Privacy

Within the framework of its missions, Léger aims to offer various services to its members. During your navigation and your interactions with the application, we may collect and process some of your personal data.

However, Léger is responsible and respectful of privacy and attaches great importance to the protection of your personal data. The present policy therefore aims to explain to you, in complete transparency, the methods and characteristics of the data processing implemented by the company by means of or through, in whole or in part, the application.

What is the purpose of this policy?

In accordance with the provisions of Togolese Law No. 2019-014 of 29 October 2019 on the protection of personal data, it is brought to the attention of the "Users" of our Léger mobile platform that our legal notices are available free of charge on the platform. The purpose of this policy is to inform you of the methods of collection, processing and use of your personal data, as well as your rights in this context with regard to the provisions applicable in this area.

When do we process your data?

Your data is collected or processed in whole or in part when you browse the Léger application and enter information in the data collection forms provided, and more generally in the context of your relationship and subsequent exchanges with the company. Generally speaking, your data is therefore collected directly from you in the aforementioned cases.

In addition to this information, you are informed that the data we collect and process concerning you may be enriched by us, particularly for commercial, prospecting, communication or marketing purposes, by means of other sources of information (social networks, so-called "public" information, file rentals, etc.).

What categories of data do we collect?

Several categories of personal data concerning you may be collected, and in particular the following data :

• Identification data: this includes data such as your title, your first and last name, your contact details (e-mail address, telephone number, postal address, your profile photo, etc.);
• Your traffic and browsing history on the application, including information relating to the traceability of your actions on and interactions with the application (Facebook and Google Firebase SDK) as well as location data (location of the IP address for example), data relating to your terminal or tracking data on your actions with regard to the emails we may send you (openings, clicks, etc.);
• Data relating to the follow-up of your relationship with the company: request for contact, information or documentation, correspondence exchanged, data relating to your family, personal or even professional situation, data necessary for the realisation of loyalty actions, prospecting, studies, surveys, product tests and promotions, etc.
• Your geolocation data on the Léger application, after your agreement when installing the application.

Is the collection of this data mandatory?

Within the application, you are informed, on each personal data collection form, of the mandatory nature of the answers, and more generally of the information collected, by the presence of an asterisk next to the field(s) concerned. If there is no asterisk, the information requested is optional. If you do not provide the mandatory information, the request related to this data collection (for example: request for information, creation of alerts, etc.) may not be processed or its processing may be delayed.

For what purposes is your data collected?

Depending on the case, we process your data collected via the application in whole or in part for the following main purposes :

• The management, processing and follow-up of your requests and your exchanges with Léger by means of or initiated via the application (for example: request for contact, information, creation of alerts, etc.), and of Léger's relations with its contacts (customers, prospects, etc.) in general;
• The carrying out of prospecting, solicitation and communication operations (e-mails including newsletters and postal mail, telemarketing, targeting, segmentation and personalisation of exchanges, communication of job offers);
• The management and implementation of commercial, communication and marketing operations by Léger in the broadest sense;
• Accessing and benefiting from the features offered on the application such as email alerts or push notifications;
• To understand and study the use of the application by its users and their browsing behaviour in order to improve our online communication;
• To improve and optimise the quality and functionality of the application;
• To carry out and prepare studies, analyses, reports and statistics;
• The management and processing of requests from users of the application, and more generally from Léger's contacts, to exercise their rights in terms of personal data protection;
• The respect of legal and regulatory obligations resulting in particular from the company's activity.

Depending on the purposes pursued, the basis for such processing of personal data may vary. In general, such processing is necessary:

• For the management, processing and follow-up of your requests to the company (particularly in response to requests for the creation of alerts, information, etc.);
• For the pursuit of the legitimate interests of the company within the framework of the management and follow-up of its relations, in particular commercial relations, with the users of the application, and more generally with its contacts, and the organisation of its marketing, prospecting and communication operations in general;
• To comply with legal and regulatory obligations imposed on the company.

Who is your data intended for?

Your personal data is intended for Léger's authorised departments and personnel, as well as for our partners, if you agree.

It may be communicated, for some of the aforementioned purposes, and only if such communication proves necessary, to their possible service providers and partners, both contractual and commercial, who may be involved in the aforementioned processing of personal data.

