PREAMBLE

FinAfrique is committed to respecting the privacy of users (“Users”) of the website www.finafrique.com (“the Site”) and to complying with its obligations regarding the processing of personal data, particularly in accordance with the European General Data Protection Regulation No. 2016/679 of April 27, 2016 (the “GDPR”), applicable since May 25, 2018. This Privacy Policy informs Users of the Site about how FinAfrique processes their personal data. In accordance with current regulations, this Privacy Policy applies when Users browse the Site and aims to inform them about the processing of their personal data (including the collection and use of such data).

PERSONAL DATA CONCERNED

FinAfrique only collects personal data that is necessary for the purpose for which it is processed (e.g., responding to an information request). The mandatory nature of the communication of this data is indicated at the time of collection. Here is the list of personal data collected from Users of the Site:

• Their identification data (first name, last name) ;
• Their contact details (email address, phone number) ;
• Their professional information contained in the contact form or in any other document that would be transmitted via the Site (such as a curriculum vitae);
• Their connection data (IP addresses, computer type and model, browser type). This information is used to (i) fulfill our legal and regulatory obligations and (ii) ensure the proper functioning of the Site, maintain its quality, and compile general statistics.

The personal data mentioned above is obtained when Users of the Site :

• Visit the Site (through cookies, in particular) ;
• Transmit information on the Site (especially through the contact form or email) or any documents whatsoever ;
• Send questions or specific requests ;
• And more generally, through any other means by which Users of the Site contact FinAfrique.

PROCESSING OF PERSONAL DATA : LEGAL BASES AND PURPOSES ?

The personal data of Users of the Site is collected and processed in accordance with applicable regulations. This collection and processing serve four (04) distinct purposes :

1. Enable FinAfrique to comply with its legal and regulatory obligations regarding the retention of personal data. This data may also be used in identifying the authors of content that is deemed illicit. The primary legal basis for processing the relevant personal data here is compliance with applicable legal and regulatory obligations regarding the retention of personal data.

2. Enable FinAfrique to manage its business relationships with Users of the Site by informing them of the various services it offers and, where applicable, keeping them informed of the firm’s news via newsletter subscription (subject to obtaining their prior consent to receive such information and allowing them to unsubscribe at any time by clicking on the “unsubscribe” link, with a reasonable time required to process such a request). The primary legal basis for processing the relevant personal data here is the consent of the Users of the Site.

3. Enable FinAfrique to receive applications (spontaneous or not) from Users of the Site by sending resumes. The primary legal basis for processing the relevant personal data here is consent.

4. Enable FinAfrique to secure the processed personal data against any fraudulent access, use, or disclosure by third parties by implementing data protection strengthened by the use of appropriate physical and logical security measures to ensure the integrity, confidential and secure processing of data. However, it is reminded that no security system is infallible. Therefore, FinAfrique cannot guarantee that the information concerned is completely secure. The primary legal basis for processing the relevant personal data here is legitimate interest.

PROCESSING OF PERSONAL DATA: RECIPIENTS ?

To process the personal data of Users of the Site, FinAfrique may engage partners (subcontractors) to provide all the services offered on the Site, including :

• To enable contact through the contact form and respond to inquiries ;
• To ensure the sending of commercial information subject to obtaining the prior consent of the relevant Users ;
• In general, in connection with the use of the Site to ensure hosting of Users’ data, sending emails, assisting them in using the Site, or helping them perform statistical analyses.

These third parties are contractually prohibited from using the personal data transmitted for purposes other than those for which they have been commissioned and are required to maintain the security and confidentiality of the information transmitted with a protection at least equal to that implemented by FinAfrique.

Personal data may not be disclosed without notice by FinAfrique, (i) except as required by law (including in the context of legal proceedings and/or an administrative or judicial order), (ii) to protect and defend FinAfrique’s rights, and (iii) more generally, to protect the personal security of its visitors or third parties.

STORAGE OF PERSONAL DATA : DURATION ?

Unless otherwise required by law, FinAfrique retains the personal data of Users of the Site only for the period necessary for the purposes described above. Exceptionally, personal data may be archived to manage ongoing claims and litigation and to comply with legal and/or regulatory obligations or respond to requests from authorities authorized to make such requests.

TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION

Some recipients of personal data may be located in countries outside the European Union that have not been the subject of a European Commission adequacy decision. In such cases, FinAfrique ensures that the transfer is carried out in compliance with current legislation and regulations by taking all appropriate measures and under legal, technical, and operational safeguards to ensure the confidentiality and security of personal data, including through the use of standard contractual clauses provided by the European Union or any other mechanism compliant with current regulations.

RIGHTS AND MEANS TO EXERCISE THEM

In accordance with current regulations, Users of the site have the following rights:

• The right to information about the processing of their personal data (clear, concise, and accessible information) ;
• The right of access (to receive a copy of the relevant personal data), rectification (the right to update the data), erasure of their personal data (the right to be forgotten if the purpose for which they were collected no longer exists or if the consent on which the data processing was based is withdrawn or if the data has been processed unlawfully) ;
• The right to restrict the processing carried out ;
• The right to data portability (to receive data in a structured, machine-readable format) ;
• The right to withdraw consent to the processing of data for the future (to withdraw consent at any time for future data processing) ;
• The right to determine the fate of data in the event of death, subject to legal and regulatory obligations requiring FinAfrique to keep them ;
• The right to lodge a complaint with the supervisory authority responsible for ensuring compliance with obligations regarding personal data : the National Commission for Information Technology and Civil Liberties (CNIL).

For any questions regarding this Privacy Policy or the exercise of the rights mentioned above : send an email to the following address infos@finafrique.com.

AMENDMENTS TO THIS PRIVACY POLICY

FinAfrique may, at any time and on an occasional basis, make changes to this Privacy Policy (particularly due to changes in current regulations). In such a case, the modifications will apply to personal data collected after the effective date indicated in the Privacy Policy, and Users of the Site will be informed through any means provided by FinAfrique.

The current version of the Privacy Policy is that of the date indicated at the beginning of the document. The exercise of certain rights may prevent FinAfrique from providing all or part of its services and may lead to the termination of the contract concluded with its client.