Privacy Policy

1. Introduction

The purpose of this Privacy Policy is to inform users of the KòmandeL platform (hereinafter the “Platform”) about how their personal data is collected, used, processed and protected in the context of using the services offered.

KòmandeL places particular importance on the protection of the privacy and personal data of its users. As such, the Platform is committed to processing the information collected in a transparent, secure manner and in accordance with the fundamental principles of data protection, including lawfulness, fairness, proportionality and purpose limitation.

As part of its activities, KòmandeL is required to collect certain personal data necessary for the provision of its services, including connecting buyers and sellers, managing orders, organizing logistics operations and processing payments.

This Policy aims to enable each user to understand what data is collected, for what purposes, with whom, and what their data protection rights are.

By accessing the Platform or using its services, the user acknowledges having read this Privacy Policy and accepts the terms defined therein.

KòmandeL reserves the right to modify this Policy to adapt it to legal, technical, or operational developments. Any modification will be communicated to users by any appropriate means.

2. Definitions

For the purposes of this Privacy Policy, the following terms and expressions, whether used in the singular or plural, shall have the following meanings:

• “Personal data”: means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to a name, telephone number, address, location data or any other identifier.
• " Treatment ": refers to any operation or set of operations applied to personal data, such as collection, recording, organization, storage, modification, consultation, use, transmission or deletion.
• " User ": refers to any natural or legal person accessing the Platform, whether buyer, seller or simply visitor.
• " Platform ": refers to the KòmandeL digital service, accessible in particular via website or mobile application, enabling the connection between users and the provision of associated services.
• “Data Controller”: refers to the entity that determines the purposes and means of processing personal data. Within the framework of this Policy, KòmandeL acts as the data controller.
• " Partner ": refers to any third-party entity involved in providing the Platform's services, including payment providers, logistics operators, delivery companies or technical service providers.
• "Payment details": refers to the information necessary for the processing of financial transactions, generally collected and processed by secure payment providers.
• "Navigation data": refers to information relating to the User's use of the Platform, such as IP address, device type, browser, pages viewed or duration of visit.

3. Data collected

In the course of using the Platform, KòmandeL is required to collect different categories of personal data, strictly necessary for the provision of its services, the improvement of the user experience and the security of transactions.

The data collected may include, in particular:

3.1 Identification data

KòmandeL may collect information that identifies the User, such as:

• first and last name ;
• telephone number;
• email address, if applicable.

This data is particularly necessary for the creation and management of the User Account.

3.2 Location and delivery data

As part of order management and logistics services, KòmandeL collects information relating to the User's location, including:

• Delivery address ;
• additional information (landmarks, reference points, neighborhood);
• Contact details of the person in charge of reception.

This data is essential to ensure delivery, particularly within the framework of the micro-hub network and decentralized distribution.

3.3 Transaction Data

KòmandeL collects the information necessary for processing Orders, including:

• details of Products ordered;
• Order history;
• transaction amounts;
• payment status.

Data strictly related to means of payment (including bank details or information related to mobile services such as MonCash) is processed by secure payment providers and is not stored directly by KòmandeL, except to the extent necessary for the traceability of transactions.

3.4 Data relating to activity on the Platform

In order to improve its services and prevent abuse, KòmandeL may collect data related to the use of the Platform, including:

• browsing history;
• interactions with the functionalities;
• usage preferences;
• communications with customer service.

3.5 Technical Data

When accessing the Platform, certain technical data may be automatically collected, such as:

• IP address;
• type of device used;
• operating system;
• internet browser;
• connection data and activity logs.

This data contributes to the security, maintenance and optimization of the Platform.

3.6 Data related to security and fraud prevention

As part of transaction security measures, KòmandeL may collect and analyze certain specific data, including:

• purchasing behaviors;
• frequency and command plan;
• information relating to payments and transaction attempts.

This data helps to detect, prevent and combat fraudulent activities, including abusive payment disputes.

KòmandeL undertakes to collect only the data strictly necessary for the purposes pursued and not to process this data in a manner incompatible with these purposes.

