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Privacy Policy

How We Protect Your Data

Last updated: October 14, 2026

1. Introduction

Garabaly ("we", "our", "us") is committed to protecting the privacy and personal data of all users of our livestock marketplace platform. This Privacy Policy explains what information we collect, how we use it, and the rights you have regarding your data.

By using the Garabaly app or website, you consent to the practices described in this policy. The data controller is GARABALY, a sole proprietorship (entreprise individuelle) registered with the RCCM of Bamako under no. ML-BKO-01-2026-A-01130, Bamako, Republic of Mali. We process your data in accordance with Malian Law No. 2013-015 of May 21, 2013 on the protection of personal data, under the supervision of the Personal Data Protection Authority (Autorité de protection des données à caractère personnel, APDP), and with the laws that apply in the other countries where you use Garabaly.

2. Information We Collect

2.1 Information You Provide

  • Account information: Name, phone number, email address, profile photo, and preferred language.
  • Identity verification: Government-issued ID and a selfie, to verify sellers, service providers, and any user who requests a verified account (for example, for higher withdrawal limits or for wallet-to-wallet transfers).
  • Transaction data: Listing details, purchase history, and payment information.
  • Communication data: Chat messages (including negotiation messages), voice messages, images, and videos shared through the in-app messaging system.
  • Wallet information: Mobile money account numbers, bank details, and wallet transaction history.

2.2 Information Collected Automatically

  • Device information: Device type, operating system, unique device identifiers, and device fingerprints for security purposes.
  • Usage data: App interaction logs, feature usage patterns, and session duration.
  • Location data: Approximate location for connecting you with nearby livestock sellers and service providers (with your permission).
  • Notification tokens: Push notification identifiers for delivering order updates and messages.

2.3 Communication Monitoring

For your safety, Garabaly may review chat messages, voice messages, images, and videos shared through our in-app messaging system under the following circumstances:

  • User reports: When a user files a report against another user, designated Garabaly moderation staff may review the relevant conversation to investigate the report.
  • Legal requirements: When required by court order or valid legal process.
  • Disputes: When a dispute is opened, the Garabaly team may review the conversation linked to the order concerned.

Garabaly does not routinely monitor or read user messages. Reviews are conducted only by designated moderation staff, not by all company employees.

Deleted messages: A message you delete is hidden from the conversation but remains accessible to the moderation team, for evidence purposes, for as long as your account exists; after you delete your account, it is erased as set out in section 6. The "delete for everyone" option does not remove the message from moderators' access during that period. This retention protects both parties in the event of a dispute.

You have the right to request access to your data, including your conversation history, and its deletion, as provided by law. Write to [email protected].

3. How We Use Your Information

We use your information to:

  • Facilitate livestock transactions between buyers, sellers, and service providers.
  • Enable payments made in the app — by card (processed by Stripe), by mobile money (Orange Money, Moov Money, Wave, and MTN MoMo in some countries; more operators are being added) and with the Garabaly Wallet — hold them in escrow until they are released, and process your withdrawals to a mobile-money or bank account.
  • Provide real-time order tracking and delivery updates.
  • Send transaction confirmations, security alerts, and service notifications through SMS and in-app channels.
  • Detect and prevent fraud through recognition of the devices used to sign in, limits on how often operations can be made, and analysis of unusual behavior.
  • Improve our platform through anonymized usage analytics.
  • Deliver the app in your language (French, English, or Arabic) and let you use your voice in whatever language you speak.

4. Data Security

We implement robust security measures to protect your data:

  • Encryption: All sensitive data is encrypted in transit and at rest. Wallet PINs are protected with strong encryption standards.
  • Transaction integrity: Every money movement is recorded, and balances are checked continuously so that financial data stays accurate.
  • Access control: Sensitive operations, such as any manual intervention on escrowed funds, are restricted to authorized team members and recorded in an audit log.
  • Fraud detection: Automatic limits on unusual operations and recognition of the devices used to sign in help detect suspicious activity.
  • Database security: Your data is stored in secured databases, with regular backups and access logging.

5. Data Sharing

We share your data only in the following circumstances:

  • Transaction parties: Relevant information is shared with buyers, sellers, and service providers involved in your transactions (e.g., delivery addresses, contact details).
  • Payment providers: We pass on only the data each operation requires (the payer's or recipient's name, phone number or bank details, amount, currency, order reference): to Stripe for card payments; to PayDunya, a payment aggregator that routes mobile-money operations; to the mobile-money operators (Orange Money, Moov Money, Wave, and MTN MoMo in some countries); and to the banks and transfer providers that carry out bank withdrawals. Each of them processes this data under its own legal obligations.
  • Technical service providers: Our hosting, SMS, email and notification providers process some of your data on our behalf, only on our instructions.
  • Transfers outside Mali: Some of these providers process data outside Mali, for example in Europe or the United States. We subject these transfers to the safeguards required by applicable law.
  • Legal requirements: We may disclose data when required by law, regulation, or valid legal process.

We never sell your personal data to third parties for advertising or marketing purposes.

6. Data Retention

We keep your personal data for as long as your account is open. After it is closed, we delete it within 30 days, with two exceptions. First, data that the law requires us to keep: identity-verification (KYC), wallet, payment and transaction records are kept for at least 10 years from the transaction or the account closure, whichever is later, in accordance with the applicable anti-money-laundering and counter-terrorist-financing rules, including those of the WAEMU/UEMOA and CEMAC zones; during that period, this data is used only to meet those obligations. Second, messages linked to a dispute that is still open are kept until the dispute is closed, then erased. Your other messages, including those you deleted, are not part of these records: they are erased within the same 30 days. You may ask at any time for your other data to be deleted, at [email protected].

