Afenlight logo

Privacy Policy

Last updated: September 20, 2024

 

Welcome to Afenlight, an African business directory platform. The website located at www.afenlight.com (the “Website”) and the Afenlight mobile application (the “App”) are collectively referred to as the “Platform.” The Platform is owned and operated by Afenlight SAS (98070491), a company formed and operating in accordance with the laws of the French Republic from its head office at 40 rue des Blancs Manteaux, Paris 75004 (hereinafter the “Company,” “Afenlight,” “we,” “us,” or “our”).

 

This Privacy Policy applies to you when you visit the Website, sign up for an account as a Business or a Consumer on the Platform or subscribe to receive marketing communication from us. 

 

This Privacy Policy informs you how we collect, use, store, share, and safeguard your personal data. We process all personal data that we collect from you in compliance with the European Union General Data Protection Regulation 2016/679 (EU GDPR), French Data Protection Act (Loi Informatique et Libertés), and other applicable privacy laws in the jurisdictions where we offer the Platform. 

 

Please read this Privacy Policy carefully before using the Platform. By accessing or using the Platform, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. 

 

Table of Contents

1. Definitions

2. Controller

3. Personal Data Collection and Use

4. Disclosure of Personal Data

5. Transfer of Personal Data

6. Data Subject Rights

7. Security of Personal Data

8. Third-Party Links

9. Children’s Privacy

10. Amendments

 

  1. Definitions

The following words, whenever used in this Privacy Policy, shall have the meaning defined hereunder:

 

“Account”

refers to a Consumer or Business user profile on the Platform, granting the account holder access to features and services specific to their user type, subject to compliance with the Platform's Terms of Service.

 

“Business”

refers to individuals or entities, including companies, freelancers, and artisans, that subscribe to the Platform to showcase their businesses, products, and services or post events on the Platform.  

 

“Business Profile”

refers to the publicly visible page on the Platform for a Business, containing information such as business details, contact information, images, videos, and other relevant content.

 

"Consumer"

 

refers to individuals who access and use the Platform to view/interact with information about Businesses on the Platform.

 

“Controller,” “Data Subject,” “Personal Data,” “Processing,” “Processor,” and “Supervisory Authority”

 

shall have the same meanings as defined in the EU GDPR. 

 

“Data Subject Request”

means the exercise by a Data Subject of their rights in accordance with EU GDPR.

 

“Login Credentials”

means the Account access credentials that enable users to sign in and access the Platform features and functionality.

 

“Subscription Fee”

refers to the amount a Business pays the Company for their selected paid subscription plan.

 

“Subscription Plan”

refers to the various service packages offered by the Company to Businesses, including both free and paid plans. Subscription Plans determine the level of access and features available to the Business.

 

“Subscription Term”

means the initial term of a Business’s paid Subscription Plan and any subsequent renewal term (as applicable). Please note that if you are using the free plan, your subscription term will remain active until your Business Account is terminated.

 

‘User’, ‘you’ or ‘your’

refers to any registered account holder on the Platform, Consumers and/or Businesses, as applicable.

 

 

 

  1. Controller

Afenlight SAS is the controller of personal data collected through the Platform. Please send any data subject requests in writing to Afenlight at the following address:

 

Address:

Afenlight SAS

40 rue des Blancs Manteaux, 

Paris 75004

Email:

[info@afenlight.com]

 

  1. Personal Data Collection and Use

    1. What personal data do we collect from you? 

Depending on whether you use the Platform as a Consumer or a Business, we may collect the following personal data from you:

  • Full name,
  • Date of Birth,
  • Gender,
  • Email address,
  • Country of residence,
  • Nationality,
  • Billing information,
  • Multimedia content you upload;
  • Publicly available information about the Business,
  • Content of all communication you have with the Company;
  • Information that you provide us when you participate in our surveys or promotions; 
  • Information collected through the use of cookies and other tracking technologies;

 

  1. How do we collect and use your personal data?

We appreciate the trust you place in us when giving us your personal data. The details below describe how we collect and use different types of data, and our legal basis for this.

 

  1. Account Registration Data

When you sign up for an account on the Platform, you will be required to provide us with personal data, including but not limited to your:

  • Full name;
  • Email address;
  • Date of Birth; 
  • Gender; 
  • Country of Residence;
  • Nationality.

 

We process your Account Registration Data for purposes including: 

  • Assessing your eligibility for an Account on the Platform; 
  • Creating your Account;
  • Enabling you to log into your account and make use of the relevant features and functionality; 
  • Assisting you in recovering your lost account password;
  • Our compliance with applicable law or government requests; 
  • Asserting our rights and enforcing our Agreement with you.  
  • Communicate with you as and when required. 