4. Data collection methods

KòmandeL collects Users' personal data through various means, in accordance with the principles of transparency, proportionality, and security. This data is collected either directly from Users, automatically during use of the Platform, or indirectly through authorized partners.

4.1 Direct Collection from the User

Personal data is collected directly when the User:

• Create an account on the platform;
• fills out forms (registration, order, contact);
• provides information when placing an order;
• communicates with customer service or support;
• publishes content or interacts with the Platform's features.

In these cases, the User voluntarily provides their data, knowingly.

4.2 Collection within the framework of transactions

During the placement and execution of Orders, data is collected to ensure the smooth running of commercial and logistical operations, including:

• delivery information;
• details of Products ordered;
• information needed for coordination with Vendors, delivery drivers and micro-hubs.

Payment data is collected and processed by secure payment providers. KòmandeL only collects the information strictly necessary for confirming and tracking transactions.

4.3 Automatic data collection when using the Platform

Certain data is collected automatically when the User accesses or uses the Platform, including:

• browsing data (pages viewed, visit duration);
• IP address and connection data;
• technical information relating to the device and browser.

This collection helps ensure the proper functioning of the Platform, improve the user experience and strengthen security.

4.4 Use of cookies and similar technologies

KòmandeL may use cookies or similar technologies to:

• to facilitate navigation on the Platform;
• to remember user preferences;
• analyze the use of services;
• improve performance and safety.

The User may, at any time, configure their browser to refuse all or part of the cookies, provided that this may affect certain functionalities of the Platform.

4.5 Collection from partners

In some cases, data may be collected indirectly from partners, including:

• payment providers (transaction confirmation, payment status);
• logistics partners (delivery tracking, parcel status).

KòmandeL ensures that these partners comply with adequate data protection standards.

4.6 Collection for security and fraud prevention purposes

As part of securing the Platform, KòmandeL may collect and analyze certain behavioral and technical data in order to detect suspicious or fraudulent activities.

This collection is carried out in a proportionate manner and solely for the purpose of protecting Users, partners and the integrity of the Platform.

5. Purposes of data processing

The personal data collected by KòmandeL is used exclusively for specific, explicit and legitimate purposes, directly related to the provision of services offered on the Platform.

These purposes include, in particular:

5.1 User Account Management

Personal data is used for:

• create and manage User Accounts;
• to enable authentication and secure access to the Platform;
• to manage profiles and preferences.

5.2 Order and Transaction Management

KòmandeL processes data in order to:

• Register and process Orders;
• to ensure communication between Buyers and Sellers;
• monitor the execution of transactions;
• manage payments related to partner service providers.

5.3 Organization of logistics operations

Data is essential for:

• Plan and execute deliveries;
• coordinate activities between Vendors, delivery drivers and micro-hubs;
• optimize distribution routes and times;
• to track packages until they are delivered to the Buyer.

5.4 Improvement of services and user experience

KòmandeL uses certain data to:

• analyze the use of the Platform;
• improve the functionality and performance of services;
• personalize the user experience;
• develop new offers tailored to Users' needs.

5.5 Communication et assistance

The data allows us to:

• respond to User requests;
• to provide efficient customer service;
• transmit information relating to Orders, Deliveries or Platform developments.

5.6 Security and fraud prevention

To ensure a secure environment, KòmandeL processes certain data for:

• detect and prevent fraudulent or abusive activities;
• securing financial transactions, particularly via electronic payments;
• to protect Users, partners and the Platform against any malicious use.

5.7 Compliance with legal and regulatory obligations

KòmandeL may also process personal data in order to:

• comply with applicable legal obligations;
• to respond to requests from the relevant authorities;
• to preserve evidence in case of dispute or audit.

KòmandeL undertakes not to use personal data for purposes incompatible with those described above and to limit their processing to what is strictly necessary to achieve these objectives.

6. Legal basis for processing

The processing of personal data carried out by KòmandeL is based on legitimate legal grounds, consistent with the purposes described in this Privacy Policy.

Depending on the nature of the processing involved, KòmandeL relies in particular on the following legal bases:

6.1 Contract Performance

The processing of personal data is necessary for the performance of the services provided by the Platform, including:

• the creation and management of User Accounts;
• Order processing;
• the organization of deliveries and logistics services;
• transaction and payment management.

