AFRIPRO DATA PROTECTION NOTICE

Effective Date: 1.6. 2021

Josa Consulting, the company building AfriPro (“we”, “us” or “our”), places the highest value on protecting the personal data of our users (“User”, “you” or "your"). This Data Protection Notice ("Notice") explains how we collect, use, disclose, safeguard and retain your personal data when you access and use our mobile application (“Application”) and/ or our web service ("Service", Notice or Service alone or both together, depending on the context, also "Offering"). We will store your personal data in our Offering Data File. 

We process your personal data always in accordance with all applicable laws. European Union general data protection regulation (EU 2016/679) is the primary data protection enactment applicable to our Offering and processing of your personal data. 

Please read this Notice carefully. If you do not agree with the terms and content of this Notice, you must stop using our Offering immediately.

 OUR ROLE AS DATA CONTROLLER AND CONTACTING US

We are the controller of your personal data. Therefore, we are responsible for the processing of your personal data and we define the purposes and means for the processing. Our identification and contact information are as follows:

Josa Consulting OY

VAT: 3192807-1

Address: Lotankatu 3 , 02680 Espoo

Contact: hello@afri.pro

Responsible: John Samuel, CEO

Use the above contact information to reach us if you have any questions or requests related to your personal data or the processing of it.

YOUR ROLE WHEN USING OUR OFFERING 

You may access and use our Offering in two ways, namely as: 

1. Registered User With a Public profile: If you want to have a public User profile visible to other users, registration of your personal is required during the sign-up. Registered User with a public profile is identifiable by Us, and your personal data is visible to other users of the service who have access to groups you are associated with. If you wish to prevent other users seeing your personal data, use your personal settings to hide your profile or ask your group manager to remove you from the groups you no longer wish to be associated with.
2. 
   

1. Registered User With a Hidden profile: Registered User with a hidden profile is identifiable by Us, but your personal data is not visible, or accessible to other users beyond what you reveal about yourself during your interactions with them.
2. 
   

As all Users are at least indirectly identifiable to us, we will comply with applicable data protection legislation for all our Users. Our data record consists of the personal data of the Users belonging to any of the three above described user categories. Your profiles and your interactions with other users has implications to the quality and culture of this service. Therefore, We as a service provider reserve the rights to use your personal data to uphold quality of the service and enforce code of conduct. We are obliged by the law and by contracts with 3rd parties to prevent abuse, spread of inappropriate content, and criminal use of this service to infringe copyright, or national security laws. To find out more about the particular rules and code of conduct applicable to your country of residency, please refer to our terms of service, the terms of service your Internet Service Provider, Network Operator, and your country’s privacy legislation.

OUR PERSONAL DATA COLLECTING METHODS

We may collect your personal data in a variety of ways. Depending on your activities related to the Offering (e.g. sign-up), you may be required to personally actively submit to us your personal data. This may occur e.g. through completing and submitting a digital form in any of our Offering interfaces available to you (i.a. in connection with your sign-up) or answering a questionnaire. 

We may also collect your personal data in connection with your using of the Offering (i.a. related to your use of chat or any other interactive communication feature of the Offering). 

Furthermore, our servers automatically collect your personal data of a technical nature when you access or use the Offering (i.a. software versions, phone model and timestamps) or of your native actions that are integral to the Offering’s features (i.a. the number of messages you have sent and received, or other data based on your similar interactions with the Offering or with other users of the Offering).  

Finally, in order to function as intended, the Mobile Application (but not the Service) will require the access to the following mobile phone features, some of which are technically used as part of the above defined personal data collection methods:

• Microphone (to make and receive calls)
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• Notifications
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• Mobile Data & Wifi;
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• Storage;
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• Background Modes;
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• Photos (When you add a photo to your profile or send a picture as a message);
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• Camera (When you add a photo to your profile, or send a picture as a message);
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If you wish to change our access or permissions, you may, circumstances allow, do so in your device’s settings. However, please note that changing our access or permissions may cause limitations or complete denial of your access and use to the Offering. 

