Personal data protection policy

1. INTRODUCTION

This personal data protection policy, as well as any document referred to therein, details the conditions under which SYSTID, a limited liability company with a capital of 2,000,000 CFA francs, registered in the trade and Crédit Mobilier de Lomé, under number TG-LOM-2016B 1812 (hereinafter “ We ” or “ SYSTID ”) proceeds, as data controller, to the processing described below and relating to the personal data of any user and/or customer of the website https://nzara.net (hereinafter the “ Site ”) and any user of the Site being hereinafter referred to as “ you ”.

We are committed to a policy of adopting and respecting demanding standards in terms of professional conduct and ethics in customer relations, and in particular the protection of personal data.

As such, We process your personal data in compliance with the principles set by the regulations applicable to the protection of personal data, and in particular the law 2019-014 relating to the protection of personal data in Togo of October 29, 2019 (ci -after the “ Personal Data Regulation ”).

In accordance with the Personal Data Regulations, the term " personal data " means, in the context of this policy, any information concerning you and allowing you to be identified directly or indirectly as a natural person.

This personal data protection policy may change depending on the applicable legal and regulatory context or the evolution of our activity, and in particular the products or services that We offer you.

2. THE PRINCIPLES APPLICABLE TO THE PROCESSING OF YOUR PERSONAL DATA

In the context of the collection and processing of your personal data, We are committed to respecting the following principles:

1.         Lawfulness : your personal data is collected for specified, explicit and legitimate purposes, and on the basis of an appropriate legal basis;
 

2.        Transparency : you are informed of each processing that We implement and the characteristics of this processing by means of information notices, no processing of your personal data being implemented without your knowledge;

3.       Minimization : We undertake to collect and process only the personal data concerning you which is strictly necessary for the objective that We pursue and to update them regularly;

4.       Data protection by design and by default : when developing, designing, configuring and using applications, services and products that rely on the processing of personal data, We take into account your right to the protection of personal data and We ensure with our partners that they meet the legal requirements and make it possible to effectively ensure the protection of the personal data which will be processed;

5.       Security of personal data : We have implemented technical and organizational measures, adapted according to the degree of sensitivity of the personal data collected, in order to ensure the integrity and confidentiality of your personal data and to protect them against any intrusion. misuse, loss, alteration or disclosure to unauthorized third parties. In particular, We use encryption and/or pseudonymization techniques for your personal data whenever possible, useful or necessary;

6.       Commitments of our service providers and partners : We choose our subcontractors, service providers and partners with care and require them: (a) to ensure a level of protection of your personal data equivalent to ours, (b) to use your personal data only to the extent necessary for the provision of the services that We have entrusted to them, (c) to comply with the Personal Data Regulations.

3. THE PROCESSING OF YOUR PERSONAL DATA

3.1 Persons concerned

The people concerned by the processing that We carry out are:

• any user of the Site;
• any customer of the Site..

3.2 Collection of personal data

We collect personal data about you directly from you.

In addition, We indirectly collect personal data about you from the following sources:

• management ;
• partners of SYSTID and Sellers;
• third parties, such as fraud prevention organizations or personal data providers;
• CinetPay and PayPal payment institutions .

3.3 Cookies

We use cookies and other tracers to collect personal data about you for the purpose of pursuing some of the processing purposes described in article 3.4 of this policy.

You can configure these cookies and tracers by clicking on this LINK EN . All the information about them in the cookie policy can be accessed HERE .

3.4 Purposes of processing, legal bases and retention periods

We implement various processing operations relating to your personal data, the purposes of which are detailed below and the legal bases of which are as follows: your consent, the performance of a contract concluded with you, our legitimate interest, or our obligations. legal and regulatory.

In accordance with the Personal Data Regulations, the personal data that We collect will be used for the fulfillment of the purposes for which they were collected and this for the period detailed in the table below, it being specified that a user and/or customer of the Site is considered "active" when he connects or modifies his personal space on the Site, makes an online purchase using his personal account, and/or makes an offline purchase or another interaction with We by identifying ourselves;

At the end of the storage periods described below, your personal data will be deleted or, for those that We are legally required to keep or which are necessary to safeguard our rights, placed in an archive and kept for an additional period. corresponding to the duration detailed in the table below. At the end of this period, your personal data will be deleted.

