Should you have any request or concern regarding this Privacy Policy, how we treat any personal data, or want to exercise one of your rights, please send an e-mail to info@afriwise.com and we will immediately deal with any of your queries. Alternatively, you can reach out directly to our Data Protection Officer via email at the following address: giorgia.mattiello@afriwise.com.

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For the purposes of this Privacy Policy:

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• “Personal Data” means any information related to a living and identifiable person. It can include name, addresses, phone number, email address and any other information that can be used in order to identify a person;
• “Processing” covers all activities related to the use of personal data by an organization. It includes any kind of activity than can be performed on data, such as the collection, recording, storage, consultation, disclosure, alteration, erasure or destruction;
• “Data Controller” refers to the organization responsible for processing personal data;
• “Data Subject” indicates the person whose data is being processed;
• “Data Processor” means any person or legal entity involved in processing personal data on behalf of the controller.

Below you will find more information on:

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1. Who is responsible for processing your personal data
2. How we collect information from you
3. How your information is used
4. What are the legal grounds to process your data
5. Who has access to your information
6. For how long your personal information are stored
7. What are your rights as data subject
8. Which security precautions we put in place to protect the loss, misuse or alteration of your information
9. Review of this Privacy Policy

1. Who is responsible for processing your personal data?

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Afriwise is responsible for processing your personal data in its quality of Data Controller in accordance with this Privacy Policy. Afriwise is a company developing and operating an online platform offering access to African legal knowledge and a comprehensive database of legal experts on demand. We are a public limited liability company registered in Belgium (BE 0679799160). Our registered office address is Avenue Louise 292, 1000 Brussels, Belgium. However, we work with partners and contractors across the world.

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2. How do we collect information from you?

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We obtain information about you in three different ways:

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• When you directly provide us with your personal data: this information may include your name, address, email address, phone number, job title and/or company;
• We may collect your data from other sources: this information may include data received from third parties, prior data processing agreement with them or information we can find in publicly available websites;
• When you interact with our website we collect data through automated technologies: this information may include your IP address, browser type and version, and your operating system. It also includes usage data, such as which URLs are accessed and when. These technologies include web analytics services, such as Google Analytics, Hotjar and Hubspot, that make it possible to analyse your use of our website in order to collect data on users’ behavioural patterns and their devices and use them for strategy and marketing purposes.

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3. How is your information used?

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We may use your information to:

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• Activate and manage your user account access to our platform;
• Notify you of any update, change or announcements related to our products’ and services’ offering;
• Send you newsletters about legal developments in Africa;
• Send you invitations for webinars or other events;
• Create a profile of your interests and preferences to contact you with targeted content and relevant information;
• Provide support and answer to your requests, queries and concerns;
• Promote our business through marketing communications and company or product newsletters;
• Invite you to participate to initiatives, surveys or events;
• Seek views or comments on the products we develop and the services we provide;
• Identify trends and conduct data analysis for research and operational purposes;
• Process a consulting or job application.

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4. What are the legal grounds to process your data?

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We collect and process your personal data only where we have legal basis for doing so, in accordance with Article 6 of the GDPR. This means your data is processed only where:

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• You provided your consent;
• It is essential to perform the contract between you and Afriwise;
• It is required to fulfil a legal obligation; or
• It is necessary for the purposes of our legitimate interest to operate our business. This includes our interest to the continued development and improvement of existing and new products, tools and services.

Please remember that where the processing of your data just relies on your consent, you have the right to withdraw it at any time by sending your request to info@afriwise.com or giorgia.mattiello@afriwise.com , or by unsubscribing from automated newsletters or mails using the button at the bottom of such communication.

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5. Who has access to your information?

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Our third-party service providers who help us to place our products and services in the market and sell them, may have access to your information in their capacity of data processors. When we share your data with them, we disclose only the personal information that is necessary to deliver the service. A prior DPA (Data Processing Agreement) between them and Afriwise requires them to keep your information secure and process them in accordance with this Privacy Policy.

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Besides our service providers, Afriwise contributing partners may also have access to your personal information, for the purposes of helping us providing you with a relevant, up-to-date, and interesting offers. A prior agreement between them and Afriwise requires them to keep your information secure and process them in accordance with this Privacy Policy.

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We will not sell, rent or release your information in any other way to third parties beyond our network for them to use for their own direct marketing purposes, unless you have requested us to do so.

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However, we may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party, or as part of any business restructuring or re-organisation, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to enforce or apply our terms of use, or to protect the rights, property or safety of our supporters and customers. In this case, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

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6. For how long are your personal information stored?

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We will store your personal information for as long as necessary or permitted within the limitations of the purposes mentioned in this Privacy Policy and in accordance with the GDPR. The criteria used to determine the storage include the duration of the period in which we have a current relationship with you and provide you with our services.

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7. What are your rights as data subject?

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You may decide to exercise one of the following rights concerning the processing of data at any time by sending your request to info@afriwise.com or giorgia.mattiello@afriwise.com. Our DPO will make sure to answer your request as soon as possible. You have the right to:

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• Access the personal information we have processed and be informed about what data we have collected, why and with whom we may share it;
• Ask for the deletion of your data from our database if you have withdrawn your consent to the processing of your personal information, if the personal data is no longer required for the purposes it was collected for or if your data has been processed unlawfully. We will also request any third-party service provider, agent or subcontractor, with whom we have shared your information, to delete it immediately;
• Rectification when data has been wrongly recorded or has become inaccurate or incomplete;
• A temporary restriction of processing of your personal information under certain circumstances;
• Receive personal data you have provided to us in a structured, commonly used and machine-readable format and to ask that your personal data is transferred directly to another data controller;
• Object to further processing of your personal data if it is inconsistent with the primary purposes for which it was collected.
• Not to be subject to a decision solely based on automated processing which produces legal effects on you.

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8. Which security precautions do we put in place to protect the loss, misuse or alteration of your information?

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When you give us personal information or we collect your information, we take steps to ensure that it is treated securely. We have put in place an internal framework of policies and minimum standards to keep your data safe. More specifically and in accordance with the law, we take appropriate technical and organisational measures (policies and procedures, IT security and others) to ensure the confidentiality and integrity of your personal information and the way it is processed.

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9. Review of this Policy

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We keep this Privacy Policy under regular review. This Privacy Policy was last revised in April 2021.

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