Privacy policy
This Privacy Policy was prepared by Empower Africa LLC, a limited liability company having its registered office at 133 East Warms Springs Rd. Las Vegas, Nevada and registered with the state of Nevada under the number E0576562018-5 (hereafter, the “Company”, “us“, “we” or “our“).
The Company offers a platform which connects companies, governments, and NGOs interested in doing business in and with Africa. Users of the Platform will be able to share information and opportunities related to Africa’s private sector. Users will also gain access to our member directory, which can be used to identify business opportunities and find partners for local implementation, project financing, and government coordination.
The Platform will be open to its users which have subscribed on the Platform and as such have a user account (hereafter, the “Users”). The Platform is available at the following url address [network.empowerafrica.com] The Company has an internal solution which enables the import and export of user lists and data, the management of content and events, the organization of emailing campaigns and opportunity research and sharing as well as the management of funds and contributions of any kind.
In this regard, as data controller, the Company is particularly aware and sensitive with regard to the respect of its Users privacy and personal data protection. This privacy policy describes the types of information we collect from you when you visit our website and/or mobile application (collectively, “Platform“), as well as how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. “You” means any adult user of the Platform.
If you are an individual located in the European Union (“EU Individual“), some additional terms and rights may apply to you, as detailed herein. Our registered office is 133 East Warms Springs Rd. Las Vegas, Nevada and our registration number is NV20181903389.
“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law.
ARTICLE 1. COLLECTED PERSONAL DATA, USES AND LEGAL BASIS
1.1 When subscribing to the Platform
When you subscribe to the Platform, you must create an individual profile and a company profile of the organization you represent. When you do so, we collect the following information you provide about yourself (“Profile Information“):
- Full Name
- Contact information of the business you represent
- Address
- Phone Numbers
- Employment History
- Education History
- Details of the organization you represent
- Trade Union Membership, if you elect to provide us with such information.
- Personal memberships in any business association
- Non-Personal Data such as any applicable Business License or membership of the business you represent in any business association
- Other information which you may provide to us or is available over the Internet.
Depending on your account settings, your Profile Information will be publicly available to all or certain types of additional users of the Platform. Please make sure that your sharing and/or visibility settings within your account are configured according to your preferences so that your information is only shared with the people with whom you would like it shared.
If you use the Platform by logging in through a third-party login/account registration service (such as Facebook, LinkedIn or Google), we also receive Personal Data about you as provided by such third-party service, as determined by such third party’s policies and your preferences.
How we use this data: (1) to create your user account and provide you with access to the Platform; (2) to respond to your inquiries and requests and to contact and communicate with you; (3) to prevent fraud, protect the security of and address any problems with the Platform; and (4) and to provide you with informational newsletters and promotional materials relating to our Platform and services, including with respect to projects and other opportunities operated by our partners and published on the Platform. For more information about our direct marketing activities and how you can control your preferences, please see the Direct Marketing section below.
Legal Basis: (1) We process this Personal Data for the purpose of providing you with the Platform, which is considered performance of a contract with you, including responding to your inquiries and requests and providing customer support, introducing you to potential business opportunities or introducing third parties to you as part of the services provided by the Platform.. (2) We process any Personal Data that you elect to provide relating to your trade union membership based on your explicit consent. You may withdraw your consent by contacting us at privacy@empowerafrica.com. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective. (3) When we process your Personal Data for the purposes of preventing fraud, protecting the security of and/or addressing problems with the Platform and/or for the purpose of providing you with informational newsletters and promotional materials relating to our services, such processing is based on our legitimate interests. Additional information regarding direct marketing is provided below.
1.2 Payment Data
If you make a purchase through the Platform, we and/or our service providers or subcontractors receive information related to such purchase, such as your credit or debit card number, bank account information or information regarding other payment methods you may use, as well as the date of purchase, purchase amount, name, email, billing or shipping address and in some cases your transaction history to authenticate you.
How we use this data: To process the payment for your purchase and for the purposes of fraud prevention.
Legal Basis: We process this Personal Data for the purpose of performance of a contract with you. Processing for the purposes of fraud prevention is based on our legitimate interest.
1.3 Contact Information
When you request information from us, or contact us for any other reason, we will collect any data you provide, such as your name, email address, phone number, company you represent and the content of your inquiry. When you sign up for newsletters, we collect your name, email address, phone number, and the company you represent.
How we use this data: To respond to your request or inquiry, to provide you with newsletters and for retargeting purposes, or for making business introductions as part of the services provided by the Platform.
