Privacy and cookie policy

This is a translation. In case of discrepancy, the French version prevails.

Key points

• Who: DIGITAL TRADE PRO (“DitPro”), a company registered in Togo, which publishes Trans-izi.
• What: the data needed for your account and your transactions (identity, email, mobile money numbers, transactions, Alipay account), and technical data (IP address, device).
• Why: to run the service, secure your account and comply with the law. Advertising and audience measurement only if you accept them.
• With whom: our technical providers, our payment partners, and Alipay for top-ups. Never sold.
• Where: many of our providers are outside Togo (Ireland, United States, China, United Kingdom, Benin, Burkina Faso).
• How long: as long as necessary, then the periods required by law (up to 10 years for money transactions).
• Your rights: access, correction, deletion, objection, withdrawal of consent. Write to support@transizi.com.

1. Who is responsible for your data

The data controller is DIGITAL TRADE PRO (“DitPro”, “we”), a SARLU with share capital of 1,000,000 FCFA, registered office in Lomé (Togo), RCCM TG-LFW-01-2024-B13-02216, represented by its manager, Mr TEOU Tovenim François.

Contact for your data: support@transizi.com (subject “Personal data”) or WhatsApp +226 79 98 15 50.

2. Applicable laws

• Togolese Law No. 2019-014 of 29 October 2019 on the protection of personal data.
• Our team works from Ouagadougou: Burkinabe Law No. 001-2021/AN of 30 March 2021 also applies to processing carried out from Burkina Faso.
• The laws of your country may also protect you.

3. Who this policy applies to

It applies to anyone who:

• visits the transizi.com website or the Trans-izi app;
• creates an account and uses our services;
• pays through a payment link without having an account;
• is enrolled in an Academy course, including by our team;
• takes part in the referral programme;
• contacts our customer service;
• responds to an advertisement or fills in one of our forms;
• applies for a job on our recruitment page.

Our business partners receive separate information about the data we process about them.

4. The data we use

4.1. When you visit the website or the app

• IP address, type of device and browser, pages viewed, date and time.
• The cookies and trackers described in part 14.

4.2. Your account

• First name, last name, email address, password (stored in an encrypted form that we cannot read).
• If you use “Continue with Google”: the name, email address, photo and identifier of your Google account.
• Chosen country, currency and language, and a profile photo if you add one.
• The referral code entered, if any.
• The date on which you accepted the terms of use and the version accepted.

4.3. Your wallet

• Balance, currency, transaction history (amounts, fees, rates, dates, references, status, reasons for failure).
• For deposits and withdrawals: mobile money number, country, operator.
• For transfers: the recipient’s email or QR code, their name, the amount, your message.
• Your PIN code, stored in an encrypted form that we cannot read.
• The Trans-izi QR code of your wallet.

4.4. Alipay top-ups

• The name of the Alipay account and the image of its receiving QR code.
• The amounts in yuan and in francs, the rate, the status, the proof of payment (screenshot of the confirmation), the reasons for refusal.

4.5. Payment links

• If you create a link: its title, description, image, attached file and the payments received.
• If you pay through a link: your name, email, phone number, country and the amount paid. Your browser also keeps this information on your device to fill in the form the next time; you can erase it by clearing the website’s data.

4.6. The Academy

• Your enrolments, the price paid, your progress, and the personal notes you write in the lessons.
• If our team enrols you: your name and email, used to create your account and send you your access link.

4.7. The referral programme

• The link between referrer and referee, the date the code was entered, the referee’s activity needed to calculate earnings (fees paid, status), the earnings and their withdrawals.
• The IP address at the time the code is entered, to detect abuse.
• The referrer sees only the first name and last-name initial of their referees, and their status in the programme.

4.8. Customer service

• Your messages (WhatsApp, email) and the information you give us to handle your request.

4.9. Security

• A log of sensitive events (sign-in, PIN code change, blocked transactions…) with the IP address.
• The IP address, used for a short time to limit the number of attempts and block attacks.

4.10. Notifications

• The content of the notifications we send you in the app.
• If you accept notifications on your phone: the technical subscription address of your browser.

4.11. Advertisements and forms

• If you fill in a form after an advertisement (for example on Facebook) or on our website: the information in the form, usually your name, phone number and city.

