Regulations on Digital Services, Platform Transparency, and User Information 

Job229, as a digital platform for posting job listings, facilitating professional connections, providing employability support services, and, where applicable, related services, reaffirms its firm commitment to ensuring a fair, transparent, secure, and legally compliant digital environment for the benefit of all its users, advertisers, recruiters, candidates, partners, and competent legal authorities. This commitment is in accordance with the principles set forth in the EU Digital Services Act, the African framework for cybersecurity and personal data protection, and the Digital Code of the Republic of Benin.

The purpose of this page is to provide clear, accessible, and enforceable information all Job229 users about the platform’s operating rules, reporting mechanisms, procedures applicable in the event of illegal or disputed content, the transparency obligations implemented by the publisher, as well as the safeguards provided regarding the protection of the rights, data, and legitimate interests of data subjects. Specifically, the DSA imposes on online platforms increased obligations of transparency, due diligence, and accountability, particularly when their services are accessible within the European Union market.

Legal Basis

In the event that all or part of Job229’s services are offered, accessible, or directed to recipients located within the European Union, the platform intends to comply with the requirements of the Digital Services Act, which aims to ensure a safer digital space, strengthen platforms’ obligations regarding the handling of illegal content, and improve the protection of users’ fundamental rights. The DSA is now one of the central pieces of legislation in the European framework applicable to online platforms and intermediary services.

At the African level, Job229 recognizes the transformative impact of the African Union Convention on Cybersecurity and the Protection of Personal Data—known as the Malabo Convention—which was adopted in 2014 and entered into force on June 8, 2023. This convention aims to encourage African states to establish national legal frameworks that ensure the protection of privacy, personal data, and the security of digital communications.

At the national level in Benin, Job229 notes that Law No. 2017-20 of April 20, 2018, establishing the Digital Code of the Republic of Benin, governs, among other things, electronic communications, e-commerce, cybersecurity, cybercrime, and the protection of personal data. The purpose of this Code is to ensure that information technology remains at the service of citizens and that no data processing infringes upon human dignity, human rights, privacy, or individual and public freedoms.

Principle of Transparency

Job229 is committed to providing its users, in a clear, consistent, and easily accessible manner, with all material information regarding the platform’s operation, content publication rules, terms of service access, procedures for handling reports, measures that may affect a user account, as well as the legal, technical, and commercial terms governing the use of the digital services offered. This requirement for transparency is at the heart of the DSA and is also consistent with the principles of accountability, fairness, and information set forth in the African and Beninese regulatory frameworks applicable to the digital sector.

As such, Job229 ensures that its contractual, informational, and regulatory documents—including the general terms of use, terms of service, privacy policies, complaint procedures, publication rules, payment terms, refund policies, security rules, and moderation procedures—are drafted in a precise, up-to-date, and legally consistent manner.

User Responsibilities

All Job229 users are required to use the platform in a lawful, fair, responsible, and non-abusive manner. As such, users are specifically prohibited from publishing, transmitting, reposting, promoting, or maintaining online any listings that are fictitious, misleading, unlawful, discriminatory, defamatory, fraudulent, impersonating, infringing on the rights of others, or contrary to public order, public decency, or the applicable laws in the relevant jurisdictions. The DSA is based precisely on the idea that what is unlawful offline cannot become lawful online.

Recruiters, companies, candidates, and users—whether professional or non-professional—also agree to provide accurate, complete, and truthful information when creating an account, posting a job listing, submitting a profile, or using the platform’s 

payment, the submission of documents, or interaction with the services offered by Job229. In the event of inaccurate, misleading, incomplete, or fraudulent information, Job229 may take any appropriate, proportionate, and legally justified measures.

Reporting Illegal Content

Any person who believes that content, an advertisement, a job posting, a profile, a message, a document, or any other item accessible on Job229 is unlawful, fraudulent, misleading, or clearly contrary to applicable rules may request that it be reported or removed using the tools provided on the platform. The DSA requires platforms to implement mechanisms for reporting illegal content and for the prompt handling of such reports.

The report must be sufficiently substantiated and, to the extent possible, identify the content in question, the nature of the alleged infringement, and any contextual information relevant to the review of the request. Job229 reserves the right to request additional information when necessary to assess the report, determine the legal classification of the alleged facts, or protect the rights of the defense.