7. Your Rights

You have the right to:

  • Access the personal data we hold about you.
  • Correct inaccurate or incomplete information.
  • Request deletion of your data (subject to legal retention requirements).
  • Withdraw consent for optional data processing (e.g., location services).
  • Export your data in a portable format.

To exercise any of these rights, write to us at [email protected]. You may also lodge a complaint with the APDP (Mali) or with the data protection authority of your country.

8. Cookies & Storage on Our Website

This section covers the website www.garabaly.com. The app is covered in sections 2 to 7.

No advertising cookies, no tracking. The website sets no advertising cookies and uses no audience-measurement or tracking tool.

Only what is necessary. The website keeps a few preferences in your browser: your language, light or dark mode and, on mobile, whether you closed the download bar. They cannot identify you, stay on your device and are not sent to us. Our hosting provider may also use a cookie that is strictly necessary for the website's security, for example to protect it against bots.

These items are essential for the website to work the way you use it, so they do not require your consent. You can clear them at any time in your browser settings; the website will simply return to its default settings.

Contact form. Messages sent through the form pass through a technical provider that forwards them to us. They are used only to reply to you and are not kept longer than needed to handle your request.

If this changes. If we ever use an audience-measurement tool or any other non-essential tracker, it will either work without cookies and without identifying you, or be turned on only with your consent: you will be able to refuse as easily as accept, and to change your mind at any time. This section will be updated first.

Questions? Write to us at [email protected].

9. Children's Privacy

Garabaly is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us for removal.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes through the app or via email. If you continue to use Garabaly after these changes, the updated policy applies.

Terms of Service

Rules of the Marketplace

Updated October 7, 2026 — effective October 21, 2026

The following changes apply on publication: wording corrections; Garabaly's role (art. 3); cash payments (art. 4.1, 6 and 9); payment for a standalone service order (art. 5.1); payment methods, escrow and conversion fees credited back (art. 6); and the dispute procedure, with a decision within 72 hours (art. 10).

1. Acceptance of Terms

By creating an account or using the Garabaly platform (app and website), you accept these Terms of Service. If you do not agree, you must not use the platform. These terms apply to all users, including buyers, sellers, service providers, and visitors.

2. Eligibility

  • You must be at least 18 years of age to use Garabaly.
  • You must provide accurate and complete registration information.
  • Seller and service provider accounts are subject to identity verification.
  • You are responsible for maintaining the security of your account credentials and wallet PIN.

3. Platform Role

Garabaly is an online marketplace that connects livestock buyers with sellers and with independent service providers (delivery drivers, butchers, veterinarians). We are not a party to transactions between users. We provide the technical tool — messaging, order tracking and escrow of payments made in the app — but the actual sale and delivery of livestock is a matter for the parties to the transaction. Payments are carried out by licensed payment providers: Garabaly is not a bank, a payment institution or an electronic-money issuer.

4. Listings & Content

  • Sellers are responsible for the accuracy of their livestock listings, including descriptions, photos, videos, voice descriptions, and prices.
  • Listings must represent real, available livestock. Fraudulent or misleading listings will result in immediate account suspension.
  • All content uploaded (images, voice notes, chat messages) must comply with applicable laws and community standards.
  • Garabaly reserves the right to remove any content that violates these terms.

4.1 In-App Communications

Garabaly moderates chat content as part of its marketplace rules. For your safety, messages may be reviewed if a report is filed. By using the in-app messaging system, you acknowledge that:

  • If a user files a report, designated Garabaly moderation staff may review the relevant conversation.
  • Deleted messages remain accessible to moderators for evidence purposes for as long as your account exists; after you delete your account, they are erased as set out in section 6 of our Privacy Policy.
  • You must never share financial PINs, passwords, or sensitive account credentials through chat.
  • Apart from paying cash for an order placed in the app, you must never arrange a payment outside Garabaly. Payments made outside the app, including in cash, do not go through escrow and are not protected by Garabaly.

For your safety, keep conversations on Garabaly and inspect animals before paying. If a report is filed, moderators may review the chat.

5. Transactions & Orders

5.1 Independent Orders & Bundles

Orders are independent by default, with an optional bundle:

  • Independent Orders (Default): Every item in the cart is its own order with its own escrow, confirmation code, and tracking — whether it is livestock or a standalone service (butcher, vet, or delivery). For a standalone service order, the service provider is paid when the buyer enters their confirmation code, once the service is completed; the 24-hour buyer-protection window applies only to the livestock seller's share.
  • Bundle (Optional): The buyer explicitly bundles 1 listing + up to 3 services (maximum 1 delivery + 1 butcher + 1 vet) into one order with a single confirmation code. The buyer can reorder the fulfillment steps by drag and drop.

5.2 Order Flow

Orders follow these steps:

  1. Browse & Select — All items are independent by default.
  2. Bundle (optional) — Buyer may bundle 1 listing + up to 3 services and drag to reorder fulfillment.
  3. Pre-Checkout Approval — All parties (seller and any service providers) must approve before checkout.
  4. Checkout & Escrow — One payment, held in escrow and split between the parties. You pay only after this approval.
  5. Fulfillment — Stages: confirmed → preparing → ready for pickup → in transit → delivered.
  6. Confirmation — The buyer enters the 6-character code after receiving and inspecting the order.
  7. Payment Release — Nothing is paid out before the code is entered. When the code is entered, service providers are paid at once; the seller's share is paid out at the end of a 24-hour buyer-protection window, which opens when the code is entered.

