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  1. Preamble and Scope

This Privacy Policy (the “Policy”) describes how Africa Exporter Hub — the “Made In Africa 5.0” platform (“AEH”, “the Platform”, “we”, “us”) collects, uses, retains, shares and protects the personal data of users of its website, mobile application and related services (the “Services”).

AEH is a digital B2B and B2C marketplace, operating from Abidjan, Republic of Côte d’Ivoire, connecting Sellers (African artisans, cooperatives, SMEs, exporters and producers) with Buyers (individuals, businesses, distributors and importers located in Côte d’Ivoire, within the ECOWAS/UEMOA region, and internationally) for the marketing of “Made In Africa” products.

This Policy applies to any individual who uses the Platform as a Buyer, a Seller, an unregistered visitor, a logistics/payment partner, or a representative of a legal entity registered on the Platform. It includes provisions specific to Buyers and to Sellers, clearly identified in the relevant sections.

By creating an account, browsing the Platform, publishing a listing, placing an order, or otherwise using the Services, the user acknowledges having read this Policy and consents, where applicable, to the processing of data described herein, within the conditions and limits set by Ivorian law.

This Policy is established in accordance with Law No. 2013-450 of 19 June 2013 on the Protection of Personal Data of Côte d’Ivoire, its implementing decrees, and the guidelines of the Telecommunications/ICT Regulatory Authority of Côte d’Ivoire (ARTCI), the competent authority for personal data protection. For Buyers and Sellers located outside Côte d’Ivoire, in particular within the European Union, AEH endeavours to apply protection standards aligned with the General Data Protection Regulation (GDPR) where applicable.

  1. Identity and Contact Details of the Data Controller

The controller responsible for the processing of personal data collected in connection with the Services is:

  • Corporate name: AFRICA EXPORTER HUB SARL — “Made In Africa 5.0” Platform
  • Legal form: Private limited liability company (SARL) under Ivorian law [to be completed]
  • Registered office: [Full registered office address], Abidjan, Côte d’Ivoire
  • Trade Register number (RCCM): [RCCM number to be completed] — Abidjan
  • Taxpayer Account Number (NCC): [to be completed]
  • General email address: contact@africaexporterhub.com
  • Data protection email address: dpo@africaexporterhub.com

 

AEH has appointed a Data Protection Officer (DPO) responsible for ensuring compliance with this Policy, responding to data subject requests, and acting as the point of contact with ARTCI. Any question relating to the processing of personal data may be addressed to the DPO using the contact details set out in Article 23 of this Policy.

  1. Definitions

For the purposes of this Policy, the following terms shall have the meaning given below:

Term Definition
Personal data Any information relating to an identified or identifiable natural person, directly or indirectly, by reference to an identifier (name, identification number, location data, online identifier, etc.).
Processing Any operation or set of operations performed on personal data, whatever the method used (collection, recording, storage, alteration, consultation, disclosure, erasure, etc.).
User Any natural person who accesses the Platform, whether as a Buyer, a Seller, or a mere visitor.
Buyer Any natural or legal person, represented by a natural person, who uses the Platform to browse, order or purchase products offered by Sellers.
Seller Any artisan, cooperative, sole proprietorship, SME or exporter registered on the Platform to offer and market “Made In Africa” products to Buyers.
Account A secure personal space created by the User on the Platform, associated with a login and password.
Transaction data All information relating to an order, payment, delivery or exchange between a Buyer and a Seller via the Platform.
Processor Any natural or legal person who processes personal data on behalf of, and on the instructions of, the Data Controller.
ARTCI Telecommunications/ICT Regulatory Authority of Côte d’Ivoire, the supervisory authority competent for personal data protection.

 

  1. Data Collected From Buyers

In connection with the creation of a Buyer account, browsing, placing orders and using the Services, AEH may collect the following categories of data:

  • Identification data: surname, first name(s), date of birth, gender, copy of identity document (where required for fraud-prevention purposes or for high-value orders);
  • Contact data: email address, phone number, billing and delivery postal address;
  • Account data: login, password (encrypted), language and currency preferences, login history;
  • Transaction and order data: products viewed, added to cart or ordered, amounts, purchase history, reviews and ratings left for Sellers;
  • Payment data: payment method used (bank card, Mobile Money, bank transfer, e-wallet), data strictly necessary for payment processing via a licensed payment service provider — AEH does not retain full bank card numbers;
  • Delivery and customs data: delivery address, information required for customs clearance for international orders (where applicable, the importer’s tax identification number);
  • Communication data: messages exchanged with Sellers or customer service via the Platform’s integrated messaging system;
  • Technical and browsing data: IP address, browser type and version, operating system, pages viewed, time spent, cookies and similar identifiers (see Article 11).

