This document was published in its 1.1. version, on the 20th of July 2022 and is effective from that date.The purpose of this privacy notice is to inform you, the user and/or Participant (registered user and/or anonymous visitor) of this website in a clear, simple and transparent manner of the processing carried out on the personal data that you entrust to us, or that we may be led to collect during your browsing on our website www.sango.org (hereinafter the “Website”), of their possible transfer to third parties, and of the rights and options available to you to control your personal information and protect your privacy.
You agree to release us from any claims or disputes that may come from using these websites.
You should read all terms and conditions, privacy policies and end user licenses that relate to these websites before you use them.
General
This Privacy Policy sets out the basis on which any information and/or data of the Participant, is collected, used and disclosed by COMIGEM (Comptoir de Mineraux Et Gemmes), Rue de L’Industrie, BP 26 Bangui, Republique Centrafricaine, hereafter referred to as the Company and/or COMIGEM, when participating in the Token Offer, accessing or using the Website or the Services. The Company is committed to preserving the privacy of all visitors of the Website and/or Participants and users of the Services. The Policy explains how the Company complies with the General Data Protection Regulation (‘GDPR’) and the Brazilian General Data Protection Law (”LGPD”). By accessing this website and/or using the Services, the Participant is subject to the Terms. Please take time to read the provided Privacy Policy. By proceeding further, you have read and expressly consent to the collection, use, retention, processing, transfer and disclosure of Personal Data under the terms of this Privacy Policy. Information and/or Personal Data which may be collected, stored, processed, transferred, used and disclosed by the Company includes but is not limited to information and/or data that can be used on its own or with other information to, directly or indirectly, identify, contact, or locate a single person, or to identify an individual in context.
Definitions
The following terms “Controller”, “Processor”, “Data Subject” (as it is identified the Participant who originated from a European Union member state), “Personal Data”, “Processing Activity/ies”, “Cross-Border processing of Personal Data”, “Supervisory Authority” used in this document shall have the same meaning as in the GDPR.
Basic Principles Regarding Personal Data Processing
The Company, considered to be a Controller under the GDPR, shall adhere to the GDPR principles as stipulated in Article 5(2) of the GDPR as following: “Controller shall be responsible for, and be able to demonstrate, compliance with the principles.” The Personal Data must be processed fairly and lawfully; be obtained only for specific and lawful matters; be adequate and up to date; not to be held for any longer than necessary; and be protected in appropriate ways.
The Company shall be accountable and must disclose information held to the Data Subject when requested and the Processing of Data must be carried out in accordance with the rights of the Data Subjects.
The Company May Collect and/or Use the Following Information
Use of Information
Consent
Your Personal Data may be processed only if you have unambiguously given your consent or, the processing is necessary for the performance of the Services you request or, for compliance with legal obligations, pursuant the public interest or, requested in the exercise of official authority vested in the Company or a third party with whom the Personal Data is disclosed except where such interest is overridden by the interest to protect the fundamental rights and freedoms that arise from the right of privacy.
As an individual you may exercise your right to access your Personal Data held about you by the Company by submitting your request in writing to the following email address: [email protected].
Rectification, deletion
The Company shall at your request immediately rectify, block or erase your Personal Data that has not been processed according to the GDPR and Data Protection Act or processed unlawfully and where applicable proceed with notifying any third party about the measures undertaken. Although all reasonable efforts will be made to keep your information updated, you are kindly requested to inform us of any change referring to the Personal Data held by this Company. In any case if you consider that certain information about you is inaccurate, you may request rectification of such data.
International or Cross-border Transfer of Your Data and Your Express Agreement
The transfer of the Participant’s data may be necessary for enrolling in a newsletter and/or registering the interest in Products and/or Services offered by the Company, such as acquiring, holding or using the Token and/or using the Services, to provide updates and to respond to the Participant’s inquiries. As the internet operates in a global environment, the use of the internet to collect and process personal data necessarily involves the transmission of data on an international or cross-border basis. By using the Services or by communicating with the Company, the Participants acknowledge and expressly consent to the Company’s processing and disclosure of their Personal Data in this way. By using the Website, communicating with us, and using the Company’s Services, the Participants provide their express consent to the Company’s disclosure of their personal data to third-party intermediaries (if applicable) for the purposes described in this Privacy Policy.