PERSONAL DATA WE COLLECT AND PROCESS 

When you use the Offering we will collect and process the following personal data of you:

• Name, which you have provided in connection with creation of your Offering account;
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• Password (automatically generated and cryptographically hashed);
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• Synthetic identifier, associating your user account to an individual mobile or other device;
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• Technical information about communication between your device and our servers (e.g. software version, phone model, timestamps);
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• E-mail address
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• Phone number
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• Images you store on your bio or send;
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• Biography
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• Topics of your interest;
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• Your favourites: other users, sessions, organisations, etc
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• Sessions you have reserved a seat to
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• Content you have accessed;
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• Recommendations you have given;
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• Recommendations you have received;
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• Time you have been available online;
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• Groups you belong to;
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• Sessions and other content you have been associated with
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• Search terms you have used;
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• Other users you have contacted;
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• Number and the duration of the phone calls you have made and received;
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• Number of messages you have sent and received;
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• Content of the messages;
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• Feedback you have provided and any contact information associated with it
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NOTE ABOUT COMMUNICATION AND CONTENT: Message and voice communication are protected by data encryption. We do not monitor the content of the communication between our users and voice calls are not recorded or stored by us. Therefore you are solely responsible for the relationships you establish in the Offering. We advise you not to provide any confidential information if you do not trust the other party in the Offering. Chat history remains accessible on both participating Users' devices and on our servers needed for the message content relay. In certain circumstances, Us and 3rd parties are technically capable of breaking the encryption of the private messages, access their content, and at least indirectly identify their senders and receivers personally.

YOUR CONSENT TO US

Some of the above personal data provided to us by you may contain personal data belonging to special categories ("Sensitive Personal Data"). When you access the Offering the first time, you provide us with your explicit consent for processing your Sensitive Personal Data. 

Further instructions and remarks on your consent and withdrawing it are below in this Notice.

LAWFULNESS OF PROCESSING OF YOUR PERSONAL DATA 

Our processing of your personal data is based on:

1. Contractual relationship between you and us (the contract is executed when you accept our service terms and conditions as a necessary precondition for your access to and use of the Offering); and/or
2. 
   
3. Consent received from you for:
4. 
   
5. The processing your Sensitive Personal Data; or
6. 
   
7. Sending you electronic direct marketing.
8. 
   

You may at any time withdraw the consent to which the processing of your Sensitive Personal Data or our electronic direct marketing to you is based on by contacting us with the above contact information.

Please note, that subject to our sole decision, withdrawing of your consent may make the provision of our Offering to you more limited or impossible and lead to:

• Immediate termination of your access to and use of the Offering as well as the contractual relationship between us; or
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• Limitation of the features of the Offering (e.g. by removing the possibility to use photos, comments and/or chat messages).
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 PURPOSES OF USES OF YOUR PERSONAL DATA

We process your personal data for maintaining AfriPro community; to match players with teams; to keep a guest registry for the community and the events we organise; to perform our administrative duties; to enforce rules of the service terms and code of conduct of the community; to report about the community and promote it to current and potential partners, sponsors and supporters; to comply with relevant legal obligations; to provide you with this Offering and to fulfill our contractual obligations and rights towards you. We may also process your personal data for the development of the Offering as well as our other products & services, and conduct statistical analyses, scientific & academic studies.

Your personal data can also be used to provide you with personalized content and communication (including personalized push notifications to your mobile device) as part of the Offering. This content and communication may include, but is not limited to, player and recruiter matches, event information, personalized recommendations, customer relations communication, marketing, feedback and research. However, we will not send you electronic direct marketing without your consent. If you receive undesirable content, or you are unhappy about the frequency of messaging, please do not hesitate to contact AfriPro community managers, so that we can improve the relevancy of the content together with you. You can use the privacy settings of your mobile device to control the notices you receive from us, by for example disabling push notifications, or by switching off sound alerts for the notices. To fully ensure your privacy, you can also uninstall the application at any time and resume the use of the Platform with your browser.

Personal data processing for the above-mentioned purposes may involve profiling. However, it will never include solely automated decision-making that would produce legal (or other similarly serious) effects for you.

DISCLOSURES AND INTERNATIONAL TRANSFERS

We do not generally disclose your personal data to be independently used by other data controllers unless required by mandatory law (such as to tax and other authorities).

We may transfer your personal data to third parties e.g. subcontractors such as Mesensei Oy, which are responsible for hosting the AfriPro platform and providing other capabilities needed in the service delivery. Subcontractors process your personal data on behalf of us as “data processors” and their data processing is restricted for the purposes described in this Notice.

As we operate internationally, due to technical and practical data processing requirements your personal data may be processed by our subcontractors located outside the European Union or European Economic Area (including Switzerland). Countries to which your personal data may be sent to or accessed from may have a data protection standard differing from the country in which you are situated. However, in all such personal data transfer situations, the processing of your personal data shall be in accordance with applicable legislations and our data processing policies and instructions.