Without these treatments, KòmandeL would not be able to provide its services effectively.

6.2 User Consent

In some cases, data processing is based on the User's prior consent, particularly for:

• the use of certain cookies or similar technologies;
• sending non-essential communications;
• any specific use requiring explicit authorization.

The User may withdraw their consent at any time, without affecting the legality of processing carried out before this withdrawal.

6.3 Legitimate interest

KòmandeL may process certain personal data on the basis of its legitimate interest, provided that this interest does not infringe on the rights and freedoms of Users.

These treatments include, in particular:

• the improvement of services and performance of the Platform;
• the prevention of fraud and abuse;
• securing systems and transactions;
• dispute management and defense of KòmandeL's rights.

6.4 Compliance with legal obligations

Certain data may be processed in order to comply with legal or regulatory obligations, including:

• the retention of data for accounting or tax purposes;
• responding to requests from the competent authorities;
• compliance with requirements related to the fight against fraud and illegal activities.

KòmandeL ensures that each processing of personal data is based on an appropriate legal basis and limits the use of data to what is strictly necessary.

7. Sharing of personal data

KòmandeL undertakes to share Users' personal data only to the extent necessary for the provision of Services, compliance with legal obligations and the security of transactions.

Personal data may be disclosed to the following categories of recipients:

7.1 Sharing with Vendors

As part of the order fulfillment process, certain data is transmitted to the Sellers, including:

• the information necessary for the preparation of the Products;
• the delivery data essential for the proper execution of the Order.

This sharing is strictly limited to what is necessary to allow the Seller to fulfill its obligations.

7.2 Sharing with logistics partners

In order to ensure the Delivery of Products, KòmandeL may share certain data with its logistics partners, including in particular:

• the delivery drivers;
• the managers of micro-hubs or relay points;
• any service provider involved in transport or distribution.

The data transmitted is limited to the information necessary for the management and monitoring of deliveries.

7.3 Sharing with payment providers

Payment data is processed by specialized providers, including mobile payment services and banking institutions.

KòmandeL does not store sensitive information relating to payment methods, except to the extent necessary for transaction traceability. Exchanges with these service providers take place within a secure framework.

7.4 Sharing with technical service providers

KòmandeL may use technical service providers for hosting, maintenance, analysis or improvement of the Platform.

These service providers may have access to certain personal data strictly within the scope of their missions, subject to contractual commitments guaranteeing the confidentiality and security of the data.

7.5 Sharing for legal reasons

Personal data may be disclosed to administrative, judicial or other authorized bodies when required by law or in the context of legal proceedings.

7.6 Sharing for security and anti-fraud purposes

In order to prevent and detect fraudulent activities, KòmandeL may share certain information with:

• service providers specializing in fraud detection;
• financial institutions;
• competent authorities.

This sharing is strictly regulated and limited to situations requiring the protection of the Platform and its Users.

7.7 CommandeL Commitment

KòmandeL ensures that all sharing of personal data is carried out securely and in compliance with data protection principles.

Partners and service providers with access to personal data are required to comply with strict confidentiality and security obligations, and are only authorized to use this data for the purposes defined.

KòmandeL undertakes not to sell Users' personal data to third parties.

8. Transfer of personal data

In the course of providing its services, KòmandeL may transfer certain personal data outside the national territory, particularly when this data is processed by technical service providers, payment partners or hosting services located abroad.

8.1 Principle of the transfer

Transfers of personal data may occur in the following cases:

• use of internationally based hosting or data storage services;
• use of technical service providers or digital solutions operating outside the national territory;
• payment processing by financial institutions or mobile payment services with international infrastructure.

These transfers are made only when necessary for the provision of services offered by the Platform.

8.2 Framework for transfers

KòmandeL is committed to framing all transfers of personal data appropriately in order to ensure an adequate level of protection.

In this capacity, KòmandeL is particularly responsible for:

• select partners and service providers offering sufficient guarantees in terms of security and confidentiality;
• frame the transfers with appropriate contractual commitments;
• limit the data transferred to that which is strictly necessary.