 

  1. Data Collected From Sellers

Sellers, as professionals marketing products on the Platform, are subject to enhanced data collection, in particular for identity verification, tax compliance and fraud-prevention purposes. The relevant categories of data include:

  • Identification data of the legal representative: surname, first name(s), date and place of birth, nationality, copy of identity document or passport;
  • Identification data of the entity: corporate name, legal form, RCCM registration number, Taxpayer Account Number (NCC), articles of association, supporting evidence of activity (business licence, accreditation, quality certification, “Made In Africa” label, etc.);
  • Professional contact data: address of the registered office or production workshop, professional email address, professional phone number;
  • Banking and financial data: bank account details (RIB), Mobile Money account or e-wallet details for the payment of amounts owed for sales made through the Platform;
  • Product-related data: descriptions, photographs, certificates of origin, quality certifications (organic, fair trade, ISO, Rainforest Alliance, UTZ, etc.), technical data sheets;
  • Commercial performance data: turnover generated through the Platform, customer satisfaction rate, order-processing times, disputes and complaints;
  • Verification data (KYC — Know Your Customer): additional supporting documents that may be required under the due-diligence obligations applicable to marketplaces (see Article 17);
  • Technical and browsing data: identical to those described in Article 4 for Buyers.

 

  1. Sources and Methods of Data Collection

Personal data processed by AEH originates from the following sources:

  • Directly from the User, when creating an account, publishing a listing, placing an order, or communicating with customer service;
  • Automatically, while browsing the Platform, through cookies and similar technologies (see Article 11);
  • From authorised third parties, in particular payment service providers, logistics partners, customs authorities, or in the course of identity verifications carried out by specialised KYC providers;
  • From public or officially accessible sources, such as the Trade and Personal Property Credit Register (RCCM), for verifying the legal existence of a Seller.

 

  1. Purposes of Processing

Personal data collected is processed by AEH for the following purposes:

  • Creating, managing and securing Buyer and Seller accounts;
  • Enabling connections between Buyers and Sellers and facilitating the conclusion, performance and monitoring of commercial transactions;
  • Processing orders, payments, deliveries and, where applicable, customs-clearance operations;
  • Providing after-sales service and managing complaints, returns and disputes between Buyers and Sellers;
  • Verifying Seller identity and preventing fraud, money laundering, and fraudulent use of the Platform;
  • Ensuring tax, accounting, customs and regulatory compliance of AEH and its professional users;
  • Personalising the user experience (product recommendations, Seller promotion, translation and content adaptation);
  • Improving the Platform, its features and its technical performance, including through statistical analysis and security audits;
  • Communicating with Users for information, technical support, or, subject to their consent, commercial and promotional purposes;
  • Ensuring the security of the Platform, preventing intrusions, misuse and infringement of third-party rights;
  • Complying with legal and regulatory obligations applicable to AEH in Côte d’Ivoire and, where applicable, in the countries of residence of international Buyers and Sellers.

 

  1. Legal Basis for Processing

In accordance with Law No. 2013-450 on the Protection of Personal Data, each processing activity carried out by AEH relies on one of the following legal bases:

  • Performance of the contract between AEH and the User (terms of use and, where applicable, terms of sale) — in particular for account, order and payment management;
  • Consent of the data subject, in particular for the sending of marketing communications and the use of certain non-essential cookies;
  • Compliance with a legal obligation to which AEH is subject, in particular in tax, customs and anti-money-laundering matters;
  • AEH’s legitimate interest, in particular for securing the Platform, preventing fraud and continuously improving the Services, provided that such interest does not disproportionately affect the rights and freedoms of data subjects.

 

Where processing is based on consent, the User may withdraw it at any time, without affecting the lawfulness of processing carried out on the basis of consent prior to its withdrawal.

