Privacy Policy

Effective date: July 1, 2024

1. Definition

“Expert” means the person who offers Services on the Platform.
“Client” means the person who creates an account on the Platform in order to benefit from the Services offered by the Experts.
“User”, including the terms “you” and “your”, means any person, Expert or Client, who creates an account on the Platform and/or registers on one or more of the Platform’s information channels in order to benefit from or provide Services.
“Service” or “Consultation” means the session during which the Expert provides personalized advice to the Client.
“Platform” or “Site” refers indistinctly to the internet platform and/or application made available, published and operated by the Company enabling the provision of the Services.

2. Introduction

The protection of your personal data is important to us .

We are committed to collecting only the data we need to provide you with optimal service, to ensuring its confidentiality and security, including when we use service providers, and to facilitating the exercise of your rights over your data.

Capitalized terms have the meanings set forth in the General Conditions of ENTOURAGE AFRICA Inc. (« Entourage » or the « Company »).

Our first commitment is to comply with applicable legislation regarding the protection of personal data.

We comply with the obligations resulting from the General Data Protection Regulation (also known as “GDPR”).

This policy (the « Policy ») describes the personal data we collect, how it is used and, where applicable, shared, and your rights in this regard. It applies to all Users of the Company’s Services (the « Services »). We advise you to read it carefully. We have made every effort to ensure that it is clear, easily understandable, and accessible at all times during your browsing.

We strive to be as clear as possible.

If you would like any clarification or have any questions regarding this, you can contact our team at: hello@entourage.africa.

Modification : We reserve the right to modify the Policy at any time.

If we make a material change to this Policy, we will notify you via the email address you have provided on the Platform or other website operated by the Company (« Site »).

3. Data controller

ENTOURAGE AFRICA Inc., a company whose registered office is located at 131 Continental Dr, Newark, 19713, New Castle, registered with the Delaware Register of Companies under number 32-0775159.

4. Contact details of our personal data contact

You can send us any questions relating to the protection of personal data or send a request to exercise your rights of access, rectification, opposition, erasure, limitation, portability, administration of data after a death to our data protection officer:

by email addressed to: hello@entourage.africa.

5. Data we process

As part of your use of our Services and your browsing on our Site, we process several categories of data, the details of which you will find below. This data comes from:

Information you provide to us.
Information resulting from your use of our Services.

We do not process special categories of data (sensitive data) such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, genetic data, biometric data, data concerning health or data concerning an individual’s sex life or sexual orientation.

5.1 Data relating to Experts

We inform you at the time of collection whether or not the data is mandatory.

Type of collection	Categories	Details/Data	Purposes
Communicated by the Expert	Identification of Experts	Name and surname (including the legal representative of the company) Gender (optional) Phone number Email Professional function Sector of activity and areas of expertise Profile picture Nationality Professional career Certifications and training LANGUAGES Geographic location	This information allows the Expert to be referenced on the platform and contributes to the identification of their level of expertise in relation to the Client’s needs, and thus offers clients the available and most appropriate Expert in their geographical area.
	Information relating to exchanges with our teams	Expert’s email addresses Dates and duration of Consultations Recordings of Consultations Customer Comments / Ratings / Opinions on Experts	This information helps to secure Consultations and exchanges between Experts, Clients and our teams, as well as to provide quality customer support and follow-up.
	Banking information and relating to transactions	Experts’ Bank Identity Statement Details of banking transactions (e.g. payment for Consultations).	This information allows payment of amounts due to Experts for Consultations to be made.
	Social networks	Identification of Experts (names/nicknames, location) on social networks (LinkedIn, Twitter, Behance, StackOverflow, Github)	This information is used to facilitate communication about our services with the Expert’s networks.
Generated by your use of the Platform	Navigation data	Necessary cookies and other cookies subject to your consent IP address	This information helps secure your data and provide a better browsing experience on our Platform.
Generated by your use of the Platform	Recommendations	Customer Comments / Ratings / Opinions on Experts	This information allows our teams to provide appropriate and high-quality customer support and follow-up.

5.2 Data relating to Customers’ representatives

We inform you at the time of collection whether the data is mandatory or not.

