Privacy Policy
Key Terms
In this privacy policy, these terms have the following meanings:
"Contact" is a person a Member may contact through our Services. In other words, a Contact is anyone on a Member's Distribution List or about whom a Member has given us information. For example, if you are a Member, a subscriber to your email marketing campaigns would be considered a Contact.
"Distribution List" is a list of Contacts a Member may upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).
"Member" means any person or entity that is registered with us to use the Services.
"Personal Information" means any information that identifies or can be used to identify a Member, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
"Website(s)" means any website(s) we own and operate (such as www.africa.co, www.thea25n.com, www.edutainmentafrica.org) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.
"Visitor" means any person who visits any of our Websites.
"you" and "your" means, depending on the context, either a Member, a Contact, or a Visitor.
Privacy for Members
This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Services. If you are not a Member, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Members and potential Members.
Information We Collect
The Personal Information that we may collect broadly falls into the following categories:
(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with ATF), or communicate with us in any other way.
We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in this privacy policy.
(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement
(iii) Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.
Use of Personal Information
We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:
• To send you event alerts and ecosystem news/messages.
• To communicate with you about our programs and provide customer support.
• To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us prevent violations.
• To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
• To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
• To prosecute and defend a court, arbitration, or similar legal proceeding.
• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• To provide, support and improve the Services. For example, this may include sharing your or your Contacts’ information with third parties in order to provide and support our Services or to make certain features of the Services available to you.
• Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
Cookies and Tracking Technologies
We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to measure the performance of your email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.
Other Data Protection Rights
You and your Contacts may have the following data protection rights:
• To access, correct, update or request deletion of Personal Information. ATF takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a Member, you can manage many of your individual account and profile settings within the dashboard provided through the ATF platform, or you may contact us directly by emailing us at [email protected]. You can also manage information about your Contacts within the dashboard provided through the ATF platform to assist you with responding to requests to access, correct, update or delete information that you receive from your Contacts.
• In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us using the contact details provided in the "Questions and Concerns" section below. If any of your Contacts wishes to exercise any of these rights, they should contact you directly, or contact us as described in the "Privacy for Contacts" section below.
• Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. If you receive these requests from Contacts, you can segment your lists within the ATF platform to ensure that you only market to Contacts who have not opted out of receiving such marketing.
• The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from one of your Contacts, we will either direct the Contact to reach out to you, or, if appropriate, we may respond directly to their request.
Privacy for Contacts
This section applies to the information we process about our Members’ Contacts as a data controller pursuant to our legitimate business interests. Our Services are intended for use by our Members. As a result, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. ATF is not responsible for the privacy or security practices of our Members, which may differ from those set forth in this privacy policy. Please check with individual Members about the policies they have in place. For purposes of this section, "you" and "your" refer to Contacts.
We and our partners may use various technologies to collect and store information when you interact with a Member’s email campaign or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on behalf of our Members. When you receive and engage with a Member’s campaign, web beacons track certain behavior such as whether the email sent through the ATF platform was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our Members’ email campaigns, and to provide analytics information and enhance the effectiveness of our Services.
Legal Basis for Processing
We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; ensuring the security of the Services and our Website; and for our marketing activities.
Other Data Protection Rights
You may have the following data protection rights:
• To access, correct, update or request deletion of your Personal Information. ATF takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at [email protected]. We will consider your request in accordance with applicable laws.
• In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at [email protected].
• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by ATF as a processor on behalf of our individual Members, you should contact the relevant Member that is using the ATF Services, and refer to their separate privacy policies.
If you no longer want to be contacted by one of our Members through our Services, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
Privacy for Visitors
How We Share Information
We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Members, Contacts, and Visitors unless otherwise indicated):
(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.
(ii) Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information with them for this purpose.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.
(v) Any other person with your consent.
Your Choices and Opt-Outs
Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided below.
Our Security
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at [email protected].
International Transfers
(i) We operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy.
Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
• Whether we have a legal or contractual need to retain the data.
• Whether the data is necessary to provide our Services.
• Whether our Members have the ability to access and delete the data within their ATF accounts.
• Whether our Members would reasonably expect that we would retain the data until they remove it or until their ATF accounts are closed or terminated.
• When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
California Privacy
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us at [email protected].
Changes to this Policy
We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.
Key Terms
In this privacy policy, these terms have the following meanings:
"Contact" is a person a Member may contact through our Services. In other words, a Contact is anyone on a Member's Distribution List or about whom a Member has given us information. For example, if you are a Member, a subscriber to your email marketing campaigns would be considered a Contact.
"Distribution List" is a list of Contacts a Member may upload or manage on our platform and all associated information related to those Contacts (for example, email addresses).
"Member" means any person or entity that is registered with us to use the Services.