  1. Sharing of Data With Third Parties

AEH does not sell or rent its Users’ personal data. Data may nonetheless be disclosed, strictly to the extent necessary, to the following categories of recipients:

  • Between Buyers and Sellers: information strictly necessary to fulfil an order (name, delivery details, order content) is shared between the relevant Buyer and Seller;
  • Licensed payment service providers (banks, Mobile Money operators, electronic payment aggregators) for the secure processing of transactions;
  • Logistics providers and carriers (domestic and international), including customs brokers, for the delivery of orders;
  • Technical service providers (hosting, maintenance, cybersecurity, email and notification delivery) acting as processors within the meaning of applicable law, bound to AEH by contractual clauses ensuring an adequate level of data protection;
  • Administrative, customs, tax or judicial authorities, upon lawful request and within the limits provided by law;
  • Specialised identity-verification and anti-fraud (KYC/AML) service providers;
  • Any commercial or institutional partner of AEH (export-promotion bodies, chambers of commerce, certification bodies), only with the prior consent of the Seller concerned or in the form of aggregated and anonymised statistics.

 

In the event of a merger, acquisition, restructuring or transfer of assets of AEH, personal data may be transferred to the new operator of the Platform, subject to the maintenance of a level of protection at least equivalent to that guaranteed by this Policy.

  1. International Data Transfers

Given the export-oriented nature of the Platform, certain personal data may be transferred to countries outside Côte d’Ivoire, in particular where the Buyer or logistics partner is established abroad (ECOWAS/UEMOA countries, the European Union, North America, Asia, etc.).

Where such a transfer is made to a country not recognised as providing an adequate level of data protection, AEH implements appropriate safeguards, such as standard contractual clauses, enhanced confidentiality undertakings, or any other mechanism recognised by ARTCI or, where applicable, by the data protection authority of the destination country.

The User may request, from the DPO, a copy of the safeguards implemented for an international transfer of data concerning them.

  1. Cookies and Similar Technologies

The Platform uses cookies and similar technologies (pixel tags, local storage) to ensure its proper functioning, measure its audience and improve the user experience. Three categories of cookies are used:

  • Strictly necessary cookies: essential for the Platform to function (authentication, shopping cart, security) — these do not require prior consent;
  • Audience-measurement and performance cookies: enabling analysis of Platform usage for continuous improvement purposes;
  • Personalisation and marketing cookies: enabling content adaptation and, where applicable, targeted offers, subject to the User’s prior consent.

 

On first visit, the User is informed of the use of cookies via a dedicated banner allowing them to accept, refuse or configure their preferences. The User may modify their preferences at any time via their browser settings or the cookie-management module available on the Platform.

  1. Data Retention Periods

AEH retains personal data for a period not exceeding that necessary to achieve the purposes for which it was collected, extended, where applicable, by the applicable statutory limitation periods. As an indication:

Data category Retention period
Active Buyer/Seller account data Duration of the account, plus 3 years after last activity
Transaction and billing data 10 years from the close of the relevant financial year (accounting and tax obligations)
Identity-verification (KYC) data 5 years from the end of the business relationship, in accordance with applicable anti-money-laundering regulations
Connection logs and technical records 1 year from collection
Cookies Maximum of 13 months from being placed on the User’s device
Data relating to an ongoing dispute Duration of the proceedings, plus applicable appeal periods

 

Upon expiry of these periods, data is deleted, anonymised, or archived in a form that no longer permits direct identification of the data subject, unless otherwise required by law.

  1. Data Security

AEH implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of sensitive data and passwords (hashing);
  • Secure communication protocol (HTTPS/TLS) across the entire Platform;
  • Restriction of data access on a need-to-know basis, limited to authorised staff and service providers;
  • Firewalls, intrusion-detection systems and regular backups;
  • Periodic security audits and an incident-management policy;
  • Training and awareness-raising of internal teams on personal data protection.

 

Despite these measures, AEH cannot guarantee absolute security of data transmissions over the Internet. Users are encouraged to exercise vigilance, in particular by keeping their login credentials confidential.

  1. Rights of Data Subjects

In accordance with Law No. 2013-450 on the Protection of Personal Data, every User has the following rights over their personal data:

  • Right of access: to obtain confirmation that data concerning them is being processed and to obtain a copy of it;
  • Right to rectification: to request correction of inaccurate, incomplete or outdated data;
  • Right to object: to object, on legitimate grounds, to processing of their data, in particular for direct marketing purposes;
  • Right to restriction of processing, in the cases provided for by law;
  • Right to erasure, subject to AEH’s applicable statutory retention obligations (accounting, tax, KYC);
  • Right to data portability, where technically feasible;
  • Right to withdraw consent at any time, where processing is based on this legal ground;
  • Right to issue directives regarding the fate of their data after death;
  • Right to lodge a complaint with ARTCI.

