1- INTRODUCTION

YAS TOGO is a company within the pan-African AXIAN TELECOM group, which enables digital inclusion in emerging markets through access to mobile services, infrastructure, and more. It is a leader in the telecommunications sector in the various markets in which it operates. YAS TOGO relies on information, which comes in various forms, to provide services to customers. Therefore, the protection of this information and respect for privacy are fundamental to its daily operations and success.

2- PURPOSE AND SCOPE OF THE POLICY

This personal data protection policy details how YAS TOGO collects, uses, and protects information related to the website and digital services.

It applies to all personal data that YAS TOGO processes when Internet users use the services made available to them, visit our website, or when they interact with us through the various channels made available to them. It is important that users read this Policy, as well as any other privacy policy that YAS TOGO may publish, in order to be fully informed about the processing of their personal data, the means implemented to protect them and the ways in which they can exercise their rights.

Please read this binding privacy policy carefully. By providing your personal data on YAS TOGO websites and through contact channels, you declare that you have read this policy and expressly consent to it and to the processing itself.

3- DATA CONTROLLER

The data controller is YAS TOGO, whose registered office is at Reconciliation square, Atchanté District. Telephone: +228 22 53 44 01. For more information, visit the dedicated page at www.yas.tg .

The YAS TOGO website contains links to other websites. If you follow these links, you will leave our website. YAS TOGO is not responsible for the processing carried out on these third-party websites. This policy does not apply to these websites.

To learn more about how these third parties process your personal data, you can consult their personal data protection policies.

The data controllers take all necessary measures to ensure the security of your data and comply with legal obligations in this area. They are firmly committed to adhering to a set of rules to guarantee the confidentiality of all data concerning you.

· Transparency Commitment: Throughout this document, we detail how your personal data is obtained, stored, and

· Security Commitment: Technical and organizational security measures that meet industry standards are applied at all levels of information processing, whether for collection, storage, or backup.

· Non-dissemination Commitment: No data is automatically shared with service providers or third parties. However, some information may be published and disseminated within the strict limits of regulatory requirements or the essential needs of our company’s activities to provide you with the best of our services and

· Commitment to respect the rights of data subjects: The rights to access, consult, rectify, and delete some of your personal data and to export all of it are

· Commitment to compliance with legislation: The information system complies with data protection regulations.

In addition, we have implemented appropriate technical and organizational security measures to prevent the destruction, loss, falsification, alteration, unauthorized access, or improper disclosure to third parties of the personal data collected, as well as any other unauthorized processing of this data.

We guarantee an adequate level of protection by making the obligations applicable to employees. You are therefore solely responsible for the use of your computer, your IP address, your identification and login data, and their confidentiality from the website. You must always comply with security rules, including preventing any unauthorized access to your identifiers, codes, and login information.

4- PERSONAL DATA PROCESSED

YAS TOGO collects and processes the following personal data:

Identification data (e.g., last name, first name, email address, postal address, telephone number).

Data relating to the assessment of skills, abilities, and motivation (CV, diplomas obtained, positions held, cover letter).

Connection data (e.g., IP address, connection logs).

If personal data is collected through a form, an asterisk (*) next to the relevant fields indicates that the information must be completed. The absence of an asterisk indicates that the requested information is not mandatory.

Only personal data strictly necessary for the purposes described below is collected.

5- LEGAL BASIS FOR THE PROCESSING AND COLLECTION OF PERSONAL DATA

Your personal data is collected and processed on the following legal bases:

· For legitimate purposes based on your consent.

· To comply with our legal and regulatory requirements.

6- PURPOSES OF PROCESSING

Your personal data is processed for the following purposes:

· Subscriber identification.

· Management of subscriber complaints and

· Management of recruitment operations.

· Building a network for Managing your requests to exercise your rights regarding your personal data

· Communications (responses to questions, complaints, or requests regarding YAS TOGO’s business, brands, strategy, and values)

7- Personal Data Retention Period

The personal data collected is retained for the relevant legal and regulatory periods.

However, your personal data will only be retained for the period strictly necessary to achieve the purposes for which it was collected and processed, when it is not subject to any specific legal or regulatory retention period.

Furthermore, in the context of recruitment, if your application is unsuccessful for one or more of the positions you applied for, YAS TOGO reserves the right to retain your CV in the CV database (or “talent pool”) for a maximum period of two years following receipt of your application, in order to assess whether your profile is likely to match a future job offer, and to contact you if necessary.

By default, your connection, browsing, and traffic data are not retained for more than one (01) year.

However, your personal data will be retained for a longer period if we are required to do so by law or regulation.

8- RECIPIENTS OF PERSONAL DATA

Your personal data is processed by YAS TOGO. Depending on the processing carried out, the recipients of said personal data are:

· YAS TOGO’s internal departments (customer service, HR department, communications department, etc.).

· Other YAS TOGO subsidiaries, if applicable.

· Service providers and partners acting on our behalf for the purposes mentioned above.

9- NATURE AND EXERCISE OF RIGHTS RELATING TO PERSONAL DATA

Within the context of the processing of personal data, Internet users have the following options:

· The right of access.

· the right to ask questions about the processing of your data

· the right of rectification: update and/or additional information.

· the right to erasure when the data is no longer necessary for the purposes for which it was collected – this right can be exercised provided that it does not affect the performance of the contract or compliance with our legal and regulatory obligations

· the right to restrict one or more processing operations of your personal data.

· The right to modify and/or withdraw your consent at any time to the processing of your personal data based solely on your consent. The right to object to the processing of your personal data, particularly in the case of commercial processing.

· The right to the portability of your personal data.

· You also have the right to specify how you wish your personal data to be processed after your death.

To ensure that the information we hold about you is always accurate, we recommend that you regularly update your personal data.

How can I exercise my rights?

You can make any request to exercise your rights relating to your personal data by contacting us via email: [email protected].

If you are not satisfied, you have the right to refer the matter to the competent authority.

10- COOKIES

Cookies are small text files that uniquely identify your browser or device. The cookie is placed on your browser or device by the website you visit. When you return to this website (or visit websites or mobile applications that use the same cookies), those websites recognize the cookies and your device.

Cookies and other tracking technologies may be installed and/or read in your browser when you visit our website. The cookies placed by YAS TOGO allow us to collect information about how you use our services and how we offer certain features.

YAS TOGO uses functional and analytical cookies to enable this site to function properly and provide you with the best possible experience. If you use this site, functional and analytical cookies will be installed on your browser.

11- DPD CONTACT

If you have any further questions regarding our personal data protection policy and the processing of personal data, please contact the Personal Data Protection Department at the following address: [email protected].

12- POLICY CHANGES

This policy is subject to change and may therefore be amended. In the event of minor changes, the new policy will be updated on the website. In the event of substantial changes, such as changes to the purposes or the exercise of your rights, you will be informed by any appropriate means.