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Privacy Policy

 

Introduction and Data Controllers

 

At Water African Project, we place great importance on protecting your privacy. We are committed to complying with the General Data Protection Regulation ("GDPR", Regulation (EU) 2016/679) and other applicable data protection laws in France.

 

This privacy policy describes the personal data we collect from you, how we collect it, why we collect it, and how we may use and possibly share it. For information regarding the processing of cookies/pixels on our websites, please refer to our cookie policy (insert the link for the terms and conditions regarding cookies). Our contact details are provided at the end of this privacy policy.

 

Personal Data Collected by Water African Project

Privacy Policy

Effective January 1, 2024

 

Personal Data Collected by Water African Project

 

Website Visitors

When you visit our websites, we may collect personal data about you, such as the details entered in the contact form on the site. This collection and storage of information is not automatic. We manually store information based on the commercial relevance of the contact for Water African Project.

 

We also collect personal data through interactions with the websites, for example, by using cookies (please refer to our cookie policy at www.africanproject.com).

 

Finally, we may collect or receive personal data from third parties, such as social media platforms, websites, and business partners of Water African Project, or from publicly accessible sources. We use personal data to improve our services and to learn more about the behavior of our visitors through analytics and statistics based on the data we collect.

 

Customers or Prospects

When you are a customer of Water African Project, we collect personal data to provide you with the best possible service.

The personal data collected includes, among others:

- Your personal information, such as name and surname, signature, language preferences, video/audio recordings, and photos of you (in case of remote assistance), birthday, etc.

- Your contact details, such as (business) address, country of residence/geographic region, phone number, email address, etc.

- Work-related information, such as industry, role, employer, relationships with other parties (e.g., distributors or installers), your interests, etc.

- Sales-related information, to the extent it contains personal data, such as email correspondence, information on business visits, participation in events or trade shows, participation in webinars, ongoing orders or active subscriptions, purchase/order history, subscription history, quote history, delivery addresses, discounts, and premiums, etc.

- Product-related information, to the extent it contains personal data, such as a list of sold equipment, the condition of the equipment on a project (photos, videos, list of brands in place, serial number, etc.), installation dates, project information and financing, interventions carried out by us, etc.

- Information on product usage conditions, to the extent it contains personal data and can be linked to you as a customer, such as water flow and pressure, water and wastewater discharge, energy consumption, raw water analyses, treated water objectives, temperature, other usage data, error reports, maintenance status, ongoing service visits, usage logs, etc.

- Service provision and customer support information, such as pre-sizing reports, support reports, commissioning reports, etc.

- Transactional and/or financial information, to the extent it contains personal data, such as billing details, bank details, credit or debit card information, credit agency information, etc.

- Details concerning visits to Water African Project or elsewhere, to the extent we host or facilitate your visits and travel as part of a collaboration with Water African Project, such as the reason for your visit, and if applicable, your dietary needs, accommodation, travel itinerary, a copy of your passport (if necessary), your personal address (if necessary), emergency contacts, photos, and group photos, etc.

- Your activity on relevant third-party platforms, such as social media (in accordance with your consents/settings on these social media) and our business partners' platforms.

- Survey and customer satisfaction data, such as responses to surveys, feedback provided to Water African Project or its employees.

 

The personal data mentioned above will only be collected to the extent relevant to our customer relationship. Generally, we collect your personal data directly from you or your employer/colleague.

We may also collect personal data from Water African Project offers (e.g., product type, your company’s or your service's applications) and our website when you use our contact form.

Finally, we may collect or receive personal data from third parties, such as social media platforms, websites, and business partners of Water African Project, or from publicly accessible sources.

 

Suppliers

If you or your employer are a supplier to Water African Project or a subcontractor of a Water African Project supplier, we may collect personal data about you to ensure the smooth running of our business relationship.

The personal data collected includes, among others:

- Your personal information, such as name and surname, username/login and password (if applicable), signature, language preferences, etc.

- Your contact details, such as your (business) address, country of residence/geographic region, phone number, email address, etc.

- Work-related information, such as industry, role, employer, relationships with other parties, work permit status, training and courses/certifications completed (if applicable), etc.

- Transactional and/or financial information, to the extent it contains personal data, such as billing details, bank details, credit agency information, etc.

- Details concerning visits or work at Water African Project or elsewhere

- Supplier survey data, such as responses to surveys, feedback provided to Water African Project or its employees, etc.