 

These rights may be exercised by sending a written request to AEH’s DPO, accompanied by proof of identity, using the contact details set out in Article 23. AEH undertakes to respond to any request within a reasonable time, and no later than the period prescribed by applicable regulations.

  1. Marketing Communications and Preferences

Subject to the User’s prior consent, AEH may send communications relating to new products, promotional offers, invitations to events (trade fairs, exhibitions) or news about the Platform.

The User may unsubscribe from these communications at any time, either by clicking the unsubscribe link included in each electronic communication, by updating their preferences in their account settings, or by contacting customer service. Withdrawal of consent to receive marketing communications does not affect the performance of the Services or of ongoing transactions.

  1. Protection of Minors

The Platform is intended for adult Users with full legal capacity to enter into contracts. Creation of a Buyer or Seller account is reserved for persons at least eighteen (18) years of age.

AEH does not knowingly collect personal data relating to minors. If AEH becomes aware that an account has been created by or for a minor in breach of this Policy, AEH reserves the right to suspend or delete that account and the associated data.

  1. Identity Verification and Anti-Fraud (KYC/AML)

To ensure the security of transactions and trust between Buyers and Sellers, AEH implements identity-verification procedures (“Know Your Customer” — KYC) proportionate to the nature and volume of transactions carried out, in particular for Sellers and for Buyers placing high-value orders.

These procedures may include verification of identity documents, verification of the legal existence of the business (RCCM), verification of bank details, and, where applicable, the use of specialised third-party providers for anti-money-laundering and counter-terrorist-financing purposes (AML/CFT).

Data collected for these purposes is treated with strict confidentiality and used solely for verification, regulatory compliance and, where applicable, reporting to the competent authorities in the event of suspected unlawful activity.

  1. Payments and Financial Data

Payments made on the Platform are processed by licensed third-party payment service providers, subject to their own regulatory obligations regarding the security of financial data (in particular the PCI-DSS standard for card payments).

AEH does not directly store or process full bank card numbers, security codes, or login credentials for Users’ Mobile Money accounts. Only the information necessary for accounting reconciliation (amount, date, transaction status, payment reference) is retained by AEH.

Sellers provide AEH with the bank or Mobile Money details necessary for the payment of amounts owed for sales made, net of AEH’s commission where applicable. This data is processed with enhanced confidentiality and shared only with the relevant payment service providers.

  1. Complaints and Competent Supervisory Authority (ARTCI)

Any User who considers that AEH’s processing of their personal data does not comply with applicable regulations may first submit a complaint to AEH’s DPO using the contact details set out in Article 23.

In the absence of a satisfactory response, or in the event of continued disagreement, the User may lodge a complaint with the Telecommunications/ICT Regulatory Authority of Côte d’Ivoire (ARTCI), the supervisory authority competent for personal data protection in Côte d’Ivoire, whose contact details are available on its official website.

For Users residing in another State with its own data protection authority (in particular within the European Union), a complaint may also be lodged with the competent authority of their place of residence, without prejudice to ARTCI’s jurisdiction.

  1. Personal Data Breach

In the event of a personal data breach likely to result in a high risk to the rights and freedoms of data subjects, AEH undertakes to notify ARTCI and the affected data subjects as soon as possible, in accordance with applicable legal obligations, and to take any corrective measures necessary to limit the consequences of the incident.

  1. Amendments to This Policy

AEH reserves the right to amend this Policy at any time, in particular to reflect legal, regulatory, technical or internal practice developments. Any material change will be brought to the attention of Users by notification on the Platform and/or by email, at least fifteen (15) days before it takes effect.

The date of the last update appears on the cover page of this Policy. Continued use of the Services after amendments take effect constitutes acceptance of the amended Policy.

  1. Governing Law and Jurisdiction

This Policy is governed by Ivorian law. Any dispute relating to its interpretation or performance that cannot be resolved amicably shall be submitted to the exclusive jurisdiction of the courts of Abidjan, Côte d’Ivoire, without prejudice to the right of a consumer User to bring proceedings before the courts of their place of residence where applicable law so guarantees, nor to their right to refer the matter to ARTCI or any competent data protection authority.

  1. Contact

For any question relating to this Policy or the exercise of the rights described in Article 14, the User may contact AEH:

  • By email: privacypolicy@africaexporterhub.com
  • By post: Data Protection Officer — Africa Exporter Hub, [Full registered office address], Abidjan, Côte d’Ivoire
  • Via the contact form available on the Platform, under “Privacy”

 

AEH undertakes to handle every request diligently and within the time limits prescribed by applicable regulations.

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