Privacy policy and general terms and conditions

PRIVACY POLICY

Company : Expatman S.A.R.L.U
Effective date : 1st January 2023
Version : 2.0

PREAMBLE

Expatman S.A.R.L.U ("Expatman", "we", "us", "our") is committed to protecting the privacy and security of the personal data of its users ("you", "your"). This Privacy Policy transparently describes our practices regarding the collection, use, storage, sharing and protection of your Personal Data in the context of the use of our web and mobile platform accessible at the following address www.expatman.us (the "Platform") and the services offered on it (the "Services").

ARTICLE 1: DEFINITIONS

• Personal data : Any information relating to an identified or identifiable natural person.
• Treatment : Any operation or all together operations whether or not carried out using automated processes and applied to Personal Data (collection, recording, etc.), organisation, conservation, etc.).
• Data controller : Expatman S.A.R.L.U, which determines the purposes and means of the Processing of your Personal Data.
• Subcontractor : Any entity that processes Personal Data on behalf of the Data Controller.

ARTICLE 2: LEGAL BASIS FOR PROCESSING

We will only process your Personal Data if at least one of the following conditions is met: a) Performance of a contract : The processing is necessary for the performance of the General Terms and Conditions of Use binding us to you or for the performance of pre-contractual measures taken at your request. b) Consent : You have given your free, specific, informed and unequivocal consent to the processing of your Personal Data for one or more specific purposes.

c) Legal obligation : Processing is necessary to comply with a legal obligation to which we are subject (e.g. accounting obligations, transmission of information to government authorities).

d) Legitimate interest : Processing is necessary for the purposes of our legitimate interests, such as improving our Services or preventing fraud, unless your interests or fundamental rights and freedoms prevail.

ARTICLE 3: PERSONAL DATA COLLECTED

As part of our Services, we collect the following categories of data:

• Identification details : Surname, first name, date and place of birth, nationality, passport photograph, signature.
• Contact details Postal address, e-mail address, telephone number.
• Professional information : Profession, employer, position, curriculum vitae, qualifications.
• Data from official documents : Passport number, date of issue and expiry, previous visas, work permits and any other information contained in the documents required for administrative procedures.
• Financial data : Payment card information, bank details, billing history. This data is processed by our secure payment service providers and we only have limited access to it.
• Connection and browsing data : IP address, browser type, connection logs, data relating to use of the Platform (cookies and other tracers).

ARTICLE 4: PURPOSES OF PROCESSING

Your Personal Data is collected and processed for the following purposes:

1. Provision of Services : Preparing, submitting and following up your applications for visas, work permits and other administrative documents with the relevant authorities in the DRC.
2. Customer relationship management : Communicate with you on the progress of your files, respond to your requests, send invoices and manage payments.
3. Improving the platform : To analyse the use of our Services in order to improve their ergonomics, performance and security.
4. Legal and regulatory compliance : Ensuring that client companies and their expatriates comply with Congolese immigration and labour legislation.
5. Marketing (with consent) : To inform you of our new offers or training courses, subject to your prior consent.

ARTICLE 5: RECIPIENTS AND SHARING OF DATA

We do not sell or rent your Personal Data. It is only shared with the following recipients, and only when it is strictly necessary:

• Government authorities in the DRC : Immigration services (DGM), Ministry of Labour, and any other public authority responsible for processing your applications.
• Subcontractors and service providers : Web hosting providers, payment service providers, data analysis tools and other technical partners, who are contractually obliged to guarantee the confidentiality and security of your data.
• External advice : Lawyers, accountants or auditors as part of their statutory duties.

ARTICLE 6: INTERNATIONAL DATA TRANSFERS

Our servers may be located in jurisdictions other than the DRC. By using our Services, you consent to the transfer of your Personal Data to these jurisdictions. We undertake to ensure that such transfers are governed by appropriate protection mechanisms (such as standard contractual clauses) guaranteeing an adequate level of protection for your data.

ARTICLE 7: RETENTION PERIOD

Your Personal Data is kept for no longer than is necessary for the purposes for which it is processed.

• Active files : Kept for as long as your request is being processed.
• Archives : Once your file has been closed, the data is archived for the duration of the legal statute of limitations applicable in the DRC (particularly in commercial and tax matters) before being permanently deleted or made anonymous.

ARTICLE 8: DATA SECURITY

We implement appropriate technical and organisational security measures (encryption, access control, pseudonymisation, etc.) to protect your Personal Data against destruction, loss, alteration, unauthorised disclosure or unauthorised access. However, as no method of transmission over the Internet is infallible, we cannot guarantee absolute security.

