Legal
Privacy policy
HOEX LLC, together with its affiliates ("Gytev", "we", "our" or "us"), is the controller of the Personal Data described in this policy. We are headquartered in Cotonou, Republic of Benin, and we work with users, partners and service providers in multiple countries. This policy is designed to apply across the jurisdictions where we operate and where our users are located. It reflects the core principles of Benin's Digital Code (Law No. 2017-20 of 20 April 2018, as amended) and the role of Benin's Personal Data Protection Authority (APDP), as well as, where applicable, the EU/UK General Data Protection Regulation, the Swiss Federal Act on Data Protection, the California Consumer Privacy Act as amended by the CPRA, and other data protection laws. Where local law gives you stronger rights or imposes stricter obligations, those rules prevail.
1. Personal Data we collect
"Personal Data" means any information relating to an identified or identifiable person. We collect Personal Data in the following ways.
Information you provide
- Contact and account details: your name, email address, organisation, role, country, and any account credentials or preferences you create.
- Communications: the content of messages you send through our forms, email, newsletter, support channels, events, or recruitment processes.
- Content and inputs: information, files or instructions you submit when using our Services, including when products under development become available.
- Preferences and consent records: your marketing choices, cookie settings, and records of the consents you give or withdraw.
Information collected automatically
- Log and usage data: IP address, browser type and settings, device type, operating system, pages viewed, actions taken, referring pages, timestamps, and error logs.
- Approximate location: we may infer a general location from your IP address for security, fraud prevention, analytics, and to present relevant content. We do not use IP addresses to identify your precise location.
- Cookies and similar technologies: identifiers and preferences stored through cookies, pixels, local storage, and similar technologies, as described in section 3.
Information from other sources
We may receive information from service providers, security and fraud-prevention partners, publicly available sources, and partners that help us understand how our Services are discovered and used. We do not intentionally collect special categories of Personal Data unless this is necessary, lawful, and explained to you at the point of collection.
2. How we use Personal Data and our legal bases
We use Personal Data to:
- provide, operate, maintain, and secure our Services, including this website, our public content API, and our developer resources;
- respond to requests, questions, applications, and support messages;
- send service messages and, where permitted, information about our work, events, and products;
- understand how our Services are used, improve them, and develop new features and research;
- prevent fraud, abuse, security incidents, and misuse of our systems;
- comply with legal obligations and protect the rights, safety, and property of our users, Gytev, and others;
- manage our business, including accounting, procurement, and corporate transactions.
Depending on where you live, we rely on one or more of the following legal bases: performance of a contract with you; our legitimate interests, provided they are not overridden by your rights; your consent; compliance with a legal obligation; and protection of vital interests. Where Benin law applies, we process Personal Data in accordance with the Digital Code and any prior formalities or authorisations required by the APDP.
We do not use Personal Data for decisions that produce legal or similarly significant effects based solely on automated processing without appropriate safeguards. We do not sell Personal Data for monetary consideration.
4. How we share Personal Data
We do not sell Personal Data for monetary consideration. We share Personal Data only as described below:
- Service providers and processors: hosting, cloud, security, analytics, communications, payment, support, and professional services providers that process data on our instructions and under contractual confidentiality and security obligations.
- Affiliates: entities that control, are controlled by, or are under common control with HOEX LLC, for the purposes described in this policy.
- Professional advisers: lawyers, auditors, insurers, and accountants where necessary for the operation and protection of our business.
- Authorities and legal processes: courts, regulators, law enforcement, and other public authorities where required by law or necessary to protect rights, safety, and security.
- Business transfers: in a merger, acquisition, financing, reorganisation, insolvency, or transfer of assets, Personal Data may be disclosed to counterparties and transferred to a successor, subject to appropriate protections.
- Parties you choose: when you direct us to share information or interact with a third-party service.
- Aggregated or de-identified information: we may share information that no longer identifies you, and we will not attempt to re-identify it except where the law requires.
Where we share Personal Data with a processor, we require it to protect the data and to use it only for the purposes we instruct.
5. International transfers
We are based in Benin and may process Personal Data in Benin and in other countries where we, our affiliates, or our service providers operate. Data protection laws in those countries may differ from the laws where you live.
