Privacy policy

3. Purpose of the personal data collected

3.1. The personal data collected on the Website and/or Platform are used solely for and during the performance of the services for sending notifications to the User for:

- providing SynWell services ;
- communicating with the User.

SynWell may also use data to meet its legal and/or regulatory obligations.

3.2. SynWell reserves the right to publish, disclose and use aggregated information (information about Users or specific groups or categories of Users combined in such a way that an individual User can no longer be identified or referred to) and non-personal information for industry and market analyses, demographic profiling, promotional and advertising purposes and other commercial purposes.

4. Collection time

The data collected by SynWell is freely communicated by Users and automatically collected during use of the Website and/or Platform, in particular when the User sends a request to SynWell by email or creates an account as defined in SynWell's GTC.
In any case, personal data collected :

- will be obtained and processed fairly and lawfully ;
- will be recorded for specific and legitimate purposes ;
- will be used for these purposes ;
- are adequate, relevant and not excessive with regard to these purposes ; and
- precautions will be taken to ensure the security and confidentiality of the data in order to prevent
prevent damage, alteration, destruction or disclosure to unauthorized third parties.

5. Consent

The present privacy policy is systematically brought to the attention of Users when they visit the Website and/or use the Platform. Visiting the Website and subscribing to a service to use the Platform implies the User's express, full and entire acceptance of the present privacy policy.

By ticking the box: "I acknowledge that I have read and understood the privacy policy and I accept it", the User consents to his/her personal data being stored and processed by SynWell and/or any of its partners.

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IMPORTANT: NOTE TO USERS
ANY BROWSING OF THE WEBSITE AND/OR USE OF THE PLATFORM AFTER THE PUBLICATION OF THIS PRIVACY POLICY IMPLIES UNRESERVED ACCEPTANCE THEREOF.

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Should the User wish to withdraw his/her consent to the processing of his/her data, he/she may do so by sending an email directly to the following address: contact@synwell-sante.com.
In addition, where required by law and/or in certain circumstances, the User's consent will be obtained or an opportunity to refuse will be provided prior to any transmission of data.

6. Recipients of personal data

6.1. The recipient of personal data collected on the Website and/or Platform is first and foremost SynWell.

6.2. Personal data will not be disclosed to third parties. However, other recipients may have access to personal data. These include, where applicable, SynWell's resource providers in charge of the Website and/or Platform (administrative, sales, marketing, legal purposes, etc.) and its external service providers (technical, access and product service providers, communications agencies, etc.).

6.3. In the event of SynWell undergoing a change of control due to a merger, acquisition, insolvency or any other form of asset transfer, the data collected by SynWell may be transferred to third parties. Nevertheless, SynWell undertakes to guarantee the confidentiality of the personal data collected and to inform Users before such data is transferred or subjected to new confidentiality rules.

Where required by law, the User's consent will be obtained or a possibility of refusal will be provided before any data is transmitted.

7. User rights

In accordance with law n°29/2019 of October 10, 2019 on personal data protection and decree n°2020-286 of August 20, 2020 ratifying the African Union convention on cybersecurity and personal data protection adopted on June 27, 2014, the User has:

- the right of access to personal data;
- the right to modify personal data;
- the right to rectify personal data;
- the right to delete and erase personal data;
- the right to object to the use of personal data;

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- the right to restrict the use of your data; and
- the right to data portability.

Users wishing to exercise one of their rights may send their request by email or by post to the following addresses:

- Postal address: 54, avenue Felix Eboue, Poto-Poto, BRAZZAVILLE
- Email: contact@synwell-sante.com

In the event of exercising one of these rights, the User must provide SynWell with the information required for identification: surname, first name and/or company name, email address and, if applicable, postal address.

In addition, in accordance with the regulations in force, the request must be signed, accompanied by a photocopy of a signed identity document, be clear and specify in detail the right they wish to exercise, as well as the address where they wish to receive a reply if they wish to exercise one of the rights listed above.

SynWell undertakes to respond within a maximum of three (3) months following receipt of the User's complete request.

Due to the complexity of the request and/or the number of requests, this period may be extended to six (6) months on condition that SynWell informs the User of the reasons for the postponement within one (1) month of receipt of the request.

SynWell informs Users of their right to lodge a complaint with the data protection authority, as provided for in article 4, paragraph 2, of the aforementioned law no. 29-2019.

