Privacy policy

Effective date: November 7, 2026

This policy explains what data Funda processes, why, where it is kept, for how long, and how you can act on it. It applies to the Funda app (iPhone and Android), to the Funda journey on WhatsApp and to Funda's web pages (forms, public map).

1. Who is responsible for your data

Funda is a private and independent service. It is not a government service, nor the police, nor an emergency service.

• Publisher and data controller: [À COMPLÉTER : raison sociale]
• Address: [À COMPLÉTER : adresse]
• Registration: [À COMPLÉTER : RCCM / Id. nat.]
• Contact: [À COMPLÉTER : e-mail de contact]
• Data protection officer: [À COMPLÉTER : responsable de la protection des données]

2. The principle

Funda is for reporting a fact, not a person. We aim to collect as little as possible, to keep it for as short a time as possible, and never to publish anything that can identify someone.

3. The data we process

Your account

• Your phone number. It is used to create your account and to log you in. We also keep an encrypted fingerprint of this number (a code calculated from the number, which cannot be turned back into the number). It is used to prevent a banned account from being recreated straight away with the same number.
• The verification code we send you. We keep only a fingerprint of the code, never the code itself. A login code is valid for 10 minutes. An account deletion code is valid for 5 minutes.
• The display name you choose, your language and your time zone.

Your profile (optional)

None of this is mandatory. A number is enough to report something or ask for help.

• Last name, first name, date of birth, sex, languages spoken.
• Address in parts (municipality, neighborhood, avenue, number, landmark, directions) and, if you choose, an approximate "home" point.
• Occupation.
• Type and number of identity document, medical information. These three items are encrypted by the application before being saved in the database. This protects a copy of the database or a lost backup. It does not protect against someone who has taken control of the server, since the key is stored there. Medical information is intended for emergency services only.
• We do not ask for any photo of an identity document.

Your reports and contributions

• The content you post: category, text, place, time, photos, voice note (30 seconds at most).
• Your confirmations ("still there", "gone"), your comments and your thanks.
• Your abuse flags and your appeals against moderation decisions.

Photos

• Blurring is done on your phone, before anything is sent. The app looks for faces and license plates and blurs them automatically, on iPhone and on Android alike. On Android, it uses the Google Play services models for this, which run on the phone: the photo is not sent to Google. You can always blur a missed area yourself. The blur is written into the image and cannot be removed.
• The app removes the photo's metadata before sending it.
• If a GPS location is still present in the file we receive, we read it to check that the photo was indeed taken near the reported place. This location is never published. The displayed versions of the photo are recreated without any metadata.
• Photos received through WhatsApp do not go through the app's blurring. They remain private and are reviewed by the Funda team before any use.

Your location

• The app asks for your location only while you are using it, never in the background. You can refuse: the map remains usable.
• Your location is read at the moment you need it: to place a report, to show what is happening around you, for an on-site confirmation, for a help request or an SOS.
• For sensitive categories, the published location is rounded, so that a report made from home does not reveal the address.
• A device location saved to target alerts is rounded to about 100 meters and erased after 30 days.
• During an SOS, a help request or "Watch over me", your location is sent for as long as the session is open. When you close the session, its locations are deleted. No route history is kept after it ends.

Your areas and alert preferences

The areas you follow (circle, neighborhood, route, drawn shape), their schedules and categories, the alert radius, quiet hours, frequency and notification switches.

Your trusted contacts

• To invite someone close to you, you choose a contact from your address book. We receive their name as you write it and their number. They receive an invitation on WhatsApp.
• The contact's number is erased as soon as they accept or decline. The link then goes through their Funda account.
• A contact is warned only if you ask for help or trigger an SOS. They never see your location the rest of the time.

Data about other people (missing person notices)

When you report a missing person, you entrust us with information about another person, sometimes a child: first name, last name, age, sex, approximate height, build, clothing, distinguishing features, circumstances, last known place, and possibly a photo. This data is kept separately from other reports and access to it is restricted. See section 6.

WhatsApp

If you write to Funda on WhatsApp, we process:

• your WhatsApp number and WhatsApp profile name;
• a reduced content of the messages (the text received, the button chosen, a summary of the messages sent), their date and their delivery status;
• the steps of the current journey. Intermediate answers are cleared at the end of the journey;
• your alert subscriptions (municipalities, categories, frequency) and each consent or withdrawal ("STOP", "START"), with its date and scope;
• the locations and media you send.