When we transfer Personal Data internationally, we use appropriate safeguards. These may include an adequacy decision, standard contractual clauses, binding corporate rules where applicable, contractual protections, or your consent where the law permits. Under Benin law, transfers outside Benin may require prior authorisation from the APDP; we will obtain that authorisation where required.
You can contact us at privacy@gytev.com for more information about the safeguards that apply to a particular transfer.
6. Retention
We retain Personal Data only for as long as necessary for the purposes described in this policy, including providing the Services, maintaining business records, resolving disputes, preventing fraud and abuse, and complying with legal obligations.
Retention periods depend on the type of data, its sensitivity, the purpose of processing, your settings and requests, and applicable legal requirements. When data is no longer needed, we delete it or de-identify it. Some information may remain in backups or archival systems for a limited period and may be retained where the law requires or permits a longer period.
7. Security
We use technical, administrative, and organisational measures designed to protect Personal Data against loss, misuse, unauthorised access, disclosure, alteration, and destruction. These measures include access controls, secure configuration, monitoring, and incident-response procedures, and are adapted to the sensitivity of the data and the risks involved.
No internet transmission, storage system, or security measure is completely secure. You should take care when deciding what information to send to us. If we become aware of a breach that requires notification under applicable law, we will notify the relevant authorities and affected individuals as required.
8. Your rights and choices
Depending on where you live, you may have some or all of the following rights:
- access your Personal Data and information about how it is processed;
- correct inaccurate or incomplete Personal Data;
- request deletion of your Personal Data;
- restrict or object to certain processing;
- receive your Personal Data in a portable format;
- withdraw consent at any time where processing is based on consent;
- opt out of marketing communications;
- not be subject to a decision based solely on automated processing that produces legal or similarly significant effects, without appropriate safeguards;
- lodge a complaint with the APDP in Benin or with your local data protection authority.
You can exercise your rights by contacting privacy@gytev.com. We may need to verify your identity before acting on a request, and we may ask for information necessary to locate the relevant data. You may use an authorised agent where local law allows it. We will respond within the time required by applicable law and will not discriminate against you for exercising your rights.
9. Children
Our Services are not directed to children under 16, or a higher age where local law requires it. We do not knowingly collect Personal Data from children below the applicable age. If you believe that a child has provided Personal Data to us, contact privacy@gytev.com and we will investigate and delete the data where appropriate. Where local law permits a lower age with parental consent, we apply the conditions required by that law.
10. Data controller and contact
HOEX LLC, headquartered in Cotonou, Republic of Benin, is the controller responsible for the processing of Personal Data described in this policy.
For privacy questions, rights requests, or concerns, contact our Data Protection Officer at privacy@gytev.com. Where required by law, we will appoint and identify a representative in the relevant jurisdiction.
HOEX LLC
Cotonou, Republic of Benin
Attn: Data Protection Officer
privacy@gytev.com
11. Changes to this policy
We may update this policy to reflect changes in our Services, our practices, or the law. We will publish the updated version on this page and update the effective date. Where changes are material, we will provide additional notice as required by applicable law. The version published here is the version in force.
12. Jurisdiction-specific information
European Economic Area and United Kingdom
If you are in the EEA or the UK, the GDPR or UK GDPR applies. We process Personal Data on the legal bases described in section 2, and you can exercise the rights described in section 8. You may lodge a complaint with your local supervisory authority. International transfers are made using the safeguards described in section 5.
Benin
In Benin, personal data protection is governed in particular by Book V of the Digital Code (Law No. 2017-20 of 20 April 2018, as amended) and by the rules of the APDP. You may exercise your rights directly with us and may contact the APDP if you believe your data has been processed unlawfully. We will complete any prior formalities or authorisations required for our processing and transfers.
California
If you are a California resident, you may have rights under the CCPA as amended by the CPRA, including the right to know, delete, correct, and opt out of the sale or sharing of Personal Data, to limit the use of sensitive Personal Data, and to be free from discrimination for exercising those rights. We do not sell Personal Data for monetary consideration. To the extent our use of cookies or marketing partners constitutes "sharing" or a "sale" under California law, you can opt out by contacting privacy@gytev.com. Authorised agents may submit requests where permitted. We will verify requests as required by law.
Other jurisdictions
If another data protection law applies to you, we will honour the rights and obligations that law requires. This policy is a general description of our practices and does not limit rights granted by applicable law.