8. Data retention period

8.1. Data retention after collection
The personal data collected from Users is not retained longer than is necessary for the purposes described in this Privacy Policy, except for data that SynWell may need to retain as evidence, for legal or administrative purposes, or in accordance with applicable law.

8.2. Retention of anonymized data outside the relationship between SynWell and the User
SynWell retains Users' personal data for as long as such information is strictly necessary for the purposes described in this Privacy Policy.
In the event of termination of the contractual relationship between the User and SynWell, SynWell will retain the information provided for a period of three (3) years from the date of termination of the contract or closure of the account, and in particular :

- first and last name or company name;
- associated postal addresses;
- pseudonyms used;
- associated email or account addresses;
- phone numbers;
- profession and business sector; and
- the URL address of the various social media accounts.

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Browsing data will be kept for a maximum of six (6) months.
After this period, it will be anonymized and kept exclusively for statistical purposes and will not be used in any way whatsoever.

8.3. Data deletion

Means of purging the personal data collected from Users are put in place in order to provide for their effective deletion as soon as the retention or archiving period necessary for the fulfillment of the determined or imposed purposes has been reached.

9. Links

On the Website, Users may have access to various links directing them to third-party websites.
SynWell is not responsible for information sent to or collected by these third parties.

This Privacy Policy does not govern third party websites or third party content accessed by the User of the Website.

 

SynWell has no control over hypertext links and/or other promotional formats.
Consequently, SynWell does not give any guarantee concerning the personal data protection practices of the indexed websites and cannot be held liable in any way in the event of a dispute arising between a website indexed on the Website and one of the Users, in particular for any loss or damage suffered, as the operators of the indexed websites are solely responsible for their personal data protection practices.

10. Cookies

A cookie is a text file that may be stored in a dedicated space on the hard disk of the User's computer when he/she visits an online service via his/her browser.

In practice, cookies are small text files that are placed on the User's computer by the websites the User visits. They are used to operate the websites and improve their usability. The cookie is transmitted by a website's server to the User's browser. Each cookie is assigned an anonymous identifier. A cookie cannot be traced back to an individual.

 

When consulting the Website and using the Platform, Users are informed that cookies or other means of recording browsing data are used by the Website, in particular Google Analytics or by third parties, service providers for the Website and deposited on the User's terminal (computer, mobile or tablet).

 

SynWell may install, subject to the User's acceptance, various cookies, in particular:
- session cookies, which disappear as soon as the User leaves the Website;
- permanent cookies, which remain on the User's terminal until their expiration date, or until the User deletes them using his or her browser's functions; and
- statistical cookies (used to measure the Website's audience).
Only the sender of a cookie can read or modify the information it contains.
When connecting to the Website for the first time, the User will be expressly asked to accept the Website's cookies.

10.1. Purpose of cookies

The cookies used by SynWell enable the identification of Users, the recognition of Users' browsers when they connect to the Website and/or the Platform, the recording of their access frequencies (traffic measurement) and the display preferences of Users' terminals, the adaptation and/or personalization of the presentation of the Website and/or the Platform to improve Users' experience and the optimization of the Website and/or the Platform with the sole aim of providing the services requested by the User.

In addition, the cookies used on the Website and/or Platform are based on the International Chamber of Commerce's guide by categories:
- strictly necessary;
- functional.

10.1.1. Strictly necessary cookies
Strictly necessary cookies enable the User to browse the Website and use the Platform.
These cookies do not collect any information about the User that could be used for marketing purposes.
SynWell uses these cookies to:
- ensure the operation of the Website and Platform;
- secure forms and protect them against malicious scripts.
SynWell does not use cookies to:

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- collect information that could be used to promote services to the User; or
- remember the User's preferences or name after visiting the Website or using the Platform.

10.1.2. Functionality cookies
These cookies are used to provide services or to remember the User's settings in order to improve the User's visit to the Website and use of the Platform.
SynWell does not use cookies to collect personal information that could be used to promote products or services for the User on other websites.

10.2. Cookie retention period
Cookies are kept for a maximum of thirteen (13) months after they are first placed on the User's terminal, as is the period of validity of the User's consent to the use of these cookies. The lifetime of cookies is not extended with each visit. The User's consent must therefore be renewed at the end of this period.