5.3 Negotiation

Buyers and sellers may negotiate prices through the in-app chat. A transaction binds the parties once the buyer has confirmed the purchase: for a payment made in the app, when the payment is placed in escrow; for an order to be paid in cash, when the buyer places the order in the app. An order paid in cash therefore binds the parties like any other order; however, it does not go through escrow and is not protected by Garabaly (article 6).

5.4 Seller Pre-Approval

Sellers pre-approve the sale before checkout. The buyer can complete the order only after the seller has accepted the deal. There is no seller confirmation step after that: an order paid in the app is active as soon as the payment is placed in escrow; an order to be paid in cash is active as soon as the buyer places it.

5.5 Confirmation Codes

Each order generates a unique 6-character confirmation code. The buyer — and only the buyer — enters this code directly in the app, after receiving and inspecting the livestock or service. Entering the code triggers the escrow release process. Only enter your confirmation code after you have received and inspected the livestock to your full satisfaction.

6. Payments

  • Payments made in the app are carried out by licensed payment providers — Stripe for cards, the mobile-money operators for mobile money — and held in escrow under our Escrow Policy. Cash payments are made directly between the parties: they are not protected by Garabaly.
  • The payment methods accepted in the app are card (Visa, Mastercard), mobile money (Orange Money, Moov Money, Wave, and MTN MoMo in some countries; more operators are being added) and the Garabaly Wallet. Bank transfer is not a payment method. Withdrawals are governed by article 7.
  • You always pay in your own currency, and the seller is always paid in theirs. When the two differ, Garabaly converts at a rate fixed the moment you pay and shown to you before you confirm.
  • No conversion fee applies to same-currency payments, or between the CFA franc (XOF or XAF) and the euro, which are converted at the official fixed rate. For other currencies, a small conversion fee applies; it is always shown to you before you confirm. If an order paid in another currency is canceled in full, this fee is credited back to your Garabaly Wallet; it is not returned on a partial refund.
  • Garabaly takes no commission on your purchases. Fees charged by the card provider or the mobile-money operator may apply; they are shown to you before you pay.
  • Funds remain in escrow until the buyer enters the confirmation code. See our Escrow Policy for details.

7. Wallet

7.1 Your wallet. Each user has a Garabaly Wallet for receiving payments and making purchases. Operations are protected by your personal PIN and by anti-fraud controls; every movement is recorded and balances are checked continuously. A deposit by card or mobile money may incur the provider's fees, which are deducted from the amount credited and shown before you confirm. Wallet-to-wallet transfers are governed by the Wallet & Transfer Policy.

7.2 Withdrawals. You may withdraw your wallet balance to a mobile-money account or to a bank account in your name, within the limits shown in the app for your account. No single transaction may exceed 5 000 000 FCFA, or the equivalent in your wallet's currency; this ceiling applies in every country. Withdrawal to a bank card is not offered. A withdrawal to a mobile-money account bears the operator's fees, passed on at cost and shown before you confirm.

7.3 Bank withdrawals. Withdrawals to a bank account are subject to the following conditions, shown in the app before you confirm:

(a) they are made only in your wallet's currency; to withdraw in another currency, first convert the amount with a wallet-to-wallet transfer (available to eligible wallets, and subject to the cross-currency transfer fee shown before you confirm);

(b) minimum amount: 300 000 FCFA per withdrawal;

(c) maximum amount: 2 000 000 FCFA per withdrawal, on an interim basis;

(d) bank withdrawal fee: 1.5% of the amount withdrawn, never less than 5 000 FCFA, rounded up to the next whole unit of the currency;

(e) timing: 3 to 8 working days between your request and the credit to your account (1 to 3 days of processing by Garabaly, then 2 to 5 days for the bank transfer), not counting your own bank's processing times.

For a currency other than the CFA franc, these amounts are converted into your wallet's currency; the applicable values are those shown in the app before you confirm. Bank withdrawal is offered only in the currencies for which the app shows it. If a bank withdrawal is refused during processing, the amount requested and the bank withdrawal fee are credited back to your wallet in full. An unfavorable change to these conditions follows the procedure in article 13 and does not apply to withdrawals already confirmed.

8. Service Providers

  • Service providers (delivery drivers, butchers, veterinarians) must complete verification before offering services on the platform.
  • Service providers are independent, verified professionals and are not employed by Garabaly.
  • Service provider fees (the provider's service costs, not Garabaly platform fees) are agreed upon before booking and protected by escrow.
  • Users may rate and review service providers after each transaction.

9. Prohibited Conduct

Users may not:

  • Post fraudulent, misleading, or deceptive listings.
  • Attempt to circumvent escrow or arrange a payment outside the app (paying cash for an order placed in the app remains possible, but is not protected by Garabaly).
  • Harass, threaten, or abuse other users through chat or any other channel.
  • Use the platform for money laundering, fraud, or any illegal activity.
  • Create multiple accounts to evade bans or manipulate reviews.
  • Attempt to reverse-engineer, hack, or compromise platform security.

Violations may result in immediate account suspension, fund freezing, and reporting to relevant authorities.

10. Dispute Resolution

In the event of a dispute between transaction parties, Garabaly will review the available evidence (chat logs, photos, order data) and decide on a fair resolution. During the process, every share not yet released remains in escrow until the decision. Each party concerned may present its case. Garabaly gives its decision within 72 hours of the dispute being opened; if information is missing, it tells the parties what is needed. Every decision is recorded.

