Privacy Policy
Personal Data Protection
This privacy policy is based on Article 415 of the Fifth Book of the Digital Code concerning the Protection of Personal Data. It references proof of completion of prior formalities with the Personal Data Protection Authority (APDP) under number 2024-035/AT/APDP/DST/SC dated May 29, 2024, and helps you understand which personal data we collect and process within our company, the intended purposes, and the measures taken to comply with the legislation in force in the Republic of Benin regarding the protection of personal data and privacy.
By providing your Personal Data on our website https://soaga.net/ and our related services ("SOAGA One" mobile application, etc.), you declare that you have read this privacy policy and expressly consent to it, as well as to the processing itself. Please read this Privacy Policy carefully.
1. Data Controller
The data controller for your Personal Data is the West African Asset Management Company (SOAGA S.A.) represented by its General Manager, Mr. Mécapeu GBANDAH-KOHEMUN.
The data controllers take all necessary measures to ensure the security of your data and comply with legal obligations regarding personal data. They firmly commit to a set of rules to guarantee the confidentiality of all data concerning you.
- Transparency commitment: we detail throughout this document how the various data concerning you are obtained, stored and processed.
- Security commitment: technical and operational security measures meeting industry standards are applied at all levels of information processing, whether collection, storage or backups.
- Non-disclosure commitment: no data is subject to automated disclosure to service providers or third parties. Some information may nevertheless be published and disseminated strictly within the limits required by public procurement laws.
- Respect for data subject rights: the rights allowing access for consultation, rectification and deletion of certain personal data, and export of all data are ensured.
- Compliance with legislation: the information system complies with data protection legislation.
We have implemented appropriate technical and organizational security measures to prevent destruction, loss, falsification, modification, unauthorized access, or erroneous disclosure to third parties of collected Personal Data, as well as any other unauthorized processing of such data.
We guarantee a sufficient level of protection by making the applicable obligations binding on employees.
You are solely responsible for the use made of our online services, your computer, your TCP/IP address and your identification data, as well as their confidentiality. You must at all times comply with security rules, in particular by preventing any unauthorized access to your login settings.
2. Preliminary formalities
In accordance with Articles 405 and 407 of the Digital Code, the collection and processing of personal data are subject to the completion of preliminary formalities. Depending on the category of data concerned, this may involve declaring data processing or applying for authorization to process data with the Personal Data Protection Authority.
The processing described in this policy has been the subject of appropriate preliminary formalities by SOAGA S.A. with the Personal Data Protection Authority (APDP).
You can contact the Authority and verify the terms of this policy using the following details:
- Rue 6.076 "Aïdjèdo, Immeuble El MARZOUK Joël"
- 01 BP: 04837 Cotonou
- (+229) 21 32 57 88 / 69 55 00 00
- Green line: 150
3. Personal data subject to processing
- Data collected from users on our online services: surname, given name(s), physical and electronic addresses, date and place of birth, CIP/passport/ID card information, birth certificate, business register, title, phone number, ID photo, etc.
4. Operations performed
The West African Asset Management Company (SOAGA S.A.) collects personal information relating to users and service providers only for the exclusive need of the services it offers.
The information collected is processed either electronically or manually for the purposes mentioned below.
Processing operations include: collection, copying, consultation, retention, recording, extraction, modification, deletion, destruction.
Personal Data will not be used for profiling purposes and you will not be subject to automated decisions on our part.
5. Purpose(s) of processing
Information is collected for the following purposes:
- Client account management: collection of personal data of investors to open and manage their investment accounts in UCITS managed by the company;
- Financial analysis and risk management: use of collected information to perform financial analyses and assess risks associated with investments in UCITS;
- Communication and customer services: use of data to communicate with investors, provide information about the company's products and services, respond to requests and offer quality customer service;
- Regulatory compliance: collection and retention of data necessary to comply with legal and regulatory requirements for UCITS management, such as AML/CFT;
- Improvement of products and services: analysis of collected data to identify market trends, investor preferences and emerging needs, in order to continuously improve the products and services offered by the company.
It should be noted that these purposes correspond to a single processing activity.
6. Recipients of personal data (communication and transfer)
The recipients of this data are the internal departments and services of SOAGA S.A.:
- General Management
- Information Systems Department
- Internal Control Department
- Customer Service Department
- Marketing & Commercial Department
- Operations Department
No data will be transmitted to a third party. However, we may be required to communicate data to authorized persons due to legal, regulatory and judicial obligations.
In any event, SOAGA S.A. will not sell, rent, distribute or make your Personal Data commercially available to third parties, except in the cases described above or with your prior consent.
7. Processing duration, retention and storage
Personal Data is retained for a period of 10 years, not exceeding the purposes for which it was collected and processed by the West African Asset Management Company.
For more information regarding retention periods, you can contact us at the following address: 232 Avenue Jean Paul II – Lot n°87 Villa n°3 – Cotonou, Benin 08 BP 960, Tel: +229 21 31 88 14 / 15 – +225 27 24 30 48 49 / 50 – E-mail: infos@soaga.net
Personal Data is retained and stored as follows:
| Storage and retention methods | Country of storage and retention |
|---|---|
| In the form of paper files | Benin, SOAGA S.A. premises |
| In the form of electronic files | Benin, secured company computers, local server rooms and extra-SOAGA cloud infrastructure |
8. Rights of data subjects regarding processing
The Digital Code grants you rights over your personal data. Within the framework of processing activities at SOAGA S.A., the following rights may be exercised depending on the processing concerned:
- Right of access to collected information;
- Right of inquiry;
- Right of modification;
- Right of rectification;
- Right to object to processing;
- Right to data deletion;
- Right to be forgotten;
- Right to compensation.
You can consult the definition of these rights at: https://apdp.bj/wp-content/uploads/2022/01/Droits_Des_Personnes_Concernees_Pt_YD_sans-Bonhomme.pdf
You can exercise your rights by writing to the General Manager of SOAGA S.A. by contacting us by telephone: +229 21 31 88 14 / 15, by email: infos@soaga.net, or by letter at the addresses below:
- Post Office Box: 08 BP 960
- Headquarters: 232 Avenue Jean Paul II – Lot n°87 Villa n°3 Cotonou, Benin
We guarantee a response to your requests on average within one (01) month from the date of submission.
9. Complaints
You have the right to lodge a complaint with the Personal Data Protection Authority: the complaint is:
- Filed at the institution's headquarters, Rue 6.076 Aïdjèdo Cotonou
- Addressed (email only) to: contact@apdp.bj
This is without prejudice to an appeal before a competent court.
10. For more information
If you have any other questions or comments regarding the processing of your personal data, please do not hesitate to contact the Personal Data Protection Officer:
By email: llaouroukiki@presidence.bj
By mail: Avenue Steinmetz Rue 108, District 1320 Tokpa HOHO, Lot 35B, 4th and 5th floors Immeuble KOUGBLENOU
