PERSONAL DATA PROTECTION POLICY

African Legal Factory undertakes to implement adequate measures to ensure the protection, confidentiality and security of your personal data and to process and use such data in compliance with applicable provisions and in particular with European Regulation 2016/679 of April 27, 2016 (hereinafter the ” General Data Protection Regulation “) and Law no. 78-17 of January 6, 1978, known as the “Loi Informatique et Libertés”, and any laws or regulations that may supplement or replace it (hereinafter the ” Applicable Regulations“). “The purpose of this privacy policy (hereinafter the “Policy”) is to inform the User about how we process your data and about the commitments made by African Legal Factory to ensure that your personal data is respected.For the purposes hereof, the terms ” Personal Data “, ” Traitement “, ” Responsable du Traitement “, ” Sous-traitant “, have the definition given to these terms within Article 4 of European Regulation 2016/679 of April 27, 2016 (hereinafter the ” General Data Protection Regulation ” or ” GDPR “).

1. WHAT PERSONAL DATA DO WE PROCESS?

African Legal Factory collects personal data concerning its users in the following cases, for the following purposes:

1.1 WHEN BROWSING THE WEBSITE

In connection with the use of the African Legal Factory website accessible at www.africanlegalfactory.com (the ” Site “), African Legal Factory collects, through its servers, the following data:

• Your terminal’s IP and/or MAC address;
• Your terminal type ;
• The version of your browser.

This data is collected and processed for the purpose of displaying the Site on your terminal. This processing is based on the necessity of its implementation for the performance of a contract to which the user is a party, namely the conditions of use of the Site.and for the processing of certain personal data concerning you in your capacity as a user of the Site.

1.2 When using the contact form

When you use the contact form integrated into the Site, African Legal Factory collects, through this form, the following data:

• Your name ;
• Your telephone number
• Your e-mail address ;
• Your message as entered in the corresponding field.

This data is collected and processed for the purposes of African Legal Factory receiving and processing your message, and responding to you if the message contains a request from you. This processing is based on your consent, as expressed by your clicking on the button to send the form.

In the event that you enter data in the message input field that may be qualified as “sensitive data” under the applicable regulations, such as data relating to your state of health, you explicitly consent, by clicking on the send button on the form, to African Legal Factory receiving this data and processing it in order to reply to you.

It is understood that African Legal Factory neither requires nor encourages its users to communicate “sensitive” data in the context of the contact form.

1.3 Contract performance

As part of the execution of the contract, African Legal Factory is required to collect and process Personal Data concerning Customers in order to enable them to manage the contractual relationship. The data collected are only those strictly necessary for the performance of our services.

In this context, African Legal Factory, in its capacity as Data Controller, is required to implement Data Processing, in compliance with the Applicable Regulations, the purposes of which are the management of Customers (including for contact and communication purposes, the performance of assignments entrusted in particular the provision of legal services, contract management, invoices, accounting, monitoring of the contractual relationship), and more generally the management of operations enabling it to communicate with Customers about assignments that have been entrusted by the latter to African Legal Factory. The data collected may also be used for analysis purposes (such as trends, marketing progress, click and open rates).

Customers may also receive newsletters, informational content on various professional and legal subjects, press releases, invitations to training courses or events organized by African Legal Factory, all in an exclusively professional context.

2. WHAT IS THE LEGAL BASIS FOR OUR USE OF YOUR PERSONAL DATA?

The Treatments implemented in this context are based on :

• performance of the contract: this refers to processing for the purpose of carrying out assignments entrusted to African Legal Factory by customers, managing the contract, invoicing and monitoring the contractual relationship;
• the legitimate interest of African Legal Factory, and more particularly its economic interest: this concerns Processing linked to commercial prospecting operations. Such processing contributes to the promotion and improvement of its services by African Legal Factory and benefits visitors to the Site, Customers, employees, representatives and/or managers of Customers (who thus benefit from additional services free of charge) as well as African Legal Factory without infringing the interests, rights and fundamental freedoms of Customers.
• African Legal Factory’s compliance with its legal obligations: for example, processing related to accounting and tax obligations.

3. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

The Personal Data collected and processed in this context, as well as the entire Customer file, will be kept for the duration of the contractual relationship and for the applicable statute of limitations (5 years in this case). They may also be kept for a period of 10 years to comply with accounting and tax obligations.

4. FOR WHOM IS YOUR PERSONAL DATA INTENDED?

The Personal Data collected and processed in this context is accessible to the relevant departments within the company, i.e. lawyers, legal advisors (and any trainees) dealing with customer inquiries, and those in charge of billing, communications and IT.

The information collected, and in particular the Personal Data, may be communicated to third parties, acting as Subcontractors, bound by a subcontracting agreement to perform, in particular, hosting, storage, communication, data processing, database management or IT maintenance services. These Sub-Processors will only act on instructions from African Legal Factory and will only have access to your Personal Data in order to perform their services. They will be bound by the same security and confidentiality obligations as African Legal Factory.

5. IS YOUR PERSONAL DATA TRANSFERRED OUTSIDE THE EUROPEAN UNION?

The Personal Data collected and processed in this context are hosted within the European Union and are not transferred outside the European Union.

6. WHAT ARE YOUR RIGHTS?

Pursuant to the applicable laws and regulations on the protection of personal data, you have the following rights concerning the processing of your personal data:

• Right of access
• Right to portability
• Right of rectification
• Right to erasure
• Right to object
• Right to restrict processing
• The right to define directives concerning the fate of data after one’s death
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority.

To exercise these rights, please send a request to :

• by email to formation@africanlegalfactory.com ;
• or by post to : African Legal Factory, 14 rue le sueur 75016 Paris.

As these rights are purely personal, and can therefore only be exercised by the person concerned, please enclose a copy of your identity card with your request. This information will not be kept longer than is necessary to verify your identity.

You may object to receiving newsletters, communications and invitations to training courses and events organized by African Legal Factory by sending an email to one of the addresses given above. In addition, our commercial prospecting messages contain an “unsubscribe” option should you no longer wish to receive newsletters or invitations to events from us.

In the event of difficulty in connection with the management of Personal Data, you may lodge a complaint with the CNIL or any other competent authority. However, we invite you to contact us before lodging a complaint with the CNIL.

Customers undertake to pass on this information to their employees, representatives and/or managers whose Personal Data may be processed by African Legal Factory as a result of the performance of our assignments.

7. CHANGES TO THIS PRIVACY POLICY

Users of the Website will be notified of any changes or updates to this Privacy Policy by a posting on the Website.