11. Limitation of Liability

Garabaly facilitates transactions but does not guarantee the quality, health, or condition of livestock listed on the platform. We provide escrow protection and verification tools to minimize risk, but buyers should always inspect livestock upon delivery before confirming the transaction. Garabaly's liability is limited to the fees collected for the specific transaction in question.

12. Account Termination

You may delete your account at any time. Garabaly reserves the right to suspend or terminate accounts that violate these terms. When your account is deleted or terminated, pending transactions are settled under our Escrow Policy, and the remaining balance of your wallet is returned to you by a withdrawal to an account in your name, under article 7, unless a freeze has been applied under the Wallet & Transfer Policy. If this balance is below the withdrawal minimum, that minimum does not apply: Garabaly pays out your balance anyway.

13. Changes to Terms

We may update these Terms of Service and the policies they refer to. Material changes are notified to you in the app or by email at least 14 days before they take effect. Changes that are more favorable to you, or that only correct the wording, apply as soon as they are published. If you refuse a change, you may delete your account before it takes effect; otherwise, continued use of the platform constitutes acceptance. An operation already confirmed remains governed by the version in force when it was confirmed.

14. Content You Publish & Promotional Use

  1. License granted. By publishing content on Garabaly (listings, text, photos, videos, descriptions, reviews, voice notes — the "Content"), you grant Garabaly a non-exclusive, royalty-free, worldwide, sub-licensable license to host, store, reproduce, display, adapt, translate and distribute that Content for the purposes of: (i) operating, running and improving the service; and (ii) promoting and marketing the service, including on garabaly.com, social media, advertising campaigns and any marketing material.
  2. Your warranties. You represent and warrant that you hold all rights necessary in the Content you publish, and that it does not infringe the rights of third parties (intellectual property, image rights, privacy).
  3. Personal data and image rights. Where the Content includes personal data or the image of identifiable persons, your acceptance of these Terms constitutes consent to their use for the purposes described above. Garabaly does not use your personal contact details (phone number, address, etc.) in its public promotional material.
  4. Duration and withdrawal. The license lasts as long as the Content is published on the service. When you remove Content, Garabaly ceases using it within a reasonable time, subject to (a) material already produced or distributed before removal and (b) copies retained for legal or backup purposes.

15. Who represents Garabaly

Only Garabaly binds Garabaly, and only in writing.

No field agent, contractor, facilitator, relay point, partner or intermediary has the power to bind Garabaly. Such persons may not enter into any contract on Garabaly's behalf, grant any discount, reduction, guarantee or extension of time, or receive any funds for Garabaly's account. No verbal commitment made by such a person binds Garabaly.

People who work in the field on Garabaly's behalf act as technical assistance: they introduce the platform and help you use it. They do not represent you, and they do not represent Garabaly to you.

Field assistance is free of charge. No one is authorized to ask you for money, or to collect a payment, in Garabaly's name.

Before handing money, an animal or a document to anyone claiming to be from Garabaly, check them: the rules and the procedure are set out in our Representation Policy.

16. Language

These terms and the policies they refer to are available in French, English and Arabic. In the event of a discrepancy between these versions, the French version prevails.

Escrow Policy

How Your Money is Protected

Updated October 7, 2026 — effective October 21, 2026

The following changes apply on publication: wording corrections; the rules on cash payments (sections 1, 2 and 9); the confirmation code (section 3); opening a dispute, the 72-hour decision and refunds (section 2, "Disputed" stage, and sections 7.1 to 7.3); manual interventions (section 6); and conversion fees credited back (section 9).

1. What is Escrow?

Escrow is a protection mechanism that keeps your payment secure until a deal is complete. When you pay in the app for an animal or a service, your payment is held in escrow until you enter your confirmation code, then released under the rules below. This mechanism protects both buyers and sellers. Cash payments do not go through escrow.

2. The Per-Party Escrow Lifecycle

Every payment made in the app follows a per-party escrow process. The seller and the service providers approve the order before checkout: you can pay only once the deal is accepted. Nothing is released until the buyer enters their confirmation code. The moment the buyer enters it, the service providers are paid, and the seller's share enters a 24-hour buyer-protection window, at the end of which it is released to the seller. One code releases the whole order — independent or bundled — with no per-step payout.

1

Funded

The buyer places an order (after the seller and the service providers have approved it) and pays. The amount, paid by card, mobile money or wallet, is placed in escrow, kept separate from Garabaly's operating funds. The order is active and delivery can proceed.

2

Releasing

The buyer has entered their confirmation code after delivery — nothing is released before that. Any service providers booked are paid at once; the seller's share remains in escrow during the 24-hour buyer-protection window, which opens when the code is entered and during which the buyer may still file a dispute.

3

Released

The 24-hour buyer-protection window, opened when the 6-character confirmation code was entered, has passed with no dispute: the seller's share is paid out to the seller's Garabaly Wallet. The transaction is complete.

4

Disputed

A dispute has been opened: by the buyer, before entering their code or during the buyer-protection window, or by the seller or a service provider if the buyer does not enter the code after delivery. Every share not yet released remains in escrow until the decision. Garabaly gives its decision within 72 hours of the dispute being opened; if information is missing, it tells the parties what is needed. Possible outcomes: a full or partial refund to the buyer (Refunded), or payment to the seller or the service provider concerned if the dispute is decided in their favor.