"Personal Information" means any information that identifies or can be used to identify a Member, a Contact, or a Visitor, directly or indirectly. Examples of Personal Information include, but are not limited to, first and last name, date of birth, email address, gender, occupation, or other demographic information.
"Website(s)" means any website(s) we own and operate (such as www.africa.co, www.thea25n.com, www.edutainmentafrica.org) or any web pages, interactive features, applications, widgets, blogs, social networks, social network "tabs," or other online, mobile, or wireless offerings that post a link to this privacy policy.
"Visitor" means any person who visits any of our Websites.
"you" and "your" means, depending on the context, either a Member, a Contact, or a Visitor.
Privacy for Members
This section applies to the Personal Information we collect and process from a Member or potential Member through the provision of the Services. If you are not a Member, the Visitors or Contacts section of this policy may be more applicable to you and your data. In this section, "you" and "your" refer to Members and potential Members.
Information We Collect
The Personal Information that we may collect broadly falls into the following categories:
(i) Information you provide to us: In the course of engaging with our Services, you may provide Personal Information about you and your Contacts. Personal Information is often, but not exclusively, provided to us when you sign up for and use the Services, consult with our customer service team, send us an email, integrate the Services with another website or service (for example, when you choose to connect your e-commerce account with ATF), or communicate with us in any other way.
We will let you know prior to collection whether the provision of Personal Information we are collecting is compulsory or if it may be provided on a voluntary basis and the consequences, if any, of not providing the information. By giving us this information, you agree to this information being collected, used and disclosed as described in our Terms of Use and in this privacy policy.
(ii) Information we collect automatically: When you use the Services, we may automatically collect certain information about your device and usage of the Services. We use cookies and other tracking technologies to collect some of this information. Our use of cookies and other tracking technologies is discussed more below, and in more detail in our Cookie Statement
(iii) Information we collect from other sources: From time to time, we may obtain information about you or your Contacts from third-party sources, such as public databases, social media platforms, third-party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally or contractually permitted to disclose such information to us.
Use of Personal Information
We may use the Personal Information we collect through the Services or other sources for a range of reasons, including:
• To send you event alerts and ecosystem news/messages.
• To communicate with you about our programs and provide customer support.
• To enforce compliance with our Terms of Use and applicable law, and to protect the rights and safety of our Members and third parties, as well as our own. This may include developing tools and algorithms that help us prevent violations.
• To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms.
• To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
• To prosecute and defend a court, arbitration, or similar legal proceeding.
• To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• To provide, support and improve the Services. For example, this may include sharing your or your Contacts’ information with third parties in order to provide and support our Services or to make certain features of the Services available to you.
• Other purposes. To carry out other legitimate business purposes, as well as other lawful purposes about which we will notify you.
Cookies and Tracking Technologies
We and our partners may use various technologies to collect and store information when you use our Services, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on your behalf. These web beacons track certain behavior such as whether the email sent through the Services was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as the recipient’s IP address, browser, email client type and other similar details. We use this information to measure the performance of your email campaigns, and to provide analytics information and enhance the effectiveness of our Services. Reports are also available to us when we send email to you, so we may collect and review that information.
Other Data Protection Rights
You and your Contacts may have the following data protection rights:
• To access, correct, update or request deletion of Personal Information. ATF takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete and up to date. As a Member, you can manage many of your individual account and profile settings within the dashboard provided through the ATF platform, or you may contact us directly by emailing us at [email protected]. You can also manage information about your Contacts within the dashboard provided through the ATF platform to assist you with responding to requests to access, correct, update or delete information that you receive from your Contacts.
• In addition, individuals who are residents of the EEA can object to processing of their Personal Information, ask to restrict processing of their Personal Information or request portability of their Personal Information. You can exercise these rights by contacting us using the contact details provided in the "Questions and Concerns" section below. If any of your Contacts wishes to exercise any of these rights, they should contact you directly, or contact us as described in the "Privacy for Contacts" section below.
• Similarly, if Personal Information is collected or processed on the basis of consent, the data subject can withdraw their consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent. If you receive these requests from Contacts, you can segment your lists within the ATF platform to ensure that you only market to Contacts who have not opted out of receiving such marketing.
• The right to complain to a data protection authority about the collection and use of Personal Information. For more information, please contact your local data protection authority. Contact details for data protection authorities in the EEA are available here.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection law. We may ask you to verify your identity in order to help us respond efficiently to your request. If we receive a request from one of your Contacts, we will either direct the Contact to reach out to you, or, if appropriate, we may respond directly to their request.
Privacy for Contacts
This section applies to the information we process about our Members’ Contacts as a data controller pursuant to our legitimate business interests. Our Services are intended for use by our Members. As a result, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our Members. ATF is not responsible for the privacy or security practices of our Members, which may differ from those set forth in this privacy policy. Please check with individual Members about the policies they have in place. For purposes of this section, "you" and "your" refer to Contacts.