4.12. Job applications

• Name, phone, email, neighbourhood, motivation, availability, CV, voice note, links to videos, our team’s interview notes, chosen interview slot.

4.13. Data we do not ask for

We do not ask you for data about your health, religion, political opinions or ethnic origin. Do not include any in your messages or content.

5. What is mandatory and what is not

• Mandatory: the data marked as mandatory in the forms (for example, the email to create an account, the mobile money number for a withdrawal, the Alipay QR code for a top-up). Without it, we cannot provide the service requested.
• Optional: the profile photo, personal notes, acceptance of measurement and advertising cookies, promotional messages. Refusing them changes nothing about your access to the service.
• Supporting documents: if we ask you for a supporting document (article 8 of the terms of use) and you do not provide it, some transactions may be limited.

6. Why we use your data, and on what basis

To perform the contract between us (your requests and our terms of use):

• create and manage your account;
• carry out your transactions: deposits, withdrawals, transfers, conversions, Alipay top-ups, payment links, course purchases;
• give you access to courses;
• calculate and pay referral earnings;
• send you confirmations, receipts and alerts about your transactions;
• answer your questions and complaints;
• secure your account and detect fraud.

To comply with our legal obligations:

• keep records of transactions and contracts for the legal periods;
• verify identity or the origin of funds when the law requires it;
• respond to requests from the authorities (courts, financial intelligence unit, IPDCP);
• keep the identification data of the authors of published content.

With your consent, which you can withdraw at any time:

• audience measurement and advertising cookies and trackers (part 14);
• sending your data to Meta to measure and improve our advertisements (part 14);
• promotional messages (part 15);
• the voice note and video of recruitment applicants;
• keeping an application beyond the planned period.

We never sell your data.

7. Who receives your data

Only the people and companies that need your data receive it, and only what they need.

Our team, according to their role (customer service, operations, security). Each member is bound by confidentiality.

Our technical providers, who act on our instructions:

Our payment partners, to process your mobile money or card payments: pawaPay (United Kingdom), FeeXPay (Benin), YengaPay (Burkina Faso), FedaPay (Benin), and your mobile money operator. They receive the amount, your mobile money number, the country and the operator, and, for a payment link, the payer’s name and email. They also apply their own privacy policy. This list may change; it is updated here.

For Alipay top-ups: the name of the Alipay account, its QR code and the amount are sent to the payment partners involved in the transaction, then to Alipay (China), which credits the account. Alipay applies its own privacy policy.

Meta Platforms (United States, Ireland), only if you accept measurement and advertising cookies (part 14).

Other users, in the cases provided for:

• the person who created a payment link sees the name, email, phone and country of those who paid it;
• the recipient of a transfer sees your name and your message;
• before a transfer, you see the recipient’s name;
• the referrer sees the first name and last-name initial of their referees.

The authorities, when the law requires us to (courts, police, financial intelligence unit, IPDCP).

A buyer or a partner, if all or part of DitPro’s business is transferred. You will be informed beforehand.

8. Data transfers outside Togo

8.1. As shown in part 7, a large part of your data is stored or processed outside Togo: in Ireland, the United States, France, the United Kingdom, Benin, Burkina Faso and, for Alipay top-ups, China.

8.2. These transfers are necessary to provide you with the service (hosting, payment, Alipay top-ups). We choose recognised providers, we send them only what is useful, and we rely on their contractual data protection commitments.

8.3. The transfer to Meta for advertising takes place only if you accept it.

9. How long we keep your data

At the end of these periods, the data is deleted or anonymised. It may be kept longer if an authority requires it or in the event of a dispute, for the time needed to settle it.

10. Security

We take measures to protect your data, including:

• encrypted connections (HTTPS);
• passwords and PIN codes stored in encrypted form;
• sensitive files (Alipay QR codes, proofs of payment, documents) kept in private storage;
• team access limited according to role;
• a log of sensitive actions;
• limits on the number of attempts.

No system is perfect. If a data breach poses a risk to you, we will notify you and the competent authority.

11. Your rights

At any time, you can:

• find out whether we hold data about you and receive a copy of it;
• have inaccurate or incomplete data corrected;
• request the deletion of your data, except data the law requires us to keep (part 9);
• object to the use of your data for marketing, free of charge and without giving reasons;
• withdraw your consent (cookies, promotional messages…), without affecting what was done before;
• give instructions on what happens to your data after your death.

