Last Updated: April 27, 2021
“Andela” means Andela Inc., a Delaware corporation. We may also refer to Andela as “we”, “us”, or “our”.
“Andela Client” means any customer that has entered into an agreement with Andela to use Andela’s services.
“Andela Engineer” means any authorized member of the Andela Talent Network who has agreed to the Talent Network Terms & Conditions.
“PII” or “Personally Identifiable Information” means any information which may identify an individual, directly or indirectly. 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 or aggregated, and other information which is excluded from the scope of applicable privacy laws.
“Visitor” refers to anyone accessing the Andela Site, www.andela.com.
- INFORMATION COLLECTION
- GENERAL INFORMATION ON OUR USE OF PII
- USE OF THIRD-PARTY RESOURCES, APPLICATIONS AND WEBSITES
- OTHER ONWARD TRANSFERS
- YOUR CHOICES & RIGHTS
- PRIVACY SHIELD STATEMENT
- LINKS TO EXTERNAL SITES
- CHILDREN’S PRIVACY
- CONTACT US
- ENFORCEMENT AND ARBITRATION
1. INFORMATION COLLECTION
A. Information Collected Automatically
Like other companies with online services, we receive technical information when you use our Site or access certain Site Services. We use these technologies to analyze how people use the Site Services and to improve how our Site and Site Services function.
We and our third party service providers, including analytics and third party content providers, may automatically collect the following information from you whenever you access or interact with the Site or Site Services: pages visited, links clicked, text entered into contact forms or chat widgets, and mouse movements. We may also collect the referring URL, browser, operating system, and Internet Protocol (“IP”) address you used to access the Site Services. We (and/or our service providers) may use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address. We collect this information to improve the services we offer you, and to improve marketing, analytics, and the functionality of our Site Services.
B. Information You Voluntarily Provide to Andela
Site Visitors may choose to interact with the Site in a way that results in your providing PII to Andela, such as giving us your name, email address, phone number, and country location when signing up to learn more about Andela’s Client services or when signing up to apply to be an Andela Engineer in the Andela Talent Network. If you make use of our Site to register for certain services, download e-books, attend virtual events or webinars, complete online registration forms, apply for roles via our Site, or to create or update any of your marketing preferences, you will be asked to provide personal information. If you choose to provide us with any PII, we will use the information provided to respond to your request.
If you provide us with your consent to be contacted for marketing purposes, we may send you information about our products and services, including marketing communications, as follows:
- To market events, promotions, competitions, webinars, reports, our services, news or relevant industry updates.
- 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.
While Visitors do not have a statutory obligation to provide us with any information, Andela Engineers may have a contractual obligation (pursuant to the Talent Network Terms & Conditions) to do so, and if we do not receive certain information from you, then we will not be able to provide certain Site Services to you. If you have any questions regarding whether the provision of information is mandatory and the consequences for withholding such information, please contact our Privacy Officer using the contact information below.
2. GENERAL INFORMATION ON OUR USE OF PII
Use of or access to our Site does not require you to provide any PII to us. Andela does not buy or sell PII for its business practices or for commercial purposes.
Andela stores, maintains, processes, and/or handles PII data of Andela employees as necessary to perform its business functions for our employees.
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.
Andela may provide PII of our users to only those of its personnel and third-party vendors that (1) need to know such information in order 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 and affiliated organizations may be located outside of your home country; by using the Site and/or Site Services, you consent to the transfer of information to such individuals and organizations in order to accomplish these purposes.
In some instances, we may be required by law to disclose information you submit or email to us electronically by law, court order, law enforcement request or other purposes to protect our sites or other sites due to security threats. We may, as necessary, disclose this information or any other information that may identify you to state and local authorities or law enforcement as required under law or by court order.
3. USE OF THIRD-PARTY RESOURCES, APPLICATIONS AND WEBSITES
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 does not buy or sell PII for its business practices or for commercial purposes.
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.
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.
In addition to the automatic and voluntary provided information collected by Andela, third-parties may host embedded content, applications on the webpage, and/or cookies that collect information from your machine while you are on our website. These services provide Andela with website analytics, enhance the user experience, provide ease of navigation through Andela’s sites, send tailored marketing communications or ads, and promote your access to information.
In relation to third-party advertising on our website or through any advertising entities, you may opt-out of being served personalized advertisements by clicking on these two links (US and EU).
4. OTHER ONWARD TRANSFERS
Andela may transfer data to third-party vendors acting as our agents, due to an acquisition of business assets by another entity, in the ordinary course of business due to expansions or fund-raising, or as otherwise prescribed by this policy. In the course of any change of ownership, Andela shall notify any impacted parties in writing of any transfer of PII.
All transfers of PII will be: (1) limited for specific purposes; (2) based on a proper determination that the recipient shall: (i) adhere to Privacy Shield principles; (ii) notify Andela if they determine at any subsequent time they will not be able to adhere to Privacy Shield principles; and (iii) stop and remediate any unauthorized processing; and (3) based on contractually established privacy terms with the recipient of such information that can be either: (i) shared with you; or (ii) reasonably summarized for you. Any transfer of Andela employee PII will be consistent with our internal privacy practices and as disclosed in our employee handbook.
Andela is responsible and liable for the processing of PII it receives and transfers to a third party acting on Andela’s behalf. Andela complies with the Privacy Shield Principles for all onward transfers of PII from the EU including liability provisions of such onward transfer.
5. YOUR CHOICES & RIGHTS
You can use our Site without providing any personal identifiable information. However, if you choose not to provide any PII, you may not be able to use certain Site Services.
Individuals also have the opportunity to 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 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 Engineers, 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 Site Services, and any account you have with us may become deactivated.
- Direct Marketing Opt Out. 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.
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 forty-five (45) 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.
Andela uses industry-standard technologies, administrative, technical, and physical measures to protect the security, confidentiality and integrity of any information or data collected by us.
However, no website, service, mobile application, database or system is completely secure or “hacker proof.” You are responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.
7. PRIVACY SHIELD STATEMENT
8. LINKS TO EXTERNAL SITES
Our Site and Site Services may contain links to websites created and maintained by other public or private organizations. 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 Site 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 practices or the content of such external sites.
9. CHILDREN’S PRIVACY
Andela is committed to the protection of children’s online privacy. Because of the nature of our business, our services are not designed to appeal to, and our Site and Site Services are not directed to children under the age of 13. Andela does not intend to solicit or collect information and we do not knowingly collect personal information from children under the age of 13.
The Children’s Online Privacy Protection Act (COPPA) governs information gathered online from or about children under the age of 13. Verifiable consent from a child’s parent or guardian is required before collecting, using, or disclosing personal information about a child under the age of 13. If an Andela Site or Site Services intends to collect information about children under 13 years old, instructions and information pertaining to COPPA will be provided by the specific Site Service that collects information about the child. The Site Service will specify exactly what such information will be used for, who will see it, and how long it may be kept.
10. CONTACT US
Attn: Privacy Officer
576 Fifth Avenue, Suite 903
New York, NY 10036
11. ENFORCEMENT AND ARBITRATION
Andela is committed to responding to requests in a timely manner as provided above. However, if you have not received a timely or satisfactory response from Andela to your question, complaint, or request, please contact our alternative dispute resolution provider based in the United States: https://www.jamsadr.com/eu-us-privacy-shield.
You may invoke binding arbitration if your complaint remains unremedied following our dispute resolution process described above. More information is available on the Privacy Shield website: https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.