The legal bases and retention periods associated with each purpose of processing your personal data are described below:

If We are led to process your personal data for purposes other than those listed in the table above, you will be informed beforehand and We will take any additional steps that may be necessary to ensure the legal compliance of all the processing carried out.

3.5 Recipients of your personal data

To achieve the purposes described above and only to the extent necessary for the pursuit of these purposes, the personal data that We collect may be transmitted to all or part of the following recipients:

• within SYSTID :

1.         entities in charge of awarding, managing and executing contracts and orders;

2.        the SYSTID entities in charge of marketing (in particular the advertising agency and the media agency), customer relations, complaints, prospecting, administrative services, IT services;

3.       the SYSTID entities in charge of the centralized management of our customers' databases;

4.       any other SYSTID entity whose intervention would be necessary for the execution of the processing implemented in accordance with this policy

• outside of SYSTID:

1.         our service providers involved in all or part of the identified processing (in particular IT service providers responsible for maintaining the Site, technical intermediaries in the field of advertising and personalized communications, those responsible for the routing and delivery of products);

2.        our partners who sell products or services directly from our Site;

3.       our partners involved in the production and sending of commercial prospecting campaigns;

Furthermore, when you connect to your customer account using a Google account or a social network, or when you interact with links or advertisements accessible on our Site and referring to other sites or applications, it is possible, the third parties operating these sites, services or advertisements proceed, as separate data controllers, to process your personal data, under their own responsibility. We invite you to read their policies relating to the protection of personal data in order to know the conditions and methods applicable to the processing of your personal data that these actors implement.

4. YOUR RIGHTS AND HOW TO EXERCISE THEM

4.1 The content of your rights

With regard to your personal data, you have a right of access, rectification, erasure, opposition, limitation of processing, portability of your personal data and the right to give instructions relating to the fate of your personal data after your death.

You can also withdraw your consent at any time, in cases where it has been requested.

1.         Permission to access

You can request access to your personal data that We collect and process.

If you make an access request, We will provide you with a copy of your personal data in our possession as well as all legally required information.

2.        Right of objection

You can object at any time, for reasons relating to your particular situation, to the processing of your personal data when it is based on our legitimate interest, unless our legitimate interest prevails over your own interests and your rights and freedoms, or that the processing is necessary for the establishment, exercise or defense of legal claims.

You can also, at any time, oppose the processing of your personal data by us when this processing is carried out for commercial prospecting purposes by electronic or postal means, including when the processing concerned constitutes profiling.

3.       Right of rectification

You can at any time ask us to rectify any personal data concerning you that is inaccurate or incomplete.

4.       Right to erasure

You can request the erasure of your personal data under the conditions provided for by the Personal Data Regulations, unless they must be kept to enable us to comply with legal obligations, or to enable us to exercise or defend our rights or again, when they are necessary for the execution of the contract which binds us.

5.       Right to restriction of processing

You can request the limitation of the processing of your personal data under the conditions provided for by the Personal Data Regulations.

6.       Right to portability

You have the right to the portability of the personal data that you have provided to us and that We process by automated means, when the processing that We implement is based on your consent or on the performance of a contract or measures -contractual , provided that the exercise of this right does not infringe the rights and freedoms of third parties. Right to define directives relating to the fate of your data after your death

You have the possibility of defining general or specific directives concerning the way in which you intend to exercise, after your death, the rights which are guaranteed to you by the applicable regulations.

The general directives concern all the personal data concerning you, and you can revoke them at any time. They can be registered with a digital trusted third party certified by the National Commission for Computing and Liberties.

The specific directives concern the processing operations mentioned by these directives and are registered with Us: they are the subject of specific consent on your part and you can revoke them at any time.

4.2 Exercising your rights

In order to exercise your rights, you can:

• Complete this online form https://www.nzara. net /contact-us/data/form ;
• Or failing that, send us an e-mail or postal mail to the addresses below, specifying the right you wish to exercise, your personal data concerned by your request and indicating your surname and first name as well as the email address. -email associated with your customer or loyalty account (if applicable):
• Email: droitsdespersonnes@serviceclients-nzara. net
• Postal mail: “: SYSTID Customer Service - Right to Personal Data , 05 BP 727, Lomé 05.

4.3 Submitting a complaint

If you believe, after having contacted Us in this regard, that your rights relating to your personal data are not respected, you can submit a complaint to the Personal Data Protection Authority (IPDCP) (Av. Abdoulaye FADIGA, Opposite BCEAO, Lomé, Togo 01 BP 3679).