 

The personal data mentioned above will only be collected to the extent relevant to our relationship with you. Generally, we collect your personal data directly from you or your employer/colleague. We may also collect personal data from offers made to Water African Project. Finally, we may collect or receive personal data from third parties, such as social media platforms, websites, and our business partners, or from publicly accessible sources.

 

Legal Bases for Processing Personal Data by Water African Project

 

In accordance with European and French data protection law, depending on the various contexts, we:

- Ask for your consent (Article 6(1)(a) of the GDPR), such as for cookies on our websites. You have the right to withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal or processing based on another legal basis for consent.

- If you are a customer or prospect, we may use your data in accordance with the GDPR (data Article 6(1)(b) of the GDPR), our use of personal data will often be necessary to contact you, provide a quote, fulfill an order, or provide a service contract with you.

- Are subject to several legal obligations under European, French, or destination country law, including accounting and record-keeping, tax and customs obligations, sanctions, and export control obligations, etc. Therefore, we process your personal data to ensure our compliance with these obligations (Article 6(1)(c) of the GDPR).

- Finally, in some contexts, we process your personal data based on the legitimate interests of Water African Project (Article 6(1)(f) of the GDPR). This is the case, for example, when we use data from our offers (products, services) and/or orders.

 

These legitimate interests are deemed not to be overridden by your interests or fundamental rights and freedoms as a data subject - in this regard, we emphasize that our pursuit of legitimate interests is also in your interest as a prospect, customer, supplier, and website visitor. If you want to learn more about how your personal data is processed in the context of our legitimate interests, please contact us using the contact details below.

 

Sharing and Transferring Your Personal Data

 

We only share your personal data when necessary to achieve the objectives described above. We may share it with:

- Our employees based on their role and the nature of the data

- Water African Project's business partners (e.g., suppliers, sales and marketing partners (including social media platforms), logistics partners, event organizers, Water African Project customers)

- IT service providers and data processing companies on behalf of Water African Project, such as hosting services, IT support, cloud services, etc.

- Other recipients supporting Water African Project's business or legal operations, such as consultants, lawyers, etc.

- Other authorized third parties who may need to access or store personal data if required or permitted by applicable law

 

We do not sell your personal data and do not share it with unrelated third parties. In some cases, your personal data may be transferred to countries outside the EU/EEA. Water African Project ensures that such transfer will be conducted in accordance with applicable data protection laws (e.g., during our exchanges with a potential Water African Project subsidiary or company with a business relationship with Water African Project).

 

Retention Period for Personal Data

 

The personal data collected for the purposes mentioned above will only be retained for as long as necessary to achieve the intended purpose.

For example:

- If you are a customer, prospect, or supplier, or if your employer is, we will retain your contact details for as long as we have an active relationship with you. When the relationship is no longer active, personal data will be retained for an additional period to enable us to re-establish the relationship if necessary, or as required by applicable law and as long as necessary to ensure the proper execution of any remaining contractual obligations.

- Financial, transactional, tax/customs, and compliance-related personal data (such as billing details, payments received or made, sanction screening results, etc.) will be retained for as long as required by applicable law or as long as necessary to ensure the proper execution of contractual obligations.

- If a legal or disciplinary action is initiated or contemplated, personal data may be retained until the end of such action, including any potential appeal period, and will then be deleted or archived.

- When personal data is deleted, the data (including behavioral information

 

) may be retained in an anonymous form that does not allow identification.

 

Location and Security for Retention of Personal Data

 

At Water African Project, data backup and security are at the core of our concerns to ensure the protection and confidentiality of our employees' and customers' information. To this end, we use a combination of advanced technologies and platforms from recognized providers such as Apple and Microsoft. We use a CRM for storing some of the data and a cloud server with local backup for sharing and server storage.

- Backup Location: All data collected and processed by Water African Project is securely stored on highly protected cloud servers. A secure online folder-sharing software serves as a central repository for collaborative documents and data, while a CRM hosts information related to customers, prospects, employees, suppliers, or partners, ensuring secure and controlled access to relevant information. The data is accessible on these servers based on their professional nature to authorized personnel with two-factor authentication.

