Honora Madagascar Public Limited Company, (hereinafter “Telma”, “us” or “our”), as the entity responsible for processing the personal data of users of the web portal www.telma.mg (“Portal”) recognizes the importance of protecting the privacy and confidentiality of users’ data (hereinafter “user” or “you”), and provides you with this Privacy Notice (“Notice”), designed in compliance with our global data protection policies and the applicable laws and regulations of Tanzania.

Through the Portal, Telma may collect certain information about you. This Notice informs you about the processing of your personal data, in particular (1) what data we collect about you, (2) how we collect it, (3) for what purpose, (4) what your rights are and how you can exercise them, (5) with whom it is shared, (6) how long it is kept, (7) what law applies, and (8) Telma’s contact information, as the party responsible for processing your personal data.

Telma requests your consent to collect, use, store, process and ultimately manage your personal data, including data used for advertising and commercial purposes, in compliance with the terms of this Notice. In the event of a conflict between the provisions of the Notice and other policies or terms and conditions available to users through other means, this Notice shall prevail. To obtain information about the terms applicable to the use of the Portal, we suggest you refer to our terms and conditions

Telma may make changes to the Notice from time to time. In the event that we make material changes to the Notice, we will post those changes through the Portal. You will be able to determine when the Notice was last revised in the “version history” at the end of the document.

In order to provide you with products or services, or access to our Portal, Telma may collect the following personal data:

registration information: your full name, age, telephone number, e-mail address, mailing address, payment information, billing address or username and password.

information about your use of the Portal: the network address and operating system of your computer, type of browser used, the website from which you linked to our site, your activity on our Portal, as well as your viewing history, the time and date you visited and purchased products and services through the Portal.

information about your location.

mobile application information based on the websites visited and applications downloaded from the Telma network.

In addition, Telma informs you that it does not request or process, to the best of its knowledge, personal data of minors under the age of 18.

We obtain your personal data either because you provide it directly to us (e.g. you register through our Portal or subscribe to receive news and information from Telma, or contact us for any other reason via email, telephone, fax, or by written means or personally at any of our business premises or offices), we obtain it through third parties, or it is public information.

Telma may process your personal data for any of the following purposes:

Adequate provision of services: Includes all activities aimed at analyzing and developing the feasibility and execution of the Portal’s service, such as: determination of consumption, maintenance and improvement of services and the Web Portal, customer service, customization of content, services and offers, business plans, customer satisfaction, creation of databases, analysis of information and data, creation of key performance indicators (KPI) applications, billing, security, quality control and, in general, all information necessary to comply with our product or service contracts, as well as applicable laws and regulations.

Telma’s Business Purposes: Includes any activity aimed at presenting offers, promotions, products, advertisements, opportunities, sweepstakes, campaigns, loyalty programs, customer retention and, in general, information on new products and services, already requested or contracted, or that may be of interest to customers and users.

Relationship with target audience. Includes all activities oriented to the management of relations with our affiliates and subsidiaries, shareholders, authorities and community in general, in accordance with the current legal framework, in the development of business management for the adequate fulfillment of the corporate purpose.

Legal Purposes: includes any treatment justified by the need to comply with applicable legal requirements, such as meeting a requirement of a governmental or administrative entity in the exercise of its functions or by order of a competent judicial authority, or to protect the rights, property or safety of Telma, as well as the safety of our customers, employees and the general public.

Telma does not market your data to third parties.

What are your rights regarding the processing of your personal data?

You can ask Telma about your personal data as well as request access to or correction of your personal data. You can also object to Telma using your personal data to send you advertising content. You can contact us via the contact information provided at the end of this Notice. You can also access or rectify your personal data through the Portal, in the Contact us section or the Telma Account.

With whom do we share your personal data?

In compliance with applicable laws, the recipient of your personal data is Telma, who is also responsible for guarding and storing your personal data. However, Telma may share your personal data with third parties who provide services to Telma such as storage services, order fulfillment, collection and shipping, surveys, customer service, or advertising. In addition, Telma may share your personal information with other Telma entities, or in the event of a merger, acquisition, sale of company assets, or transition of service to another provider. Telma may share your personal data with other jurisdictions that have data protection laws other than those established in Tanzania, by written order of a competent judicial authority or where permitted in compliance with the law.

The use and communication of personal data will be made through physical and electronic security systems and reasonable procedures to prevent alteration, accidental or unlawful destruction, loss, or unauthorized processing or access to your personal data.

Applicable law and jurisdiction

The interpretation, use, scope and termination of this Notice is governed by the laws of the United Republic of Tanzania and, in case of dispute, the courts of Tanzania will have exclusive jurisdiction.

How long your personal data will be stored?

Telma stores your personal data only for as long as is necessary to fulfill the purpose for which it was collected, and as required by applicable local regulations. The data will be kept in accordance with the authorization granted for its management, unless the holder revokes it.