Type of collection	Category	Details	Purpose
Communicated by the Client / Clients’ agents using the Platform	Personal information	First and last name Gender Phone number E-mail Profile picture Sector of activity	This information allows the Client to be identified and, more specifically, for the Expert to best prepare the Consultation with the Client, according to the latter’s profile.
	Information relating to Consultations	Customer email addresses Dates and duration of Consultations Recordings of Consultations Experts’ comments/ratings/opinions on Customers	This information helps to secure Consultations and exchanges between Experts, Clients and our teams, as well as to provide quality customer support and follow-up.
	Banking information and relating to transactions	Customer Billing Information Details of banking transactions on the Platform	This information allows us to track the payment of amounts owed by Customers and provide Customers with a transaction history.
Generated by your use of the Platform	Navigation data	Necessary cookies and other cookies subject to your consent IP address	This information helps secure your data and provide you with a better browsing experience on our Platform.

5.3 Statistical information relating to your use of our Services

For example, we collect statistics:

On the end of Consultation evaluations (comments left by Clients and Experts, average ratings);
Statistics based on Users’ connection and browsing data;
On the use of the search engine and the Expert profile;
On commercial data such as the number of Consultations carried out, business volumes by category of Experts, Clients.

6. Cookies

We use authentication cookies, security cookies and cookies related to the integrity of the Site, location cookies, cookies related to the functionality of the Site and Services, analysis and research cookies and cookies to deliver advertising messages. You can accept, refuse or configure your cookie choices when you first connect to the Platform and modify your choices at any time.

7. Legal bases and Purposes

Entourage processes most of your personal data as part of the Contract you entered into when you registered on the Site by accepting our General Terms and Conditions. However, we may process certain data about you based on your consent, due to legal obligations, or to fulfill our legitimate interest in processing them.

The data we collect allows us to provide, administer, protect and improve our Services, to develop new ones, and to protect both Users and ourselves from potentially fraudulent use of our Platform.

Especially,

7.1 Data processing implemented on the basis of the execution of the Contract

Based on the execution of the Contract that you entered into when you registered on the Site via the acceptance of our General Conditions which bind us, we use your data to provide you with our Services.

In particular, in the context of the execution of the Contract, we process your data for :

The creation and management of your account;
Allow you to use the Services

For Experts:

Verification of your identity based on your legal documents;
Optimizing your search engine ranking;
Ensure that the Consultations offered by the Experts are relevant (moderation of leads, anti-spam policy).

For Customers:

Provide the most relevant search results
Propose an Expert’s profile in response to a Client’s specific search: Entourage may transmit the Personal Data of Experts registered on the Platform to Client companies to assist them in their search for Experts or to present them with Experts corresponding to their needs. Thus, if, following a request from a Client, the profile of an Expert matches their search, we could transmit this profile information to the Client;
Centralize ongoing consultations with experts in a dedicated interface.

For all Users:

Send you communications related to your actions on the Platform (transactional emails);
Keep your documents (invoices, contracts, etc.) available to you within your Entourage account;
Allow payment for your Consultations. Thus, your data is processed to ensure the management of financial flows occurring, where applicable, via the Platform and in particular, the invoicing of Consultations and payments as well as, in accordance with the law, the fight against terrorism and money laundering.
Allow the use of cash advance services with our various partners/financial providers;
Allow you to leave a review/comment at the end of the Consultation;
Assist you in using the Platform by offering a Customer/Expert service responding to your requests.

7.2. Data processing implemented on the basis of Entourage's legitimate interest

Based on our legitimate interest, we use your data for the following purposes:

When registering on Entourage, we ask Experts to provide a certain amount of information relating to their identity, in order to facilitate contact between Experts and Clients by presenting the Client with the profile of the already verified Expert and speed up payment for Consultations ;
Protect Users from spam;
Carry out personalized follow-up to send you only relevant communications adapted to your needs directly linked to the Platform Services (for example: offering adapted Consultations, inviting you to update/complete your profile in order to maximize your chance that your Expert profile corresponds to the needs of customers, etc.);
Secure the Platform and secure the data and exchanges occurring on the Site;
Develop our Services to offer you new features and adapt them to your needs: to this end, we produce statistics on the use of our Services and monitor the audience of the pages of our Platform and monitor commercial activities and the behavior of Users on the Platform. These statistics are anonymized as often as possible;
Evaluate your satisfaction and, if you accept, contact you again to discuss this with you.
Ensure the quality of profiles, fight against fraud , verify profile information (e.g. location);
To combat fraud when posting Expert profiles and, if anomalies are detected, to provide a reminder of the applicable rules or to block the messages you send. We also use automatic content analysis technology for ads to detect unsolicited content, including fraudulent content;
Assist you in the event of difficulty using the Platform or request for help, particularly in the event of a dispute with another User;
Send you notifications related to your activity on the Platform , such as when you have booked a consultation / received a consultation;
Offer you the opportunity to participate in surveys (e.g. satisfaction, opinion, study on Experts in your country or in the European Union). You are free to participate and can object according to the terms provided at the time of the survey.
Communicating with you : Entourage may use the information collected to communicate with you about products, services, promotions, studies, surveys, news, updates and events.

