I - INTRODUCTION

In its ambition to create a space for the exchange of knowledge and skills for its employees, the Axian Group has launched its corporate university: AXIAN UNIVERSITY.This establishment brings together the various training and development structures to challenge and implement the business strategies of the AXIAN Group and reveal talents.

AXIAN UNIVERSITY supports the talents of the Axian Group to grow and reach their full potential through the transmission of knowledge and skills from passionate experts.

In this context, AXIAN SUPPORT SERVICES, through AXIAN UNIVERSITY, offers online training for Group employees.

This document sets the privacy policy applicable to all access and use of the AXIAN UNIVERSITY online training platform.

          A. Objective and scope of the policy

This Policy details how AXIAN UNIVERSITY collects, uses and protects information related to the Axian Group's online training platform.

It applies to all personal data that AXIAN UNIVERSITY processes, in particular when Group Employees use the e-learning platform. It is important that users read this Policy in order to be fully informed of the processing of personal data concerning them, the means implemented to protect them and the methods by which they can exercise their rights.

This policy is not a contract and does not create any contractual obligation.

           B.AXIAN UNIVERSITY

In this policy, AXIAN UNIVERSITY designates a Department within the company AXIAN SUPPORT SERVICES, whose head office is located at Building KUBE D, Zone Galaxy Andraharo, Antananarivo Madagascar.

Third Party Websites.

The E-learning platform may contain links to other websites. If you follow these links, AXIAN UNIVERSITY is not responsible for the processing carried out on the websites of these third parties. This policy does not apply to these websites.

To learn more about how these third parties process your personal data, you can consult their personal data protection policies.

II- RESPONSIBLE FOR PROCESSING

The data controller is AXIAN SUPPORT SERVICES, a limited liability company, registered with the RCS of Antananarivo under number 2017 B 00272, whose head office is located at Building KUBE D 5th floor, Zone Galaxy Andraharo, Antananarivo, Madagascar.

III- PROCESSED PERSONAL DATA

AXIAN UNIVERSITY collects and processes the following personal data:

• Identification data (surname, first name, e-mail address, telephone number);

• Professional data (company, personnel number, function, service/department/management)

• Data relating to training (modules followed, evaluation, etc.);

• Connection data (IP address, connection logs).

Only personal data that is strictly necessary for the purposes described below is collected.

IV- LEGAL BASES FOR THE PROCESSING AND COLLECTION OF PERSONAL DATA

Your personal data is collected and processed on the following legal bases:

• for purposes of legitimate interest;

• on the basis of your consent;

• in order to ensure compliance with our legal and regulatory obligations.

V- PURPOSES OF PROCESSING

Your personal data is processed for the following purposes:

• Training management;

• Reporting;

• The management of your requests to exercise rights over your personal data;

• Communication (answers to questions, announcements, etc.);

VI- PERIOD OF CONSERVATION OF PERSONAL DATA

The personal data collected is kept for the relevant legal and regulatory periods in force.

However, your personal data is only kept for the time strictly necessary to fulfill the purposes for which it is collected and processed when it is not subject to any specific legal or regulatory retention period.

By default, your connection, browsing and traffic data are not kept for more than one (01) year.

Your personal data will be kept for a longer period when legal and regulatory obligations require us to do so.

VII- RECIPIENTS OF PERSONAL DATA

Your personal data is processed by AXIAN UNIVERSITY as well as its service providers and partners acting on our behalf for the purposes mentioned above.

VIII- NATURE AND EXERCISE OF RIGHTS RELATING TO PERSONAL DATA

As part of the processing of personal data, users have the following:

• permission to access ;

• right to question the processing of your data;

• right of rectification: updating and/or additional information if necessary;

• right to erasure when the data are no longer necessary for the purposes for which they were collected – this right can be exercised insofar as it does not harm/affect the performance of the contract or compliance with our legal and regulatory obligations;

• right to limit one or more processing of your personal data;

• rights of modification and/or withdrawal, at any time, of the consents concerning the processing of your personal data based solely on your consent;

• right of opposition to the processing of your personal data, in particular with regard to commercial prospecting;

• right to the portability of your personal data. You also have the right to specify how you want your personal data to be processed after your death.

To ensure that the information we have about you is always accurate, we recommend that you regularly update your personal data.

How do I exercise my rights?

You can make any request to exercise your rights relating to your personal data by contacting us by email: axian.university@axian-group.com. You can also ask any additional questions relating to the personal data protection policy and the processing of said personal data. In case of dissatisfaction, you have the right to seize the competent authority in the matter, the Malagasy Commission for Computing and Freedoms (CMIL).

IX- SECURITY MEASURES

As data controller, AXIAN UNIVERSITY takes all useful and required measures to preserve the security and confidentiality of the data and in particular, to prevent it from being damaged, or that unauthorized third parties have access to it.

To this end, all technical and organizational measures to guarantee an adequate level of security adapted to the risks are implemented.

X- MODIFICATION OF THE POLICY

This policy is intended to evolve and is therefore subject to change. In case of minor changes, the new policy will be updated on the platform. In the event of substantial changes relating, for example, to the purposes, the exercise of your rights, you will be kept informed by any useful means.