 

Legal Basis of Processing 

Depending on the purpose of the processing, we may rely on the performance of a contract or our legitimate interest as the legal basis for processing your account registration data.

 

Retention Period

We will erase all personal data you provided during your Account registration within 90 days of your Account termination unless we are legally permitted to retain any portion or all of the Account Registration data for a longer period based on another legal basis.

 

  1. Subscription Data

As a Business, when you subscribe to one of our paid Subscription Plans on the Platform, we may process the following personal data about you:

 

  • Full name;
  • Email address; and
  • Billing address of the payment cardholder; 

 

Please note that although you provide your payment details when subscribing to a paid Subscription Plan on the Platform, all payment card data is directly collected and processed by the third-party payment processor Stripe Inc., in accordance with their own legal policies. We do not collect or store any payment card data on our database. 

 

We process your Subscription Data for the following purposes: 

  • To process your Subscription Fee; and
  • To provide you access to the Platform features and functionality according to your selected Subscription Plan; 
  • To process any cancellations and refund requests, if applicable; and
  • For our accounting and legal compliance purposes. 

 

Legal Basis of Processing 

We rely upon the performance of our contract with you as the legal basis for processing your Subscription Data. 

 

Retention Period

We may retain this data for up to ten years from the date of your last Subscription Fee payment for our accounting and legal compliance purposes.

 

  1. User Content Data

When you upload or post any content on the Platform, we collect the information contained in your User Content. 

 

We process your User Content Data to: 

  • Make your User Content available on the Platform, such as publishing your Business Profile, ratings and reviews;
  • Detect and prevent any fraud or other similar unauthorised activities on the Platform.  

 

Legal Basis of Processing 

Our legal basis for processing your User Content data is the performance of our contract with you and our legitimate interest.

 

Retention Period

We may retain your User Content Data so long as your Account remains active on the Platform. Following the termination of your Account, we shall have the right to retain your User Content Data for up to six (6) months. Please note that any Business ratings and reviews you submit through the Platform may be retained by us even after the termination of your Consumer Account. We will remove or redact any personal identifiers contained within your reviews while maintaining the substantive content.

 

  1. Support Request Data

We also collect personal data from you when you send a support request to our customer support team. Support request data may include your username, email address, and the content of the message ("Support Data"). Support Data may also include any other personal data requested by the Company to service your support request.

 

We process your Support Data to understand and respond to your support requests. 

 

Legal Basis of Processing 

Our legal basis for processing Support Data is our legitimate interest, which does not override your privacy rights. 

 

Retention Period

We will retain your Support Data for up to two years from the date of your Account termination. After this period, we may retain the content of your support request message by anonymizing it for our internal business purposes.

 

  1. Marketing Data

We collect your name and email address when you subscribe to receive marketing material from us or participate in our surveys/promotions. 

 

We process your Marketing Data to: 

  • Send you marketing material that we think you will find interesting; 
  • Create new offerings and improve our Platform; 
  • Fulfil any other purpose specified at the time we collect your personal data. 

 

Legal Basis of Processing 

Our legal basis for processing this personal data is your consent, which you grant us when you subscribe to receive marketing communication from us or voluntarily participate in our surveys or promotions. 

 

Retention Period

We may process your personal data for our marketing purposes until you withdraw your consent. 

 

  1. Publicly Available Data

For building initial Business Profiles, we may collect publicly available information about Businesses from various online sources, including but not limited to business websites, directories, social media platforms, and other publicly accessible data sources. We may receive data such as contact details (e.g., phone number, email, business address), website URLs, descriptions of products and services, images and logos, etc. 

 

We process this Publicly Available Data to create an initial business profile that can later be claimed and managed by the respective business. 

 

Legal Basis of Processing 

Our legal basis for processing Publicly Available Data is our legitimate interest that does not override your privacy rights. 

 

Retention Period

We will retain this data for up to two years from the date we originally obtained it. 

 

  1. Cookies

When you access our Platform, we may automatically collect some personal data about you through cookies such as your IP address. We can also infer your location from your IP address. 

 

Please note that except for strictly necessary cookies which do not require your consent (ePrivacy Directive 2002/58 EC), your personal data is only processed with your consent, which you grant us when you accept our cookies. 

 

We use cookies to improve our understanding of our users.

 

You can turn off cookies or remove them from your device by changing your browser settings at any time. To learn more about how you can manage cookies on your browser, please visit the applicable browser links provided hereunder: 

 

 

Please note that blocking cookies may result in a poor user experience. To learn more about how to delete cookies, please visit  https://www.aboutcookies.org/how-to-delete-cookies/.

