Privacy Policy.

1. Introduction

Kweli places fundamental importance on protecting personal data and the privacy of the individuals whose data it processes. This privacy policy describes Kweli's principles and commitments regarding the protection of personal data, in accordance with Regulation (EU) 2016/679 (GDPR) and French law no. 78-17 of 6 January 1978, as amended, on information technology, data files and civil liberties.

2. Data Controller

The controller of personal data is Kweli, represented by Pierre Mulhbach as President, whose registered office is located in France. For any question relating to this policy or to the processing of your data, you can contact our data protection officer at donneespersonnelles@kweli.tech.

3. Scope

This policy applies to all personal data processed by Kweli in the course of its activities, and concerns users of the Kweli platform, distributors, partner points of sale, service providers (telecom operators, mobile money, content providers), as well as any visitor to the public website.

4. Categories of Data Collected

Kweli may collect and process the following categories:

• Identification data: last name, first name, address, email address, phone number.
• Professional data: job title, affiliated distributor or point of sale, country of operation.
• Financial and transactional data: sales, cash collections, mobile money, any IBAN, payment and commission history.
• Stock and activity data: stock levels, movements, provider activity reports.
• Connection data: login credentials, access logs, IP address, device and browser used.
• Content of messages exchanged with support or through integrated channels (email, forms).

5. Purposes and Legal Bases for Processing

Data is processed for the following purposes:

• Performance of the contract entered into between Kweli and the distributor or point of sale (account management, platform access).
• Tracking of sales, stock, cash collections and associated commissions.
• Operational communication by email or SMS (transaction notifications, alerts, reminders).
• Compliance with legal and regulatory obligations (accounting, fraud prevention, archiving).
• Handling of support requests, complaints and requests to exercise rights.
• Improvement of services and platform security (legitimate interest).

The applicable legal bases are the performance of the contract, compliance with a legal obligation, Kweli's legitimate interest and, where required, the consent of the data subject.

6. Retention Period

Personal data is kept for no longer than is necessary for the purposes for which it was collected. For example, data relating to the contractual relationship is kept for the entire duration of the contract and for up to 5 years after its end, unless a legal obligation requires longer retention (accounting, anti-money-laundering).

7. Rights of Data Subjects

In accordance with the GDPR, you have the following rights:

• Right of access to your data;
• Right to rectification;
• Right to erasure (right to be forgotten);
• Right to object to processing;
• Right to restriction of processing;
• Right to data portability;
• Right not to be subject to a decision based solely on automated processing;
• Right to set directives regarding the fate of your data after your death.

To exercise these rights, write to us at donneespersonnelles@kweli.tech. You also have the right to lodge a complaint with the CNIL (www.cnil.fr).

8. Data Security

Kweli implements appropriate technical and organisational measures to ensure data security:

• Access control and strong authentication (passwords, SSO).
• Encryption of data in transit (TLS) and at rest for critical secrets.
• Regular backups and a recovery plan.
• Periodic audits (code reviews, penetration testing).
• Awareness and training of teams on data processing.

9. Data Sharing and Transfers

Kweli may share certain data with subprocessors strictly necessary for the delivery of the service (hosting providers, mobile money operators, email providers, observability tools). When these subprocessors are located outside the European Union, appropriate safeguards are put in place (adequacy decisions, standard contractual clauses, recognised certifications). No data is sold to third parties for commercial purposes.

10. Data Breach Management

In the event of a data breach likely to result in a risk to the rights and freedoms of the data subjects, Kweli notifies the incident to the CNIL within 72 hours of becoming aware of it and, where applicable, directly informs the data subjects as soon as possible.

11. Cookies

The Kweli website uses only cookies that are strictly necessary for its operation (authentication, security, preferences). No advertising or profiling cookies are placed. You can delete cookies at any time from your browser settings.

12. Changes to the Policy

This policy may be updated to reflect changes in regulations or in our practices. Any change takes effect on the date of its publication on the website. For any question, contact us at donneespersonnelles@kweli.tech.

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