Privacy Policy

1. What we record

Kotiza only records what it uses to keep the ledger of a tontine (sou-sou, savings circle):

• your phone number, which is used as your sign-in identifier, and your name if you provide it;
• your email address: required to create a tontine, optional otherwise;
• the tontines you take part in, your position in the payout order, and your status;
• your contributions: amount due, due date, amounts received with their date and the payment method reported, and any remainder waived;
• the payouts received and their confirmation;
• the reminders sent: message content, channel, date, and any failure;
• a history of the actions taken in the tontine, which the organizer can view and which we keep.

2. Where this data comes from

Most of it is entered by the organizer of your tontine, including your name and your number, often before you open the app. The organizer is the one who added you to it.

If you do not want to be listed in a tontine, first ask your organizer to remove you. You can also write to us.

Kotiza does not collect any data about you from anywhere else. No data is bought or obtained from a third party.

3. What it is used for

To run the app: display the ledger, calculate due dates, send the reminders the organizer decides on, and authenticate you.

Your email address is used to contact you about your account. It is used to send you Kotiza news ONLY if you checked the matching box when you signed up. We keep the date of that consent, and each message includes an unsubscribe link. Saying no changes nothing about how the app works.

If an organizer added you to a tontine, you do not receive any marketing messages: this box only exists when an account is created, and only you can check it.

We do not sell or rent your data. We do not show any third-party advertising, and we do not pass anything on to a data broker.

4. Who can see it

The organizer of your tontine sees your contributions: that is the purpose of the tool.

Other members see the payout order, including members who have been deactivated, and the group's payouts. They do not see the details of other people's contributions. The history of actions is for the organizer only.

Organizers of other tontines see nothing about you. This separation is enforced by the database itself, as well as on screen.

Kotiza's operator is notified by email when an account is verified for the first time, and when an organizer creates their first tontine. This message includes the account's name, phone number, email address, country, and language, and, for an organizer, the name, amount, and number of members of their tontine. It is used to welcome and support new accounts, and stays in the operator's mailbox.

5. Our service providers

Kotiza relies on third-party services to host data and deliver messages. Each one only has access to what its function requires, and is not allowed to use it for any other purpose.

These providers operate outside Senegal: your data is therefore hosted and transmitted outside Senegal.

• Supabase — Database and authentication
• Vercel — Application hosting
• Twilio — Sending SMS and WhatsApp messages
• Paddle — Collecting subscription payments made by card, as Merchant of Record
• Sentry — Detecting application failures
• Google — The operator's mailbox (Google Workspace), which receives sign-up alerts and sends emails to organizers (welcome, invoices, credit notes)

6. How long we keep it

A tontine's data is kept as long as the tontine exists.

When the organizer deletes a tontine, it disappears from the app, but its members, contributions, payouts, reminders, and history are kept for 12 months in our databases: this is what makes it possible to recover the tontine after a deletion made by mistake. After 12 months, they are automatically and permanently erased.

The organizer can ask for this erasure sooner, and a member can ask for the erasure of the data about them (section 7).

Invoices and credit notes issued by Kotiza are kept for at least 10 years, with the name and phone number on them, because accounting law requires it. So an account that has any cannot be deleted. If you ask, we deactivate it: sign-in is blocked, the account's name and email address are erased, and its phone number stays on record.

To limit abusive attempts, our anti-abuse log keeps the phone number that receives a sign-in code for 25 hours, then erases it automatically. The first code request for a number also creates an account for that number, with no name or email address. If the sign-in is not completed, this account is erased after 30 days.

Sign-up alerts received by the operator are kept for 12 months at most.

7. Your rights

You can ask to see the data about you, have it corrected, object to its processing, or ask for it to be deleted.

Write to us from the number, or with the name, listed in the tontine, so that we can identify you without asking you for any additional document. We reply within a reasonable time.

Some data does not belong to you alone: a tontine's ledger is also your group's ledger. In that case, we will tell you what can be deleted and what you must ask your organizer for.

You can also file a complaint with the Commission de protection des données personnelles (CDP), Senegal's data protection authority.

8. Security

Communication with the app is encrypted. Access to data is separated by tontine directly in the database, so that a display error is not enough to expose another group's ledger.

No system is infallible. If an incident affects your data, we will inform you.

9. Cookies

Kotiza only sets the cookies it needs to work: your session cookies, which keep you signed in from one screen to the next, and the cookie that remembers the language you chose. There are no advertising cookies, no analytics, and no third-party trackers.

That is why you do not see a cookie banner: there is nothing to refuse.

10. Children

Kotiza is intended for adults. We do not try to collect data about minors.

Legal notice

Publisher:

Ascend International Professional Service SUARL

RCCM:

SN.DKR.2024.B.30459

NINEA:

011403467

Share capital:

300,000 FCFA

Registered office:

SICAP Dieuppeul 02, Villa n° 2458-D, Dakar, Sénégal

Publication director:

Madogal Tall

Sales in euros and dollars:

Paddle.com, our reseller and Merchant of Record; service provided by Ascend Intelligences LLC, registered in Maryland (United States) under No. W27302025

Contact:

contact@getkotiza.com