8.3 Security and protection of transferred data

KòmandeL implements reasonable measures to ensure that the transferred data benefits from a level of protection equivalent to that applied on the Platform.

However, the User acknowledges that data protection laws may vary from country to country.

8.4 User Consent and Information

By using the Platform, the User agrees that their personal data may be transferred and processed under the conditions described above, when necessary for the provision of the Services.

KòmandeL is committed to informing Users transparently about the terms of these transfers in this Policy.

9. Data Security

KòmandeL attaches particular importance to the security of its Users' personal data and implements appropriate technical and organizational measures to prevent any unauthorized access, loss, disclosure, alteration or destruction of data.

9.1 Technical safety measures

KòmandeL implements security measures to protect systems and data, including:

• the use of secure communication protocols for data exchange;
• securing access to computer systems (authentication, access control);
• the implementation of protection mechanisms against intrusions and cyberattacks;
• Regular data backups to ensure availability.

9.2 Organizational Measures

KòmandeL ensures that access to personal data within its organization is regulated, in particular by:

• limiting access to authorized persons only;
• raising staff awareness of data protection and IT security;
• the implementation of internal procedures aimed at ensuring the confidentiality of information.

9.3 Transaction Security

For payments made via the Platform, KòmandeL relies on recognized and secure payment providers.

Sensitive data relating to means of payment are processed directly by these providers and are not kept by KòmandeL, except to the extent necessary for the management and monitoring of transactions.

9.4 Security in the context of logistics operations

Given KòmandeL's logistics model, measures are also implemented to protect delivery-related data, including:

• secure transmission of information needed by delivery drivers and micro-hubs;
• limiting the data accessible to logistics partners;
• raising awareness among stakeholders regarding respect for the confidentiality of information.

9.5 Safety Limits

Despite the efforts made, the User acknowledges that no security system is infallible and that the Internet carries inherent risks.

Consequently, KòmandeL cannot guarantee absolute security of transmitted or stored data, without however waiving its commitment to implement all reasonable means to ensure its protection.

9.6 Security Incident Management

In the event of a security incident likely to affect personal data, KòmandeL undertakes to take appropriate measures to limit the impacts and, where relevant, to inform the Users concerned within a reasonable timeframe.

10. Data retention period

KòmandeL retains Users' personal data only for the period strictly necessary to achieve the purposes for which it was collected, in accordance with the provisions of this Privacy Policy and applicable legal requirements.

10.1 Retention related to account management

User Account data is retained as long as the Account remains active on the Platform. In the event of deletion or prolonged inactivity, this data may be deleted or archived securely, unless otherwise required by law.

10.2 Retention related to transactions and orders

Data relating to Orders, transactions and logistics operations is kept for the time necessary for their processing, as well as for an additional period allowing:

• the handling of any complaints or disputes;
• the justification of accounting and financial operations;
• compliance with applicable legal and tax obligations.

10.3 Retention for security and fraud prevention purposes

Certain data may be kept for a longer period when necessary for the prevention, detection or management of fraud, abuse or illegal activities, as well as for the protection of the Platform and its Users.

10.4 Technical Data Retention

Technical and navigation data is kept for a limited period, necessary for analyzing the performance of the Platform, maintaining systems and improving services.

10.5 Archiving and legal obligations

Certain data may be kept in secure archives when required by legal, accounting, or regulatory obligations. In this case, it is no longer used for commercial or operational purposes.

10.6 Data Deletion

At the end of the applicable retention periods, personal data is either securely deleted or irreversibly anonymized so that it no longer allows Users to be identified.

KòmandeL is committed to applying appropriate procedures to ensure the deletion or anonymization of data under adequate security conditions.

11. User Rights

In accordance with the principles of personal data protection, KòmandeL recognizes that Users have a set of rights relating to their personal data, under the conditions and within the limits provided for by the applicable regulations.

11.1 Right of access

The User has the right to obtain from KòmandeL confirmation as to whether or not personal data concerning him or her are being processed, as well as access to said data and to obtain a copy thereof.

11.2 Right of rectification

The User may request the modification or updating of their personal data when it is inaccurate, incomplete or outdated.

