GROUPE 41DEVS — Parcel A, Maison Armand Brice KOM’KO, Gbèdjromédé, 6th District, Cotonou, Littoral — BENIN. Tax ID (IFU): 3202279087232. Email: legal@41devs.com.
Important note: for data processed as part of verification flows, the client institution requesting the verification is the data controller; GROUPE 41DEVS then acts as a processor, under the instructions and the agreement concluded with that institution. For www.nayaid.com and account management, GROUPE 41DEVS is the data controller.
2.1 Data provided by the user:
- Site visitor: full name, company, work email and message content (contact form);
- Client institution: identity of representatives, professional contact details, verification documents (KYB: legal registration documents, licences);
- Team member: full name, email address, phone number, assigned role;
- End user (as part of a verification): identity document and extracted data (name, date of birth, number…), face images and biometric data, supporting and complementary documents requested by the institution, proof of consent and, where applicable, electronic signature.
When you use the platform, Naya ID automatically collects:
- IP address and approximate geolocation data;
- Browser type and operating system;
- Pages visited, session duration and actions performed;
- Connection data and activity logs;
- For institution invoicing: bank details and invoicing history. Naya ID does not store full payment data on its own servers; that data is processed by licensed payment providers.
Your data is used for the following purposes:
- Account creation and management — performance of the contract;
- Running the identity verifications requested by client institutions (KYC/KYB) — performance of the contract and the institutions’ legal obligations;
- Building the evidence file and logging every check — legal obligation / performance of the contract;
- Handling contact and demo requests — pre-contractual measures;
- Fraud prevention and platform security — legitimate interest;
- Improving the platform — legitimate interest;
- Marketing communication — consent;
- Compliance with legal obligations — legal obligation.
- Biometric data is sensitive data: it is processed only within the verification flow, with the explicit consent of the person concerned, captured and kept with the case file.
Your data is kept for the following periods:
- Active account data: for the duration of the contractual relationship;
- Deleted account data: up to 3 years after deletion, to meet possible legal obligations or disputes;
- Verification files: for the period defined by the client institution in line with its regulatory obligations (AML/CFT in particular), configurable per country;
- Institution KYB documents: 5 years after the end of the contractual relationship;
- Invoicing data: 10 years, in line with the accounting and tax obligations applicable in Benin;
- Connection logs: rolling 12 months.
- When these periods expire, data is securely deleted or anonymised.
Naya ID never sells, rents or transfers your personal data to third parties for commercial purposes. Your data may be shared only in the following cases:
- Service providers: hosting, email delivery, payment. These providers act as processors and are contractually bound to process your data in strict compliance with this policy;
- Client institutions: the results and file of a verification are shared only with the institution that requested it, for the sole purpose set out in the agreement;
- Competent authorities: where disclosure is required by law or by a judicial or administrative decision applicable in the covered countries.
Naya ID implements appropriate technical and organisational measures to protect your data against unauthorised access, loss, destruction or alteration, in particular:
- Encryption in transit (HTTPS/TLS) and at rest (AES-256);
- Password hashing;
- Internal access control based on least privilege, with named and logged access;
- Per-institution data isolation;
- Regular security audits.
- In the event of a data breach likely to create a risk to your rights and freedoms, Naya ID undertakes to inform the persons and institutions concerned as soon as possible, in line with the applicable legal obligations.
Naya ID operates in several West African countries. Data is hosted in a secure cloud; the hosting region is specified in the contract.
Where processing involves several covered countries, it is governed by appropriate contractual safeguards and carried out in environments providing an adequate level of protection.
Under the applicable laws — in particular Benin’s personal data protection law and the equivalent regulations of the covered countries — you have the following rights:
- Right of access: confirmation that your data is processed, and a copy of it;
- Right to rectification: correction of inaccurate or incomplete data;
- Right to erasure: deletion of your data, subject to legal retention obligations;
- Right to restriction: temporary suspension of the processing;
- Right to object: to the processing of your data for marketing purposes;
- Right to portability: receiving your data in a structured, machine-readable format;
- Right to withdraw your consent at any time, for processing based on consent.
- To exercise your rights: write to legal@41devs.com. We reply within 30 working days; proof of identity may be requested. If your data was processed at the request of a client institution, your request may be relayed to that institution as data controller. You may also lodge a complaint with Benin’s data protection authority (APDP) or the competent authority of your country.
Verification flows are run at the request of client institutions; the required age depends on the product or service concerned and the applicable law. Naya ID does not knowingly collect data about minors outside this framework. If you believe a minor’s data has been collected without a valid basis, contact legal@41devs.com so we can delete it.
The www.nayaid.com site uses no advertising cookies. Strictly functional cookies are set:
- naya_lang: remembers the display language you chose;
- naya_cgu: remembers your acceptance of the terms of use, so we don’t ask again on every visit;
- naya_analytics: remembers your choice about audience measurement.
- Audience measurement: with your consent, we use Google Analytics 4 (Google Ireland Ltd) to understand page traffic. _ga cookies are only set after you accept in the banner; without consent, no identifier is stored. IP addresses are anonymised. You can withdraw consent at any time by deleting the naya_analytics cookie in your browser.
- You can manage your preferences through your browser settings; declining some cookies may affect how the site works.
The platform may contain links to third-party sites or services. Naya ID is not responsible for the privacy practices of these third parties and encourages you to review their respective policies.
This policy may be updated at any time; in the event of a significant change, Naya ID will inform you by email or by a notice on the site. The current version is always available on this page, with its last-updated date.
This policy is governed by the laws of Benin, in particular Law No. 2009-09 of 22 May 2009 on the protection of personal data in the Republic of Benin and the implementing texts issued by the Personal Data Protection Authority (APDP). For users residing in the other covered countries, the equivalent local regulations are also complied with to the extent applicable.
For any question about this policy or to exercise your rights:
GROUPE 41DEVS — Data Protection Officer. Email: legal@41devs.com. Address: Parcel A, Maison Armand Brice KOM’KO, Gbèdjromédé, 6th District, Cotonou, Littoral — BENIN.