Furthermore, your data may be communicated to any authority legally entitled to know about it, in particular in the event of a requisition from the judicial, police or administrative authorities. It is specified that the recipients referred to above are not necessarily recipients of all your data, but only those necessary for the purpose involving such communication.

How long will your data be kept?

Unless otherwise specified :

• Your data collected and processed by Léger is kept for a period of three years from the date of your last contact with the company (online request, e-mail or postal mail, telephone call, subscription to the newsletter, click in an e-mail addressed to you by the company, participation in an event,) or from the end of your contractual or commercial relationship with the company;
• The connection, navigation and traffic data are kept for a maximum period of thirteen (13) months.

It is specified that all of this data may however be kept for longer than the above-mentioned periods:

• Either after obtaining your consent;
• Or, in the form of archives, to meet any legal and regulatory obligations imposed on the company or during the legal limitation periods.

The above-mentioned retention periods have been defined in such a way as to enable us to process your requests (information, contact, registration, etc.) and/or to carry out our commercial, communication and marketing operations, while respecting the principle of proportionality, according to which personal data must not be retained for longer than is necessary to achieve the purpose for which it was collected.

What are your rights?

In accordance with the above-mentioned legal and regulatory provisions, you have the right to query and access your data.

You also have the right to rectify, delete and limit the processing of your data to a certain extent, as well as the right to the portability of your data. You also have the right to define general and/or specific directives concerning the fate of your personal data and the way in which you wish your rights to be exercised after your death. In this respect, in the event of your death which is brought to our attention, your data will be deleted, unless it is necessary to keep it for a specific period of time for reasons relating to our legal and regulatory obligations and/or legal limitation periods, and after having been communicated to a third party designated by you, if applicable.

All requests to exercise these rights, as well as all requests for information concerning the protection of personal data, must be made by mail to Team Alafia at its headquarters mentioned above:

• At the following e-mail address: support@teamalafia.com;
• The following postal address: Boulevard de le Voie Expresse, Lomé – TOGO

In the interests of confidentiality and protection of your personal data, the company must ensure your identity before responding to such a request. Therefore, any request to exercise these rights must be accompanied by a copy of a signed identity document. Some online forms on our application ask users to enter their telephone number and e-mail address. Users who do not wish to be canvassed are not obliged to provide this information. Finally, you should know that you have the possibility of lodging a complaint with a Togolese judicial authority responsible for the protection of personal data if you consider that your data is not being processed in accordance with the applicable provisions.

Cookies and other tracers or similar technologies

Cookies and other tracers or similar technologies (hereinafter "cookies") may be installed and/or read in your browser when you visit the application (SDK on Facebook and Google Firebase).

What measures are taken to ensure the security of your data?

In order to guarantee the security of your data, the company takes all useful and appropriate precautions and measures, whether physical, logical, technical, functional, administrative or organisational, with regard to the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing as well as the risks, the risks to the rights and freedoms of natural persons, the likelihood and severity of which vary, in order to safeguard the security and confidentiality of the data and to ensure a level of security appropriate to the risk, in particular to prevent their distortion, damage or unauthorised access by third parties.

Because of the difficulties inherent in conducting business on the Internet and the risks, which you are aware of, resulting from the transmission of data by electronic means, the company cannot be held to an obligation of result.

In the event of difficulties arising, the company will make its best efforts to circumscribe the risks and will take all appropriate measures, in accordance with its legal and regulatory obligations (corrective actions, informing the national authority in charge of the protection of personal data and, if necessary, the persons concerned).

In the event of subcontracting all or part of the processing of personal data, the company contractually requires its subcontractors to provide security guarantees and in particular confidentiality guarantees for the personal data to which they may have access (appropriate technical and organisational measures for the protection of such data).

What happens to your data on third party websites?

Links on the application may direct you to third party websites outside the company's website.

In this respect, your attention is drawn to the fact that the personal data protection policies of these sites may differ from that of the company.

It is therefore recommended, in all cases, to read the personal data protection policy of each of the sites concerned.

In any case, the company cannot be held responsible in the event that the data processing implemented via one of these sites contravenes the applicable legal and regulatory provisions.

How can I be informed of updates to this policy?

This privacy policy may be modified or adjusted at any time.

In case of modification or adjustment, the new policy will be posted on the application in the dedicated section. In addition, all the personal data collection forms on our platform provide a link to this policy.

We invite you to consult it regularly.

Last modification: 01/02/2023