This Privacy Policy is established in accordance with: - Senegalese Law No. 2008-12 of January 25, 2008 on the protection of personal data - Decree No. 2008-721 of June 30, 2008 implementing Law No. 2008-12 - UEMOA and BCEAO regulations relating to anti-money laundering and counter-terrorist financing - The African Union Convention on Cyber Security and Personal Data Protection - The Senegalese Civil and Commercial Obligations Code - Applicable accounting, tax and regulatory obligations in Senegal

Welcome to Maman Tontine. IMCO Digital is committed to protecting your personal data and your privacy. This policy explains: - What information we collect - How we use it - How we protect it - What rights you have over your data By using Maman Tontine, you agree to this Privacy Policy.

Maman Tontine is a platform operated by IMCO Digital, dedicated to digitizing, securing and automating traditional tontines, savings wallets and group contribution management. Data controller: IMCO Digital Contact: contact@imco.digital Location: Dakar, Senegal

4.1 Registration information Identity document collection is limited to users accessing sensitive features, especially users authorized to release tontine funds. Other users may be verified indirectly through mobile money partner operators. 4.2 Financial data - Mobile Money number, including Orange Money and Wave - Transaction history, including contributions and withdrawals - Contribution amounts 4.3 Usage data - Login dates and times - Device type - IP address - Activity logs within the application 4.4 Tontine and group data - Information about groups created - Lists of participating members - Management rules defined by the group - Communications within groups

We use your information to: - Manage your account, including registration, authentication and profile management - Process transactions, contributions, withdrawals and payment tracking - Verify identity and prevent fraud - Facilitate notifications, alerts and group communications - Improve our services through analysis, support and bug fixes - Comply with legal and regulatory obligations

For sensitive features, especially the release of tontine funds, enhanced identity verification mechanisms may be applied under supervision and as part of technology partnerships with duly authorized financial institutions. 6.1 Who we may share data with Payment providers: - Orange Money, Wave and other approved payment partners for transaction processing - These partners access only the data needed to process payments Members of your tontine or group: - Other members may see your name, first name and contribution status - Group administrators may access information needed to manage their group Legal authorities: - When required by law, court order or regulation - To prevent fraudulent, illegal or abusive activities 6.2 What we never do - We do not sell your data - We do not rent your data - We do not share your data for advertising purposes

We apply security measures to protect your information: - Encryption of sensitive data - Restricted access for authorized personnel only - Monitoring for suspicious activity - Regular security updates - Account protection through authentication mechanisms Important: no system is completely risk-free. If a security incident occurs, we will take appropriate action and notify affected users when required.

- Active account: for as long as the account is used - After account deletion: up to 3 months for legal and accounting reasons - Financial data: up to 5 years when legally required - Identity documents: up to 5 years after the end of the relationship when applicable You may request early deletion of your data unless retention is required by law.

Subject to applicable data protection laws, you may have the right to: - Access the data we hold about you - Correct inaccurate or incomplete information - Request deletion of your account and personal data - Object to certain data processing activities - Receive your data in a usable format - Request restriction of data processing IMCO Digital relies on internal resources and specialized providers to support regulatory compliance.

The application may use cookies or similar technologies to: - Keep your session active - Remember preferences - Analyze service usage You can disable cookies through your device or browser settings, but some features may no longer work properly.

Personal data collected through Maman Tontine may be hosted on secure cloud infrastructure operated by technology providers. Some data may be stored or processed outside Senegal, including in data centers located in countries that provide appropriate personal data protection standards. IMCO Digital ensures that transfers outside Senegal are governed by appropriate safeguards in accordance with applicable personal data protection laws and recognized security and confidentiality standards.

Maman Tontine is intended for adults aged 18 and over. We do not knowingly collect personal data from minors. If you believe a minor has created an account, please contact us immediately.

We may update this Privacy Policy. In case of significant changes, we may notify users through the application. The latest update date should always be indicated in the applicable policy document.

If you have concerns about how your data is processed, please contact us first: contact@imco.digital If you are not satisfied, you may contact the competent authority: Commission de Protection des Données Personnelles (CDP) of Senegal Email: Contact.cdp@cdp.sn Phone: +221 33-859-70-30 / 76-678-74-52

For questions about this Privacy Policy: Email: contact@imco.digital Phone: +221711157676 WhatsApp: +221711157676 Application: Support section in the settings Address: IMCO Digital, Dakar, Senegal

By creating an account on Maman Tontine, you confirm that you have read and accepted this Privacy Policy. Important - Account verification and security Each user is identified by a mobile phone number verified by OTP. All transactions are linked only to that number. Changing a phone number requires a new OTP verification. Funds are processed exclusively through approved operators, and Maman Tontine does not directly store or process user funds. This English version is provided for convenience. In case of conflict or interpretation issue, the French version of the Privacy Policy prevails.