Last updated: 10 January 2024
This Privacy Policy ("Policy") provides the following information:
For the purposes of this Policy, the terms "personal data", "data subject(s)", "processing", "controller", "processor", "supervisory authority", "transfer" and "data breach" have the meanings ascribed to them in Article 4 of the General Data Protection Regulation (EU) 2016/679 ("GDPR").
Capitalized terms not defined in this Policy refer to terms as defined in the AFX54 Terms of Use - ("ToU") available here.
The data controller is AFX54, a société par actions simplifiée (simplified joint stock company), registered with the Paris Companies' Registrar under No. B 978 558 674, having its registered office at 12, rue de Lincoln, 75008 Paris, France.
AFX54 is a platform for broadcasting, exchanging and sharing texts, podcasts and videos (the "Platform"). The Platform is a digital window of which content is "Made in Africa" and where artists, athletes, influencers, writers, economists, comedians, whether well-known or not, can publish their content ("User Content") at their in their own time. The Platform and Services are available on computers, tablets and mobile phones.
As part of providing the Services, AFX54 collects personal data about users and visitors to the Platform under the conditions detailed below.
AFX54 only uses users' personal data if there is a legal basis for doing so.
AFX54 does not use algorithms to make decisions that would significantly affect without human review. AFX54 uses visitors’ and users’ data only for the purposes described below.
| Data | Detail | Purpose | Justifications / Legal basis |
|---|---|---|---|
| Identification data* | Surname, first name, e-mail address, telephone number, social media login details | Account creation and management of AFX54's relationship with users. Contractual obligation to provide the user with the Services associated with the use of their account. | Contractual necessity |
| Identification data | Surname, first name, e-mail address, telephone number, social network login details | Direct prospecting for marketing purposes | User consent |
| Identification data* | User and device IDs assigned at the time of registration | To recognize the user in order to provide the Services | Contractual necessity |
| Identification data* | Age group (under 18 or 18 and over) | Verification of the right to use the Platform and the Services and verification of the right to accept the ToU. | Legal obligation |
| Identification data | Age, gender | Audience measurement | Legitimate interest in audience analysis |
| Financial information | Payment information, transactions provided by the user when subscribing to a paying package or a trial and purchase offer. |
Processing of payment transactions not carried out by an external service provider Processing to comply with tax and accounting obligations and to pay all royalties to copyright holders and collecting societies | Contractual necessity Legal obligation |
| Location | Approximate location (IP address) collected by AFX54 when using the platform | Geo-blocking of unauthorized territories | Legitimate interest in managing access to the Platform |
| Usage data | Interactions with the product (including listening data), advertising data | Analyses of interaction with user content, market research, Service improvement studies, etc. | Legitimate interest in improving and developing the Service |
| User content | Photos, audio data, requests to customer Services. | Optimized interaction between the user and AFX54 and between users themselves | Legitimate interest in improving and developing the Service |
| Research history | Searches carried out on the Platform | Personalization of services, market research and improvement of the Services | Legitimate interest in improving and developing the Service |
| Diagnostics and performance data | Collected by AFX54 during use of the Platform and in the event of a crash. | Solving technical problems and preventing crashes | Legitimate interest in improving and developing the Service |
*Failure to provide this information will make it impossible to use the Services.
it was collected, but for no longer than 3 years, or 10 years in the case of financial data, as required by law. The specified retention periods start from the date of the user's last interaction with AFX54.
AFX54 takes technical, physical and organizational measures to protect user data against any unauthorized access, use or disclosure or any other data breach, and to prevent its loss or alteration. The implementation of these measures takes into account the state of the art, the nature of the processing, the sensitivity of the data and the potential threats and risks. In addition:
AFX54 restricts and limits access to users’ data by setting up access controls to monitor who accesses, uses and transfers personal data.
Employees who have access to data are required to comply with robust data confidentiality, protection and security policies.
Service providers who process user personal data on behalf of AFX54 are also required to comply with strict contractual requirements regarding the protection and security of personal data.
In connection with contracts, the Platform, the Services, legal obligations or the protection of AFX54's legitimate interests and the other purposes set forth in this Policy, AFX54 may disclose personal data to third parties.
AFX54 works with service providers, particularly technical and commercial service providers, who are located in different countries and/or who use service providers and computer servers located in different countries (for example, computer service providers, shipping companies, advertising service providers, connection service providers, security companies, banks, debt collection companies, etc.). For service providers used in the IT field for the Platform, AFX54 uses Easybroadcast SAS located at 10 rue de Strasbourg, 44000 Nantes, France. In each case, AFX54 provides these service providers with the data they require for their services. In addition, AFX54 enters into contracts with these service providers which include provisions to protect data, where such protection does not derive from law.
AFX54 may also share personal data with companies in its group and other companies in the event of an acquisition, merger or sale, or with law enforcement agencies.
AFX54 is fully committed to allowing users to exercise their rights regarding their data. These can be exercised by contacting the Data Protection Officer at dpo@afx54.com. Depending on the actions required, rights may also be exercised in the settings and preferences in the user account.