ARTICLE 9: YOUR RIGHTS

In accordance with the applicable regulations, you have the following rights:

• Right of access : Obtain confirmation that your data is being processed and, if necessary, access it.
• Right of rectification : Request correction of inaccurate or incomplete information.
• Right to erasure ("right to be forgotten"): Request the deletion of your data, subject to our legal retention obligations.
• Right to restrict processing : Obtain the restriction of processing in certain circumstances.
• Right to portability : Receive your data in a structured, commonly used and machine-readable format and transmit it to another data controller.
• Right to object : Oppose the processing of your data on legitimate grounds.

To exercise these rights, please contact us contact us at privacy@expatman.us.

ARTICLE 10: MODIFICATIONS POLICY

We reserve the right to modify this Privacy Policy at any time. Any modification you will be notified by e-mail or via a visible announcement on the Platform.

GENERAL TERMS AND CONDITIONS OF USE (GTD)

Company : Expatman S.A.R.L.U
Effective date : 1st January 2023
Version : 2.0

ARTICLE 1: PURPOSE AND ACCEPTANCE

These General Terms and Conditions of Use (the "GTCU") govern access to and use of the Platform. www.expatman.us and the Services offered by Expatman S.A.R.L.U. Access to and use of the Platform implies full acceptance of these GCU. IF YOU DO NOT ACCEPT THESE CONDITIONS, YOU MUST NOT ACCESS THE PLATFORM OR USE OUR SERVICES.

ARTICLE 2: DESCRIPTION OF SERVICES

Expatman is a service company acting as an agent and facilitator. Our services consist of assistance, preparation, submission and follow-up of administrative procedures relating to immigration and employment of foreigners in the DRC.

IMPORTANT NOTICE : Expatman is neither a government agency nor a law firm. We have no power of decision over the outcome of applications submitted. The final decision to grant or refuse a visa, work permit or any other document is at the sole and sovereign discretion of the relevant Congolese authorities.

ARTICLE 3: OBLIGATIONS OF THE USER

By using our Services, you agree to: a) Provide true, accurate, complete and up-to-date information and documents. Any false declaration is your sole responsibility and may result in the rejection of your application and the termination of your account. b) Maintain the confidentiality of your login details and be solely responsible for any activity carried out from your account. c) Use the Platform in accordance with the laws in force in the DRC and not to infringe the rights of third parties or public order. d) Cooperate fully with Expatman and respond promptly to any request for additional information required to process your application.

ARTICLE 4: INTELLECTUAL PROPERTY

All the elements making up the Platform (texts, images, logos, software, structure, database) are the exclusive property of Expatman S.A.R.L.U. or are subject to a licence. Any reproduction, representation or distribution, in whole or in part, without prior written authorisation, is strictly prohibited and constitutes an infringement of copyright.

ARTICLE 5: PRICES AND PAYMENT

The rates for our Services are indicated on the Platform or in a personalised quote. They include our service fees and may, if expressly indicated, include government charges. Payment is due according to the agreed terms. In the event of non-payment, Expatman reserves the right to suspend the provision of its Services. Unless otherwise stated, Expatman's fees are non-refundable, including in the event of rejection of the application by the authorities.

ARTICLE 6: LIMITATION OF LIABILITY

Expatman is subject to an obligation of means and not of result. We cannot be held liable in the following cases:

• Delays or rejections of files attributable to DRC administrations.
• Damaging consequences resulting from erroneous or incomplete information provided by the User.
• Changes to legislation or administrative procedures by the Congolese authorities.
• Loss of documents by postal services or administrations.
• Force majeure, as defined in Article 7.

Under no circumstances may Expatman's liability exceed the total amount of the service fees paid by the User for the service in question.

ARTICLE 7: FORCE MAJEURE

Expatman cannot be held responsible if the non-execution or delay of the order is due to a fault on the part of the customer. in the performance of any of its obligations described in these GCU is due to force majeure. Force majeure refers to any event external, unforeseeable and irresistible (e.g. strikes, wars, natural disasters, pandemics, unforeseen government decisions, telecommunications failures).

ARTICLE 8: TERMINATION

Expatman reserves the right to suspend or terminate your access to the Platform and the Services, without notice or compensation, in the event of a serious breach by you of any of the obligations of these GTC, in particular in the event of fraud or misrepresentation.

ARTICLE 9: APPLICABLE LAW AND JURISDICTION

These GCU are governed by the laws of the Democratic Republic of Congo. Any dispute relating to their interpretation and/or performance shall fall within the exclusive jurisdiction of the courts of Kolwezi, notwithstanding the plurality of defendants or the introduction of third parties.

ARTICLE 10: CONTACT

If you have any questions about these GTC, please contact us at the following e-mail address: legal@expatman.us.