11.3 Right to erasure

Subject to legal retention obligations, the User may request the deletion of their personal data when:

• they are no longer necessary for the purposes for which they were collected;
• he withdraws his consent (when the processing is based on this consent);
• He opposes the treatment and there is no overriding legitimate reason to continue it.

11.4 Right to object

The User may object, for reasons relating to his or her particular situation, to certain processing of his or her personal data, in particular those based on the legitimate interest of KòmandeL.

11.5 Right to restriction of processing

The User may request the temporary suspension of the processing of their personal data in certain cases, for example when they contest the accuracy of the data or object to its processing.

11.6 Procedures for exercising rights

The aforementioned rights can be exercised by the User by contacting KòmandeL via the official communication channels made available on the Platform.

KòmandeL is committed to processing requests within a reasonable timeframe and providing a response that complies with applicable legal requirements.

11.7 Limitations of rights

The exercise of these rights may be limited in certain cases, particularly when data processing is necessary:

• to comply with a legal obligation;
• to the execution of a contract;
• to the establishment, exercise or defense of legal rights;
• to fraud prevention or to the security of the Platform.

In such cases, KòmandeL will inform the User of the reasons why their request cannot be fully satisfied.

12. Cookies and similar technologies

12.1 Definition and role of cookies

Cookies are small text files that may be stored on the User's device (computer, phone or tablet) when visiting the KòmandeL Platform. They allow the User's device to be recognized and facilitate their browsing experience.

KòmandeL may also use technologies similar to cookies, such as tags, pixels or login identifiers, to collect certain technical or behavioral information.

12.2 Purposes of cookie use

The cookies and similar technologies used by KòmandeL are primarily intended to:

• to ensure the proper functioning and security of the Platform;
• to facilitate navigation and use of services;
• to remember the User's preferences and choices;
• improve the performance and ergonomics of the Platform;
• analyze the use of services in order to optimize their operation;
• detect any anomalies or fraudulent activities.

12.3 Types of cookies used

KòmandeL may use several categories of cookies, including:

• Strictly necessary cookiesessential for the operation of the Platform and access to essential services;
• Performance and analytics cookiesenabling us to understand the use of the Platform and to improve its functionalities;
• Functional cookies: facilitating the personalization of the user experience (language, preferences, etc.);
• Security cookiescontributing to fraud prevention and the protection of User accounts.

12.4 User Cookie Management

The User has the option to manage, configure or disable cookies at any time via their browser settings or, where applicable, via the tools offered on the Platform.

However, disabling certain cookies may affect the proper functioning of the Platform and limit access to certain features or services.

12.5 Consent

During their first visit to the Platform, the User may be informed about the use of cookies and invited to accept or refuse some of them, according to the terms provided by the Platform.

The User's consent can be modified at any time.

12.6 Similar Technologies

In addition to cookies, KòmandeL may use other tracking or analytics technologies to improve service quality, transaction security, and user experience. These technologies are subject to the same principles of transparency and data protection.

13. Protection against fraud and abuse

13.1 Objective of protection

As part of its activities, KòmandeL implements mechanisms for processing and analyzing personal data in order to prevent, detect and combat fraudulent, abusive or illegal activities that may affect the Platform, Users or partners.

This approach aims to guarantee the security of transactions, the reliability of services and trust between the different actors of the Platform.

13.2 Processing carried out for security purposes

For fraud prevention purposes, KòmandeL may analyze certain data, including:

• navigation and usage behaviors of the Platform;
• Order and payment history;
• transaction attempts that were refused or disputed;
• inconsistencies in the information provided by Users.

These analyses can be performed automatically or manually, depending on security requirements.

13.3 Detection and management of suspicious behavior

If suspicious or inconsistent behavior is detected, KòmandeL may take precautionary measures, including:

• the temporary suspension of the account in question;
• blocking or verifying ongoing transactions;
• the request for additional supporting documents;
• the limitation of certain functionalities of the Platform.

These measures are solely intended to protect the Platform and its Users, without prejudice to any fault on the part of the User concerned.

