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Privacy Policy

DATA CONTROLLER. Richesses d'Afrique E-Learning ("RDAE", "the platform", "we", "us") is a service operated from France by DIAMBILAY BUSINESS CENTER (D.B.C.), a French simplified joint-stock company (SAS) with share capital of €2,000, registered under SIREN 940 839 145 (SIRET of the registered office 940 839 145 00015), R.C.S. Pontoise 940 839 145, business activity code (APE) 70.22Z, whose registered office is at 43 Avenue du Gros Chêne, 95220 Herblay-sur-Seine, France (referred to below as "DBC"). DBC is the data controller for the personal data described in this Policy. For any privacy question, or to reach our data-protection contact, write to contact@rdaelearning.com.

SCOPE AND FRAMEWORK. This Policy explains what personal data we process, for which purposes, on what legal basis, with whom we share it, how long we keep it and the rights available to you. We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the French Data Protection Act (Loi Informatique et Libertés), under the supervision of the Commission Nationale de l'Informatique et des Libertés (CNIL).

1. DATA WE COLLECT. Account and identity data: first and last name, date of birth, email address and, when you provide them, telephone or WhatsApp number, postal or invoicing address, occupation and gender. Usage and analytics data: pages and courses viewed, clicks, watch-time, session length and sign-in frequency, the source that referred you, and your approximate location (country, region, city) derived from your IP address. Precise location (GPS): collected only where you explicitly opt in for a specific feature. Marketing preferences: your email and WhatsApp opt-in choices. Order and payment data: the products you buy, amounts, invoices and the status of each payment. We do not store your full card number; card and account details are entered directly with our payment providers.

2. PURPOSES AND LEGAL BASIS. We use your data to create and operate your account and to deliver the courses, coaching, digital products and webinars you sign up for, and to provide support — legal basis: performance of our contract with you (Art. 6(1)(b) GDPR). We use it to issue invoices and to meet our accounting and tax obligations — legal basis: compliance with a legal obligation (Art. 6(1)(c)). We rely on your consent (Art. 6(1)(a)) to run first-party analytics, including approximate IP-based location, to send marketing by email or WhatsApp, and to collect precise (GPS) location; you may withdraw that consent at any time. We rely on our legitimate interest (Art. 6(1)(f)) to keep the platform secure, to prevent and detect fraud and abuse, and to maintain audit logs.

3. RECIPIENTS AND SUB-PROCESSORS. Your data is accessed by authorised DBC staff and by service providers acting on our documented instructions ("processors"), bound by contract to protect it: Supabase (EU hosting, database, authentication and storage), Vercel (application hosting and content delivery), Stripe and PayPal (payment processing), and our email and WhatsApp delivery providers. We may also disclose data where required by law or to establish or defend legal claims. We do not sell your personal data and we do not share it for third-party advertising.

4. INTERNATIONAL TRANSFERS. Your data is hosted in the European Union (Supabase, region eu-west-3, Paris). Where a processor operates, or provides support, from outside the European Economic Area (EEA), any transfer is protected by an appropriate safeguard under the GDPR — an adequacy decision of the European Commission, or the European Commission's Standard Contractual Clauses, together with additional technical and organisational measures where required. A copy of these safeguards can be requested at contact@rdaelearning.com.

5. HOW LONG WE KEEP YOUR DATA. We keep personal data only for as long as necessary for the purposes above and to meet our legal obligations, applying these retention windows: analytics events for about 14 months, with the IP address pseudonymised after 90 days; referral and funnel data for 12 months; contact activity and audit logs for 24 months; orders and invoices for about 10 years, as required by French commercial and tax law. Proof of your consent is kept for as long as needed to demonstrate compliance. When a period ends, data is deleted or irreversibly anonymised.

6. YOUR RIGHTS. Subject to the conditions set by the GDPR, you have the right to access your data, to have it rectified or erased, to restrict or object to its processing, to data portability, and to withdraw any consent you have given (without affecting processing already carried out). You can exercise several of these rights directly from your account using "Export my data" and "Delete my account", or by writing to contact@rdaelearning.com; we may ask you to confirm your identity. You also have the right to lodge a complaint with the CNIL (www.cnil.fr) or with the supervisory authority of your country of residence.

7. AUTOMATED DECISIONS. We do not take decisions producing legal effects concerning you, or similarly significantly affecting you, based solely on automated processing, including profiling.

8. CHILDREN. The platform is not directed to children. In France, a minor under the age of 15 may not consent alone to the processing of their data without the authorisation of the holder of parental authority; where an account concerns such a minor, a parent or guardian must give and manage the consent.

9. SECURITY. We implement appropriate technical and organisational measures to protect your data, including encryption in transit, access controls and least-privilege permissions, hashing and pseudonymisation of sensitive identifiers (such as IP addresses), audit logging, and EU data residency. No system is completely secure, but we work to protect your data and to notify you and the CNIL of any personal-data breach where the law requires it.

10. WHEREVER YOU ARE. RDAE is operated from France under European data-protection law. We apply the same GDPR-level protections to every user, including those in the Americas and in Africa, regardless of where you access the platform.

11. CONTACT AND UPDATES. For any privacy request, or to reach our data-protection contact, write to contact@rdaelearning.com or to DBC at the address in our Legal Notice. We may update this Policy; the version in force is the one published here, and we will indicate material changes.