Privacy Policy

ANDELA INC

PRIVACY POLICY

Last Updated: 04/13/2018

Andela Inc. (“Andela”) is committed to upholding the privacy rights of individuals. The below Privacy Policy explains the collection, use, purpose, and sharing of personally identifiable information (“PII”) related to the use of Andela’s website www.andela.com, services to our customers (“Partners”), and our employees. Andela does not require you to register or provide information to visit our website.

 

Andela complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of all personal information transferred from the European Union to the United States. Andela has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, and is subject to the investigatory and enforcement powers of the Federal Trade Commission. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the list of companies that have self-certified to the Privacy Shield, please visit https://www.privacyshield.gov/ and https://www.privacyshield.gov/list.

 

Information Collected and Stored Automatically

 

If you access information on Andela websites, the following basic information is automatically collected from you by our servers or to that of our third parties:
 

Any pages you visit, including the information you request:

  • If you linked directly to our site, the internet address of the website you linked through,
  • The Time and date you access our site, and
  • The Internet Protocol address from which you access our site.  

 

The information collected by accessing our site is not used to track the individuals, their browsing, or their access to our site.  The information is collected and used only for technical improvements and statistical analysis of our site. 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.

 

Personal Identifiable Information (PII)

 

Use or access to our website does not require you to provide any personal information. If you chose to provide us with any personal information through email, filling out any form and submitting it through our site, links through our sites to partner sites, or through any links for partnership or employment opportunities, we will use the information provided to respond to your request.

 

Andela stores, maintains, processes, and/or handles PII data as necessary to perform its business functions for our employees.  We also receive personal information from our Partners (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 Partners.

 

If you wish to access, correct, amend, or delete PII you have provided directly to us, please contact our Privacy Officer at privacy@andela.com.  If you are an Andela employee, please work directly with your HR professional.  We respond to requests within forty-five (45) days. If you wish to access, correct, amend, or delete PII you have provided to our Partners, please contact those Partners directly.  Alternatively, you may contact our Privacy Officer at privacy@andela.com and we will pass your request along to our Partners.

 

When any Partner requests Andela to remove any Partner 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 Partner.  If you wish to no longer have your PII used or disclosed by our Partners, or by us in connection with our work for our Partners, please contact the Partner that you interact with directly. Alternatively, you may contact our Privacy Officer at privacy@andela.com and we will pass your request along to our Partners.

 

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.  

 

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 the access to information.

 

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 (i.e: by using “hashtags”, “liking”, “friending”, “tweeting”, commenting on any content or media on our designated accounts).  At times, Andela, through its 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.

 

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. This Privacy Policy does not apply to third party websites or services.  You may wish to review their privacy policies for details about how each third party collects, uses, and shares information. You can control the use of cookies at the individual browser level.

 

Andela processes PII we receive from our Partners to fulfill our services to them.  If we forward PII to any third parties vendors acting as our agents, we will ensure that such information will be:  (1) limited data for specific purposes; (2) based on proper determination that: (i) the recipient shall adhere to Privacy Shield principles; (ii) notify Andela if they determine at any subsequent they will not adhere to such principles; and (iii) to 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.

 

In relation to third-party advertising on our Site or through any advertising entities, you may opt-out of being served personalized advertisements by clicking on these two links (US and EU).

 

Other Onward Transfers

 

Other than as described above, Andela does not process, store, maintain, or disclose PII received from its Partners.

 

Andela does store and maintain PII of its employees, and such transfers are consistent with our internal privacy practices and as disclosed on our employee handbook. Andela does not, however, buy or sell PII for business practices or purposes.  Andela may transfer data 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, employees PII, and PII of any other parties as impacted by Partner relationships, Andela shall notify such parties in writing of any transfer of your PII information.

 

All transfers of such information will be:  (1) limited data for specific purposes; (2) based on proper determination that: (i) the recipient shall adhere to Privacy Shield principles; (ii) notify Andela if they determine at any subsequent they will not adhere to such principles; and (iii) to 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.

 

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.

 

Links to External Sites

 

Our websites may contain links to websites created and maintained by other public or private organizations.  We provide these links as a service to our visitors. Please note that when you follow a link to an external site, you will be leaving Andela’s sites and are subject to the privacy and security policies of the site to which you are visiting.

 

Security

 

Andela takes administrative, technical, and physical measures to protect the security, confidentiality and integrity of information collected on this site or from our Partners so that we may provide services for them.

 

However, no website, service, mobile application, database or system is completely secure or “hacker proof.”  You are also responsible for taking reasonable steps to protect your personal information against unauthorized disclosure or misuse.

 

Interaction With Children Online

 

Andela is committed to the protection of children’s online privacy. Our sites do not intend to solicit or collect information from children under 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 website intends to collect information about children under 13 years old, instructions and information pertain to COOPA will be provided by the specific web page that collects information about the child. The website, page or link will specify exactly what information will be used for, who will see it, and how long it will be kept.

 

Children

 

Andela is committed to the protection of children’s online privacy. Our sites are not directed to children under 13, and we do not knowingly collect personal information from Children under the age of 13.

 

Privacy Policy Contact Information

 

We welcome feedback from all our users and if you have any question regarding our privacy policy or the use of your information please contact us.  You can email our privacy officer at privacy@andela.com or you can send mail to us at:

 

Andela, Inc.

℅ Privacy Officer

Kirsten Canton

129 West 29th Street, 5th Floor

New York, NY  10001

 

Enforcement and Arbitration

 

Andela commits to responding to requests timely 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