Last Updated: 01 September, 2022
“Andela Client” means any customer that has entered into an agreement with Andela to use Andela’s Services.
“Andela Talent” means any authorized member of the Andela Talent Network who has agreed to the Talent Network Terms & Conditions.
“PII”, “Personally Identifiable Information”, and/or “Personal Information” means any information which may identify an individual, directly or indirectly or, if you are located in the European Economic Area (“EEA”) or United Kingdom (“UK”) any information relating to an identified or identifiable individual. Examples of PII include, but are not limited to, first and last name, home address, billing address or other physical address, email address, telephone number, etc. PII does not include information which is anonymized, and other information which is excluded from the scope of applicable privacy and data protection laws.
1. PERSONAL INFORMATION WE COLLECT
2. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
3. HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT
4. INTERNATIONAL DATA TRANSFERS
10. CONTACT US
1. PERSONAL INFORMATION WE COLLECT
We may collect a variety of Personal Information from or about you or your devices from various sources, as described below.
A. Personal Information You Voluntarily Provide to Andela
Registration and Profile Information. You may choose to sign up for an account on our Services, including to join the Andela Talent Network. Upon your signup to the Andela Talent Network, we may ask you for your name, email address, phone number, country location, English proficiency, primary skill, years of working experience, years of experience with primary skill, information included in your resume, and name of a person who referred you.
Communications. If you contact us directly, we may receive additional Personal Information about you. For example, if you contact us for technical support, we may receive your name, email address, phone number, the contents of your message, attachments that you may send to us, and other Personal Information you choose to provide. If you subscribe to our newsletter, we will collect Personal Information such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better experience and improve our Services.
Hire Talent Through Andela. You may choose to use our Services to access pre-vetted talent if you are interested in hiring through Andela. Upon submitting your request form, we may ask you for your name, company name, job title, work email, company URL, phone number, employee range, your current role and country.
Additional Services. If you make use of our Site to register for certain services, including to download e-books, attend virtual events or webinars, or submit a testimony to be published on our Services, we may ask you to provide your name, company name, job title, (work) email address, phone number, employee range, primary skill, years of experience in framework and country.
Andela Learning Community. If you choose to submit your interest in joining the Andela Learning Community, we may ask you for your name, email address, country, seniority level, most proficient framework, professional years of experience in framework, top 5 tech skills, top 5 tech tools, and resume.
Become a Partner. If you are interested in becoming our Partner, we may ask to submit your name, company name, work email address, phone number, and your current role.
Careers. If you decide that you wish to apply for a job with Andela, we may ask you to submit your name, email address, phone number, location (city), your resume, cover letter, the name of the Andela employee who referred you, the number of years of experience relevant for the job profile, desired compensation range, the information on how you learned about the job offer, and other relevant information. We will collect the information you choose to provide on your resume and in your cover letter, such as your education and employment experience. You may choose to voluntarily provide information on your gender, race/ethnicity, veteran status, and disability status. If you apply for a job with us through a third-party platform (such as LinkedIn), we will collect the Personal Information you make available to us through such third-party platform.
If you do not provide your Personal Information when requested, you may not be able to use our Services if that Personal Information is necessary to provide our Services or if we are legally required to collect it. For example, while Users visiting our Site do not have a statutory obligation to provide us with any Personal Information, Andela Talent may have a contractual obligation (pursuant to the Talent Network Terms & Conditions) to do so. Where required by applicable law, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you have any questions regarding whether the provision of Personal Information is mandatory and the consequences for withholding such information, please contact our Privacy Officer using the contact information provided in section “Contact Us” below.
B. Personal Information We Collect When You Use Our Services
Like other companies with online services, we receive technical information when you use our Site or access certain Services. We use these technologies to analyze how people use the Site Services and to improve how our Site and Services function.
Location Information. When you use our Services, we may approximate your geographic region and Internet Service Provider based on your internet protocol (IP) address.
Device Information. We receive information about the device and software you use to access our Services, including IP address, web browser type, and operating system version.
Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like log files, performance logs, diagnostic reports, the pages or other content you view, mouse movements, the searches you conduct, your comments, any content you post, and the dates and times, and duration of your visits.
Information from Cookies and Similar Technologies. We and third-party partners collect information using cookies, pixel tags, or similar technologies (collectively “Cookies”). Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small files of letters and numbers that we store on your browser or the hard drive of your computer. We may use both session Cookies and persistent Cookies. A session Cookie disappears after you close your browser. A persistent Cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. For more information, including disclosures related to the active cookies on our Site, please see our Cookie Notice.
C. Personal Information We Receive from Third Parties.
Social Sign-In. We may collect Personal Information about you when you log in to our Services via third-party services (such as Google). This information may include your social media user id, email address, full names and profile picture.
Third-Party Services. You may also post photos, comments, or reviews on our pages available through third-party platforms, including Facebook, LinkedIn, Twitter, and Instagram. If you do so, we and other users on those third-party platforms may be able to view the Personal Information you make available through these third-party platforms.
