LE COINTAR

Privacy Policy

Last updated: [date to be filled in at launch]

This policy explains what personal data Le Cointar collects, why, who it is shared with, and what rights you can exercise. The data controller is [company name — to be registered with the RCCM], [address to be completed].

1. The data we collect

When you create your account, and as you use the Service:

  • Identity and contact: phone number (required, SMS-verified), username, display name, bio, profile photo, commune, email (optional).
  • Payment details: the Mobile Money number and operator you choose to receive your sales on, which every seller must provide to publish a listing, and which is shared with a buyer once they place an order so they can pay you directly — never your Mobile Money PINs or login credentials.
  • Identity verification (optional): if you choose to have your identity verified, a photo of your ID is transmitted to a moderator through a secure, restricted-access link; we do not retain the ID document number itself.
  • Platform activity: listings published, messages exchanged and their attachments, reviews given and received, offers, orders, disputes, reports, favorites, search alerts.
  • Trust signals: Cointar Score and its components (completed sales, disputes lost, response rate and time, account age).
  • Technical: your device's push notification token (if enabled), chosen language, low-data mode preference, last-seen date.

2. Why we use it

  • Create and secure your account, and verify your identity by SMS.
  • Enable listing publication, matching, messaging, and coordinating orders paid directly between buyer and seller.
  • Share your receiving Mobile Money number with a buyer who has placed an order, so they can pay you directly.
  • Calculate the Cointar Score to strengthen trust between buyers and sellers.
  • Moderate listings, and handle reports and disputes.
  • Send the notifications and alerts you requested (new offer, message, search alert, order status).
  • Prevent fraud and keep the Service secure.

3. Who we share it with

Le Cointar never sells personal data. Some data is passed to technical providers, solely to operate the Service, under contracts that require them to protect it:

  • Clerk — phone number verification and login management.
  • The Mobile Money payment provider chosen by Le Cointar (pawaPay or FlexPay) — used only for the optional paid listing-boost feature, when available; purchases between users are paid directly between them and never pass through this provider.
  • Cloudinary — hosting listing photos, profile photos, and ID documents submitted for verification.
  • Resend — sending emails (search alerts, notifications).
  • Expo / Google / Apple — delivering push notifications to your device.
  • Vercel and Neon — hosting the website and the database.

Some of these providers process data outside the Democratic Republic of Congo. We only work with providers that impose contractual security safeguards for this.

We may also disclose data to a competent authority where required by law, or to assert our rights in the event of proven fraud.

4. What other users see

Your username, photo, bio, commune, listings, Cointar Score and reviews about you are public. Your login phone number is never shown to other users; only a WhatsApp number you choose to provide may be publicly visible. Your receiving Mobile Money number stays private except to a buyer who has placed an order on one of your listings: it is then shared with them so they can pay you directly.

5. How long we keep it

Your data is kept as long as your account is active. If your account is deleted, identifying data is deleted or anonymized within a reasonable time, except for information we must retain longer to comply with a legal or accounting obligation (in particular transaction history), or for as long as needed to resolve an ongoing dispute.

6. Your rights

You may at any time ask us for:

  • access to the data we hold about you;
  • correction of inaccurate information;
  • deletion of your account and your data, subject to the legal retention periods mentioned above;
  • a copy of your data in a reusable format.

To exercise these rights, contact us at [contact email to be created, e.g. privacy@lecointar.cd]. We respond within a reasonable time after verifying your identity.

7. Security

Access to ID documents submitted for verification is restricted to authorized moderators and happens through time-limited signed links. Passwords and login codes never pass through our internal messaging. We apply reasonable technical and organizational measures to protect your data against unauthorized access, loss or disclosure.

8. Cookies and trackers (website)

The website only uses cookies strictly necessary for it to function (keeping you signed in, remembering your chosen language and the source of a referral). We do not currently use any advertising cookie or third-party audience-measurement tracker.

9. Minors

The Service is reserved for people aged 18 and over. We do not knowingly collect data about minors; if we become aware of any, the account concerned is deleted.

10. Changes to this policy

We may amend this policy to reflect changes to the Service, our providers, or applicable regulations. Any substantial change will be notified to you before it takes effect.

11. Contact

For any question about your personal data: [contact email to be created, e.g. privacy@lecointar.cd].