Introduction
Users of the Yewaan platform (hereinafter the "User" and the "Platform") are informed that Niten, publisher and operator of the Platform, carries out processing of personal data for the purposes of operating the services made available to them, acting as data controller with respect to:
- Law No. 2019-014 of 29 November 2019 on the protection of personal data (Republic of Togo);
- Law No. 2011-018 of 6 December 2011 governing electronic communications and electronic transactions (Republic of Togo);
- Regulation (EU) 2016/679 ("GDPR"), for Users located in the European Economic Area.
The User is informed of the following.
1. Identity of the Data Controller
The Yewaan platform is published and operated by Niten (Niten Software), a digital solutions company, accessible at niten.dev.
Data controller contact details:
- Email: contact@niten.dev
- Phone: +228 97 29 62 62
- Website: niten.dev
- Marketplace form: yewaan.com/en/contact
2. Data Collected
For the purposes of performing the services offered on the Platform, Yewaan collects, in whole or in part, the following personal data (hereinafter "Personal Data"):
2.1 Data Collected for All Users (Buyers and Artisans)
| Category | Data processed |
|---|---|
| Identification data | First name, last name, email address, phone number, IP address |
| Connection data | Secure session identifiers, date and time of connection, preferred language |
| Profile data | Profile photo (optional) |
| Transaction data | Order history, amounts, payment statuses, order numbers |
| Delivery data | Delivery address (first name, last name, phone number, address, city, region) |
| Browsing data | Pages visited, interactions with the Platform, IP address (via analytics tools) |
| Preferences | Wishlist, notification preferences, interface language, cookie consents |
2.2 Data Collected Specifically for Artisans
| Category | Data processed |
|---|---|
| Professional data | Shop name, biography, artisanal specialities |
| Location data | Address, city, region, country, GPS coordinates (optional, with consent) |
| Online presence | Website URL, links to social media (Facebook, Instagram, WhatsApp) |
| KYC documents | Valid official identity document (national identity card, passport or driving licence) |
| Financial data | Bank or payment details for payouts, earnings history and payout history |
| Communication data | Messages exchanged with Buyers via the integrated messaging system |
2.3 Third-Party Authentication Data
If the User chooses to authenticate via a third-party account (social network or identity provider), Yewaan receives only the information necessary to create the account (for example: first name, last name, email address and profile photo), within the limits authorised by the User at the time of login.
In application of the principle of data minimisation, Yewaan ensures that it only collects the data strictly necessary for the purpose for which it is processed.
Certain data strictly necessary for delivery is communicated to the relevant Artisan for the fulfilment of the order, in accordance with section 10 of the Terms of Use.
3. Purposes of Processing and Legal Bases
| Purpose | Legal basis |
|---|---|
| Registration on the Platform and creation of user account | Performance of contract |
| Authentication and session security | Performance of contract |
| Performance of services offered (browsing, purchasing, selling) | Performance of contract |
| Payment processing (Mobile Money) | Performance of contract |
| Order management and delivery tracking | Performance of contract |
| Escrow system and Artisan payout management | Performance of contract |
| Artisan KYC identity verification | Performance of contract and legal obligation |
| Management of refunds, disputes and chargebacks | Performance of contract and legal obligation |
| Invoicing and accounting archiving | Legal obligation |
| Claims management and customer support (tickets) | Performance of contract and legitimate interest |
| Real-time messaging between Buyers and Artisans | Performance of contract |
| Transactional notifications (email, push) | Performance of contract |
| Customer relationship tracking and management | Legitimate interest |
| Platform usage statistics and analytics | Legitimate interest |
| Commercial prospecting, newsletters and loyalty programmes | Consent |
| Personalisation of the User experience | Consent |
| Targeted advertising | Consent |
| Artisan geolocation for map display of their shop | Consent |
| Push notifications | Consent |
4. Audience Measurement and Analytics Tools
Yewaan may use audience measurement tools to understand overall use of the Platform and improve its services.
- Essential audience measurement: certain aggregated and anonymised indicators may be collected without advertising cookies or individual profiling.
- Advanced audience measurement: when offered, it is only activated after obtaining the User's explicit consent via the cookie management banner.
When service providers located outside Togo are involved, Yewaan ensures that appropriate contractual and regulatory safeguards govern such processing.
5. Cookies and Tracking Technologies
5.1 Types of Cookies Used
| Category | Description | Consent required |
|---|---|---|
| Essential cookies | Authentication, language preferences, shopping cart, cookie consent | No (necessary for operation) |
| Analytical cookies | Audience measurement and service improvement | Yes |
| Marketing cookies | Targeted advertising, marketing emails | Yes |
5.2 Consent Management
On the first visit, a cookie management banner allows the User to:
- Accept all: activate all cookies, including analytical and marketing cookies.
- Reject all: activate only essential cookies.
- Customise: individually select which categories to activate.
Preferences are saved on the User's device and, where applicable, synchronised with the Platform.
The User may modify their preferences at any time from the settings page or by clearing their browser's browsing data.
5.3 Cookie Lifespan
Essential cookies have a limited lifespan, adapted to session security. Consent preferences may be revoked at any time.
6. Rights of Data Subjects
In accordance with applicable regulations, each User has the following rights with respect to their Personal Data:
6.1 Right of Access
The User has the right to obtain confirmation as to whether or not their Personal Data is being processed and, where it is, to obtain a copy.
