I- INTRODUCTION

The AXIAN Group is a diversified group with leading activities in telecommunications, energy, real estate, finance, fintechs and mobile money in the various markets where it operates. AXIAN Group relies on information, which comes in various forms, to provide services to customers. As such, the protection of this information and respect for privacy is fundamental to its daily operations and success.

          A. Target and scope

This Privacy Policy sets out the manner in which the AXIAN Group collects, uses and protects information relating to the AXIAN website and digital services.

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

This policy is not a contract and does not create any contractual obligation.                                                     

          B. AXIAN

In this policy, the “AXIAN group” refers to the company AXIAN SUPPORT SERVICES, whose registered office is located at Batiment KUBE D, Zone Galaxy Andraharo, Antananarivo.

For more information, you can visit the dedicated page on the website www.axian-group.com/en/contact-2.

Third party websites

The AXIAN Group website contains links to other websites. If you follow these links, you will leave our website. The AXIAN Group is not responsible for the processing that takes place on the websites of these third parties. This policy does not apply to these websites.

To find out more about how these third parties process your personal data, you can consult their privacy policies.

II- DATA CONTROLLER

The data controller is AXIAN SUPPORT SERVICES, a limited liability company, registered with the R.C.S. of Antananarivo under the number 2017 B 00272, located at Immeuble KUBE D 5th floor, Zone Galaxy Andraharo, Analamanga, 101 Antananarivo Renivohitra, Madagascar.

III- PERSONAL DATA PROCESSED

The AXIAN Group collects and processes the following personal data:

• Identification data (e.g. last name, first name, e-mail address, postal address, telephone number);
• Data relating to the evaluation of skills, aptitudes and motivations (CV, diplomas obtained, functions exercised, letter of motivation);
• Connection data (example: IP address, connection logs).

In the event that personal data is collected through a form, an asterisk (*) next to the relevant fields will indicate that the information is mandatory. The absence of an asterisk means that the information requested is not mandatory.

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

IV- LEGAL BASIS FOR PROCESSING AND COLLECTION OF PERSONAL DATA

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

• for legitimate interest purposes;
• on the basis of your consent;
• to ensure compliance with our legal and regulatory obligations.

V- PROCESSING PURPOSES

Your personal data are processed for the following purposes:

• Managing recruitment operations ;
• Building a talent network ;
• Management of your requests to exercise your personal data rights;
• Communication (answers to questions, complaints or requests about the AXIAN group’s business, brands, strategy and values).

VI- DURATION OF PERSONAL DATA RENTENTION

The personal data collected is kept for the legal and regulatory periods in force.

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

Furthermore, if your application has not been accepted for one or more of the jobs you applied for, the AXIAN Group reserves the right to keep your CV in the CV database (or “talent pool”) for a maximum of two years after receiving your application, in order to assess whether your profile may be suitable for a future job offer and to contact you if necessary.

By default, your connection, navigation and traffic data are not kept beyond one (01) year.

However, your personal data is kept for a longer period of time when required by legal and regulatory obligations.

VII- PERSONAL DATA RECIPIENT

Your personal data are processed by the AXIAN Group. Depending on the processing carried out, the recipients of these personal data are:

• Internal departments of the AXIAN Group (HR department, communications department, etc.);
• Other AXIAN Group entities, where applicable;
• Service providers and partners working on our behalf for the purposes mentioned above.

VII- NATURE AND EXERCISE OF RIGHTS RELATING TO PERSONAL DATA

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

• right of access ;
• right to question the processing of your data;
• right of rectification: update and/or additional information;
• right to erasure when the data is no longer necessary for the purposes for which it was collected – this right can be exercised insofar as it does not interfere with the performance of the contract or the fulfilment of our legal and regulatory obligations;
• the right to limit the processing of your personal data;
• the right to modify and/or withdraw, at any time, consents regarding the processing of your personal data based solely on your consent;
• the right to object to the processing of your personal data, in particular with regard to commercial prospecting;
• the right to the portability of your personal data.

You also have the right to specify how you want your personal data to be handled after your death.

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

How can I exercise my rights?

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

In case of dissatisfaction, you have the right to seize the competent authority in the matter, the Malagasy Commission of Data processing and Freedoms (CMIL).

IX- 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 are visiting. When you return to that website (or visit websites or mobile applications that use the same cookies), those websites recognize the cookies and your device.

Cookies and other tracers may be installed and/or read in your browser when you visit our website. The cookies set by the AXIAN Group enable us to collect information about how you use our services and how we offer you certain features.

The AXIAN Group uses functional and analytical cookies to ensure that this website functions properly and that you have the best possible experience. If you use this website, functional and analytical cookies will be installed on your browser.

If you do not want our websites and services to save cookies in your browser other than those necessary for the proper functioning of the websites/services, you can click on the following links where you will find additional information:

• Google Analytics cookies https://tools.google.com/dlpage/gaoptout

X– DPO CONTACT

If you have any further questions regarding the personal data protection policy and the processing of personal data, please contact the department responsible for personal data protection at the following address: [email protected].

XI- SECURITY MEASURES

As the data controller, the AXIAN Group shall take all necessary measures to ensure the security and confidentiality of the data and in particular to prevent it from being damaged or accessed by unauthorised third parties. To this end, all technical and organisational measures are taken to ensure an adequate level of security that is appropriate to the risks.

XII- CHANGE IN POLICY

This policy is intended to evolve and is therefore subject to change. In case of minor modifications, the new policy will be updated on the site. In case of substantial modifications concerning for example the purposes, the exercise of your rights, you will be informed by any written useful.