Privacy Policy

1. Data controller

The data controller is TrustChange SARL, which develops and operates the TrustChange Pay solution (TrustChange Pay is not a separate legal entity), RCCM CM-DLA-01-2025-B12-00673, with its registered office at 659 rue Centrale à gaz, Douala, Cameroun.

For any question about your data, write to contact@trustchange.fr with the subject "Personal data". Your request is handled by the compliance officer. We apply Cameroonian Law No. 2010/012 of 21 December 2010 on cybersecurity and cybercrime and, where applicable, the EU General Data Protection Regulation (GDPR).

2. Who this policy covers

• Customers and their representatives: account holder, beneficiaries, invited members.
• Recipients of a payout or payers of a payment link.
• Visitors to the websites, people contacting us or filling in a form.

3. Data we process

• Account: first and last name, email, phone, country, hashed password, security settings.
• Identity verification: document type, number, expiry date, front and back images, selfie and liveness gestures, consent date, IP address and capture device.
• Account and compliance: address, occupation, source of funds, screening results (sanctions, politically exposed persons), review notes and decisions.
• Transactions: amount, currency, operator, Mobile Money number, wallet address and network, reference, status, timestamp.
• Wallet and documents: movements, monthly statements, address book entries, messages to support and in the chat.
• Technical: IP address, device, login and API logs, push notification tokens, audit log.

We never ask for your password, PIN or one-time codes. No card number is entered in our forms: card payments, where offered, are entered in a secure field provided by the payment provider.

4. Purposes and legal bases

• Create and manage your account, execute transactions, provide support: performance of the contract.
• Verify your identity, screen sanctions, assess risk, monitor transactions: legal obligation and partner requirements, legitimate interest in preventing financial crime.
• Secure the platform, detect fraud and abuse, keep evidence: legitimate interest.
• Keep you informed about the service (security, incidents, changes to terms): performance of the contract.
• Send you product news: your consent, which you may withdraw at any time.
• Respond to authorities and defend our rights: legal obligations, legitimate interest.

We do not sell your data and do not use it for advertising.

5. Identity verification and biometric data

Identity verification is carried out in the application with guided capture: face and requested gesture detection, image quality and screen or virtual camera checks.

• Consent: capture only starts after your explicit, timestamped consent.
• Restricted access: only authorised members of the compliance team can view the images, through an authenticated and logged interface.
• Human decision: no refusal is ever decided in a fully automated way; automated checks assist a reviewer, who decides.
• Single purpose: these data are used exclusively for identity verification and the prevention of document fraud.

6. Recipients

Your data are only accessible to authorised TrustChange staff, according to their duties. They may be shared, strictly to the extent necessary, with the following categories:

• Mobile Money operators and licensed payment aggregators: execution of collections, payouts and refunds (number, amount, reference).
• Public blockchains: the address and amount of a transfer are, by nature, public and final.
• Sanctions and media screening providers: screening of persons and addresses.
• Microsoft Azure: hosting of the websites, the back office and automated processing.
• Push notification service and SMS/email delivery service: routing of codes and alerts.
• Judicial or administrative authorities, on lawful request, and payment partners for anti-money laundering purposes.

7. Transfers outside Cameroon

Some recipients are established in, or process data from, outside Cameroon, in particular in the European Union. These transfers are limited to what the service requires and are governed by contractual confidentiality and security commitments, in line with applicable regulations.

8. Retention periods

• Account and profile: duration of the relationship, then archived for the applicable limitation period.
• Identity verification file, images and screening results: duration of the relationship then five (5) years (AML/CFT obligation).
• Transactions, statements and accounting records: five (5) years after account closure.
• Security, login and API logs: twelve (12) months, unless an incident or investigation is ongoing.
• Support and chat exchanges: three (3) years after the last contact.
• Cookie and theme choices: thirteen (13) months at most.

At the end of these periods, data are deleted or anonymised. They may be kept longer in the event of proceedings, an investigation or a request from an authority.

9. Security

• Encrypted communications (HTTPS/TLS); secrets and credentials stored as hashes.
• Protected passwords, transaction PIN, time-limited one-time codes with a limited number of attempts.
• Short sessions with renewal, ability to sign out a device, optional biometric lock.
• Need-to-know access to data, audit log of sensitive operations, identity documents kept on access-restricted servers, never publicly exposed.

In the event of a data breach posing a risk to your rights, we will inform you, and the competent authority where the law requires, as soon as possible.

10. Your rights

You have the right to access, rectify, erase, restrict and object to the processing of your data, and to withdraw any consent at any time.

Some data cannot be erased before the end of the statutory periods, in particular due diligence and transaction data kept for anti-money laundering purposes; they are then archived with restricted access. Account and data deletion is requested from the Delete my data page, or by email to contact@trustchange.fr.

To exercise your rights, write to contact@trustchange.fr with the subject "Personal data". We may ask you to prove your identity. We respond within one month, which may be extended by two months for complex requests. If you believe your rights have not been respected, you may lodge a complaint with the competent data protection authority.

11. Deleting your account and your data

You may at any time request the deletion of your TrustChange account and the data attached to it, or the deletion of certain data only, from the pay.trustchange.fr/mydata page. The same page is also reachable at pay.trustchange.fr/delete-account. This form is also the page declared to Google Play as the "account deletion URL".

The request is sent to support with a reference (for example DEL-20261024-A1B2C3). We check that the requester is the account holder, acknowledge receipt within 72 hours and process the request within thirty (30) days. No data is deleted on the basis of an unverified email request.

• Deleted: account, profile, address book entries, notification tokens, chat history and deletable usage data.
• Kept after closure for five (5) years: identity verification file, supporting documents and transaction data, to meet our anti-money laundering obligations.
• Kept for the duration of the investigation: data relating to a disputed transaction, a fraud or a request from an authority.
• Anonymised: usage statistics and technical logs, once the retention period is reached.

Account deletion is final: the available balance must be withdrawn beforehand. A closed account cannot be reactivated; a new registration starts a new verification file.

12. Cookies and local storage

To date, we use no audience measurement tools and no advertising trackers. Only items needed for the service to work or to remember your preferences are stored:

• Website language (French or English): cookie, one year.
• Light or dark theme and consent choice: local storage, until deleted.
• Application session: access and refresh tokens, stored securely on the device, time-limited and revocable.
• Interface preferences (display currency, last identifier entered): local storage, until sign-out or deletion.

Should we ever introduce a measurement or marketing tool, it would only be enabled with your prior consent, collected and changeable through the consent banner.

13. Recipients' and payers' data

When you pay a customer by Mobile Money or through a payment link, that customer remains responsible for its commercial relationship with you. TrustChange processes your payment data to execute the transaction, prevent fraud and meet its legal obligations. For a question about an order, contact the beneficiary first; for a question about the processing of the payment itself, write to us.

Accounts are reserved for adults. We do not knowingly collect data from minors to open an account. This policy may change: the effective date appears at the top of the page and, in case of a significant change, we will inform you by email or in the application.