Due to the rarity of available EU Commission data protection adequacy decisions, EU Commission standard contractual clauses (of type controller to processor, EU Commission decision 2010/87/EU) and Binding Corporate Rules (“BCR)” are used as appropriate and suitable safeguards for these data transfers.

We may also need to share your personal data with a purchaser or potential purchaser of our business. Such sharing does not occur regularly, but should it be necessary, we will share only smallest possible amount of your personal data and always in the limits of applicable legislation. Should the data controllership be changed from Josa Consulting to a new legal entity you as a data subject will be notified about the transfer and you have the right to object to the transfer of your personal data to the new data controller.

SECURITY

Our organisation uses organisational and technical measures to protect your data and privacy according to standards and requirements set in European Union General Data Protection Regulation (EU 2016/679). The main servers of AfriPro and the personal data file are located in Helsinki, Finland, on KATAKRI & VAHTI Tier 3 certified environment. Electronic and physical access to the servers is restricted and enforced with personal user credentials and access passes.

USE OF COOKIES

To improve your experience when accessing the Platform with a web browser and using elements connected with the Offering, we may use small text files known as cookies ‘cookies’, which your browser stores locally on your computer.

Cookies are an industry standard and commonly used by most websites. A cookie is a small text which, which is used as a tool to remember your interactions and preferences on our website. You can prevent the use of cookies from your web browser privacy settings, but please be noted that our site might not function correctly.

You might be particularly interested to know which 3rd party services and cookies we use. Please be noted that our site uses Google Analytics, which helps us to understand our website traffic and usage of this site. We use this data to improve the site functionality to make it more appealing to our different customer segments and to you individually.

While we do not have the direct capability to identify individual users visiting our site, or associate your IP address to you personally, it is possible that other parties, like Google and your Internet Service Provider have access to other data sources which can be used to identify you personally. Google Analytics is registered in the United States and statistics about our website traffic data is sent to Google servers in the United States.

If you have any privacy concerns related to our use of cookies, our partners or data transfers to United States, please take appropriate measures with your privacy settings for your browser.

YOUR RIGHT TO OBJECT PROCESSING

At any time, you have the right to object to the processing of your personal data for direct marketing purposes and unsubscribe (opt-out) yourself from any direct marketing of us. If you do not wish us to process your personal data or receive communication associated with our Offering, stop using the Mobile Application and Uninstall it from your device.

YOUR OTHER RIGHTS

At any time, you have also the following rights: 

• Gain access to your personal data;
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• Verify the accuracy of your personal data and at your request, have your incomplete, inaccurate or outdated personal data modified or erased;
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• Under certain circumstances, be forgotten by us;
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• Under certain circumstances, have the processing of your personal data restricted;
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• Receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller; and
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• Lodge a complaint with a supervisory authority (in Finland, Dataprotection ombudsman,  Tietosuojavirasto).
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Also, at any time, you have the right to:

• Withdraw your consent(s) (if any) to processing of your personal data.
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To use your rights, contact us with the contact information provided above. 

RETENTION PERIOD OF YOUR PERSONAL DATA

We retain your personal data until the termination or expiration of the contract between us and up 12months afterwards. We conduct data lifecycle management activities at least once a year, during which unnecessary personal data is removed. Your personal data will be anonymized or permanently deleted after the termination or expiration of the contract, however, allowing us always additional limited time period necessary for the technical execution of the deletion or anonymization. 

The above retention rule is always subject to differing requirements possibly included in any mandatory laws applicable to your personal data, its processing and the Offering. Therefore, in some cases, your personal data retention period may be shorter or longer than the above-mentioned. 

Notwithstanding the above, the retention of your personal data may always be extended due to our existing or imminent need to establish or exercise legal or administrative claims or defend us against legal or administrative claims related to your personal data, its processing and the Offering.

PROVISION OF YOUR PERSONAL DATA 

Provisioning your personal data to us is voluntary but necessary for you to proceed with the access and use of the Offering. Failing to provide us with your personal data prevents or may prevent us from providing you with access to Offering or enabling your use of Offering.

VALIDITY OF AND UPDATES TO THIS NOTICE

This Notice is valid until further notice beginning from 14 July 2021. 

We reserve the right to make changes to this Notice at any time and for any reason. We will alert you about any changes by updating the “Effective Date" of this Notice. You should therefore periodically review this Notice to stay informed of updates.

You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Notice by your continued use of the Offering after the then current Effective Date.