 

  1. Disclosure of Personal Data

We respect your personal data, and we only disclosure your personal data as described hereunder:

 

  1. Third-Party Service Providers

We may share and disclose some personal data of our users with third-party service providers that we engage during the performance of our business operations, such as payment processing, web hosting, email distribution, marketing, and customer support services. For the avoidance of any doubt, we will only disclose your personal data, which is necessary for our authorised service providers to perform their functions on our behalf. Our service providers will only use your personal data in accordance with our written instructions. In no event will they be allowed to use it for any purpose other than those specified in this Privacy Policy. 

 

  1. Change of Ownership

In the future, if we acquire a business or are acquired by another business, our users’ personal data may be disclosed to the new entity as part of due diligence and transferred as part of the commercial transaction. In the event of any such changes in ownership, your personal data will continue to be governed by this Privacy Policy, except in cases where you expressly consent otherwise.

 

  1. Compliance with the laws

In some circumstances, we may be required to disclose your personal data if required to do so by the law or in response to valid requests by public authorities.

 

  1. To protect ourselves or our Users

We may disclose your personal data to:

  • Enforce our Agreement with you; 
  • Defend ourselves in legal actions; or, 
  • Protect our users or others from threats posed by your actions by sharing your personal data with other organizations as part of fraud protection.

 

  1. Transfer of Personal Data

Although we aim to process all personal data within the European Economic Area, we may use some tools and services provided by entities domiciled outside of the EEA, where data protection laws are not as stringent as those in the EEA. When we use such tools/services, your personal data may be transferred and processed outside the EEA. Whenever such data transfer takes place, we will ensure that it complies with the data transfer requirement as set out in the EU GDPR.

 

  1. Data Subject Rights

As a user, you have the following rights relating to your personal data:

 

  1. Right to access your personal data

You have the right to request access to your personal data or a copy of it by contacting us.

 

  1. Right to rectification

If the personal data we process for you is incorrect, outdated, or incomplete, you have the right to request we rectify, update, or complete it.

 

  1. Right to withdraw consent

To the extent the legal basis of our processing of your personal data is your consent, you have the right to withdraw your consent at any time. You may withdraw your consent from receiving direct marketing communication from us by clicking the unsubscribe link at the bottom of our marketing emails, and we will cease processing your personal data for direct marketing purposes.

 

  1. Right to the erasure of personal data

In limited circumstances, you may exercise your right to request the erasure of your personal data, such as where your personal data is being processed unlawfully.

 

 

  1. Right to file a complaint

If you believe that we have violated your privacy rights or are not complying with data protection laws, you have the right to file a complaint with the Commission Nationale de l'Informatique et des Libertés (CNIL), the French data protection authority.

 

You can contact the CNIL through their website or write to them at:

 

Commission Nationale de l'Informatique et des Libertés (CNIL)

3 Place de Fontenoy,
 TSA 80715,
 75334 PARIS CEDEX 07,
 France
Website: https://www.cnil.fr

 

Please note that we may request that you provide proof of your identity before servicing your data subject requests. 

 

  1. Security of Personal Data

The security of your personal data is important to us. We take all reasonable and financially viable steps to safeguard your personal data from unauthorised access, use, modification, destruction, or loss. We have integrated various security measures into the design of our Platform and our day-to-day business operations. Although we make our best effort to safeguard your personal data, you acknowledge that no mode of transmission over the Internet is one hundred percent secure; therefore, we cannot offer you any guarantees as to the absolute security of your personal data. By using the Platform, you understand and accept that the transmission of data through the Platform is carried out at your own risk.

 

  1. Third-Party Links

The Platform may contain links that will redirect you to third-party websites. Such third-party websites are not owned or operated by us. These third-party websites are governed by their own legal terms and conditions and privacy policy. We advise our users to review all third-party legal agreements before making use of their websites. You understand that the presence of any third-party links on our Platform does not constitute an endorsement of such a third party, and we cannot be held responsible for such a third party’s actions. Your decision to visit these third-party sites is entirely at your own risk. 

 

  1. Children’s Privacy

We are committed to protecting children’s privacy. The Platform does not allow individuals under the age of 13 years to submit any personal data. If you believe that a child has provided his/her personal data to us, please contact us, and we will investigate the matter and take appropriate action. 

 

  1. Amendments

We reserve the right to make changes to this privacy policy by inclusion, modification, or removal of any part at any time. When we make any material changes to this privacy policy, we will notify you by email or by changing the last modified date on top of this privacy policy. You agree that it is solely your responsibility to review this privacy policy when you revisit the Platform. Your continued use of the Platform after we post the updated privacy policy will constitute your acceptance of such changes.