6.2 Right of Rectification
The User has the right to obtain the rectification of inaccurate Personal Data concerning them and to have incomplete data completed. Most profile data can be modified directly from the My Profile page on the Platform.
6.3 Right to Erasure (Right to be Forgotten)
The User may request the erasure of their Personal Data where:
- The data is no longer necessary for the purposes for which it was collected.
- The User withdraws consent on which the processing is based (and there is no other legal basis).
- The User objects to the processing and there are no overriding legitimate grounds.
- The data has been unlawfully processed.
- Erasure is required to comply with a legal obligation.
Certain data may be retained despite an erasure request, in particular for legal accounting or evidentiary obligations.
Account closure is accessible from Profile Settings (Security tab) and requires password confirmation.
6.4 Right to Restriction of Processing
The User may request the restriction of processing of their data (temporary inaccessibility) in the following cases:
- Contesting the accuracy of the data.
- Unlawful processing with objection to erasure.
- Retention necessary for the establishment or defence of legal claims.
- Objection to processing pending verification of legitimate grounds.
6.5 Right to Object
The User has the right to object at any time to the processing of their Personal Data based on Yewaan's legitimate interest, in particular for commercial prospecting purposes.
6.6 Right to Data Portability
The User may request to receive their Personal Data in a structured, commonly used and machine-readable format, or to have it transmitted to another data controller, where processing is based on consent or the performance of a contract and is carried out by automated means.
6.7 Right to Withdraw Consent
Where processing is based on consent, the User may withdraw it at any time, without affecting the lawfulness of processing carried out prior to that withdrawal. Withdrawal of consent to marketing cookies may be done directly from the cookie management banner.
6.8 Right to Give Post-Mortem Directives
The User has the right to give directives regarding the fate of their Personal Data in the event of death.
6.9 Right to Lodge a Complaint
The User may lodge a complaint with the competent supervisory authority:
- For Users in the EU: the CNIL (Commission nationale de l'informatique et des libertés, France) or any other data protection authority in their Member State.
- For Users in Togo: the Personal Data Protection Authority (APDP) of Togo, in accordance with Law No. 2019-014 of 29 November 2019 on the protection of personal data.
7. How to Exercise Your Rights
To exercise any of the rights mentioned above, the User submits their request to the data controller by one of the following means:
- Email: contact@niten.dev
- Phone: +228 97 29 62 62
- Contact form: yewaan.com/en/contact
Each request must be accompanied by proof of identity (copy of identity card or passport). If there is reasonable doubt as to the identity of the requester, additional information may be requested.
Yewaan undertakes to respond within a maximum period of one (1) month from receipt of the request. This period may be extended by a further two months in the case of a complex or high-volume request, after prior notification to the User.
8. Data Retention Periods
| Data category | Active retention period | Archiving period |
|---|---|---|
| Account data (profile, credentials) | Duration of the contractual relationship + 1 year after account closure | 5 years for evidentiary purposes |
| Order and transaction data | Duration of the contractual relationship | 10 years (statutory accounting obligation) |
| Artisan KYC documents | Duration of the contractual relationship | 5 years after termination |
| Messaging data | Duration of the contractual relationship | 1 year after account closure |
| Log and connection data | 1 year | — |
| Session cookies | Limited duration, adapted to security | — |
| Cookie consent preferences | Until revoked by the User | — |
| Payment data | Duration of the transaction + legal compliance | 5 years |
9. Data Security
Yewaan implements appropriate technical and organisational measures to ensure the security and confidentiality of Personal Data, including:
- Secure authentication: protected sessions and access limited to authorised accounts.
- Encrypted communications: exchanges between the User and the Platform are encrypted.
- Access control: each user only accesses the data necessary for their role (Buyer, Artisan or administration).
- Restricted access: only authorised Yewaan services and personnel have access to Personal Data, strictly within the scope of their functions.
- Secure hosting: data is stored on a protected infrastructure, with appropriate backups and monitoring.
In the event of a data breach likely to create a risk for the rights and freedoms of the persons concerned, Yewaan undertakes to notify the competent authorities and, where applicable, the affected Users within the timeframes provided for by applicable regulations.
10. Minors' Data
The Yewaan Platform is reserved for persons aged at least 18 years. Yewaan does not knowingly collect personal data from minors. If Yewaan becomes aware that a minor has created an account, the associated data will be deleted as soon as possible.
11. Push Notifications
With the User's explicit consent, Yewaan may send notifications via the browser or the application. These notifications are used to inform the User:
- Of the status of their orders (confirmation, shipment, delivery).
- Of the receipt of new messages.
- Of stock alerts or promotions (if activated).
The User may manage and revoke this authorisation at any time from the Notification Settings in their profile or directly from their browser settings.
12. Links to Third-Party Sites
The Platform may contain links to third-party websites (Artisan shops, social media, etc.). Yewaan is not responsible for the privacy practices of these sites. The User is invited to consult their respective privacy policies.
13. Amendments to the Privacy Policy
Yewaan reserves the right to amend this Policy at any time to reflect legal, regulatory or operational developments. In the event of a substantial amendment, the User will be informed via the Platform or by email. The date of the last update is indicated at the top of this document. Continued use of the Platform after notification constitutes acceptance of the amended Policy.
14. Contact and Complaints
For any question relating to the protection of your personal data or to exercise your rights, please refer to the data controller's contact details (section 1) and the procedures for exercising rights (section 7).