SANGO Cookie & Privacy Policy


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 (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.

    1. General

    2. 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.

    3. Definitions

    4. 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.

    5. Basic Principles Regarding Personal Data Processing

    6. 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.

    7. The Company May Collect and/or Use the Following Information

    8. Information provided by the Participant: when using the Services and/or subscribing to the Company’s updates, responding to a survey or when filling enquiry forms on the Website and when corresponding by phone, e-mail or other communication services, you may be asked to provide Personal Data such as name, country or residence, e-mail address, phone number.
      Information, collected automatically by the Company on each visit to the Website, the Company will automatically collect the following:
      1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about the visits, including the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), products viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
      2. information may be collected by cookies and other tracking. Cookies are small data files that are stored on your device when visiting a website, which enable the Company to collect information about your device identifiers, web browsers used to access the Services, pages or features viewed, time spent on pages, mobile app performance and links clicked. Web beacons (or pixel tags) are electronic images that may be used to help deliver cookies, count website visits, understand usage, and determine the effectiveness of email marketing campaigns.
        Participants are advised that if they wish to deny the use and saving of cookies from this Website on their computer’s hard drive, they should take necessary steps within their web browsers security settings to block all cookies from this Website.
      Information, which is received from third parties this includes, but is not limited to the Company partners, sub-contractors in technical, advertising networks, or other third parties who may provide information, for the purpose of fulfilling the Services or to comply with legal requirements. The Company shall endeavor that these third parties are to provide the same level of data protection and that they shall only carry out their contractual obligations towards the Company or upon the instructions of the Company and not for any other purposes.
      Category of personal information that COMIGEM might process according to the present privacy notice and its general privacy policy:
      • information related to the identity of the user (Participant):
        • general information: first name, last name, middle name;
        • demographic information: citizenship, residency (including address of domicile and postal code), age (including date of birth), signature (including electronic signature);
        • biometric information: image and physical aspect;
      • contact information including email address and/or telephone number and/or address of correspondence;
      • digital presence: accounts’ username(s) and social media platforms that the User / Participants uses, posts and/or any related information that are published in such an account on a social media platform (e.g. Twitter, Facebook) and/or chat and/or digital communication platform and/or application (e.g. Telegram);
      • financial (transaction) related information: blockchain related addresses, transaction details, status of a transaction, type of order(s);
      • use of digital products and/or services: preferences and interests as presented in the Website and/or any related digital service that the Company provides the User/Participant;
      • other information relevant to the identity verification procedure (e-KYC which the User would need to undertake under the specific conditions of Veriff), customer / market surveys and/or offers;
      • Usage information - information about the usage of the Website, such as the pages the User viewed, the services and features the User used or interacted with, browser type and details about any links or communications with which you interacted;
      • Location information, including device motion information, or both, if the Users’/Participants grant permission to do so;
      • Expert advice – when the User/Participant interact with representatives of the Company, COMIGEM may receive information about the questions the User/Participants ask, the details of your accounts and the guidance provided to the User/Participant.
    9. Use of Information

    10. The Company may use your Personal Data when to supply you with the Services required, and to contact you when required. The Company may also analyze the Personal Data provided to help in administering, supporting and improving the business, as per the following ways:
      1. to provide, maintain, deliver and improve the Services;
      2. to send periodic emails with products and services;
      3. to follow up with the Participant after correspondence (live chat or email inquiries);
      4. for marketing and retargeting purposes;
      5. Purpose of the Processing - the reasons for which COMIGEM collects and processes your data in order to:
        • enable you to create an account on the Website and to subscribe to our newsletter;
        • manage your access to your account on the website;;
        • process and manage orders placed with COMIGEM through the Website;
        • manage the payment/deposits of your order;
        •  ensure the (electronical) delivery of the products and/or services you order;
        • ensure the security of online transactions, prevent fraud, payment incidents and manage collections (see the Website’s Terms and Conditions and the Sango Wallet Terms of Use for more details), in particular through the automated processing of your data;
        • to manage the member relationship in the context of requests for information or complaints that you may send us via the Website;
        •  to trace and manage product and/or service recalls and withdrawals, respectively annulments and refunds;
        • to carry out marketing operations (e.g. loyalty, promotions) and to send e-mail advertisements to our customers who have not objected or who have accepted it :
          • In regards to a products similar to that/those that the user has ordered -> carry out statistical analyses to develop steering, measurement and reporting tools to adapt and improve our sales and marketing activities;
          • In regards to other products offered by COMIGEM (e.g. if a registered user subscribes to a specific type of product and/or service offered through the Website, an alternative product and/or service may be offered).
        • transmit the data of the Website‘s users who have accepted to such said operation to provide COMIGEM’s commercial partners, including to enable them to send them advertising;
        • transmit the data of the Website‘s users who have accepted to such said operation to provide COMIGEM’s commercial partners, including to enable them to send them advertising;
      If you want to stop receiving information as per the above, you can opt out at any time by contacting us at the email address indicated in this Privacy Policy.
      At all times, access to the User / Participant’s Personal Data by the Company’s own staff and third-party intermediaries, will be restricted to the bare minimum required for the Company to perform our business and the provision of the Services.
      COMIGEM informs the users (Participants) that they may at any time modify their choices in terms of communications on the Website, via the specific section of their account and/or by submitting a request email at [email protected].
      The legal basis for data processing taking place through the Website:
      Account and Order management: the legal basis of the processing is the performance of a contract (see the Website’s Terms and Conditions, the Sango Wallet Terms of Use and the Token Subscription Agreement for more details);
      Sending newsletters, commercial solicitations by e-mail on products similar to those ordered by users (Participants): the legal basis of the processing is the legitimate interest of COMIGEM.
      Sending newsletters, commercial solicitations by e-mail about other products offered by COMIGEM through the Website to users: the legal basis of the processing is consent.
    11. Consent

