This is the privacy policy for the African Venture Philanthropy Alliance (AVPA, we, us, or similar).
- OUR COMMITMENT TO YOUR PRIVACY
1.1 AVPA respects your privacy and is committed to protecting your personal data. This privacy policy explains how we use and look after your personal data when you visit our website (https://old.avpa.africa/) and use the Deal Share Platform (the Platform) that AVPA provides via the website or generally in your dealings with us. This privacy policy applies to all personal data collected by us or provided by you on our website or through any other channel.
1.2 AVPA is the data controller in respect of the information that you provide or that AVPA collects. AVPA’s address is: P.O. Box 764-00606, Nairobi, Kenya. If you have any questions about this policy, please send an email to info@avpa.africa and we will respond as soon as we can. - DATA WE COLLECT
2.1 Personal data is any information relating to an identifiable, living, natural person, and where applicable, an identifiable, existing juristic person. To enable you use the Platform or our services, we must process certain personal data about you. We also process information about you if you view or otherwise use the website. If we invite you to create an AVPA profile, you will be able to use the Platform to create an investor profile or create a capital seeker’s page, and connect with investors or contacts in relation to investment opportunities. You are able to choose the level of personal data, if any, that you share with other users of the website and Platform. If you use our other services, outside the website or the Platform, you will be able to choose the level of personal data, if any, that you share with us. However, you may be required to share personal information with us in order to use our services – for example, providing your email address in order to receive newsletters.
2.2 The information collected through our website and for the purposes of the Platform includes:
2.2.1 Information that you and other users of the Platform provide: We collect the content and other information you provide when you create an AVPA profile and use the Platform, including when you input information onto the Platform, and message or communicate with others.
2.2.1.1 Contact information: When you create a profile, you must provide your name, email address, and choose a username and password. This is the only personal data we require in order to create a profile on the Platform. You can choose whether to make your contact information available on the Platform.
2.2.1.2 Additional information in your profile: You may choose to provide additional personal data about yourself and your social investment vehicle, such as your city, country, areas of expertise, links to external profiles (for example, LinkedIn or Twitter), a photograph and a brief biographical statement. This data is not required in order to use the Platform and you may update or delete it at any time and adjust your settings to indicate what information you want to make public on the Platform.
2.2.1.3 Your usage: We may collect information about how you use the Platform, such as the deals that you view and the other users that you engage with.
2.2.1.4 Capital seekers’ and deal information: When you create a capital seeker’s or deal page, you will need to input information including the organisation or venture name, relevant sectors, markets, country focus, stage of the company or organisation, staffing, type of clients and customers the organisation serves, current financial needs, program participation and status updates. You must ensure that you have a legal basis under applicable data protection laws to upload any personal data of third parties, such as employees, directors, executives, and other investors of or in the organisation or venture, including obtaining any necessary consents to upload this data.
2.2.2 Information about your device: This includes your internet protocol (IP) address (a numerical code to identify your device that can provide information about the country, region or city where you are based), your login data, browser type and version, operating system and platform, and other technology on the devices you use to access our website.
2.2.3 We do not collect any “special” personal data: We do not collect any “special” or “sensitive” personal data, such as information about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, family details, information about your health or biometric data, unless you choose to provide that information to us. - THE PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
We use the personal data we collect about you, subject to your choices on what information to make public on the Platform:
3.1 to enable you to connect you to other investors and allow you to post information about capital-seekers;
3.2 for internal administrative purposes, linked to the provision of services to you, including if we choose to make you aware of any changes to the website, the Platform or the Terms of Service;
3.3 to send communications, such as newsletters, periodic updates with information about Platform activity (e.g. new deals and member profiles), tailored to your interests and based on your preferences, invitations to events, or marketing material, but only when we have your express permission or if we are permitted by applicable law to do so;
3.4 to allow you to sign in to the Platform, remember the settings you have chosen, and recognise you when you sign in on different devices;
3.5 to improve our communications, by allowing us to see if you have viewed newsletters and other materials that we send you;
3.6 for statistical purposes including to analyse the performance of the website and Platform and to understand how users interact with them;
3.7 to respond to any queries and to resolve complaints; and
3.8 for security and fraud prevention, and to ensure that the website and Platform is safe and secure and used in line with the Terms of Service. - YOUR RIGHTS REGARDING PERSONAL DATA
4.1 Under applicable law, your rights regarding your personal data include the rights:
4.1.1 to be informed of the use to which your personal data is being put;
4.1.2 to access your personal data;
4.1.3 to request rectification, restriction, destruction, transfer or deletion of, your personal data that we have collected;
4.1.4 to object to the processing of your personal data;
4.1.5 to withdraw consent at any time where we are relying on consent to process your personal data;
4.1.6 to lay a complaint with the Office of the Data Commissioner in Kenya or any other appropriate body in terms of applicable data privacy law; and
4.1.7 (subject to certain exceptions) to be notified that your personal data has been accessed or acquired by an unauthorised person.
