Data Processing Policy

Last updated: 01/07/2026

Technical complement to the Privacy Policy, describing the record of processing activities and the minimization measures.

1. Record of processing activities

Processing	Data	Purpose	Legal basis	Retention
Payment collection	phone number (encrypted), amount, payment method	execute the payment	contract	phone 90 days; financial 10 years
Access delivery	ticket reference, access credentials	deliver the access	contract	as per ticket
Anti-fraud	phone hash, signals	prevent fraud (§90)	legitimate interest	as long as necessary
Operator account	name, WhatsApp, e-mail, withdrawals	provide the service	contract	duration of the relationship
Logging	technical events (without superfluous personal data)	security, audit	legal obligation / legitimate interest	as long as necessary

2. Minimization principles

No customer account: the end customer is not registered as a user.
Encryption at rest of the phone number, purge after 90 days, retention of a permanent hash and of a masked version only.
No decryption during the purge (direct deletion).
Masked display by default in all interfaces.
No profiling or marketing.

3. Processors

Payment providers (FedaPay, FeexPay) for carrying out the transactions; host [to be completed]. Each is bound by security and confidentiality obligations.

4. Transfers

The data is hosted by [to be completed] ([to be completed]). No transfer beyond what is necessary for the performance of the service.

5. Rights and how to exercise them

The rights of access, rectification, erasure, restriction and objection may be exercised by contacting [to be completed], subject to legal retention obligations (financial data: 10 years). Supervisory authority: APDP — Autorité de Protection des Données Personnelles (Bénin).

6. Data breach

In the event of a breach likely to result in a risk, WinetPay implements the notification measures required by the applicable regulations.