- Data Security: We apply strict security measures on all our devices and platforms. Mobile phones and computers are equipped with data encryption systems and password protections, in addition to two-factor authentication for secure access. Our CRM and file-sharing platform benefit from Microsoft's integrated security, including data encryption in transit and at rest, as well as role-based access controls to limit access to sensitive information to authorized personnel only. Similarly, our Exchange-type email system is protected by advanced anti-spam and anti-malware filters, ensuring the security of internal and external communications. By integrating these advanced technologies with strict security policies and regular training for our employees, Water African Project is committed to maintaining a secure digital environment, where data is not only reliably backed up but also protected against unauthorized access or potential threats.

 

Data Breach Procedure

 

Despite our efforts to protect confidential information, we recognize that security incidents may occur. In the unlikely event of a data breach, we have established the following procedure to respond effectively and in compliance with applicable regulations.

- Detection and Identification: At the first indication of a data breach, our IT and security teams are responsible for identifying and confirming the incident. This includes determining the nature of the breach, the data affected, and the extent of the incident.

- Containment and Eradication: Once the incident is confirmed, immediate measures are taken to limit the impact of the breach. This may include taking affected systems offline, revoking compromised access, and implementing security patches.

- Notification: In accordance with the GDPR and local data protection laws, Water African Project commits to notifying the competent regulatory authorities without undue delay, and if possible, within 72 hours of discovering the data breach. If the breach presents a high risk to the rights and freedoms of individuals, the affected individuals will also be informed without delay.

- Risk Assessment: A detailed risk assessment will be carried out to understand the potential consequences of the breach and identify the necessary measures to prevent similar incidents in the future.

- Resolution and Recovery: Efforts will be made to restore affected systems and data to their normal state, ensuring that security is strengthened to prevent future breaches.

- Post-Incident Documentation and Review: All actions and decisions taken in response to the breach will be documented in detail. A post-incident review will be conducted to evaluate the response to the incident, identify lessons learned, and make improvements to our procedures and security measures.

- Communication: Water African Project commits to maintaining transparent communication with all stakeholders throughout the incident management process. This includes regular updates on the status of incident resolution and the measures taken to strengthen data security.

 

The protection of personal data and the trust of our customers, employees, and partners are paramount to Water African Project. We are committed to treating all data breaches with the utmost seriousness and taking all necessary measures to protect the information entrusted to us.

 

Your Rights

 

You always have the following right:

- Withdrawal of Consent: If you have declared your consent for any personal data processing activity, you may withdraw it at any time with future effect. Such withdrawal will not affect the lawfulness of processing based on consent before its withdrawal or processing based on another legal basis for consent.

 

Depending on your place of residence and subject to applicable laws, including the GDPR, you may also benefit from the rights below:

- Right of Access: You may have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed and, where applicable, to request access to such data. The access information includes - among others - the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data has been or will be disclosed. However, this is not an absolute right, and the interests of other individuals may restrict your right of access. You may have the right to obtain a copy of the personal data undergoing processing. For additional copies you request, we may charge a reasonable fee based on administrative costs.

- Right to Rectification: You may have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by providing a supplementary statement.

- Right to Erasure ("Right to be Forgotten"): In certain circumstances, you may have the right to obtain from us the erasure of personal data concerning you, and we may be required to erase such data.

- Right to Restriction of Processing: In certain circumstances, you may have the right to obtain from us a restriction of the processing of your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

- Right to Object: In certain circumstances, you may have the right to object, on grounds relating to your particular situation, or - where personal data is processed for direct marketing purposes - to object at any time to the processing of your personal data by us, in which case we can be required to no longer process your personal data.

- Right to Data Portability: In certain circumstances, you may have the right to receive the personal data concerning you that you have provided to us, in a structured, commonly used, and machine-readable format, and you may have the right to transmit those data to another entity without hindrance from us.

- Right to Lodge a Complaint: If you believe that the processing of your personal data infringes the GDPR, you have the right to lodge a complaint with a supervisory authority, particularly in the EU or EEA Member State where you reside, work, or where the alleged infringement took place. The right to lodge a complaint with your local supervisory authority may also apply outside the EU/EEA, depending on your place of residence.

 

Data Protection Officers and Contact Information

 

If you have any questions regarding this privacy policy or the processing of your personal data, or if you wish to exercise any of your rights as defined above, you can contact Water African Project located at 5 avenue du canal Philippe Lamour 30660, Occitanie, France +33 9 73 26 90 30.

 

Changes to the Privacy Policy

 

We reserve the right to modify or supplement this privacy policy at any time. To the extent that the changes to the privacy policy are considered important and significant, you will be informed, for example, by email or on our website. The privacy policy in effect at any given time will always be available on our website.

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