Legal Basis: We process this Personal Data based on performance of a contract when we respond to your inquiry and provide you with newsletters. Processing your Personal Data for retargeting purposes is based on our legitimate interests. Additional information regarding direct marketing is provided below.
1.4 Information and Materials
You Upload to the Platform – If you elect to upload any information, documents, videos, pictures or other materials to the Platform, including in respect of the following, we will also collect such materials and any Personal Data and non-Personal Data therein:
- Individual profiles
- Company profiles
- Events, including, if you elect to submit such information, the location of such events.
- Company updates
- Marketing materials
- Employment opportunities
- Business opportunities
- Research materials
- Any other personal information which you provide to us.
How we use this data: To provide you with the Platform.
Legal Basis: We process this Personal Data for the purpose of performance of a contract with you for participating in the Platform.
1.5 Automatically Collected Data
When you visit the Platform, we automatically collect information about your computer or mobile device, including non-Personal Data such as your operating system and browser, and Personal Data such as device ID, as well as your browsing history and other information regarding your activity on the Platform, such as searches and download history. For more information about the cookies and similar technologies we use and how to adjust your preferences, please see the section “Cookies and Similar Technologies” below.
How we use this data: (1) to provide you with the Platform; (2) to review usage and operations, including in an aggregated non-specific analytical manner, develop new products or services and improve current content, products, and services; (3) to prevent fraud, protect the security of our Platform, and address any problems with the Platform; (4) to provide you with targeted offers and advertising related to our products and services and for making introductions related to potential business opportunities.
Legal Basis: We process this Personal Data for the purpose of providing you with the Platform, which is considered performance of a contract with you. We process this Personal Data for our legitimate interests to develop and improve our products and Services, review usage, perform analytics, prevent fraud, for our recordkeeping and protection of our legal rights and to market our own products and services. Additional information regarding direct marketing is provided below.
1.6 Special Categories of Data
In the course of providing our Platform to you, if you elect to provide us with such information when subscribing to the Platform or otherwise in connection with your individual or company profile, we also collect data relating to your political opinions, religious or philosophical beliefs, or trade union membership, which is subject to special protections under the law. We will only collect such data if you provide your consent.
How we use this data: To provide you with the Platform.
Legal Basis: We process this Personal Data based on your explicit consent. You may withdraw your consent by contacting us at privacy@empowerafrica.com. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
1.7 Additional Uses
Statistical Information
By analyzing all information we receive, including all information concerning users we may compile statistical information across a variety of platforms and users (“Statistical Information“). Statistical Information helps us understand trends and customer needs so that new products and services can be considered and so that existing products and services can be tailored to customer desires. Statistical Information is anonymous and aggregated and we will not link Statistical Information to any Personal Data. We may share such Statistical Information with our partners, without restriction, on commercial terms that we can determine in our sole discretion.
Analytics
We and/or our service providers or subcontractors, use analytics tools (“Tools“), including “Google Analytics” to collect information about the use of the Platform. Such Tools collect information such as how often users visit the Platform, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Platform. We use the information we get from the Tools to improve our Platform and Services. Google’s ability to use and share information collected by Google Analytics about your visits to the Platform is restricted by the Google Analytics Terms of Service located at http://www.google.com/analytics/terms/us.html and the Google Privacy Policy located at http://www.google.com/policies/privacy/.
Direct Marketing
As described above, we may use Personal Data to let you know about our products and Services that we believe will be of interest to you, including projects and other opportunities operated by our partners and published on the Platform. We may contact you by email, post, or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with respect to you. To protect privacy rights and to ensure you have control over how we manage marketing with you:
- We will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you.
- At any time you can change your preferences for the way in which you would like us to communicate with you, including how you receive details of latest offers or newsletters from us.
- You can ask us to stop sending email marketing by following the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact us at privacy@empowerafrica.com.
You can change the way your browser manages cookies by following the settings on your browser as explained below. If our marketing activities are based upon your consent, you may withdraw this consent at any time.
1.8 Cookie data
We and our service providers and subcontractors, use cookies and other tracking technologies when you visit the Platform.
A cookie is a message that, subject to your settings, is sent to your browser or device.
• A “session cookie” is temporary and will remain on your device until you leave the Platform.
• A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.
• First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.
• We may use the terms “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.