Your device

App installation identifier, system (iOS or Android), model, app and system versions, notification token, date of last activity. The installation identifier is also used to detect several accounts run from the same phone, to fight abuse.

Crash reports

If the app crashes, it sends a technical report to Firebase Crashlytics (Google). This report contains no number, no location and no content. Sending is on by default and you can turn it off at any time in Profile > Settings, privacy section. The choice is kept on the phone.

Technical server data

IP address and technical logs, for security and to limit abuse. Moderation decisions and staff actions are recorded in an audit log.

4. Why we use them, and on what basis

The applicable legal framework is Congolese law, in particular Ordinance-Law No. 23/010 of March 13, 2023 on the Digital Code.

5. Who sees your data

• The public sees published reports: category, text, blurred photos, place (rounded for sensitive categories), time. The author appears under their name or under a pseudonym, as they choose. Your number is never displayed.
• The Funda team (moderation, WhatsApp operators) sees what is needed for its work. Every staff action is controlled by permissions and logged.
• Your trusted contacts receive your alert and your location only during an SOS or a help request.
• Families in a missing person notice see only what the Funda team chooses to pass on to them, with a text reviewed by the team. Neither the witness nor the family decides what is shared: only Funda passes information on to families.
• Partner services that use the professional tool Funda Ops receive the reports and help requests they need to intervene. [À COMPLÉTER : liste des services partenaires et cadre des accords]
• The authorities: see the "Requests from authorities" page.
• Our technical processors (section 8).

We do not sell your data. We do not use it for advertising.

6. Missing person notices and minors in reports

• A notice about a minor is always treated as concerning a vulnerable person.
• A minor's last name is never shared. Age is shared as a range.
• Public sharing of a notice, and of the photo, is decided after submission, on the case screen, never in the form.
• The missing person, person found and assault categories are always reviewed by the Funda team before any sharing.
• Sightings ("I saw them") remain private and go to Funda first.
• The photo of the missing person is deleted as soon as the case is closed, whatever the reason.
• Without an update, a notice is archived after 30 days, removed from the map, and its photo is deleted.

7. Where your data is hosted

• Servers: Laravel Cloud, Frankfurt region (Germany, European Union).
• Database: managed Postgres (Neon) in the same region.
• Cache and queues: Valkey, in the same region.
• Photos and voice notes: a private storage space, under European Union jurisdiction. Files are never public: each access goes through a signed link valid for one hour.
• Domain name: managed with Cloudflare.

Our host currently has no hosting region in Africa.

8. Our processors

9. Transfers outside the DRC

Your data is hosted in the European Union (Germany). Some providers (Meta, Google, Infobip, Cloudflare) may process it in other countries. [À COMPLÉTER : garanties encadrant ces transferts, conformément à la législation congolaise]

10. How long we keep it

11. Your rights

You can:

• access your data and obtain a copy;
• have it corrected;
• have it erased, by deleting your account (see the "Delete my account" page);
• object to processing based on our legitimate interest;
• withdraw your consent at any time: "STOP" on WhatsApp, notification and crash report switches in Profile > Settings, location permission in the phone's settings;
• appeal a moderation decision (see the "Moderation" page).

To exercise these rights: [À COMPLÉTER : e-mail de contact]. We may ask you to prove that the number concerned is yours, for example with a verification code. Response time: [À COMPLÉTER : délai].

If you are not satisfied with our answer, you may refer the matter to the competent Congolese data protection authority. [À COMPLÉTER : coordonnées de l'autorité]

12. Minors

[À COMPLÉTER : âge minimum pour créer un compte Funda]. Funda is not designed for children. The children's data we process is mainly what a parent or relative entrusts to us in a missing person notice: see section 6 and the "Child protection" page.

13. Security

• Exchanges with Funda go through an encrypted connection (HTTPS).
• The identity document and medical information are encrypted before being saved.
• Photos are stored in a private space and leave it only through signed, time-limited links.
• Verification codes are limited in number and duration, and are kept only as a fingerprint.
• Staff access is limited by role and logged.

No system is perfect. In the event of a data breach that puts you at risk, we will inform you. [À COMPLÉTER : procédure et délai de notification]

14. Changes

We may change this policy. The effective date at the top of the page changes with each version. In the event of a significant change, we will let you know in the app.

15. Contact

[À COMPLÉTER : e-mail de contact] [À COMPLÉTER : adresse]