Developer Terms of Service & Privacy Policy
Please read all terms and policies carefully before creating an account, generating a hosted checkout link, or connecting to the Starterpay checkout platform.
PLEASE READ THESE TERMS OF SERVICE CAREFULLY. BY CREATING AN ACCOUNT, GENERATING AN API KEY, CREATING A HOSTED CHECKOUT LINK, OR CONNECTING TO THE STARTERPAY PLATFORM, YOU AGREE TO BE BOUND BY ALL PROVISIONS HEREIN. IF YOU DO NOT AGREE, DO NOT GENERATE API KEYS OR INTEGRATE THE SOFTWARE.
DEVELOPER TERMS OF SERVICE
Contractual framework, tiered compliance, and merchant obligations
1.Legal Status & Nature of Service
1.1. Technical Service Provider (PST): Starterpay operates strictly as an independent Technical Service Provider (Prestataire de Services Techniques) providing developer software, payment orchestration, API gateways, and hosted checkout redirect interfaces. Starterpay is NOT a bank, a credit institution, an electronic money issuer, a money remitter, or a payment service provider as defined under CEMAC Regulation No. 04/18/CEMAC/UMAC/COBAC.
1.2. Third-Party Processing: Starterpay does not take custody of, hold, or pool financial deposits. All payment processing, wallet crediting, mobile money escrow, and carrier settlements are executed downstream by approved, licensed telecommunication network operators (MTN Cameroon, Orange Cameroun) and licensed upstream settlement intermediaries (including Fonlok Technologies).
1.3. No Commercial Agency: Starterpay is an independent contractor. Starterpay is not an agent, joint venturer, partner, or guarantor of any developer, merchant, or end-consumer utilizing its APIs or checkout links.
2.Tiered Access Framework & Mandatory Verification
Starterpay enforces a strict Two-Tier compliance model to maintain compliance with regional Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) requirements under CEMAC Regulation No. 01/CEMAC/UMAC/CM:
Tier 1 • Builder Validation (Simplified Due Diligence - SDD)
Purpose: MVP testing, commercial validation, and early builder transactions. Start collecting real Mobile Money from customers using Hosted Payment Links & Checkout Redirects without Day-1 corporate bureaucracy.
Cumulative Lifetime Cap: 500,000 XAF gross transaction volume per developer profile with a minimum of 500 XAF per transaction.
- National ID card (CNI or Passport) — Front & Back
- Live identity selfie verification
- Platform name, project description & live demo URL
- Optional: University Student ID (unlocks campus perks & badges)
Tier 2 • Scale & Enterprise (Standard Due Diligence - CDD)
Purpose: For validated startups and growing businesses that have proven demand, outgrown validation caps, and require programmatic REST API keys.
- Unlocked once cumulative sales cross 500,000 XAF
- Formal business registration (RCCM)
- Taxpayer ID number (NIU)
- Corporate bank account or verified merchant wallet
- Unlocks Direct Server-to-Server REST API (POST /api/v1/pay)
3.Developer Responsibilities & Mandatory Merchant Disclosures
Under Cameroon Law No. 2010/021 on Electronic Commerce, developers utilizing Starterpay's hosted checkouts or REST APIs must provide clear pre-contractual disclosures to their end-consumers, including:
- 3.1. Clear and truthful product descriptions, software licenses, or digital service details.
- 3.2. Clear pricing quoted in CFA Francs (XAF) inclusive of all applicable taxes.
- 3.3. Direct contact information (email or WhatsApp support line) visibly displayed on their app or checkout page.
- 3.4. An explicit refund, cancellation, and dispute policy.
- 3.5. Automated Digital Delivery: For software, downloadable files, or digital tickets, developers must integrate automated fulfillment links or file delivery. Starterpay's automated escrow release is contingent upon verifiable digital fulfillment.
4.Acceptable Use Policy (Zero-Tolerance Prohibited Activities)
Starterpay strictly prohibits its APIs, checkout links, and services from being used directly or indirectly for:
- Unlicensed investment schemes, pyramid schemes, Ponzi arrangements, high-yield return promises, or network marketing.
- Cryptocurrency trading, peer-to-peer crypto arbitrage, or token sales.
- Sports betting, casinos, lotteries, games of chance, or gambling pools (e.g., 1xBet / Aviator betting bots).
- Adult entertainment, explicit digital content, or escort services.
- Counterfeit digital goods, unauthorized distribution of copyrighted intellectual property, or hacked software licenses.
- Sub-aggregation (acting as an unlicensed payment gateway for third parties).