3. Confirmation Code System

  • Each order generates a unique, randomly generated 6-character confirmation code assigned to the buyer.
  • The code is the only mechanism that releases funds to the seller and the service providers. Without the code, they cannot receive any payout, except through a decision made by Garabaly at the end of a dispute; every decision is recorded. Without the code, funds can otherwise leave escrow only as a refund to the buyer, if the order is canceled or a dispute is decided in the buyer's favor.
  • Only enter your confirmation code after you have received and inspected the livestock to your full satisfaction. Never share this code: only the buyer enters it.
  • If you lose your confirmation code, contact Garabaly support: once your identity has been verified, support issues you a new one. After several wrong attempts, the code is temporarily locked; support reactivates it, again after verifying your identity.

4. 24-Hour Buyer-Protection Window

Inspect the livestock or service on delivery, before entering your code: if something is wrong, open a dispute without entering the code.

  • Nothing is released until the buyer has entered their confirmation code.
  • When the code is entered, the service providers are paid at once — never before, and with no per-step payout.
  • Entering the code opens a 24-hour buyer-protection window on the seller's share. During that period, the buyer may still file a dispute; the seller's share then remains in escrow until the decision.
  • If no dispute is filed during those 24 hours, the seller's share is released to the seller automatically at the end of the period.
  • Without the code, nothing is released: if the buyer does not enter their code after delivery, the seller or service provider can open a dispute from the report screen in the app, and Garabaly's team reviews the delivery evidence. Garabaly gives its decision within 72 hours of the dispute being opened; if information is missing, it tells the parties what is needed. At delivery, the app reminds sellers and service providers to ask the buyer to check the order and then enter the code.

5. Multi-Party Escrow

For bundled orders, which combine one animal and up to three services (delivery, butchering, veterinary care), escrow protects all parties:

  • Each participant's share is tracked separately within the escrow.
  • One code releases the whole order: when it is entered, the service providers are paid at once, and the seller's share is paid out at the end of the 24-hour buyer-protection window.
  • There is no per-step payout: a delivery driver is not paid on delivery, but when the buyer enters the code.

6. Escrow Security

Our escrow relies on strong safeguards:

  • Transaction security: Every fund movement either succeeds in full or does not happen at all; there is never a partial transfer.
  • Integrity verification: Every wallet balance change is subject to systematic integrity checks, to detect and prevent unauthorized modifications.
  • Auditable records: Every movement is recorded and balanced: no amount is lost along the way.
  • Control of manual interventions: Any manual intervention on escrow (for example, a payout or refund decided at the end of a dispute) is restricted to authorized team members and recorded in an audit log.
  • Fraud detection: Automated systems monitor for suspicious patterns including unusual transaction amounts, activity spikes, and device-related anomalies.

7. Refund & Dispute Policy

Buyer-protection window: After entering their code, the buyer has 24 hours to dispute the seller's share only. Nothing is released before the buyer enters their confirmation code; service providers are paid when the code is entered (never before, with no per-step payout) and are not subject to the 24-hour window, which applies only to the seller's share. If the seller or any service provider does not approve the order before checkout, you pay nothing. Escrow stages: Funded → Releasing → Released → Disputed/Refunded.

7.1 Filing a Dispute

If you receive livestock that does not match the listing description, is unhealthy, or if any other issue arises, open a dispute before entering your confirmation code. After entering the code, you can still open a dispute about the seller's share during the 24-hour buyer-protection window. If the buyer does not enter their code after delivery, the seller or service provider can also open a dispute, from the report screen in the app. Contact Garabaly support through the app or at [email protected].

7.2 Dispute Resolution Process

  • Every share not yet released remains in escrow during the process.
  • Garabaly mediators will review all available evidence: listing details, photos, chat history, voice messages, and order tracking data.
  • The buyer, the seller and, where applicable, the service provider concerned may each present their case.
  • Garabaly gives its decision within 72 hours of the dispute being opened; if information is missing, it tells the parties what is needed. Every decision is recorded.

7.3 Refund Outcomes

  • Full refund: If the dispute is decided in the buyer's favor, the escrowed funds are returned in full to the buyer's Garabaly Wallet, including any conversion fee.
  • Partial refund: In cases where both parties share responsibility, a partial refund may be issued; any conversion fee is then not returned.
  • Release to the seller or service provider: If the dispute is resolved in favor of the seller or the service provider concerned, the escrowed share due to them is released to them.

8. Fees

Garabaly charges buyers no commission and no platform fee. A small platform fee is charged to sellers and service providers, only upon successful completion of a transaction; fee percentages are transparently displayed in the app. Holding funds in escrow and releasing them incur no additional charges. Other fees may apply, always shown before you confirm, including: fees charged by the card provider or the mobile-money operator, on a payment or on a deposit to your wallet; a small conversion fee when you pay in a currency different from the seller's (none for same-currency payments, or between the CFA franc and the euro); a fee of 1.5% on a wallet-to-wallet transfer between different currencies (transfers in the same currency are free); and, for wallet withdrawals, the fees set out in article 7 of the Terms of Service: the operator's fees for a withdrawal to mobile money, and a bank withdrawal fee of 1.5%, never less than 5 000 FCFA (or the equivalent), for a withdrawal to a bank account.

9. Payment Methods

Four payment methods are possible; only payments made in the app are protected by escrow:

  • Cash: Paid directly to the seller or service provider, not to Garabaly. No commission is charged. These payments do not go through escrow and are not protected by Garabaly. Use at your own risk.
  • Card: Full escrow via Stripe (Visa, Mastercard).
  • Mobile money: Full escrow — Orange Money, Moov Money, Wave, and MTN MoMo in some countries; more operators are being added (LIVE).
  • Garabaly Wallet: Full escrow with PIN verification.

Warning: Cash payments are not protected by Garabaly. To be protected, as a buyer or as a seller, pay in the app: card, mobile money or Garabaly Wallet.