4.2 If you want to exercise any of these rights, please contact us using the contact details given below. - WHO DO WE SHARE YOUR PERSONAL DATA WITH?
5.1 When you create an investor profile or capital seeker’s page, you choose what information you want to make available to other users of the Platform. For example, you can decide that you want to make additional information about yourself available on the Platform such as a link to your LinkedIn or Twitter account and any biographical details.
5.2 We may share your personal data with our third-party service providers to enable us to provide services via the Platform to you. We require all third parties to respect the security of your personal data and to treat it in accordance with this privacy policy. We do not allow our third-parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5.3 We may share your personal data with service providers who assist us in maintaining the website, marketing the Platform or administering any events that we hold.
5.4 We will get your express, opt-in consent before we share your personal data with any third party for marketing purposes.
5.5 We may provide your personal data to any law enforcement agency, court, regulator, government authority or other organization if we are required by law to do so, or otherwise to protect our rights or any third party’s rights.
5.6 If the ownership or control of AVPA, the website or Platform or any part of them changes, we may transfer your information to the new owner. - INTERNATIONAL TRANSFERS
6.1 Your personal data may be transferred out of the Republic of Kenya. When such transfer is necessary and for your benefit, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented by, for example, concluding contracts with any recipients that provide for the same types of protections as provided for in this privacy policy. By accepting this policy, you are providing us with your express consent to transfer your personal data as laid out above. We do not transfer sensitive personal data outside of Kenya. - CONTROL OF YOUR PERSONAL DATA
7.1 Personal information that you provide via the website or Platform
7.1.1 You can review and change the information on your profile that is visible to other users or only to you in the “Settings” tab of your AVPA account. Certain information, such as your contact details, will never be visible to other users. If other users wish to contact you, they may do so by populating a form on the website or Platform and we will send you a message to your email address. You may choose to respond to the user and share your contact details with that user. You can also update, delete or upload new information.
7.1.2 You may also update your email communication preferences in the “Settings” tab of your AVPA account. This includes opting out of all email communications from us. If you choose to delete your AVPA account, we will delete all your user profile data and all pages and content that you have posted via your account, including any capital-seekers pages and other information made available via the website or the Platform. We will retain your contact and related details to manage our relationship with you (unless you specifically ask us to delete it) and to satisfy any legal, regulatory, tax, accounting or reporting requirements, but your information will not be available on the Platform.
7.2 Other personal information that we collect and store
7.2.1 You may specifically ask us to delete any information that you provide to us when signing up for our services outside the website and the Platform. - COOKIES
8.1 AVPA uses cookies to distinguish you from other users of the website or Platform. This helps us to provide you with a good experience when you use the website or Platform and also allows us to improve the website, Platform and the services we provide.
8.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer’s hard drive.
8.3 AVPA may share information collected by cookies with third party service providers for the purpose of tracking and collecting analytics in relation to your website or Platform usage. The tracking and collection of such analytics will be conducted in accordance with applicable laws.
8.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the website or Platform. - SECURING YOUR PERSONAL DATA
9.1 We have put in place appropriate security measures, including technical and organisational measures, to prevent your personal data from being accidentally lost, used, accessed or processed in an unauthorised way, altered or disclosed. However, you are responsible for choosing a secure password and keeping your password confidential. Please do not share your password with anyone.
9.2 Unfortunately, no security measures can be guaranteed to be completely secure. Accordingly, although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through our website or otherwise provided to us, and you transmit or provide any personal data to us at your own risk. - DATA STORAGE PERIOD
10.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purpose for which we collected it. We will not retain your personal data for a period that exceeds the period allowed by applicable law except where you have consented to the retention, there has been a complaint, or there is a prospect of litigation with respect to your use of the website or the Platform.
10.2 We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10.3 In certain circumstances you can ask us to delete your data: see Your Rights Regarding Personal Data above. - CHANGES TO THIS PRIVACY POLICY
We regularly review our privacy policy. We will let you know, on the website and Platform or by email, if we intend to make material changes to this privacy policy and allow you an opportunity to review the policy before the changes take effect and for you to choose whether to continue using the website and Platform. Historic versions of this privacy policy can be obtained by contacting us. - GET IN TOUCH
If you have any questions about this privacy policy or our privacy practices, please contact us at [info@avpa.africa].
Last updated on: [22 October 2020].