Any violation of this section results in immediate termination of account access, forfeiture of integration privileges, and mandatory disclosure to national authorities (ANIF, MINFI, and the Judicial Police).
5.Chargebacks, Disputes, and Personal Financial Indemnity
5.1. Personal Financial Liability: Every Tier 1 developer is onboarded under their verified natural person identity (CNI). The developer assumes full, 100% personal financial liability for all customer disputes, fraud flags, unauthorized chargebacks, or network operator penalties originating from their application.
5.2. Indemnification: Developer agrees to defend, indemnify, and hold harmless Starterpay, its founders, and technical partners against any and all claims, financial losses, regulatory fines, or legal expenses resulting from the developer's breach of law, false product claims, or fraudulent transactions.
5.3. Clawback Authorization: If a telecommunication carrier or upstream partner claws back funds or issues penalties against Starterpay due to disputes or fraud on the developer's project, the developer authorizes Starterpay to offset pending balances or demand full restitution payable within forty-eight (48) hours.
6.Limitation of Liability
6.1. Starterpay provides its software and hosted checkouts on an "AS IS" and "AS AVAILABLE" basis. Starterpay disclaims all warranties regarding telecommunication network uptimes, USSD prompt delivery speeds, or upstream settlement delays caused by MTN, Orange, or partner aggregators.
6.2. In no event shall Starterpay or its developers be liable for indirect, incidental, punitive, or consequential damages (including lost profits or business disruption).
6.3. Starterpay's total aggregate liability arising from any event shall be strictly limited to the platform fee revenue retained by Starterpay on the developer’s specific disputed transaction, capped at a maximum of Ten Thousand (10,000) XAF.
7.Governing Law & Dispute Resolution
These Terms are governed by and construed in accordance with the laws of the Republic of Cameroon and the OHADA Uniform Acts. Any unresolved dispute arising from these Terms shall be submitted to the exclusive jurisdiction of the competent courts of Yaoundé, Cameroon.
PRIVACY POLICY & AUDIT DATA LOGGING
Compliance with Cameroon Law No. 2010/012 on Cybersecurity and Cybercrime
1.Information We Collect
To satisfy regional AML/CFT obligations (COBAC & ANIF), Starterpay collects:
- Developer KYC Data: Full legal name, phone number, CNI/Passport document scans, and live identity selfie verification.
- Technical Transaction Data: IP address, user-agent string, device fingerprint, and signed clickwrap acceptance timestamps.
- Payer Data: Payer telephone number (stored masked and cryptographically hashed for velocity fraud detection), transaction references, and purchase amounts.
2.Purpose of Processing
Your data is used strictly for:
- Provisioning developer credentials and payment checkout routing.
- Calculating velocity thresholds and enforcing the 500,000 XAF Tier 1 cap.
- Defending against payment fraud, credential cycling, and chargeback disputes.
- Fulfilling statutory customer due diligence requirements under CEMAC law.
3.Disclosure to Authorities
Starterpay maintains confidentiality and does not sell or lease personal data. However, you acknowledge and agree that Starterpay is legally mandated to surrender developer identities, KYC dossiers, IP logs, and transaction audit records to:
- ANIF (Agence Nationale d'Investigation Financière) in the event of structured AML/CFT investigations.
- Law enforcement bodies (Gendarmerie Nationale, Judicial Police) acting under an official warrant or court order.
- Upstream regulated banking/fintech partners for resolving merchant chargeback fraud disputes.
4.Data Retention Period
Under COBAC and regional banking guidelines (CEMAC Regulation No. 01/CEMAC/UMAC/CM, Article 42), all transaction logs, KYC verification files, and Terms of Service clickwrap acceptance records are archived in immutable, encrypted audit logs for a minimum statutory period of ten (10) years following account closure.
DEVELOPER ATTESTATION REQUIREMENTS
Mandatory declarations confirmed during developer account registration
Upon account creation and prior to generating live checkout links, developers electronically attest to the following statutory commitments:
- All submitted documents (National ID or Passport and live identity selfie) are authentic and belong personally to me.
- Tier 1 access is an MVP validation tier capped at 500,000 XAF cumulative lifetime volume.
- The developer agrees to the Starterpay Terms of Service and accepts full personal financial liability for all transactions processed through their project.
- The project does not involve sports betting, crypto arbitrage, forex trading, adult services, or high-yield investment schemes (Ponzi/MLM).
- Starterpay operates strictly as a Technical Service Provider (PST) and does not hold public deposit accounts.