Sharing of Information
The Company may share the Users’ / Participants’ data with others as follows:
Social Sharing and Links to Third Party Websites
When sharing the Website, Services or other Company’s information on social websites, this will enable the sharing of information with your contacts or the public, depending on the settings you establish with the entity that provides the social sharing feature. Service links to third party websites may be made available to you, and that are not owned or controlled by the Company.Please be aware that the Company is not responsible for the privacy practices of such websites.For more information about the purpose and scope of data collection and processing in connection with social sharing features and links to third party websites, the Company encourages you to visit the privacy policies of the entities that provide these features.
Furthermore, you are advised to conduct yourself appropriately when engaging with the Company on social media or when sharing the Website, Services or other Company’s information.
Data Retention
The Company will retain your Personal Data and that of visitors of the Website for a reasonable period or as long as the law requires. The Company will retain your data as long as needed for acquiring, holding or using the Token and/or for the provision of the Services.
Governing Law
By participating in the Token Offer and/or using the Services, or otherwise providing information to the Company, you consent to the processing and transfer of information in accordance with the national legislation in the Central African Republic.
If you believe that any information, we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
Use of Cookies
Security of Using the Website
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.
How we use cookies
A cookie is a small file which asks permission to be placed on your compute‘s hard drive. Once you agree, the file is added, and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.
There are different types of Cookies:
First-party Cookies are Cookies that are placed by COMIGEM or a third party for us.
Third-party Cookies are placed by our partners, vendors and other third parties. We do not control the collection or further use of data by third parties using third-party Cookies.
Web beacons (also known as pixel tags or clear GIFs) are small graphic images that are used in connection with the provision of our Services, and which typically work in conjunction with Cookies to track the use of an online service by its users. For example, when we send you emails, web beacons allow us to track if you opened the emails and clicked links to measure campaign performance and improve features.
Similar technologies are technologies which enable the entity using it to track your user behavior. This can be done by HTML5 Local Storage, pixels, tags, Flash Cookies (also known as “local shared objects” or “LSOs”), and other web application software methods, all of which store information in your browser or device. We may employ Flash Cookies in certain situations where we use Flash to provide some content such as video clips or animation.
The Company may use traffic log cookies to identify which pages are being used in order to analyze data about web page traffic and improve our website in order to tailor it to customer needs - COMIGEM only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
Links to other websites
Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.
Controlling your personal information
You may choose to restrict the collection or use of your personal information in the following ways:
Please note hat even if you opt-out of Cookies or interest-based advertising, you will still receive advertisements, they just won‘t be tailored to your interests. Also, if you opt-out or later delete your Cookies, use a different browser, or use a new or different device, you may need to renew your Cookie preferences. It could also affect the availability and functionality of our Services.
List of cookies we collect
The table below lists the cookies we collect and what information they store.
Cookie Name | Cookie Description |
---|---|
FORM_KEY | Stores randomly generated key used to prevent forged requests. |
PHPSESSID | Your session ID on the server. |
GUEST-VIEW | Allows guests to view and edit their orders. |
PERSISTENT_SHOPPING_CART | A link to information about your cart and viewing history, if you have asked for this. |
FSTF | Information on products you have emailed to friends. |
STORE | The store view or language you have selected. |
USER_ALLOWED_SAVE_COOKIE | Indicates whether a customer allowed to use cookies. |
MAGE-CACHE-SESSID | Facilitates caching of content on the browser to make pages load faster. |
MAGE-CACHE-STORAGE | Facilitates caching of content on the browser to make pages load faster. |
MAGE-CACHE-STORAGE-SECTION-INVALIDATION | Facilitates caching of content on the browser to make pages load faster. |
MAGE-CACHE-TIMEOUT | Facilitates caching of content on the browser to make pages load faster. |
SECTION-DATA-IDS | Facilitates caching of content on the browser to make pages load faster. |
PRIVATE_CONTENT_VERSION | Facilitates caching of content on the browser to make pages load faster. |
X-MAGENTO-VARY | Facilitates caching of content on the server to make pages load faster. |
MAGE-TRANSLATION-FILE-VERSION | Facilitates translation of content to other languages. |
MAGE-TRANSLATION-STORAGE | Facilitates translation of content to other languages. |
Final Provisions - changes to the Privacy Policy
The Company may update this Privacy Policy from time to time at its own discretion and in response to changing legal, technical and/or business development. The revised Privacy Policy will take effect immediately upon publication by the Company and we will replace this page with an updated version. When we update our Privacy Policy, we shall take appropriate action and inform you accordingly by a Privacy Notice consistent with the significant changes we would have made.
However, you acknowledge that it is your sole responsibility to check the “Privacy Policy” page from time to any time so as to be aware of any changes which may have occurred from time to time.