We use cookies and similar technologies for a number of reasons as specified below:
Type of Cookie | Why We Use These Cookies | Cookie |
Necessary | These cookies are necessary in order to allow the Platform to work correctly. They enable you to access the Platform, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled. | addevent_track_cookie user_ID remember_user_token admin_id first_user_experience search_path _alumni_connect_session |
Functionality | These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content. | cookie_consent cookie_eu_consented __stripe_sid __stripe_mid __stripe_orig_props cookie_check rmuc ts tsrce ui_experience x-pp-s PYPF enforce_policy id_token login_email last_linkedin_sync remember_backoffice_admin_token remember_user_token intercom-id-qvr789d3 |
Security | These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information. | user_ID admin_id |
Performance | These cookies can help us collect information to help us understand how you use our Platform, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Platform. | _ga _ga_thivebriteTracker |
Analytics | These cookies collect information regarding your activity on our Platform to help us learn more about which features are popular with our users and how our Platform can be improved. | _ga _gid |
ARTICLE 2. SHARING THE PERSONAL DATA WE COLLECT
We share your information, including Personal Data, as follows:
Service Providers, and Subcontractors
We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who have agreed to confidentiality restrictions and who use such information solely on our behalf in order to: (1) help us provide you with the Platform; (2) aid in their understanding of how users are using our Platform; (3) for the purpose of direct marketing (see above for more details).
Such service providers and subcontractors provide us with payment processing services, IT and system administration services, data backup, security, and storage services, data analysis, provide marketing services and assist in the operation of the Platform and services thereon.
Business Transfers
Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation) in such case, your Personal Data shall continue being subject to the provisions of this Privacy Policy.
Law Enforcement Related Disclosure
We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party’s rights, property or safety (including the enforcement this Privacy Policy); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.
Legal Uses
We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.
ARTICLE 3. INTERNATIONAL TRANSFER
We use subcontractors and service providers who are located in countries other than your own and send them information we receive (including Personal Data). We conduct such international transfers for the purposes described above. We will ensure that these third parties will be subject to written agreements ensuring the same level of privacy and data protection as set forth in this Privacy Policy, including appropriate remedies in the event of the violation of your data protection rights in such third country.
Whenever we transfer your Personal Data to third parties based outside of the European Economic Area (“EEA“), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission.
- Where we use certain service providers not located in countries with an adequate level of protection as determined by the European Commission, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EEA.
- Where we use service providers based in the US, we may transfer Personal Data to them if they have been certified by the EU-US Privacy Shield, which requires them to provide similar protection to Personal Data shared between the EU and the US or any other arrangement which has been approved by the European Commission or other body having jurisdiction to approve such arrangement.
Please contact us at privacy@empowerafrica.com if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
ARTICLE 4. LENGTH OF DATA RETENTION
Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes. Retention by any of our processors may vary in accordance with the processor’s retention policy.
In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether those purposes can be achieved through other means, as well as applicable legal requirements.
Subject to your consent, we may retain your Profile Information and continue to make such information publicly available to other users following the termination of your account. You can revoke your consent at any time by sending us an email to privacy@empowerafrica.com.
Please contact us at privacy@empowerafrica.com if you would like details regarding the retention periods for different types of your Personal Data.
ARTICLE 5. EXERCISE OF THE USERS’ RIGHTS
Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to the Personal Data that we hold about you, as detailed below. We will investigate and attempt to resolve complaints and disputes and make every reasonable effort to honor your wish to exercise your rights as quickly as possible and, in any event, within the timescales provided by applicable data protection laws. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information and/or comply with any of your requests, as detailed below:
- Right of Access. You have a right to know what Personal Data we collect about you and, in some cases, to have such Personal Data communicated to you. Subject to applicable law, we may charge you with a fee. Please note that we may not be able to provide you with all the information you request, and, in such case, we will endeavor to explain to you why.
- Right to Data Portability. If the processing is based on your consent or performance of a contract with you and processing is being carried out by automated means, you may be entitled to (request that we) provide you or another party with a copy of the Personal Data you provided to us in a structured, commonly-used, and machine-readable format.
- Right to Correct Personal Data. Subject to the limitations in applicable law, you may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data.
- Deletion of Personal Data (“Right to Be Forgotten”). You have a right to request that we delete your Personal Data if either: (i) it is no longer needed for the purpose for which it was collected, (ii) our processing was based on your consent and you have withdrawn your consent, (iii) you have successfully exercised your Right to Object (see below), (iv) processing was unlawful, or (iv) we are required to erase it for compliance with a legal obligation. We cannot restore information once it has been deleted. Please note that to ensure that we do not collect any further Personal Data, you should also delete our Platform from your mobile devices, terminate your account with us, and clear our cookies from any device where you have used our Platform. We may retain certain Personal Data (including following your request to delete) for audit and record-keeping purposes, or as otherwise permitted and/or required under applicable law.
