I. General Terms of Service (GTS)

• Purpose: This section defines the conditions of access to the platform, the respective responsibilities of the parties, and the applicable security rules.

1. Contractual framework

• Registration and use of the la-a-la platform constitute full and unconditional acceptance of these General Terms of Service, which form a legally binding service contract between the user and the platform operator.
• The user undertakes to comply with the laws and regulations in force in Togo, as well as those applicable in their country of residence, where applicable.

2. Single identity principle and traceability

• Each user may hold only one account associated with a real, verifiable, and traceable identity.
• The use of technical means intended to conceal, falsify, or bypass real user identification (including anonymizing VPNs, fraudulent proxies, non-traceable virtual numbers) is strictly prohibited when it interferes with regulatory controls.

3. Account responsibility

• The account holder is presumed responsible for any action, publication, or transaction carried out using their credentials.
• They are responsible for maintaining the confidentiality of their access credentials.
• Any suspected compromise must be reported to the platform without delay and no later than within 12 hours.

4. Suspension, restriction, and termination

• In the event of serious violations of these GTS, proven fraudulent behavior, regulatory breaches, or persistent inability to verify identity, the platform reserves the right to restrict, suspend, or terminate the account.
• Such measures may be applied proportionately, immediately if necessary, and in accordance with applicable legal and regulatory requirements.

II. Identity Verification Procedure (KYC – Know Your Customer)

• The platform applies a strict KYC system in compliance with the requirements of its payment partners, including PayDunya, and applicable financial compliance standards.

1. First-level verification (Onboarding)

• During registration, the following data are collected:
• Phone number linked to a properly registered SIM card.
• Valid email address.
• Date of birth to verify legal age.

2. Second-level verification (Enhanced KYC)

• For any financial transaction, the user must provide a valid official identity document (national ID, passport, or Togolese voter card).
• Proof of address or certified geolocation at the time of the transaction is also required.

3. Authenticity and liveness control

• To prevent document fraud or identity theft, the platform may use dynamic biometric verification technologies.
• Such processing is carried out with the explicit consent of the user.
• They are used exclusively for identification purposes.
• They are retained only for the strictly necessary duration.

4. Refusal and consequences

• Any falsified, expired, or inconsistent document results in the suspension of payment functionalities.
• Where applicable, the account may be closed after review, without prejudice to legal reporting obligations.

III. Anti-Money Laundering and Counter-Terrorism Policy (AML/CFT)

• The platform strictly applies Law No. 2018-004 of May 4, 2018 relating to AML/CFT in Togo.

1. Screening and filtering

• Users are subject to automated and regular screening against international sanctions lists.
• Relevant national databases are also used.

2. Transaction monitoring

• Financial flows are continuously monitored to detect artificial transaction splitting.
• Atypical or economically unjustified movements are also identified.
• Any suspicious source of funds is subject to enhanced analysis.

3. Suspicious activity reporting

• Any suspicious transaction is reported to CENTIF-Togo in accordance with the law.
• Such reporting is carried out without prior notice to the user, in application of the non-disclosure principle.

4. Data retention

• KYC data and transaction logs are retained for five (5) years after account closure.
• These data are stored on secure infrastructures.

IV. Content Moderation and Judicial Compliance

1. Content moderation

• The platform implements proactive moderation combining automated tools and human intervention.
• This moderation aims to combat hate, violence, defamation, and serious misinformation.

2. Cooperation with authorities

• Based on a valid judicial request, the platform fully cooperates with competent authorities.
• Such cooperation is carried out in strict compliance with the legal framework and professional secrecy.

3. Protection of minors

• Enhanced mechanisms are deployed to protect minors.
• These include priority reporting and secure preservation of evidence.