Introductory information
Digital Africa Group ("we", "our" or "us") respects the privacy of its users ("you" or "your"). This information about the processing of personal data ("Information") explains how we collect, use, disclose and protect your personal data in connection with our website in any language version or location ("Website"). We process your personal data in connection with your use of Website, registration on Website, in connection with direct marketing and in connection with the storage of HTTP cookies on your device.
Specification of processing when using Website. If you use Website, we process for the B and C purposes set out below the records relating to your use of Website (IP address, Geo IP, operating system data, your browser type and version, and the user settings of Website) which are obtained automatically when you use Website and age information if you have provided us with such information.
Registration and Login Processing Specifications. If you create an account or log in to Website using a previously created account from our other platforms or products when using Website, we will further process your personal data when you use Website for the purposes A, B and C below, such as
- the contact details, including email, that you provided to us when you created your account;
- age information, if required for registration or after logging in;
- a pseudonymized identifier to monitor the operation of Website and report technical faults, other pseudonymized identifiers that we have put in place to protect you, and if you have chosen to register or log in to Website through your existing account with a third party (e.g. Facebook, Gmail, Apple), we also process your name, photograph and a third party generated pseudonymized identifier provided by such authorized third party for logging in;
- data about your purchases, if any, on the Website.
Purposes of processing. We process your personal data to the extent necessary for the following purposes:
- Purpose A: The purpose of processing your personal data is to perform a contract between you and us or to enable us to take steps prior to entering into such a contract in connection with your registration or login to Website.
-Purpose B: The purpose of the processing of the aforementioned personal data is to ensure the technical operation of Website, i.e. the proper and smooth functioning of Website and the related troubleshooting of reported technical errors and the subsequent optimization (prevention of errors in the future) of Website.
We have carried out an assessment of whether it is possible to process your personal data for this purpose and we have also carried out the necessary proportionality test, which assesses the interests in protecting your rights and our interests. We have concluded that, in view of the fact that most of the personal data we process is available for other purposes, that we use pseudonymized identifiers, that the removal of defects is also in the interest of Website user, that the subsequent optimization of Website is in the interest of all Website users, it does not appear to us that your interests or fundamental rights and freedoms to protect your personal data outweigh our legitimate interests as set out above.
- Purpose C: The purpose of processing your personal data is to comply with our legal obligations, particularly in the areas of tax, accounting, and advertising regulation.
for purpose A is that such processing is necessary for the performance of a contract between you and us or to enable us to take steps prior to entering into such a contract within the meaning of Article 6(1)(b) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (the "3.1 Regulation").
for purpose B is our legitimate interest under Article 6(1)(f) of the Regulation to ensure the technical operation of Website.
for purpose C, this is to comply with the legal obligations under Article 6(1)(c) of the Regulation.
- for purpose A for a period of three (3) years from the end of your contract;
- for purpose B for the duration of the contract if you have created an account with us, or for 1 month after using Website if you have not created an account; and
- for purpose C for the period necessary to comply with legal obligations in accordance with applicable generally binding legislation.
with hosting and software development services, and other companies in our group ("our group") may be other recipients of your personal data. In cases where we are required to do so by generally binding legislation, the relevant public authorities may also be additional recipients of your personal data for the purpose of fulfilling their obligations under generally binding legislation.
you have the right to request that we provide you with access to your personal data, the right to rectification or erasure of your personal data or restriction of its processing, and the right to the portability of your personal data. Please note that we may ask you to verify your identity before complying with such a request.
If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, inter alia, to lodge a complaint with a supervisory authority, in particular with a supervisory authority in the EU Member State where you are habitually resident, have your place of work or where the place of the alleged infringement of the Regulation is located.
You have the right to object at any time to the processing of your personal data for purpose B. In the event that you object to the processing of your personal data for purpose B, we will not further process your personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests or your rights and freedoms or where such data is necessary for the establishment, exercise or defense of our legal claims.
You are not obliged to provide us with your personal data. However, the provision of your personal data is a necessary requirement for purpose A, i.e. for the conclusion and performance of a contract, and without the provision of your personal data it is not possible to conclude or perform the contract and this may prevent you from using certain features and purchases within Website that are only available to registered users. The processing of your personal data for Purpose C is a legal requirement in connection with your potential purchase on Website.
6.1. Processing specifications. If you register on Website, or log in to Website using a previously created account from our other platforms or products (as our customer), we may send you commercial communications (marketing offers) regarding our own similar services in accordance with generally applicable law, and for this purpose we process:
- the contact details, including email, that you provided to us when you created your account;
- pseudonymized identifiers that we have put in place for your protection and, in the event that you have chosen to register or log in to Website via your existing account with a third party (e.g. Facebook, Gmail, Apple), we also process the pseudonymized identifier generated and provided by such authorized third party for logging in;
This processing of personal data is not based on your consent, however, you have the right to object to this processing at any time.