Professional social media link/identifier. If you include a professional social media link/identifier or your personal website in your job application with us, we may retrieve information about your professional social media / online presence from such sites.
Partners. We may receive additional Personal Information about you from third parties (such as partners that provide publicly available demographic information about you), affiliate partners, or marketing partners and combine it with other Personal Information we have about you.
Andela Clients. We also may receive PII from Andela Clients to perform services for them. Any PII used for such purposes will be limited to access by only those who require it given their job function at Andela, and except as otherwise provided herein, we only share the PII back with our respective Clients. Andela does not retain, use, or disclose any Personal Information collected on behalf of our Clients for any purpose (including any commercial purpose) other than the specific purpose of performing the services as specified in the applicable Master Services Agreement with the Client.
2. HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We use the Personal Information we collect:
- To provide, maintain, improve, and enhance our Services.
- To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer service and support.
- For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you, to market events, promotions, competitions, webinars, reports, our services, news, or relevant industry updates.
- To personalize your experience on our Services such as presenting tailored content.
- To conduct research to understand and analyze how you use our Services and develop new products, services, and features.
- To process job applications.
- To process your submissions, including to become our talent, client or partner, join the Andela Learning Community, to download e-books, or attend webinars or events.
- To find and prevent fraud and respond to trust and safety issues that may arise.
- For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
- To enforce and comply with the law, including to conduct an investigation, to protect the property and rights of Andela or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
- For other purposes for which we provide specific notice at the time the Personal Information is collected.
Legal Bases for Processing European Personal Information
If you are located in the European Economic Area or the United Kingdom, we only process your Personal Information when we have a valid “legal basis,” including as set forth below.
● Contractual Necessity. We need your Personal Information to provide you with our Services. For example, we may need to process your Personal Information to respond to your inquiries or requests.
● Compliance with a Legal Obligation. We have a legal obligation to use your Personal Information. For example, we may process your Personal Information to comply with tax and accounting obligations.
● Legitimate Interests. We or a third party have a legitimate interest in using your Personal Information. Specifically, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
3. HOW WE SHARE THE PERSONAL INFORMATION WE COLLECT
Vendors, Affiliate Partners and Service Providers. We may share any Personal Information we receive with vendors, affiliate partners and service providers retained in connection with the provision of our Services. Andela actively engages third-party resources, applications, and websites. These services provided by third parties are established to enhance user experience, provide ease of navigation through Andela’s sites, and to promote access to information. Andela may provide PII of Users to only those of its personnel and third-party vendors that (1) need to know such information to process it on Andela’s behalf or to provide services as described above, and (2) have agreed in writing not to disclose it to any other parties without Andela’s consent. Some of those employees, contractors, vendors, affiliate partners and affiliated organizations may be located outside of your home country; by using the Site and/or Services, you consent to the transfer of information to such individuals and organizations to accomplish these purposes.
Marketing. Andela does not buy or sell PII for its business practices or for commercial purposes unless we have your permission. From time to time, Andela may engage in joint marketing events with select business partners. If you register for a joint webinar or specifically express an interest in a jointly offered product, promotion or service, we may share relevant PII with those partner(s). Where you have given your consent to do so, these business partners may send you marketing communications about their own products and services.
Sweepstakes, Contests, and Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
Social Networks and Other Online Services. Please note that Andela does not control, moderate, or endorse any comments or opinions provided by visitors on third-party websites. The use and creation of official Andela accounts may cause PII to become available or accessible to Andela. Such information may become available to Andela when a user provides, submits, communicates, links, posts, or associates information with designated Andela accounts on social media (e.g., by using “hashtags”, “liking”, “friending”, “tweeting”, commenting on any content or media on our designated accounts). At times, Andela, through its personnel, employees, officers, directors, agents, and assignees, may respond publicly to content or media made available though “share,” “retweet,” “friend,” “follow,” or similar activities, or respond publicly on content made on designated and official Andela accounts. Andela may disseminate any of such information or PII to law enforcement officials, as required by law or court order.
Analytics Partners. We use analytics services such as Google Analytics, Fullstory, Hubspot Analytics, Pendo, Segment Analytics, Marketo and Mouseflow to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/. To help us understand how you use our Services and to help us improve them, we automatically receive Personal Information about your interactions with our Services, like the pages or other content you view, the searches you conduct, purchases you make, your comments, any content you post, and the dates and times of your visits.
Advertising Partners. We work with third-party advertising partners such as Adwords to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (http://optout.networkadvertising.org/?c=1#!/) or the Digital Advertising Alliance (http://optout.aboutads.info/?c=2&lang=EN). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt-out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt-out of personalized ads in mobile apps.
As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. This includes exchanging information with other companies and organizations, including law enforcement agencies, for the purposes of fraud protection and to prevent cyber or other suspected or alleged crime. For the avoidance of doubt, the disclosure of your Personal Information may occur if you post any objectionable content on or through the Services.