7.3 Data processing carried out on the basis of your consent

We may also collect your prior consent to the processing of certain data;

– for example for the reuse of your profile photo, taken by our services, on commercial media;
– or when you have not created an account on the Site but wish to receive our commercial offers/our newsletter.

7.4 Data processing carried out on the basis of our legal obligations

Finally, we process certain data due to the legal obligations imposed on us, including in the context of managing payments made via the Site or not, and in particular the fight against the financing of terrorism and money laundering.

8. Recipients or category of recipients and transfers to countries outside the EEA

The Company is the recipient of the personal data collected through the Site.

Some of the services and features made available to you through the Site require us to share information with other Users or with our business partners. We may also share this information for legal reasons or in the event of a dispute.

We only share your personal data with third-party companies, organizations or individuals in the following circumstances:

8.1 Sharing with Customers

Sharing with Clients the Expert’s identification information available on his Expert profile on the Platform.

8.2 Sharing with trusted partners and service providers

When necessary for external processing purposes, and only in this case, we transmit this data to our partners, our service providers, including payment providers, and our subcontractors. They process your data on our behalf, according to our instructions or according to a contractual agreement, in accordance with this Policy and in compliance with any other appropriate security and confidentiality measures.

8.2.1. Data location

All of our servers, on which your data is stored, are located in Europe. Very exceptionally, some of our service providers whose main establishment is located in a country outside the European Union may be required to transfer your data to that country. In this case, we first verify that they comply with their obligations regarding the protection of our Users’ data and implement a “transfer tool” such as standard contractual clauses to guarantee protection of your personal data equivalent to that offered within the European Union.

8.2.2. Our service providers

Below you will find the name of our partners and service providers, where applicable, the link to their website and their data protection policy, the contact address for data protection questions, the purpose for which they intervene as well as the location of the data and the transfer tool used to guarantee a level of protection equivalent to that offered within the European Union when they are located outside the European Union or are likely to transfer data outside the European Union. We only share your personal data with them for the purposes set out below.

Name of the service provider	Purpose(s)	Data location
Amazon Web Services	Website	Europe https://aws.amazon.com/compliance/data-privacy-faq/
Google	Analytics	https://policies.google.com/privacy?hl=en-US

8.3 Sharing with our investors, accountants and auditors in the context of possible fundraising

The Company may share information relating to Experts and representatives of Clients registered on the Site and using our Services in order to respond to requests for information from our investors, accountants and any auditors, in particular in the context of possible fundraising or verification of the use of funds raised.

8.4 With authorized third parties

We retain or disclose your information if we believe it is reasonably necessary to satisfy any legal or regulatory obligation, legal process or administrative request, to protect the safety of any person, to address fraud, security or technical issues, or to protect the rights or property of our Users.

8.5 Between Entourage Group entities

Important: Entourage does not resell your data/information and documents that you entrust to us to third parties and we do not disclose personal and private information outside of the situations described in this Protocol.

9. Retention period or criteria determining these periods

Generally, we retain your information for the following periods:

Concerning Users who have already contracted and carried out Consultations, Entourage retains your billing details for a period of ten (10) years from the closure/deletion of your User account in order to comply with our accounting obligations, payment of social security contributions as well as our reporting obligations and provision of documentation to the tax authorities.

For Experts only, Entourage retains for a period of ten (10) years the legal documentation allowing the verification of your identity in order to meet the legal obligations of Clients to demonstrate that they have satisfied their duty of care in accordance with the requirements of French law.

Depending on the specific situation, we may always retain your personal data for longer periods. This will particularly be the case if one of the following periods is longer: (i) as long as necessary for the relevant activity or Service; (ii) any retention period required by law; or (iii) the limitation period during which legal proceedings may be brought to defend our interests.

