Privacy policy

Personal data use policy

DIGITAL AFRIQUE TELECOM (hereinafter "DAT", "We") aims at bringing digital transformation to Africa using mobile technology. For this purpose we are required to collect and process information, some of which is qualified as «personal data». DAT attaches great importance to respect for privacy. We are committed to processing your personal data ethically and in accordance with law No. 2013-450 of June 19, 2013 relating to the protection of personal data in the Republic of Côte d'Ivoire. This Privacy Policy describes the personal data we collect when you use our applications, identification cards, payment cards, features or other services ("our services"), how it is used and shared, and your legal rights regarding your personal data.

To whom this policy applies

This policy applies to the following people

• any person who contracts with us for the supply of products and services, or who purchases a product from us or our partner network ("customer"), including potential customers to the extent that DAT processes your personal data;
• anyone who uses our website, mobile applications or any product or service ("users");
• resellers, such as distributors and agents of DAT, as well as partners ("resellers"), including their employees, potential resellers, to the extent that DAT processes your personal data; All persons subject to this Privacy Policy are referred to as "users", "you", "your" in this Privacy Policy.

Types of personal data we collect and how we collect it

DAT collects the following types of personal data from users of its services:

Data provided by users

• Account information: We collect data when users create or update their access accounts to our services. This may include their name, email address, telephone number, login name and password, address, and payment or banking information.
• Identity Information: We collect data submitted by users to verify user identity in accordance with our legal obligations. These may include government identification documents such as national identity cards, passports, business registrations, etc. (which may indicate document numbers as well as date of birth, gender, photograph and home address). For businesses, this may also include identifying information for staff and legal representatives. This information may be collected by an authorized partner on behalf of DAT.
• User communications: We collect data submitted by users when they contact the support service, including for the purpose of responding to user inquiries and handling user complaints, and reporting the same data to regulatory authorities when this is required. The information collected may include comments or other information submitted by users in connection with the support service. We may also record telephone calls made to our technical support teams.

Data created when using our services

• Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, names of parties to the transaction including location, date, time and value.
• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, application features used, pages viewed, crashes and other system activity.
• Device data: We collect data about the devices used to access our services, including hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device movement data and mobile network data.
• Location data: To the extent permitted by applicable law, we may collect users' precise or approximate location data in order to prevent and detect fraud, and to satisfy legal requirements.

Data received from others parties

• DAT agents and business partners: DAT agents and other business partners through whom customers create or access their service accounts provide us with customer information, including information required to create customer accounts and identify customers. They may also provide us with information relating to users requests and transactions.
• DAT partners and suppliers: We may receive personal data of users from partner banks and service providers available on our application (e.g. utility providers), to the extent that this is necessary to provide the relevant services.
• Referencing agencies: We may work with background screening companies and credit referencing agencies that help us verify the identity and background of users, and screen users, including for purposes of sanctions requirements, fight against money laundering and know your customer.
• Publicly Available Sources: We may collect information from marketing service providers or data resellers for research or marketing purposes.
• Government authorities and law enforcement authorities: We may receive information from government and law enforcement authorities in order to detect, prevent and investigate fraud or other suspicious activities, and to comply with laws and applicable regulations.

Cookies and other tracking technologies

Cookies are small text files that are used to store small pieces of information on devices and websites loaded on browsers. We do not use cookies or similar tracking technologies on our website. We use similar tracking technologies on our mobile applications, to collect usage data and device data, as described in the section above (see "Data created when using our services").

How we use personal data

DAT uses personal data to provide and continually improve our services, and for commercial and marketing purposes. More specifically, we use personal data for the following purposes:

• Providing our services: We use data to provide, personalize and maintain our services. This includes using data to: create/update accounts; process transactions; troubleshoot software bugs and operational issues; and carry out other operations necessary to maintain our services.
• Research and development: We may use personal data for internal testing, research, analysis, product development and machine learning to improve the user experience.
• User Support: We use the personal data we collect from users (which may include call recordings) to provide service support, including to investigate and respond to user concerns and to monitor and improve our support responses and processes .
• Marketing communications: We may use personal data to market our services and the services of our partners to users. This includes sending users communications about services, features, promotions, studies, surveys, news, updates and events. We may do this through a variety of methods, including emails, text messages, push notifications, in-app communications and advertisements, and advertisements on third-party platforms. DAT does not sell users' personal data to third parties for their direct marketing, except with users' consent.
• Transactional Communications: We may use personal data to generate and provide receipts to users; notify them of changes to our terms, services or policies; or send other communications necessary for the effective provision of the Services.
• Fraud prevention and compliance with the law: We use personal data to prevent, detect and investigate fraud; and comply with applicable laws, regulations and operating licenses. This includes :
  • background checks;
  • facial recognition verification from photographs; And
  • Monitoring and analysis of device and usage data, including location data.
• Claims, disputes and legal proceedings: We may use personal data to investigate or address complaints or disputes relating to the use of our services, including in legal proceedings.

Who do we share personal data with

DAT's services, operations, business transactions and legal obligations may require us to share personal data with other users or third parties. DAT may share personal data with the following third parties:

• Other users: We share personal data, including telephone number and customer names (redacted where possible), with other users when transacting with each other.
• Subsidiaries and affiliates of DAT: We share personal data with our subsidiaries and affiliates to help us provide our services or carry out data processing on our behalf.
• Marketing service providers: We share personal data (including usage data and device data) with marketing agencies, research partners, social media and marketing platform providers, advertising networks and service providers. third party data to reach or better understand our users, target advertising and measure advertising effectiveness.
• Other suppliers and business partners: We share personal data (including usage and device data) with vendors, consultants, and other service providers or business partners that we engage to perform certain functions on our behalf. These may include: payment processors and facilitators; background and identity verification providers; cloud storage providers; software and digital security providers; insurance and financing partners; and professional service providers, including consultants, lawyers, accountants.
• The general public: User questions or comments submitted through public forums such as DAT blogs and DAT social media pages may be viewed by the public, including personal data included in a user's submitted questions or comments .
• Law enforcement and other government authorities: We may share personal data with law enforcement or other government authorities if we receive the appropriate legal mandate and the form and scope of the request comply with the law.
• The judicial system: We may share personal data with lawyers, the court system and other third parties for the purpose of enforcing DAT's terms and conditions, agreements, codes, policies and guidelines; or to protect the rights or property of DAT or the rights or property of others; or in the event of a complaint or dispute relating to the use of our services.
• Transfers and commercial transactions: As we continue to develop our business, we may restructure, refinance, merge or sell (all or part) of our business or services. As part of or during negotiations of such transfers and transactions, users' personal data may be transferred, along with other business assets.

DAT may share a user's personal data other than as described in this Privacy Policy if we notify the user and the user consents to such sharing. In the event of transfer of personal data to third parties, we will ask them to accept the necessary measures to protect the data, and to continue to respect the legal rights of users in accordance with the terms of this Privacy Policy and the laws applicable in the user's country.

Data security

DAT ensures that data is processed securely and confidentially, including when certain operations are carried out by subcontractors. To this end, we implement appropriate technical and organizational measures intended to guarantee the security of our services in accordance with applicable legal provisions, in order to protect your personal data against alteration, loss, misuse, deletion or disclosure. These measures consist in particular of:

• Raising awareness of the confidentiality requirements of our employees who have access to your personal data;
• Securing access to our premises and our IT platforms;
• Implementation of a general company IT security policy;
• Securing access, sharing and transfer of data.

These measures are adapted according to the level of sensitivity of the data processed and according to the level of risk presented by the processing or its implementation.

Your legal rights

You have rights in relation to your personal data under the Personal Data Protection Act, including the right to access, correct or erase your personal data, to object to processing of your personal data or to restrict it, and to unsubscribe from our emails and newsletters. Users can exercise these rights at any time via our applications or by writing to us at compliance@groupedigital.com Following an account deletion request, DAT deletes the user's account and data, unless it must be retained due to legal or regulatory requirements, for fraud prevention purposes, or due to a problem with the user's account, such as outstanding credit or an unresolved complaint or dispute.

Data retention duration

DAT retains user data for as long as necessary for the purposes described above and in accordance with applicable regulatory requirements.

Updates to this Privacy Policy

We may update this Privacy Policy. If we make significant changes, we will notify users in advance through our applications or by other means, such as email. We encourage users to periodically review this Privacy Policy for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated Privacy Policy to the extent permitted by law.