Merger, Sale, or Other Asset Transfers. We may disclose your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets.
With Your Consent. We may also disclose your Personal Information with your permission.
4. INTERNATIONAL DATA TRANSFERS
We may transfer your Personal Information to the United States and other jurisdictions that may not be deemed to provide the same level of data protection as your home country. If you are located in the EEA, we will comply with applicable EEA data protection law when transferring your Personal Information outside of the EEA. We may transfer your Personal Information to countries that have been found to provide adequate protection by the EU Commission, use contractual protections for the transfer of Personal Information, transfer to recipients who have adopted Binding Corporate Rules, or rely on an appropriate legal derogation.
For more information about how we transfer outside of the EEA and the UK, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us using the contact details as indicated in the “Contact Us” section below.
5. YOUR CHOICES & RIGHTS
Marketing Communications. You have the right to object if we are processing your PII for direct marketing purposes. You can unsubscribe from Andela’s own marketing emails at any time by clicking the “unsubscribe” link they contain or by accessing the Email Preferences Center. Depending on which jurisdiction you are in, we may be required to give you an option to “opt-in” and we will always provide you with an option to “opt-out” with each marketing communication. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.
Individuals also can choose whether their PII is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
In accordance with applicable law, you may have the right to:
- Access Personal Information. You may request confirmation of whether we are processing your Personal Information and obtain a copy of the categories of Personal Information we may have collected on your behalf.
- Request Correction. You may request correction of your Personal Information where it is inaccurate, incomplete, or outdated. For Andela Talent, you may update your Personal Information within your Andela accounts by logging in and updating your profile.
- Request Deletion (“Opt Out”) or Withdraw Consent. You may request to remove your PII from our records. Note that if your Personal Information is deleted, you may no longer access or be able to use certain Services, and any account you have with us may become deactivated.
If you wish to access, correct, amend, or delete PII you have provided directly to us, please contact our Privacy Officer at [email protected]. For deletion/opt-out requests, please include the subject line “OPT OUT”. We will respond to requests within thirty (30) days. If we require more time, we will inform you of the reason and extension period for a response in writing.
If you wish to access, correct, amend, or delete PII you have provided to our Clients, please contact those Andela Clients directly. Alternatively, you may contact our Privacy Officer at [email protected] and we will pass your request along to the applicable Andela Client.
When any Client requests Andela to remove any Client data that Andela may have on its systems, Andela will respond as soon as practicably as possible, and no more than forty-five (45) days after such receipt from our Client. If you wish to no longer have your PII used or disclosed by our Clients, or by us in connection with our work for our Clients, please contact the Client that you interact with directly. Alternatively, you may contact our Privacy Officer at [email protected] and we will pass your request along to our Clients.
California Privacy Rights. If you are a California resident, you can review our California Resident Privacy Notice for information about your privacy rights and choices under California law.
Your European Privacy Rights. If you are located in the EEA or the United Kingdom, you have the rights described below:
- When we process your Personal Information based on your consent, you have the right to withdraw your consent at any time and free of charge. We will apply your choice going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
- You may request access to and information about the Personal Information we maintain about you, update, and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. Please note that there are exceptions and limitations to each of these rights.
- If you would like to exercise these rights, please contact us as specified in the “Contact Us” section below. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Applicable law may allow or require us to refuse your request to exercise a right with respect to your Personal Information, or we may have destroyed, erased, or made your Personal Information anonymous in accordance with our record retention obligations and practices. If we refuse your request to exercise a right, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
- You also have the right to lodge a complaint with the data protection authority of your habitual residence, your place of work or the place of an alleged infringement.
Andela uses reasonable efforts to protect the security, confidentiality, and integrity of information or data collected by us.
However, as no website, service, mobile application, database, or system is completely secure or “hacker proof,” we can make no guarantees as to the security or privacy of your Personal Information. You are responsible for taking reasonable steps to protect your Personal Information against unauthorized disclosure or misuse.
7. LINKS TO EXTERNAL SITES
Our Services may contain links to websites created and maintained by other public or private organizations that we do not own or operate. We provide these links as a service to our Users. Please note that when you follow a link to an external site, you will be leaving Andela’s Services and are subject to the privacy and security policies of the site to which you are visiting. Andela is not responsible for the security and privacy practices of these third parties or the content of such external sites.
We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when your Personal Information is no longer necessary for the purposes for which we process it unless we are required by law to keep your Personal Information for a longer period. When determining the specific retention period, we consider various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.
9. CHILDREN’S PRIVACY
10. CONTACT US
Attn: Privacy Officer
580 Fifth Avenue, Suite 820
New York, NY 10036
If you are located in the EEA, you can email our EU representative at [email protected] or you can send mail to us at:
Place de L’Université 16
Waals Brabant, 1348