This Privacy Policy (the “Policy”) outlines the collection of and uses Africa Business Portal, (“ABP,” “we” or “us”) makes of non-personally identifying information and personally identifying information received through your interactions with the website.

POLICY COVERAGE

The provisions of this Policy cover your interactions with ABP and the africabusinessportal.com website. The africabusinessportal.com website may include various links to third-party websites, including various solution providers, sponsors, and other advertisers. This Policy does not apply to your interactions with these third-party sites, and ABP encourages you to review the respective Privacy Policies of those third-party sites before providing personally identifying information to them. Those individuals and companies who submit personally identifying information for the purposes of posting investment opportunities in Africa acknowledge that ABP has, through its site Terms of Use Policy, provided penalties, including the termination of user accounts, to those who repost the personally identifying information associated with a particular investment opportunity listing on a third party site or electronically transmit it to anyone other than their business partners or employees. Individuals and companies who have posted personally identifying information associated with an investment opportunity on the site acknowledge, however, that ABP does not guarantee that such reposting will not occur but that ABP will make reasonable efforts to regulate the behavior of the user involved, stop such reposting, and have reposted content removed. ABP also cannot guarantee that individuals and companies posting investment opportunities will not be contacted by third parties associated with site users seeking to market services or products but asks that ABP be notified when such requests occur so that ABP can take appropriate user behavior enforcement action.

This Policy is laid out in distinct sections with clear headings so that you can easily navigate the contents.

POLICY TABLE OF CONTENTS:

I. IMPORTANT INFORMATION AND WHO WE ARE
II. THE DATA WE COLLECT ABOUT YOU
III. HOW YOUR PERSONAL DATA IS COLLECTED
IV. HOW WE USE YOUR PERSONAL DATA
V. DISCLOSURES OF YOUR PERSONAL DATA
VI. INTERNATIONAL TRANSFERS
VII. DATA SECURITY
VIII. DATA RETENTION
IX. YOUR LEGAL RIGHTS
X. GLOSSARY

I. IMPORTANT INFORMATION ABOUT WHO WE ARE

This privacy policy aims to give you information on how ABP collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or become a member.

ABP does not collect personally identifying information from children under the age of 13, nor are any persons under the age of 18 or otherwise unable to legally enter into a binding contract in the United States permitted to create a user profile. If ABP learns that someone under the age of 18 has created a profile and provided personally identifying information, the profile will be deleted immediately.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller Contact

ABP Is the controller and responsible for your personal data and has appointed a data protection officer (“DPO”) who is responsiblefor overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact Details
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity/DPO: Africa Business Portal
Email address: [email protected]
Postal address: 2152 E. Golf Ave., Tempe, AZ 85282
Telephone number: 1-800-573-6105

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the Policy

ABP keeps its policy under regular review and reserves the right to change the terms of the Policy at any time. The most current copy of the Policy will be found on Africabsp.com.

As ABP may change this policy periodically, the most recent copy of the policy will be available on the Africabsp.com website, and you are encouraged to visit the website to retrieve the latest copy of the policy.

It is also important that the personal data we hold about you is accurate and current. Please also inform ABP of any of your personal information changes during your relationship with us.

Third Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. ABP does not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Third Party Vendors

Your personally identifying information or data and will not be shared or made available to third parties, except as otherwise set forth on this Policy and when you as a user choose to post personally identifying information associated with a specific investment opportunity posted on the website or if you choose to use a service from a third-party vendor providing services to ABP itself, such as a credit card processing company.

Third party vendors are forbidden to use your personally identifying information for any purpose beyond that necessary for them to provide the contracted for service to you and you will be made aware of the identity of the third-party vendor at the time the service is provided. You recognize that if you choose to contact an advertiser on the ABP site and provide that advertiser with personally identifying information, that advertiser is not bound by the terms of this Policy. ABP may provide personally identifying information to other vendor companies so that they may perform various contracted for services for ABP, such as mailings or statistical analysis, but ABP will provide only the information needed for the third-party vendor to perform their services. All vendors are required to safeguard any personally identifying information provided by ABP and have agreed not to use any of the information received for their own purposes.

Non-personally identifying information may be used by ABP to evaluate site usage patterns and may be provided to potential advertisers and sponsors as part of marketing activities. ABP derives a significant portion of its revenue from advertising, and accordingly shares aggregated non-personally identifying information with current and future advertisers. ABP does not share personally identifying information with these advertisers. Unless you expressly opt in to receiving communications from third parties, ABP will not provide personally identifying information to any other third party to allow them to contact or otherwise solicit you regarding products, services, or other opportunities.

