Last Updated: 06/11/2020
Privacy Shield Statement
Information Collected and Stored Automatically
If you access any Andela website, the following basic information is automatically collected from you by our servers (which may be hosted by a third party service provider):
- Any pages you visit on the Andela website, including the information you request through the website,
- If you linked directly to our site, the internet address of the website you linked through,
- The time and date you accessed our site, and
- The Internet Protocol (IP) address from which you accessed our site.
The information automatically collected by accessing our site is not used to track 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.
You can use our site without providing any personal identifiable information (“PII”). If you choose not to provide any PII, you may not be able to use certain services.
You may choose to provide us PII, such as your first and last name, e-mail and mailing addresses, professional title, and company name when you submit a request for information from our website, sign-up for or attend our webinars or request other marketing material from us, link through our sites to partner sites, or through any links for partnership or employment opportunities. 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, you have the right to withdraw your consent at any time by following the instructions to “opt-out” of receiving marketing communication in each marketing email we send you or by contacting us as indicated below.
Individuals also have the opportunity to choose (opt out) 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. To remove your PII from our records, individuals can simply send an email to email@example.com with the subject line: “Opt Out” from the email address they used upon registration.
Personal Identifiable Information (PII)
Use of or access to our website does not require you to provide any PII to us.
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 our Partners 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. Andela does not retain, use or disclose any personal information collected on behalf of our Partners 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 Partner.
If you wish to access, correct, amend, or delete PII you have provided directly to us, please contact our Privacy Officer at firstname.lastname@example.org. 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 email@example.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 firstname.lastname@example.org 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 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 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.
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 information.
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.
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. Andela is not responsible for the security practices or the content of such sites.
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.
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 sites 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 website intends to collect information about children under 13 years old, instructions and information pertaining to COPPA 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.
Attn: Privacy Officer
129 West 29th Street, 5th Floor
New York, NY 10001
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