fraudulent transactions, unusual activity patterns, and violations of our Terms of Service.
• Dispute Resolution: To review evidence, mediate disputes, and issue binding determinations regarding escrowed funds.
• Service Communication: To send transaction confirmations, PIN codes, dispute updates, and important service notifications via WhatsApp.
• Platform Improvement: To analyze anonymized, aggregated transaction data to improve service reliability, performance, and security.
• Legal Compliance: To comply with applicable laws, regulatory requirements, and valid legal processes.

We do not sell, rent, or trade your personal data to third parties for marketing or advertising purposes. Ever.

We share your data only with the following categories of third parties, and only to the extent necessary to provide the Service:

• Mobile Money Payment Aggregator (CamPay): We share your phone number and transaction amounts with our licensed payment aggregation partner to process Mobile Money collection and disbursement. CamPay operates under its own privacy policy and regulatory obligations.
• WhatsApp Business API: Our bot operates on the WhatsApp Business platform. Messages exchanged with the FiapPay bot are subject to WhatsApp/Meta's Terms of Service and Privacy Policy.
• Cloud Infrastructure Provider: Transaction data is securely stored on encrypted cloud servers operated by our infrastructure partner (Google Cloud Platform). Data is encrypted at rest and in transit.
• Law Enforcement: We may disclose user data in response to valid legal requests, court orders, or when we believe disclosure is necessary to prevent fraud, financial crime, or to protect the rights and safety of our users.

We do not share your data with advertisers, data brokers, or any party not directly involved in the provision of the escrow service.

We implement industry-standard security measures to protect your personal information:

• Encryption: All data transmissions between our systems and Mobile Money APIs are secured using TLS/SSL 256-bit encryption.
• Access Controls: Access to user data is strictly limited to authorized personnel on a need-to-know basis, protected by multi-factor authentication.
• PIN Security: Release PINs are generated using cryptographically secure random number generators and are stored as hashed values. We never store PINs in plain text.
• No MoMo PIN Access: FiapPay integrates exclusively through official CamPay APIs. We never request, store, or have access to your Mobile Money PIN or password.
• Regular Audits: We conduct periodic security reviews of our infrastructure and codebase.

While we take extensive precautions, no system is 100% secure. We cannot guarantee absolute security of your data but are committed to promptly addressing any security incidents.

We retain your personal data for the following periods:

• Transaction Records: Retained for a minimum of 5 years from the date of the transaction, as required by applicable financial regulations and for audit purposes.
• Dispute Evidence: Retained for 2 years following dispute resolution, after which it is securely deleted.
• Communication Logs: Bot conversation logs are retained for 1 year for service quality and dispute reference purposes.
• Inactive Accounts: If your account has no transaction activity for 24 consecutive months, we may archive and subsequently delete your personal data, subject to regulatory retention requirements.

Upon expiration of the retention period, data is either securely deleted or anonymized so that it can no longer be associated with you.

Subject to applicable Cameroonian law, you have the following rights regarding your personal data:

• Right to Access: You may request a copy of the personal data we hold about you.
• Right to Correction: You may request correction of inaccurate or incomplete personal data.
• Right to Deletion: You may request deletion of your personal data, subject to our legal retention obligations. Note that deleting your data will terminate your ability to use FiapPay and will not affect completed transactions.
• Right to Restrict Processing: You may request that we limit how we use your data in certain circumstances.

To exercise any of these rights, contact our support team at +237 681 738 635. We will respond to verified requests within 30 calendar days.

FiapPay is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected data from a person under 18, we will promptly delete such information. If you believe a minor has used FiapPay, please contact us immediately.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will notify users via the FiapPay WhatsApp bot and update the "Last Updated" date at the top of this page. Your continued use of FiapPay after changes are posted constitutes your acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• WhatsApp Support: +237 681 738 635
• Company: Los Bebes Inc.
• Address: Bamenda, North-West Region, Cameroon
• Website: losbebesinc.com