    12. 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].

    13. Rectification, deletion

    14. 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.

    15. International or Cross-border Transfer of Your Data and Your Express Agreement

    16. 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.

    17. Sharing of Information

    18. The Company may share the Users’ / Participants’ data with others as follows:

      1. With partners necessary to acquiring, holding or using the Token and/or providing the Services;
      2. When using interactive areas of the Website, like our blog or other online forums, certain information you choose to share may be displayed publicly, such as your username, actions you take and any content you post;
      3. To Courts and Government authorities or bodies if requested to do so under a court order or legal process, or to establish or exercise the Company‘s legal rights or defend against legal claims;
      4. If the Company believes that the Participant‘s actions are inconsistent with the Terms or policies, or to protect the rights, property and safety of the Company or others;
      5. In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
      6. Between and among the Company for recording keeping and legal compliance related tasks;
      7. In order to use the information to improve the provided products and/or services;
      8. In order to use the presented personal data to contact the Participants/Users for market research purposes;
      9. In order to use specific information which might comprise of personal data in order to customize the Website according to Users’ interests and desires.;
      10. With the Participants’ consent or at their direction;
      11. Authorized persons within COMIGEM can access any personal data belonging to the Users (Participants) when this is necessary for the purposes of managing our business relationship or the legal obligations of the Company;
      12. Specific subcontractors such as:
        1. hosting and maintenance service providers for the Website and other dematerialized solutions for collecting personal data;hosting and maintenance service providers for the Website and other dematerialized solutions for collecting personal data;
        2. payment service providers;
        3. fraud prevention and control service providers;
        4. regulatory related service providers – Veriff (Veriff OÜ, registry code 12932944, Niine 11, Tallinn, 10414, Estonia,;
        5. digital transfer service providers;
        6. business development management and social network communication service providers;
        7. marketing and communication service providers.
    19. Social Sharing and Links to Third Party Websites

    20. 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.

    21. Data Retention

    22. 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.

    23. Governing Law

    24. 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.

    25. Use of Cookies

    26. 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:

      • Cookies are “persistent”, “permanentorsession”:
      • Persistent and permanent Cookies remain on your device even after you have gone offline. These Cookies will remain on your device until you manually delete them or until your browser deletes them based on the duration specified in the Cookie file itself.
      • Session Cookies are deleted as soon as you close your web browser.
      • Cookies can also be first-partyorthird-party”:
      • 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.

      • classify Cookies according to whether they are Essential”, “Functional”, “Improved Performance”, orAdvertising”, depending on the function that the Cookies serve in connection with our Services.
      • Essential Cookies are necessary to allow the technical operation of our Services. We use these Cookies to:
        • Authenticate you,
        • Run your session securely while you’re logged in,
        • Help detect and prevent fraud, and
        • Provide you with the Website and/or its Products, and Services, (e.g., they enable you to move around on the Website and to use its features).
      • Functional Cookies are Cookies that:
        • Evidence your use of our Website (and its respective Services) to meet our compliance obligations and contractual commitments to partners,
        • Monitor and improve the performance of our Services,
        • Remember your choices (e.g. language, region, login information, and so on), and
        • Offer enhanced functionality when using our Services (e.g.stay logged in function’).
      • Improved Performance Cookies are Cookies that:
        • Collect data to track the use of our Services,
        • Assess the effectiveness of campaigns, and
        • Understand how people found our Services.
      • Advertising Cookies are Cookies that enable us and our ad network partners, such as social media companies, to display advertising personalized to you and to prevent the same ads from being shown to you too many times. Some web browsers may attempt to block advertising Cookies without user instruction to do so, but we do not honor such blocks. Instead, to prevent our use of advertising cookies to display personalized advertisements, please follow theManage cookiesorPrivacy Settingslink on the bottom of any page of the Website.You may still see advertisements, but they may not be tailored to your interests.

      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:

      • whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
      • if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by letting us know using our Contact Us information

      Please note hat even if you opt-out of Cookies or interest-based advertising, you will still receive advertisements, they just wont 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.

    27. Final Provisions - changes to the Privacy Policy

    28. 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.