Paying from another country? You always pay in your own currency, and the seller receives theirs. Garabaly handles the conversion at a rate fixed the moment you pay; the same rate is used for any refund. Within the CFA franc zone (XOF and XAF), and for euro payments at the official fixed rate, no conversion fee applies. For other currencies, a small conversion fee is shown before you confirm. If the order is canceled in full after payment, this fee is credited back to your Garabaly Wallet; it is not returned on a partial refund. Cross-currency payment is currently available by card and with the Garabaly Wallet.

10. Contact

For any questions about our escrow system, disputes, or refunds, contact us:

  • Email: [email protected]
  • In-app: Use the Help Center in the Garabaly app
  • Response time: We aim to respond to all escrow-related inquiries within 24 hours.
Wallet & Transfer Policy

Wallet & User Transfer Conditions

Version 2.2.0 — Effective August 11, 2026

In the event of a discrepancy between language versions of these Conditions, the French version shall prevail.

The conditions for withdrawals (to a mobile-money or bank account) and their fees are set out in article 7 of the Terms of Service.

Preamble

The Garabaly wallet is an instrument integrated into the Garabaly marketplace, designed to facilitate transactions between buyers, sellers, and service providers on the platform. The wallet-to-wallet transfer service is a complementary feature to the buying, selling, and service provision journey, enabling in particular the sharing of revenue between business partners, the settlement of service providers, and the management of funds related to marketplace activity.

These Conditions supplement the General Terms of Use of the Garabaly platform without replacing them. In the event of a conflict on any point relating to the wallet or user-to-user transfers, these Conditions shall prevail.

Use of the wallet-to-wallet transfer service implies full and unconditional acceptance of these Conditions.

Article 1 — Definitions

For the purposes of these Conditions, the following terms have the meanings assigned below:

  • Wallet: An internal account on the Garabaly platform, linked to the user's verified identity, allowing the receipt, temporary holding, and sending of funds within the scope of marketplace activity.
  • Transfer: An operation whereby a user sends funds from their wallet to the wallet of another user on the platform.
  • Completed marketplace order: Any order or service provision carried out on the Garabaly marketplace — whether the purchase or sale of livestock, or a butchering, delivery, or veterinary service — that has reached the status of confirmed delivery or service completion and whose payment has been received in full.
  • Service provider: A user registered on the Garabaly platform as a provider of marketplace-related services, including butchers, delivery drivers, or veterinarians.
  • KYC (Know Your Customer): An identity verification procedure comprising the collection and validation of the user's identity documents, in accordance with applicable regulatory requirements.
  • Freeze: A precautionary measure suspending all or part of a user's wallet functionalities, taken under the conditions defined in Article 5 herein.
  • Compliance officer: A natural person designated by Garabaly, responsible for ensuring compliance with anti-money laundering and counter-terrorism financing obligations.

Article 2 — Transfer Service Eligibility

2.1 Access to the wallet-to-wallet transfer service is reserved for users who cumulatively and continuously meet all of the following conditions:

  • (a) Hold a verified account, meaning they have successfully completed the full identity verification (KYC) procedure and have reached the trust level required by the platform;
  • (b) Hold an account that has been open and active for at least fourteen (14) days;
  • (c) Have completed at least one (1) completed marketplace order within the last ninety (90) days, as buyer, seller, or service provider, with confirmed payment;
  • (d) Have an active wallet, meaning not subject to a freeze within the meaning of Article 5;
  • (e) Have accepted the current version of these Conditions in accordance with the procedure described in Article 8.

2.2 User eligibility is verified at each transfer attempt. The loss of any of the above conditions results in the immediate and automatic withdrawal of access to the transfer service, without Garabaly needing to make an individual decision to that effect.

2.3 The transfer recipient must also hold a verified account and have an active (non-frozen) wallet. Any transfer to a frozen wallet or to an account that has not completed the identity verification procedure is refused.

2.4 On an exceptional and revocable basis, Garabaly may grant an administrative exemption to a user whose situation justifies it (for example: a cooperative treasurer whose orders are still being processed). Any exemption is documented, justified, and revocable at any time.

Article 3 — Transfer Limits

3.1 Monthly limit. The cumulative amount of a user's transfers — outgoing and incoming, tracked separately — over a rolling thirty (30) day period is capped based on their actual marketplace activity on the platform.

The cap is calculated as follows: fifty percent (50%) of the total volume of completed marketplace orders by the user (as buyer, seller, or service provider) over the last ninety (90) days, with:

  • a floor of twenty-five thousand (25,000) CFA francs;
  • a maximum cap of five million (5,000,000) CFA francs.

This mechanism ensures that each user's transfer capacity is proportional to their actual commercial activity on the marketplace.

3.2 Per-transaction limits. Each individual transfer is subject to the following limits:

  • Minimum amount per transfer: one thousand (1,000) CFA francs;
  • Maximum amount per transfer: one million (1,000,000) CFA francs;
  • Maximum number of distinct recipients per day: five (5).

3.3 Order linkage requirement. For any transfer of an amount equal to or greater than two hundred thousand (200,000) CFA francs, the user must link the transaction to an existing marketplace order on the platform.

3.4 Incoming cap. A user may not receive, from senders with whom they have no documented marketplace relationship on the platform, a cumulative amount exceeding one hundred thousand (100,000) CFA francs per rolling thirty (30) day period. This measure aims to prevent the use of a wallet as a collection point for diverted purposes.

3.5 Refusal notification. When a transfer is refused due to a cap applicable to the recipient, the sender is informed of the refusal without any information regarding the recipient's cap, balance, or wallet status being disclosed.