- Right to Restrict Processing. You can ask us to limit the processing of your Personal Data if either: (i) you have contested its accuracy and wish us to limit processing until this is verified; (ii) the processing is unlawful, but you do not wish us to erase the Personal Data; (iii) it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise, or defend of a legal claim; (iv) you have exercised your Right to Object (below) and we are in the process of verifying our legitimate grounds for processing. We may continue to use your Personal Data after a restriction request under certain circumstances.
- Direct Marketing Opt Out. You can change your mind at any time about your election to receive marketing communications from us and/or having your Personal Data processed for direct marketing purposes. If you do, please notify us by contacting us at privacy@empowerafrica.com. We will process your request as soon as reasonably possible, however it may take a few days for us to update our records before any opt out is effective.
- Right to Object. You can object to any processing of your Personal Data which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
- Withdrawal of Consent. You may withdraw your consent in connection with any processing of your Personal Data based on a previously granted consent. This will not affect the lawfulness of any processing prior to such withdrawal.
- Right to Lodge a Complaint with Your Local Supervisory Authority. You may have the right to submit a complaint to the relevant supervisory data protection authority if you have any concerns about how we are processing your Personal Data, though we ask that as a courtesy you please attempt to resolve any issues with us first. The competent supervisory authorities are listed on the following website: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
You may exercise your rights, as described above, by sending an email to the following address privacy@empowerafrica.com provided that the you verify your identity in accordance with applicable law.
ARTICLE 6. COOKIE MANAGEMENT CONFIGURATION AND OTHER DATA
Your consent to the use and placement of cookies, as described herein, is requested through a banner at the bottom of the Platform homepage.
The User may at all times configure its browser in order to prevent the placement of cookie files. However, certain functionalities of the services proposed by the Platform may not function properly without cookies. In addition, even if most browsers are configured by default to accept cookie files, you may choose to accept the placement of all cookies other than the functional cookies or to systematically decline them or to choose the cookies it accepts depending on the issuer by configuring the following settings:
- Internet Explorer
- Click on the settings menu, followed by “Internet Options”;
- Under the “General” tab on the upper-left hand side, scroll down to “Browsing history”;
- Check the “Temporary Internet files and website files,” “Cookies and website data,” “History,” and “Download History” boxes;
- Click on “Delete”;
- Close out of Internet Explorer and reopen it for changes to take effect.
- Firefox:
- Click on your Tools bar;
- Click on “Preferences”;
- On the menu to the right, select “Privacy”;
- Under the “history option”, there is a shortcut titled “clear your recent history”, click on that;
- Select only the top four options and hit clear now.
- Safari:
- Click on “Safari” in the top left corner of the finer bar;
- Click on “Preferences”;
- Click on the “Privacy” tab;
- Click on “Manage Website Data”;
- Click on “Remove All”;
- Click “Remove Now”.
- Google Chrome:
- Click the Tools menu;
- Click on “More tools”;
- Clear browsing data;
- At the top, choose a time range.
- To delete everything, select “All time”;
- Next to “Cookies and other site data” and “Cached images and files”, check the boxes;
- Click on “Clear data”.
ARTICLE 7. SECURITY
We have implemented and maintain appropriate technical and organization security measures, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to Personal Data appropriate to the nature of such data. The measures we take include:
Safeguards – The physical, electronic, and procedural safeguards we employ to protect your Personal Data include secure servers, antivirus and SSL encryption of data.
Access Controls – The data of our users are accessible only to the persons duly authorized to do so by the Company on a need to know basis for the purposes set forth herein.
Personnel – We require new employees to sign non-disclosure agreements according to applicable law and industry customary practice.
Encryption – We encrypt the data in transit using secure SSL protocols.
Database Backup – Our databases are backed up on a periodic basis for certain data and are verified regularly. Backups are encrypted and stored within the production environment to preserve their confidentiality and integrity, are tested regularly to ensure availability, and are accessible only by authorized personnel.
ARTICLE 8. COMMUNICATIONS
We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your account.
ARTICLE 9. CHILDREN
We do not knowingly collect Personal Data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has enrolled without parental permission, please advise us immediately.
ARTICLE 10. CHANGES TO THE PRIVACY POLICY
We may update this Privacy Policy from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Policy, we will seek to inform you by notice on the Platform or per email.
ARTICLE 11. COMMENTS AND QUESTIONS
If you have any comments or questions about this Privacy Policy or if you wish to exercise any of your legal rights as set out herein, please contact us at privacy@empowerafrica.com.
Date of privacy policy: October 2020
Defining Cookies and what we use them for:
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Security
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