II. DATA WE COLLECT ABOUT YOU

ABP collects user personal information and data to aid in maintaining the function of the africabsp.com website and to enhance your experience and interaction with the website. ABP will not share personally identifying information with any third party unless required by law. ABP may share non-personally identifying information with third parties as part of its business operations, but such information will be aggregated (added together) and will not contain any information capable of identifying a particular user.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

ABP may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone number.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

ABP also collects, uses and shares Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

ABP does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If You Fail to Provide Personal Data
Where ABP needs to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

III. HOW YOUR PERSONAL DATA IS COLLECTED

Personally identifying information or data may be gathered through your voluntary submission of information to the site during creation of a user account or through other interactions with the site, whether through its pages or through electronic or verbal communications, which may include your name, contact numbers, email address, postal address, and other user profile-related information. Personally identifying information or data is not gathered unless you knowingly provide it to ABP through interacting with the website. Non-personally identifying information may be gathered in similar ways, and includes Internet Protocol (IP) address, page(s) visited, the time spent on each page, and other visit-related information. Non-personally identifying information and personally identifying information may also be gathered through the use of cookies, which are data files saved on your computer’s local hard drive that contain various information about what site pages you have visited, various user preferences you have selected for the site, and other items intended to enhance your user experience. Through the use of your web browser you can control whether you choose to allow cookies to be installed on your local hard drive, which will control some aspects of your user experience. Other files that function similarly to cookies, including local shared objects associated with Adobe® Flash may be used to collect personally identifying information and non-personally identifying information. You can control whether local shared objects are used through using the Macromedia Website Privacy Settings Panel at macromedia.com. ABP also gathers non-personally identifying information from log files generated by its servers and which are stored in secure locations. The information from the log files may be used in various aggregated ways to determine various patterns of site usage.

IV. HOW WE USE YOU PERSONAL DATA

ABP will only use your personally identifying information or data when the law allows us to. Most commonly we will use your persona information or data to:

  • communicate directly with you or performance of a service with which we provide you; or
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or
  • Where we need to comply with a legal obligation.

See Glossary, below, to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, ABP does not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for Which Your Persona Data Is Used

ABP have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer (a) Identity

(b) Contact

Performance of a service with which we provide you
To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a service with which we provide you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a service with which we provide you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a service with which we provide you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional Offers From Us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting-Out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences OR by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result ofa service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Sale or Bankruptcy

Ownership of ABP may change at some point in the future. Because of this, we want the site to be able to maintain contact with you as it continues operations. You acknowledge that as part of a transfer of ownership through sale, merger, bankruptcy, or public offering, your information may be shared with the new owner of the site.

VI. INTERNATIONAL TRANSFERS

Your personal data may be circulated within ABP. This will involve transferring your data outside the European Economic Area (EEA).

Whenever ABP transfers your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • ABP 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where ABP uses certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where ABP uses providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact ABP if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

VII. DATA SECURITY

ABP has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

ABP has also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Your information is stored on ABP’s servers located in the United States and is stored, handled, and processed using industry standards and technical safeguards designed to protect your personally identifying information from loss, theft, or unauthorized disclosure. A wide variety of security procedures may be utilized as part of ABP’s efforts including firewalls, Secure Socket Layer (SSL) certificates, internal access controls, and other procedures and systems. You recognize, however, that ABP cannot guarantee a perfect level of security, since such a level is not possible on the internet.

VIII. DATA RETENTION

ABP will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. ABP may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, ABP considers 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 ABP can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law ABP have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymize 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.

IX. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the legal right to find out more about the following:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us DPO.

No fee usually required.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

ABP may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. ABP may also contact you to ask you for further information in relation to your request to speed up our response.

ABP tries to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

X. GLOSSARY

1. LAWFUL BASIS
a. Legitimate Interest – means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

b. Performance of a Service-means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

c. Comply with a Legal Obligation- means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

2. THIRD PARTIES
a. Internal Third Parties – Other companies within ABP acting as joint controllers or processors.

b. External Third Parties – 1) Service providers acting as processors who provide IT and system administration services; or 2)Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurerswho provide consultancy, banking, legal, insurance and accounting services, or 3) Government Revenue & Customs, regulators and other authorities acting as processors or joint controllers basein the United Kingdom or the United States who require reporting of processing activities in certain circumstances.

3. YOUR LEGAL RIGHTS – You have the right to:
a. Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

b. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

c. Request erasure of your personal data. This enables you to ask ABP to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask ABP to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that ABP may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

d. Object to processing of your personal data where ABP is relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where ABP is processing your personal data for direct marketing purposes. In some cases, ABP may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

e. Request restriction of processing of your personal data. This enables you to ask ABP to suspend the processing of your personal data in the following scenarios:

  • If you want ABP to establish the data’s accuracy.
  • Where ABP’s use of the data is unlawful but you do not want us to erase it.
  • Where you need ABP to hold the data even if ABP no longer requires it as you need it to establish, exercise or defend legal claims.
  • You have objected to ABP’s use of your data but ABP needs to verify whether we have overriding legitimate grounds to use it.

f. Request the transfer of your personal data to you or to a third party. ABP will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for ABP to use or where ABP used the information to perform a contract with you.

g. Withdraw consent at any time where ABP is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, ABP may not be able to provide certain products or services to you. ABP will advise you if this is the case at the time you withdraw your consent.

ABP Privacy Policy updated as of June 2018

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