3.6 Cap changes. Garabaly reserves the right to modify the caps defined in this Article for operational, regulatory, or security reasons. Any change unfavorable to the user triggers the re-acceptance procedure provided for in Article 8.

Article 3 bis — Transfers in a Different Currency

3bis.1 A transfer between two users who hold the same currency carries no conversion fee.

3bis.2 When the sender and the recipient hold different currencies, Garabaly converts the amount at a rate fixed for a short period and shown to you, together with a small conversion fee, before you confirm. You see exactly how much will leave your wallet and how much the recipient will receive before approving the transfer.

3bis.3 If you do not confirm within the time shown, the quoted rate expires and you may request an updated one. No transfer and no fee occur until you confirm.

Article 4 — Transfer Holds and Mandatory Reason

4.1 First transfer to a new recipient. The first transfer to a recipient with whom the user has never made a transfer before is subject to a twelve (12) hour hold. This hold is automatically lifted at the end of the specified period. The user may cancel the transfer at no cost during the entire hold period.

A recipient is considered known once at least one prior transfer has been successfully executed between the same parties. The hold is also lifted when the sender and recipient have a documented marketplace relationship on the platform within the last ninety (90) days (completed order as buyer, seller, or service provider).

4.2 High-value transfers. Any transfer exceeding five hundred thousand (500,000) CFA francs is subject to a two (2) hour hold, including to a known recipient.

4.3 Mandatory reason. Each transfer must be accompanied by a reason selected by the user from the following categories: revenue sharing, gift, payment of an assistant or intermediary, family remittance, correction or refund, other reason. The user may additionally add a free-text note. Omission of the reason results in refusal of the transfer.

4.4 Code confirmation. Each transfer requires the entry of a single-use confirmation code sent to the user. After three (3) unsuccessful attempts, the transaction must be cancelled and re-initiated by the user.

Article 5 — Right to Freeze Without Notice

5.1 Garabaly reserves the right to immediately and without notice freeze a user's wallet in the event of reasonable suspicion, supported by the platform's technical controls or by manual review, regarding any of the following cases:

  • (a) money laundering, terrorism financing, or circumvention of identity verification rules;
  • (b) use of the transfer service as an alternative to a regulated money remittance service;
  • (c) fraudulent use of the account, including in cases of compromise, financial mule activity, or manipulation of a third party's identity;
  • (d) simultaneous use of multiple accounts on the same device for cross-transfer purposes;
  • (e) non-compliance with caps, eligibility conditions, or any obligation arising from these Conditions.

5.2 The freeze suspends all outgoing transfers. It may be extended, by reasoned decision of the compliance officer, to withdrawals, future receipts, and the creation of marketplace orders.

5.3 The user is notified of the freeze by a notification. Garabaly is not required to disclose the detailed reason for the freeze when a suspicious activity report has been filed with the competent authority or when disclosure would risk compromising an ongoing investigation conducted by a competent authority, in accordance with the legislation of the West African Economic and Monetary Union (WAEMU) on anti-money laundering.

5.4 Lifting of the freeze is subject to the completion of the internal compliance review and, where applicable, to the decision of the competent authority. A user whose wallet has been frozen may be assigned a reduced trust level for a period determined by Garabaly.

Article 6 — Data Retention

6.1 In accordance with anti-money laundering and counter-terrorism financing obligations applicable in the WAEMU zone, data relating to the wallet and its transactions are retained for a minimum period of ten (10) years from the date of the transaction or the closure of the business relationship, whichever is later, or any longer period required by a competent authority in the context of ongoing proceedings.

6.2 This includes in particular: identity documents, authentication and session logs, all wallet movements, escrow operations, orders, security events, transfer reasons, and the history of acceptance of these Conditions.

6.3 Closure of the user account does not terminate the legal obligation of retention for the period specified above.

Article 7 — Complaint and Appeal Procedure

7.1 Any user who contests a measure taken under these Conditions — including a transfer refusal, an applied cap, a hold, or a wallet freeze — may submit a complaint to Garabaly support through the channels indicated in the application.

7.2 The complaint is reviewed with a fresh perspective and, where possible, by a person other than the one who initiated the contested measure. A reasoned response is provided within a reasonable timeframe, subject to the confidentiality obligations applicable to compliance procedures (Article 5.3).

7.3 The user retains, in any event, the right to bring the matter before the competent court in accordance with Article 9 of these Conditions.

Article 8 — Versioning and Acceptance

8.1 The current version of these Conditions is indicated in the header of this document.

8.2 These Conditions are presented to the user when they become eligible for the transfer service — typically, upon completion of their first marketplace order meeting the conditions of Article 2. Acceptance constitutes a separate act from acceptance of the General Terms of Use of the platform.

8.3 Acceptance is recorded with the date, time, version accepted, and the date on which the eligibility criteria were met. The absence of valid acceptance for the current version constitutes grounds for ineligibility within the meaning of Article 2.

8.4 Any material update to these Conditions — including any modification of a threshold unfavorable to the user, any addition of an obligation, any modification of the right to freeze, or of the data retention period — triggers the presentation of a new acceptance prompt before the next transfer. Until the new version is accepted, the user is treated as ineligible within the meaning of Article 2.

8.5 These Conditions are available in French (reference version), English, and Arabic. In the event of a discrepancy in interpretation between versions, the French version shall prevail.

Article 9 — Governing Law and Dispute Resolution

9.1 These Conditions are governed by the laws of the Republic of Mali.

9.2 Prior to any judicial or arbitral proceedings, the parties undertake to seek an amicable settlement of the dispute within thirty (30) days from the date of written notification of the dispute by one party to the other.