10.3. The User's right to refuse cookies
When browsing the Website and/or using the Platform for the first time, a banner explaining the use of cookies appears. It enables the User to activate or deactivate certain cookies. The banner will only disappear once the User has agreed, or not, to the use of cookies in order to continue browsing.

 

Cookies may only be stored if Users wish to do so. In accordance with legal and regulatory provisions, SynWell requires prior consent for the storage of cookies.
Users therefore have the option of configuring their browsing software in such a way as to oppose, totally or partially (in particular depending on the issuer), the storage of cookies. The configuration also offers the possibility of accepting or refusing cookies on a one-off basis, before they are stored on the User's terminal.

Users who wish to prevent cookies from being stored can follow the procedure specific to each browser and described in the browser's help menu.
• Chrome
https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=fr
• Internet Explorer
https://support.microsoft.com/fr-fr/help/17442/windows-internet-explorer-delete-manage-cookies
• Edge
https://privacy.microsoft.com/fr-fr/windows-10-microsoft-edge-and-privacy
• Safari
https://support.apple.com/fr-fr/guide/safari/manage-cookies-and-website-data-sfri11471

Commented [PD4]: To be confirmed.

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• Firefox
https://support.mozilla.org/fr/kb/activer-desactiver-cookies-preferences
• Opera
http://help.opera.com/Windows/9.20/fr/cookies.html

 

However, in the event of opposition to the storage of cookies or the uninstallation of a cookie, Users are informed that certain services may no longer function correctly.

11. Transfer of personal data abroad

SynWell processes User data only within the Republic of Congo and does not transfer such data outside this area.

However, in the case of international transfers, a distinction must be made between:
- countries that have been the subject of an adequacy decision: in this case, data is transferred to a country that provides a level of protection deemed sufficient and adequate for data protection purposes; and
- countries whose level of data protection has not been recognized as adequate: in this case, to guarantee a compliant transfer, and in particular to ensure data security, SynWell will base its transfer on protection mechanisms adapted to each service provider and subcontractor, such as the conclusion of standard contractual clauses, the application of binding corporate rules or under an approved certification mechanism.

12. Security
SynWell undertakes to implement appropriate technical and organizational measures that are reasonably necessary with regard to the regulations applicable to the protection of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, in order to guarantee a level of security appropriate to the risks incurred for the rights and freedoms of individuals in the context of the processing referred to in this privacy policy.

When personal data is transferred to third parties for processing, SynWell ensures that these third parties implement all appropriate technical and organizational measures to ensure the protection of personal data in accordance with applicable laws.

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These measures are defined taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the risks identified.
Depending on the needs, risks, costs and purpose of the processing, these measures may include pseudonymization and encryption of data.

This protection can be ensured by mentioning "https" in the browser's URL address, and by the representation of a closed padlock at the bottom of the screen.

Commented [PD5]: To be confirmed.

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9 - Lastly, in the event of a violation of rights concerning personal data likely to give rise to a high risk for the User's rights and freedoms, SynWell undertakes to inform the User of this violation within a maximum period of seventy-two (72) hours.

14. Changes to the privacy policy

SynWell reserves the right to modify and update this Privacy Policy at any time, in particular in order to take into account any legal and/or jurisprudential developments and to meet the requirements of the regulations applicable to the protection of personal data.
SynWell will inform Users of any significant changes or updates by email.
The prevailing version is that which is accessible online on the day of consultation of the Website and/or use of the Platform.

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Any consultation of the Website after publication of the modified confidentiality policy implies unreserved acceptance by the latter of the new confidentiality policy.

15. Contacts

15.1. For any inquiries or to find out more about the processing of their personal data, including the exercise of their rights indicated above, Users may contact SynWell using the contact form, by email or by post at the following addresses:

- Postal address: 54, avenue Felix Eboue, Poto-Poto, BRAZZAVILLE
- Email: contact@synwell-sante.com
15.2. For any complaint or dissatisfaction regarding the use of personal data by SynWell, the User may contact SynWell using the contact form, by email or by post at the following address:

- Postal address: 54, avenue Felix Eboue, Poto-Poto, BRAZZAVILLE
- Email: contact@synwell-sante.com

15.3. When the User contacts SynWell, he/she will be asked to identify him/herself.