Moderation, Restriction, or Suspension Measures

In the event of a violation of applicable laws, the Terms of Use, posting rules, security obligations, or the platform’s integrity requirements, Job229 may, without prejudice to any further action, limit the visibility of content, suspend its publication, remove it, restrict certain features, temporarily suspend an account, or terminate it when circumstances warrant. Such measures are consistent with the standards of responsibility and security expected of digital platforms.

When the nature of the measure and the applicable legal framework so require, Job229 will endeavor to notify the affected user of the main reasons for the decision, subject to requirements related to security, fraud prevention, the protection of third parties, or compliance with legal obligations. The DSA sets forth specific requirements regarding justification and notification for certain moderation or restriction decisions.

Claims and Disputes

Any user who believes that a decision to remove, restrict, suspend, delist, or close an account was made incorrectly or disproportionately may file a complaint with Job229 within a reasonable period of time after becoming aware of the disputed action. The DSA specifically provides for an internal complaint-handling mechanism for decisions affecting users.

The complaint must be submitted in writing, set forth the facts, identify the contested decision, and be accompanied, where applicable, by any documents relevant to its review. Job229 will review the complaint with due diligence, impartiality, and transparency, without prejudice to any external remedies that may be available under applicable law.

Personal Data Protection

Job229 points out that compliance with regulations governing digital services cannot be separated from compliance with obligations regarding the protection of personal data. Benin’s Digital Code stipulates that all processing must respect the fundamental rights and freedoms of natural persons, regardless of their nationality or place of residence, and places the Personal Data Protection Authority at the center of the oversight framework.

Consequently, Job229 is committed to collecting only the data strictly necessary for the purposes pursued, to processing it in a fair, lawful, transparent, and secure manner, to limiting access to it solely to authorized individuals, to not retaining it beyond the required periods, and to not misusing it for purposes other than its original intent. The Beninese Digital Code specifically emphasizes the limitation on data retention and the obligation to implement appropriate technical and organizational measures to protect data against loss, alteration, disclosure, or unauthorized access.

Job229 further states that its users’ personal data will not be sold, transferred, or marketed to third parties except in cases strictly necessary for the provision of the service, compliance with a legal obligation, the technical security of the platform, or the involvement of duly regulated service providers. This position is consistent with the principles of purpose limitation, proportionality, fairness, and privacy protection that underpin the regulatory frameworks in Benin, Africa, and Europe.

Digital Security and Institutional Cooperation

Job229 is committed to implementing reasonable, appropriate, and proportionate logical, technical, and organizational security measures to ensure the integrity of the platform, the confidentiality of communications, the protection of user accounts, the prevention of intrusions, the detection of abnormal usage, and the management of risks associated with the digital services it operates. The Beninese Digital Code, like regional African and European instruments, places a strong emphasis on cybersecurity and data processing security.

When a competent administrative, judicial, or regulatory authority—including a European supervisory authority, a Beninese national authority, the APDP, or any competent body in the fields of digital services, cybersecurity, data protection, or law enforcement, submits a legally valid request to Job229, the platform may respond to it in accordance with the terms of applicable law, subject to respect for fundamental rights, professional confidentiality, and the procedural safeguards afforded to the individuals concerned.

Ongoing Information

Job229 reserves the right to update this page to reflect any legislative, regulatory, jurisprudential, technical, or operational changes affecting digital services, user protection, platform liability, transparency of information, or the processing of personal data. This regular updating is part of the requirement for ongoing compliance imposed on digital entities operating in diverse legal environments.

Job229 provides users with a dedicated point of contact for any compliance questions and reports regarding job postings published on the platform. Reports and complaints are reviewed within a reasonable timeframe, based on a documented internal procedure that ensures the traceability of the process, the review of submitted supporting documents, and, when necessary, the opportunity for the affected individual to challenge the decision made. Listings may be subject to preventive or corrective moderation based on criteria of legality, authenticity, security, and compliance with JOB229’s posting rules. Any listing that is fraudulent, misleading, abusive, or likely to harm users may be rejected, suspended, or removed. 

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