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PRIVACY POLICY — SAFI BY RECOLAND (MOBILE APPLICATION)

PRIVACY POLICY — SAFI BY RECOLAND (MOBILE APPLICATION)

Recoland RDC

Last Updated: February 25, 2026

Recoland SAS (“Recoland,” “we,” “us,” or “our”) is committed to protecting your privacy and ensuring the responsible handling of personal data. This Privacy Policy explains how we collect, use, process, store, share, and protect personal information when you download, access, or use the Safi by Recoland mobile application (the “App”).

This Privacy Policy is designed to comply with applicable data protection requirements and the strict disclosure and user-rights requirements of the Google Play Store (and, where applicable, similar app marketplace standards).

By installing, accessing, or using the App, you acknowledge that you have read and understood this Privacy Policy.

1. Data Controller

The data controller responsible for processing personal data under this Privacy Policy is:

RECOLAND SAS
Democratic Republic of the Congo
Email: contact@recolandrdc.com
Website: www.recolandrdc.com

2. Information We Collect

To provide and improve our waste management, collection, sanitation, and recycling services in the Democratic Republic of Congo, we may collect the following categories of information:

a) Information You Provide Voluntarily

When you register an account, schedule a service, submit requests, or contact us through the App, you may provide:

  • Full name (first name and surname)
  • Email address
  • Telephone number
  • Address details or neighborhood/area information (e.g., Kinshasa or other provinces)
  • Service details included in your requests (e.g., pickup preferences, descriptions, notes)
  • Any information included in your communications with us

b) Location Data (GPS and Approximate Location)

To facilitate efficient service delivery (e.g., determining pickup points, optimizing routes, verifying service areas), the App may request access to:

  • Precise location (GPS)
  • Approximate location

Important: Location data is collected only when the App is actively in use (foreground) and only to enable core service functionalities linked to your request (e.g., determining the pickup location).

c) Camera, Photos and Media (Optional)

If you choose to use App features that require media, you may grant access to:

  • Camera
  • Photo gallery / media storage

This may occur when you:

  • Report illegal dumping or sanitation issues
  • Request recycling valuations or classifications
  • Confirm a pickup or service completion

Important: Images and media are collected only when you explicitly upload them. The App does not access or upload your photos without your action.

d) Device and Usage Information (Automatically Collected)

When you use the App, we may collect certain technical and diagnostic information automatically, including:

  • Device model and manufacturer
  • Operating system version
  • App version
  • Unique device identifiers (where applicable and permitted)
  • IP address
  • App activity logs and performance data (e.g., crash reports, diagnostics, usage statistics)

This information helps us maintain security, troubleshoot issues, improve App stability, and enhance user experience.

e) Communications and Notifications Data

Where you enable notifications or messaging features, we may process:

  • Service notifications and status updates (e.g., pickup confirmation, scheduling changes)
  • Communication records necessary to respond to your requests
  • Delivery status of notifications (for operational reliability)

3. Purpose of Data Processing

We process personal data for the following purposes:

  • Service Delivery: scheduling, managing, verifying, and improving waste collection, sanitation, and recycling services at your specified location
  • Account Management: creating, managing, securing, and authenticating your user profile
  • Operational Communication: sending service updates, confirmations, administrative messages, and responding to inquiries
  • Service Improvement and Analytics: understanding usage trends, fixing bugs, improving user experience, and optimizing operational performance
  • Safety and Security: preventing misuse, fraud, or unauthorized access, and ensuring platform integrity
  • Compliance: meeting legal, regulatory, contractual, or institutional obligations (where applicable)

4. Legal Basis for Processing

Where applicable under relevant laws, personal data is processed based on one or more of the following legal bases:

  • Your consent, including where you enable optional features (such as camera access) or allow location permissions
  • Legitimate business interests, such as ensuring App security, performance, service improvement, and operational integrity
  • Performance of a contract or pre-contractual measures, where processing is necessary to provide the requested services (e.g., scheduling and executing a pickup)
  • Legal or regulatory obligations, where we must comply with applicable laws or lawful authority requests

5. Data Sharing and Disclosure

Recoland SAS does not sell, rent, or trade your personal data.

We may share personal information only when necessary, and only in the following cases:

a) Authorized Service Providers

We may share data with trusted third-party vendors that support App operation and service delivery, such as:

  • Cloud hosting and infrastructure providers
  • SMS or communication notification providers
  • Analytics and diagnostic service providers (e.g., crash reporting tools)

All service providers are expected to comply with confidentiality requirements and implement appropriate security measures.

b) Legal Requirements and Public Authorities

We may disclose data where required by law, regulation, court order, or in response to valid requests from competent public authorities in the DRC.

c) Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or similar transaction involving Recoland SAS, user data may be transferred as part of that transaction, subject to appropriate safeguards and continued protection of your personal information.

6. International Transfers

Where data processing involves international service providers or technical infrastructure located outside the DRC, Recoland SAS takes reasonable measures to ensure appropriate safeguards consistent with applicable laws and internationally recognized data protection practices.

7. Data Retention

We retain personal data only for as long as necessary to:
  • provide and manage services requested through the App
  • maintain system security and operational logs
  • comply with applicable legal obligations
  • resolve disputes and enforce our policies

Retention periods may vary depending on the category of data and legal/operational requirements.

8. Data Security

Recoland SAS implements reasonable technical and organizational measures designed to protect your personal data against unauthorized access, loss, misuse, alteration, or disclosure.

Security measures include, where applicable:
  • Encryption in transit using secure protocols (HTTPS/TLS)
  • Protection of data stored on secured servers
  • Access control and operational safeguards

However, no internet transmission or electronic storage method is 100% secure.

9. Your Rights

Subject to applicable laws, you may have the right to:

  • Request access to your personal data
  • Request correction of inaccurate or incomplete data
  • Request deletion of your personal data
  • Object to or restrict certain processing activities;
  • Withdraw consent where processing is based on consent (this will not affect the lawfulness of processing prior to withdrawal)

Requests may be submitted using the contact details in Section 12.

10. Permissions Management (Location, Camera, Storage)

You may control App permissions through your device settings at any time, including: • disabling location access • disabling camera or photo access • restricting notification permissions Please note that disabling certain permissions may limit core service functionalities (e.g., inability to locate pickup points without location access).

11. Account Deletion and Data Deletion (Google Play Compliance)

In compliance with Google Play Store policies, you have the right to request deletion of your account and associated personal data at any time.

a) In-App Deletion

You may delete your account directly within the App by navigating to:

Settings → Account → Delete Account

b) Deletion Request by Email (If App Is Not Installed)

If the App is no longer installed, you may request deletion by sending an email to:

12. Contact Us

For any questions or requests regarding this Privacy Policy, please contact:

RECOLAND SAS
Democratic Republic of the Congo
Email: contact@recolandrdc.com
Website: www.recolandrdc.com