We and our partners may use various technologies to collect and store information when you interact with a Member’s email campaign or connected store, and this may include using cookies and similar tracking technologies, such as pixels and web beacons. For example, we use web beacons in the emails we send on behalf of our Members. When you receive and engage with a Member’s campaign, web beacons track certain behavior such as whether the email sent through the ATF platform was delivered and opened and whether links within the email were clicked. They also allow us to collect information such as your IP address, browser, email client type, and other similar details. We use this information to measure the performance of our Members’ email campaigns, and to provide analytics information and enhance the effectiveness of our Services.
Legal Basis for Processing
We process Personal Information about you as a data controller as described in this section, where such processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. Our legitimate interests typically include: improving, maintaining, providing, and enhancing our technology, products and services; ensuring the security of the Services and our Website; and for our marketing activities.
Other Data Protection Rights
You may have the following data protection rights:
• To access, correct, update or request deletion of your Personal Information. ATF takes reasonable steps to ensure that the data we collect is reliable for its intended use, accurate, complete, and up to date. You may contact us directly at any time about accessing, correcting, updating or deleting your Personal Information, or altering your data, by emailing us at [email protected]. We will consider your request in accordance with applicable laws.
• In addition, if you are a resident of the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by emailing us at [email protected].
• You have the right to complain to a data protection authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority. As described above, for much of the Personal Information we collect and process about Contacts through the Services, we act as a processor on behalf of our members. In such cases, if you are a Contact and want to exercise any data protection rights that may be available to you under applicable law or have questions or concerns about how your Personal Information is handled by ATF as a processor on behalf of our individual Members, you should contact the relevant Member that is using the ATF Services, and refer to their separate privacy policies.
If you no longer want to be contacted by one of our Members through our Services, please unsubscribe directly from that Member’s newsletter or contact the Member directly to update or delete your data. If you contact us directly, we may remove or update your information within a reasonable time and after providing notice to the Member of your request.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to verify your identity in order to help us respond efficiently to your request.
Privacy for Visitors
How We Share Information
We may share and disclose your Personal Information to the following types of third parties for the purposes described in this privacy policy (for purposes of this section, "you" and "your" refer to Members, Contacts, and Visitors unless otherwise indicated):
(i) Our service providers: Sometimes, we share your information with our third-party service providers, who help us provide and support our Services and other business-related functions.
(ii) Advertising partners: We may partner with third-party advertising networks and exchanges to display advertising on our Websites or to manage and serve our advertising on other sites and may share Personal Information with them for this purpose.
(iii) Any competent law enforcement body, regulatory body, government agency, court or other third party where we believe disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish, or defend our legal rights, or (c) to protect your vital interests or those of any other person.
(iv) A potential buyer (and its agents and advisors) in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition.
(v) Any other person with your consent.
Your Choices and Opt-Outs
Members and Visitors who have opted in to our marketing emails can opt out of receiving marketing emails from us at any time by clicking the "unsubscribe" link at the bottom of our marketing messages.
Also, all opt-out requests can be made by emailing us using the contact details provided below.
Our Security
We take appropriate and reasonable technical and organizational measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. If you have any questions about the security of your Personal Information, you may contact us at [email protected].
International Transfers
(i) We operate in the United States
Our servers and offices are located in the United States, so your information may be transferred to, stored, or processed in the United States. While the data protection, privacy, and other laws of the United States might not be as comprehensive as those in your country, we take many steps to protect your privacy.
Retention of Data
We retain Personal Information where we have an ongoing legitimate business or legal need to do so. Our retention periods will vary depending on the type of data involved, but, generally, we'll refer to these criteria in order to determine retention period:
• Whether we have a legal or contractual need to retain the data.
• Whether the data is necessary to provide our Services.
• Whether our Members have the ability to access and delete the data within their ATF accounts.
• Whether our Members would reasonably expect that we would retain the data until they remove it or until their ATF accounts are closed or terminated.
• When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
California Privacy
Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third-parties’ direct marketing purposes, and (b) the names and addresses of all such third parties. To request the above information, please contact us at [email protected].
Changes to this Policy
We may change this privacy policy at any time and from time to time. The most recent version of the privacy policy is reflected by the version date located at the top of this privacy policy. All updates and amendments are effective immediately upon notice, which we may give by any means, including, but not limited to, by posting a revised version of this privacy policy or other notice on the Websites. We encourage you to review this privacy policy often to stay informed of changes that may affect you. Our electronically or otherwise properly stored copies of this privacy policy are each deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this privacy policy that was in effect on each respective date you visited the Website.