9.3 Failing amicable agreement within the above period, any dispute relating to the interpretation or performance of these Conditions may be brought before the competent courts of Bamako, without prejudice to the parties' right to resort to arbitration by the Common Court of Justice and Arbitration (CCJA) of OHADA, in accordance with its arbitration rules in force.

Article 10 — Cooperation with Authorities

10.1 Garabaly cooperates with competent authorities, including the National Financial Information Processing Units (CENTIF), the Central Bank of West African States (BCEAO), and judicial authorities, in accordance with applicable legal obligations in the WAEMU zone.

10.2 This cooperation includes, without limitation, the filing of suspicious activity reports, responses to judicial requisitions, and the provision of data retained under Article 6.

10.3 Cooperation with competent authorities may be initiated without prior notification to the user concerned, under the conditions and within the limits provided by applicable legislation.

Article 11 — Miscellaneous Provisions

11.1 Severability. If any provision of these Conditions is declared null or unenforceable by a competent court, the remaining provisions shall remain in full force and effect.

11.2 Non-waiver. Failure by Garabaly to exercise a right or invoke a clause of these Conditions shall not be construed as a waiver of such right or clause.

11.3 Entirety. These Conditions, together with the General Terms of Use of the platform, constitute the entire agreement between the user and Garabaly regarding the wallet and user-to-user transfer service.

Contact

For any questions regarding these Conditions: [email protected]

Garabaly — Bamako, Republic of Mali

Representation Policy

Who Speaks for Garabaly

Updated October 7, 2026 — effective October 21, 2026

The following changes apply on publication: wording corrections; the clarifications on fees (section 5), on our email addresses (section 6) and on how the money for a purchase is paid out (section 8).

1. Why this page exists

Garabaly sends people to livestock markets to introduce the platform and help herders use it. That is useful work, and it is our job. But wherever there are people in the field, sooner or later someone will falsely claim to have been sent by Garabaly. This page sets out exactly what a Garabaly person may do, what they may never do, and how to check in one minute.

2. Only Garabaly binds Garabaly

No field agent, contractor, facilitator, relay point or partner may make a commitment on Garabaly's behalf. Only writing issued by Garabaly binds it. A promise made out loud by someone at a market binds only that person. This rule also appears at article 15 of our Terms of Service.

3. What a Garabaly person may do for you

  • Introduce the platform and answer your questions.
  • Help you create your account, on your phone, with your number.
  • Photograph your animal and write the listing with you.
  • Help you set up your wallet so you receive your money.
  • Show you how to use the platform on your own afterward.
  • And, if they do not know the answer to your question, check with Garabaly and come back to you.

4. What a Garabaly person may never do

  • Ask you for money, on any pretext — registration, file fee, promotion, commission, a thank-you.
  • Take your money, or a buyer's money, in cash or by personal transfer.
  • Ask for your PIN, or for an order's 6-character confirmation code.
  • Promise you a price, a buyer, a subsidy, a selling deadline or the outcome of a dispute.
  • Verify an account, decide a dispute, release funds or grant a discount.
  • Accept the terms of use on your behalf: you accept them yourself, from your own account.
  • Sell your animal off the platform, or ask you to close the deal off the platform.

5. Field assistance is free

Garabaly charges buyers no commission and no platform fee. A platform fee is charged to sellers and service providers on the successful completion of a transaction, and the percentages are displayed transparently in the app. There is no registration fee, no file fee, no assistance fee. If someone asks you for money in Garabaly's name, it is not Garabaly.

6. How to check someone in one minute

Ask for their name, then call or message Garabaly:

Our email addresses all end in @garabaly.com; our official address is [email protected].

We will confirm the same day whether that person works for Garabaly and what they are authorized to do. Someone genuinely sent by Garabaly has no reason to refuse the check, and no reason to be in a hurry. Until you have checked: hand over no money, no animal and no document, and sign nothing.

7. Your confirmation code and your PIN belong to you alone

The 6-character confirmation code is entered by the buyer alone, in the app, once the livestock has been received and inspected to full satisfaction. No one will ask you for it — not an agent, not Garabaly support, not anyone claiming to be from Garabaly. If you lose your code, support verifies your identity and issues a new one: it never asks you for the old one. The same goes for your PIN. Such a request is, by itself, the sign of an attempted fraud.

8. Pay and get paid on the platform

The money for a purchase paid in the app is held in escrow; nothing is paid out before the buyer has entered their confirmation code, and the seller's share is released to the seller at the end of the 24-hour buyer-protection window — see our Escrow Policy. A sale closed off the platform, or settled in cash hand to hand, carries none of these protections, and Garabaly can do nothing for you if a dispute arises.

9. Report an abuse

If someone invokes Garabaly's name to ask you for money, to obtain your code, or to make you sell off the platform, report them. Give the name, the place and the date, and a photo, if you can take one safely.

We immediately suspend any account involved, inform the market authorities, and refer the matter to the competent authorities where the facts warrant it.

10. Scope and updates

This policy applies to anyone acting on Garabaly's behalf, whatever their title — agent, business development officer, contractor, facilitator, relay point, partner. It forms an integral part of our Terms of Service. Any substantial change is announced in the app at least 14 days before it takes effect.

11. Contact

For any question about this policy, or to check on a person:

  • Phone and WhatsApp: +223 62 77 88 71
  • Email: [email protected]
  • In the app: Use the Help Center in the Garabaly app
  • Response time: We answer verification requests the same day.

Garabaly — Bamako, Republic of Mali