10. Data security

We implement appropriate technical and organizational measures to ensure the ongoing security, confidentiality, integrity, availability and resilience of our information system and your data and to protect the data, including personal data, that we process against destruction, loss, alteration, unauthorized disclosure of data transmitted, stored or otherwise processed, or unauthorized access to such data. We are committed to implementing all available means to ensure the security and confidentiality of this data, in particular:

We verify your email address when you create your account;

We conduct internal audits of data collection, storage and processing, including physical security measures, to prevent unauthorized access to our systems;

Access to personal data is strictly reserved for employees and service providers of the Company (and its Group entities) who need to access it. These individuals are subject to strict confidentiality obligations.

11. Rights

In accordance with the GDPR, you have various rights as described below

11.1 Access rights

You have the right to access the data concerning you processed by Entourage. This right allows you to view the data we hold about you and, if you wish, to request a copy, subject to compliance with the rights of third parties whose personal data may be included in your data.

11.2 Rights to rectification

Under applicable data protection regulations, you may request that we rectify any inaccurate personal data concerning you. You may also request that incomplete personal data concerning you be completed, including by providing a supplementary statement.

To make it as easy as possible for you to exercise this right, we invite you to make these changes and additions directly to your profile. If you believe that other data concerning you should be modified or supplemented and you are unable to make this change yourself, we invite you to make a request directly in the your rights section of our data protection center or by writing to us at hello@entourage.africa.

11.3 Rights to erasure

You have the right to obtain from us the erasure, without undue delay, of personal data concerning you, subject to our legitimate interest or any legal obligation requiring us to retain it.

For security reasons and to avoid unwanted deletion of your account, we invite you to complete this process yourself once logged into your account.

Regarding your profile data, you should keep in mind that search engines and other third parties may still retain copies of your public profile information for a certain period of time when you have accepted their listing, even after you have deleted the information from the Site or deactivated your account. However, the Company is not responsible for such processing of your data by third parties. If you wish, you can exercise your right to delisting directly with these search engines. For example, to make this request to Google, you can use the tool made available by the search engine here.

11.4 Right to restriction of processing

You may request that Entourage limit the processing of your data (for example, by temporarily making your profile unavailable on the Site), when one of the following applies:

a) You contest the accuracy of the personal data concerning you. In this case, we will mask the data concerning you for a period enabling us to verify its accuracy;
b) You consider that the processing of your data is carried out unlawfully and you oppose their erasure and request instead the limitation of their use;
c) We no longer need your personal data for the purposes of the processing but it is still necessary to enable you to establish, exercise or defend a legal claim;
d) You have exercised your right to object. We will limit the processing of your data while we verify whether the legitimate grounds we are pursuing override your right.

If we decide to lift the limitation on the processing of your personal data, we will keep you informed.

11.5 Right to object

You can opt out of receiving communications, including commercial communications, from Entourage. For this purpose, we provide an unsubscribe link in all emails we send you.

You may also object, for legitimate reasons, to the processing of your data for which the Company has relied on legitimate interest. The Company will then interrupt the processing unless there are legitimate and compelling reasons to justify the continuation of the processing (for example, tax declarations, social security declarations, etc.) or for the establishment, exercise or defense of legal rights.

11.6 Right to portability

You may request the portability of your data at any time. By exercising this right, we undertake to transmit to you within a reasonable time and in a machine-readable format the data you have provided to us, whether declared by you or generated by your activity on the Site.

11.7 Right to withdraw consent

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. However, this would not affect the validity of your consent in the past.

11.8 The possibility of organizing the fate of your personal data after your death

A person may be designated to carry out these instructions. This person then has the authority, when the person has died, to take note of the instructions and request their implementation from the data controllers concerned.

These guidelines are:

General, when they relate to all data concerning a person;
Or specific, when these directives only concern certain specific data processing.
When these instructions are general and relate to all of the deceased’s data, they may be entrusted to a trusted third party certified by a personal data protection authority.

When it comes to specific instructions, they can also be entrusted to data controllers (social networks, online messaging) in the event of death. They are subject to the specific consent of the person concerned and cannot result from the sole approval by the latter of the general conditions of use.

In the absence of instructions given by the person during his lifetime, the heirs will have the possibility of exercising certain rights, in particular:

The right of access, if necessary for the settlement of the deceased’s estate;
The right to object to the closure of the deceased’s User accounts and to object to the processing of their data.

For any questions regarding the protection of your personal data processed by the Company or to exercise your rights to access, rectify, erase, oppose, limit or portability of your data or organize the fate of your data after your death, you can contact us by email at: hello@entourage.africa.