Developer & Student Escrow Agreement

Developer Terms of Service & Privacy Policy

Please read all terms and policies carefully before creating an account, generating an API key, or connecting to the StarterPay checkout platform.

Effective DateSeptember 9, 2026
Last UpdatedSeptember 9, 2026
Platformstarterpay.online
JurisdictionCameroon (CEMAC)

Mandatory Legal Notice

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.

PART 1: 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 Limits

StarterPay enforces a strict, automated 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:

2.1. Tier 0: Sandbox / Mock Testing

0 XAF
  • Purpose: Localhost and staging code testing only.
  • Capital Limit: 0 XAF (Simulated fake transactions only).
  • Requirement: Email registration.

2.2. Tier 1: Student Builder & Idea Validation Tier (Simplified Due Diligence - SDD)

Max: 200 000 XAF25 000 XAF / tx

Purpose: Minimal Viable Product (MVP) testing, student innovation, and commercial validation.

Cumulative Lifetime Cap: 200,000 XAF gross transaction volume per developer profile.

Single-Transaction Cap: 25,000 XAF maximum per single transaction.

Mandatory Documentation:
  1. Certified photocopy of valid Cameroonian National Identity Card (CNI) or valid Passport.
  2. Proof of active student status (Student ID card or current academic year tuition slip).
  3. Personal Taxpayer Identification Number (Numéro d'Identifiant Unique - NIU) issued free by the Directorate General of Taxation (DGI via impots.cm).
  4. Working Project URL, public repository, or APK demo link.
  5. Accurate, 2-sentence written statement describing the exact nature of goods/services sold.
Enforcement Rule: Crossing the 200,000 XAF lifetime cap triggers an immediate, automated hard freeze on live checkout processing. Any attempt to cycle accounts, create duplicate profiles, or split transactions to bypass this limit constitutes fraud and will result in permanent blacklisting and legal escalation.

2.3. Tier 2: Commercial Scale Tier (Standard Customer Due Diligence - CDD)

Uncapped

Purpose: Uncapped commercial processing for validated startups and established merchants.

Mandatory Corporate Documentation:
  1. Commercial Register certificate (Registre du Commerce et du Crédit Mobilier - RCCM) under OHADA Uniform Act on General Commercial Law.
  2. Corporate/Business Taxpayer Card (Carte de Contribuable).
  3. Certificate of Non-Indebtedness (Attestation de Non-Redevance - ANR).
  4. Verified commercial bank or corporate mobile money merchant account.

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 academic study aid 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 API keys, forfeiture of pending 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, hosted checkouts, and sandbox environments 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.

PART 2: 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, residential quarter/address, phone number, active student ID card image, CNI/Passport document scans, and DGI Taxpayer Number (NIU).
  • Technical Transaction Data: IP address, user-agent string, device fingerprint, API key prefix, and signed clickwrap 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 200,000 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.

PART 3: DEVELOPER ATTESTATION REQUIREMENTS

Mandatory declarations confirmed during developer account registration

Upon account creation and prior to generating live API credentials, developers electronically attest to the following statutory commitments:

  • All submitted documents (CNI, Student ID, and NIU) are authentic and belong personally to the developer.
  • Tier 1 access is an MVP testing sandbox capped at 200,000 XAF cumulative lifetime volume, with a single-transaction limit of 25,000 XAF.
  • 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.
  • StarterPay operates strictly as a Technical Service Provider (PST) and does not hold public deposit accounts.

By creating an account on StarterPay, you confirm your full consent to these legal terms.

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