How: write to support@transizi.com (subject “Personal data”) from your account’s email address, or on WhatsApp +226 79 98 15 50. If we have doubts about your identity, we may ask you for proof.

Time frame: we reply within one month.

Closing your account: see article 14 of the terms of use.

Complaint to an authority: if you think your rights are not being respected, you can contact:

• in Togo, the Instance de Protection des Données à Caractère Personnel (IPDCP), in Lomé;
• in Burkina Faso, the Commission de l’Informatique et des Libertés (CIL), in Ouagadougou;
• or the data protection authority of your country.

12. Automated decisions

Some checks are automated: for example, the anti-fraud checks of the referral programme, or the temporary blocking of PIN code attempts when there are too many in a short time. No final decision with significant consequences for you (cancellation of earnings, account closure) is taken without a member of the team reviewing the case. You can give your explanations by WhatsApp or by email.

13. Minors

Trans-izi is reserved for people aged 18 or over. We do not knowingly collect data about minors. If you think a minor has created an account, let us know: we will close the account.

14. Cookies and trackers

14.1. What are they?

A cookie or tracker is a small piece of information saved on your phone or computer when you visit a website. It makes it possible, for example, to keep you signed in or to measure the effectiveness of an advertisement.

14.2. Your choice

On your first visit, a banner offers you two buttons of the same size: “Accept” and “Refuse”.

• Necessary trackers (14.3) work in all cases.
• Measurement and advertising trackers (14.4) work only if you click “Accept”.
• Refusing has no effect on your access to the service.

Your choice is kept for 6 months. You can change it at any time with the “Manage cookies” link, at the bottom of every page of the website and in the app settings.

14.3. Necessary trackers (no consent needed)

• Sign-in: keeps your session open and secure.
• “Stay signed in”: remembers your choice on this device.
• Language and currency: remember your display preferences.
• Cookie choice: remembers your answer to the banner.
• Device storage: the app keeps drafts on your device (simulation, top-up being entered, payment link), your preferences (converter favourites, app installation) and, for payment link payers, the form information. This data stays on your device.

14.4. Measurement and advertising trackers (only if you accept)

• Meta Pixel (cookies _fbp and, if you come from a Facebook or Instagram advertisement, _fbc, lasting 90 days): tells Meta which pages you view and that you signed up, to measure our advertisements and show them to people likely to be interested.
• Direct sending to Meta from our servers (Conversions API): when you take certain actions (confirmed sign-up, first deposit, first Alipay top-up), we send Meta the event, your email address and your phone number in coded (“hashed”) form that does not show them in clear text, your IP address and your browser type. Meta uses this to know which advertisement brought you.
• Source of your visit (Trans-izi cookie, 90 days): remembers the advertisement or link that brought you, to know which campaigns work.
• Usage measurement (Trans-izi identifier, 13 months at most): helps us understand how the website and the app are used (pages viewed, buttons used). This data stays with us and is not shared with anyone.

If you refuse, none of this is saved or sent. We can only count visits and clicks anonymously, without any identifier that follows you from one visit to the next.

14.5. Videos

Course videos are played with the YouTube player, in “privacy-enhanced” mode. When you start a video, YouTube (Google) may record information under its own policy.

14.6. Your browser settings

You can also delete or block cookies in your browser settings. If you block necessary cookies, you will no longer be able to stay signed in.

15. Promotional messages

15.1. We send you promotional messages (email, notification, WhatsApp) only:

• if you have agreed to it;
• or, if you are already a customer, for Trans-izi services similar to those you use, with the option to refuse at any time.

15.2. Every promotional email contains a link to unsubscribe. You can also refuse at any time by email or by WhatsApp. It is free and taken into account quickly.

15.3. Messages about your transactions (confirmations, receipts, security alerts) are not promotional messages: you receive them as long as your account is open.

16. Changes to this policy

We may change this policy, for example if we change provider. The date of the last update is shown at the top. In the event of a significant change, we will notify you in the app or by email before it applies.

17. Contact us

• Email: support@transizi.com (subject “Personal data”)
• WhatsApp: +226 79 98 15 50
• DIGITAL TRADE PRO, Lomé, Togo