13.4 Combating payment-related fraud

Particular attention is paid to fraud related to payment methods, including abusive chargebacks, fraudulent payments or the unauthorized use of payment methods.

KòmandeL can store and analyze the necessary data in order to:

• verify the validity of the transactions;
• collaborate with payment providers and financial institutions;
• contest any proven attempt at fraud.

13.5 Cooperation with authorities and partners

As part of the fight against fraud and illegal activities, KòmandeL may collaborate with:

• payment service providers;
• logistics partners;
• the competent administrative or judicial authorities.

This cooperation is carried out in compliance with legal obligations and the protection of personal data.

13.6 Proportionality of measures

All measures implemented by KòmandeL in the context of the fight against fraud are proportionate to the identified risks and limited to the data strictly necessary to achieve this objective.

KòmandeL strives to reconcile the security of the Platform with respect for the rights and freedoms of Users.

14. Minors' Data

14.1 General Principle

The KòmandeL Platform is intended for a general public capable of entering into and using online commerce services. In principle, it is not specifically intended for minors.

14.2 Usability

Anyone wishing to create an Account or use the Platform's services must have the legal capacity required under applicable laws. Minors may use the Platform only under the supervision and responsibility of a parent or legal guardian.

14.3 Collection of data concerning minors

KòmandeL does not knowingly collect personal data from minors without the prior and verifiable consent of a parent or legal guardian.

In the event that personal data concerning a minor is collected unintentionally, KòmandeL undertakes to take appropriate measures to delete it as soon as possible.

14.4 Responsibility of legal representatives

Parents or legal guardians are responsible for the use of the Platform by minors under their authority, particularly with regard to the creation of accounts, the placing of Orders and the communication of personal data.

14.5 Enhanced protection

KòmandeL is committed to applying enhanced protection measures when personal data of minors are likely to be processed, in particular by limiting their use to the strict purposes necessary for the provision of services.

15. Changes to the Privacy Policy

15.1 Right of modification

KòmandeL reserves the right to modify, supplement or update this Privacy Policy at any time, in order to take into account legal, regulatory, technical, operational or commercial developments related to its activities.

15.2 User Information

In the event of a substantial change to this Policy, Users will be notified by any appropriate means, including notification on the Platform, by email or by any other official communication channel.

This information is intended to ensure transparency and to allow Users to be aware of the changes made.

15.3 Entry into force of the amendments

Changes to the Privacy Policy become effective on the date of their publication or on any other date indicated when they are communicated.

It is the User's responsibility to regularly consult the Privacy Policy in order to stay informed of any updates.

15.4 Acceptance of changes

Continued use of the Platform after the update of the Privacy Policy constitutes acceptance of the new provisions by the User.

If the User disagrees with the changes made, they are free to cease using the Platform and, where appropriate, to request the deletion of their Account, subject to legal obligations regarding data retention.

15.5 Maintenance of acquired rights

Changes to the Privacy Policy do not affect Users’ acquired rights or data processing carried out before they came into effect, which remain subject to the version of the Policy applicable at the time the data was collected.

16. Contact and Data Protection Officer

16.1 Contact Point

For any questions relating to this Privacy Policy, the management of personal data or the exercise of rights, the User can contact KòmandeL via the official channels made available on the Platform.

These channels may include, but are not limited to:

• an email address dedicated to support or data protection;
• a contact form accessible on the Platform;
• any other official means of communication communicated by KòmandeL.

16.2 Processing of requests

KòmandeL undertakes to process any request relating to personal data within a reasonable timeframe, depending on the nature and complexity of the request.

The User may be required to provide additional information to allow verification of their identity and secure processing of their request.

16.3 Data Protection Officer

To the extent applicable, KòmandeL may designate a person or team responsible for ensuring compliance with the rules relating to the protection of personal data within the Platform.

This role notably involves:

• to monitor compliance with data processing regulations;
• respond to User requests regarding their rights;
• contribute to the implementation of good practices in terms of confidentiality and security.

16.4 Preservation of exchanges

Exchanges between the User and KòmandeL in the context of requests relating to personal data may be kept for the purposes of monitoring, improving the service and providing evidence in the event of a dispute, in compliance with applicable data protection rules.