Privacy Policy

Welcome to the website for Africa Business Heroes (https://africasnextyoungmillionaire.com) (the “Site”), which is an initiative of Basil David Anthony Foundation (hereinafter refeered to as the “BDA”, the “Foundation”, “we”, “us”, etc.)

This Privacy Policy is incorporated into the BDA Disclaimers (“Disclaimers”) and BDA Terms and Conditions by reference. Any terms used in this Privacy Policy will have the same meanings as those in the Disclaimers unless otherwise specified. Your privacy is important to us and this Privacy Policy applies to the information collected, stored, and used when you use the Site, participate in any part of the BDA Programme and our Services. This Privacy Policy does not apply to information collected through any third party websites, platforms or services that you may access through our Services. Our “Services” mean the services provided by us which includes the use of the Site, the BDA Programme and any other events or activities organized by us at any time.

We recognize the importance of privacy as well as the importance of maintaining the confidentiality of personal information. This Privacy Policy applies to all products and services provided by us and sets out how we collect, use and disclose information in relation to users of the Site (however accessed). Please read this Privacy Policy carefully and make sure that you properly understand the provisions. Please do not use our Site if you disagree with any of the terms of this Privacy Policy.

  1. Important information about us and the Site

BDA is the controller and responsible for your personal data.

If you have any questions about this Privacy Policy or our privacy practices, please contact us via email privacy@anym.global/a>.

This Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit.

 

  1.  Collection Of Information

 

Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our Services and to protect your account.

When you create an account on our Site, submit an application to participate in or, participate as a judge in any part of the BDA Programme, request marketing information to be sent to you or otherwise contact us, you may be required to provide us with certain information including but not limited to:

  • your name, address, phone number, email, school, company name, nationality, gender, date and/or year of birth, criminal history.
  • information about your activities on our Services and BDA’s activities.
  • In addition, you will also be required to provide us with content related to your business, such as your number of employee(s), revenue history, and the revenue model you use.

Together this is referred to as “User Generated Content”.

We will need the User Generated Content in order to determine your eligibility for the BDA Programme.

We may also collect and use your live stream videos, your social media account names and profile photos, and posts or comments made by you when you use certain interactive features of the Site or referencing the Site or BDA through any social media sites (to the extent that you have consented to sharing this information with the Site). As you interact with our Site, we will automatically collect certain technical data about your equipment, browsing actions and patterns. Please see our cookie policy in Section 6 below for further details. We may also collect information about how your device has interacted with our Services, including the pages accessed and links clicked

We may receive personal data about you from various third parties and public sources if we have to verify any part of the information included in your application to participate in the BDA Programme.Certain data we collect may be defined as personal data under applicable data protection law. The information that we collect from you, including but not limited to the User Generated Content and the personal information described in this Privacy Policy is referred to as “Personal Data”. The only sensitive personal data that we collect from You is your gender and in certain cases biometric data (“Sensitive Personal Data”).

2.6 We will only be able to collect your Personal Data which includes the Sensitive Personal data if you voluntarily submit the Personal Data to us or as otherwise provided for under this Privacy Policy. Unfortunately, if you choose not to submit your Personal Data to us or subsequently withdraw your consent to our use of your Personal Data, you may not be able to participate in the BDA Programme , you also may not be able to access the Site or we may not be able to provide you with our Services.

If you contact us (by email or otherwise), we may record your conversation with us or a copy of your correspondence with us and collect additional information to verify your identity.  This will form part of the Personal Data.

 

  1. Use Of Personal Data

 

We shall use your Personal Data in accordance with this Privacy Policy or as otherwise permitted by law according to where you are located.

Such permitted uses may include the following circumstances:

  • we may use your information we collect to pursue our mission and operations and to engage in the activity and related activities for which we collect it.
  • Specifically, we collect and use your Personal Data for the following purposes:
  • verifying your identity;
  • verifying your eligibility to register as a user of the Site or to participate in the BDA Programme;
  • processing your registration as a user, providing you with a log-in ID for the Site and maintaining and managing your registration;
  • responding to your queries, feedback, claims or disputes;
  • where we need to fulfil our obligations to you, for example in relation to the BDA Programme or otherwise in the provision of the Services;
  • notifying you of any related contests, promotions, special events and/or offers organised by BDA that we think might be of interest to you.  You can unsubscribe at any time by clicking on the link in the emails or by writing to us;
  • fulfilling our obligations to you and to respond to any questions or requests from you; to contact you about material changes in our Site, terms or policies; to comply with the applicable law(s) or in good faith belief that such action is necessary to conform with the requirements of applicable law(s) or to comply with legal process served on us;
  • implementing security measures to protect our Services, your account and data processed for our Services against fraud and other security incidents;
  • carrying our audience measurement / marketing and analytics to help us improve our Services.

Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests (see section 5. COOKIES below). You will receive marketing communications from us if you have requested information from us and you have not opted out of receiving that marketing.

We may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

 

  1. Disclosure Of Personal Data

 

We may disclose and transfer (whether within or outside the jurisdiction of the entity that is the controller) Your Personal Data to our partners and to service providers (including without limitation those that provide back-office or IT services, or marketing and promotional services, catering services or security services in relation to the BDA Programme) engaged by us who process Personal Data for purposes described in this Privacy Policy or notified to you when we collect your Personal Data.

  • In particular, we may also share your Personal Data with the following parties:
    1. If you apply for or take part in any aspect of the BDA Programme, we will use the Personal Data you provide to find out about you and share it with the BDA judges, website developers, partners, service providers and vendors;
    2. Internal third parties that are affiliated with BDA and/or their designated service providers.;
    3. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy policy

We require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

In addition, we may also include your Personal Data (including, without limitation, full name, biographical information, photos and videos of you and contact details) in promotional or marketing materials (including, without limitation, video and/or audio recordings, photographs, live streaming, broadcasts, brochures and adverts) related to the BDA Programme and the finale event for the BDA Prize Competition, the BDA Show, which will be disseminated to and made available to the public worldwide.

When we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations.

We may also disclose your Personal Data to any other person for any other reason with your prior consent to the disclosure.

We retain your Personal Data as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

Please be aware that any information that you submit to the Site for publication or by using any interactive feature that is publicly available may be made publicly available on the Site and therefore accessible by any internet user. You should exercise caution when deciding what information you submit to us for publication.

We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is in a de-identified format that does not personally identify you.

 

  1. Rights Regarding Personal Data

 

Under the applicable laws, you may have the rights of access to Personal Data held by us and other rights, including the right to correction of false or misleading data.

If you have any questions regarding this Privacy Policy or if you wish to access or correct your Personal Data as a user of the Site, you may send your request to privacy@anym.global.

If and to the extent permitted by applicable law, we may charge you a fee for the processing of any request you make regarding your Personal Data.

 

  1. Cookies

 

We use “cookies” to store specific information about you and track your visits to the Site, either through a computer or via a mobile device. It is not uncommon for websites to use cookies to enhance identification of their visitors.

A “cookie” is a small amount of data that is sent to your browser and stored on your computer’s or mobile device’s hard drive. If you do not de-activate or erase the cookies, each time you use the same browser or mobile device to access the Site, our web servers will be notified of your visit to the Site and in turn we may have knowledge of your visit and the pattern of your usage. The cookies will enable us to remember your information so you do not have to re-enter it every time you use the Site.

In addition, we use cookies to manage the security of our Site, to gather information about usage by users; to research visiting patterns and conduct interest-based advertising; to assist our partners to track user visits to the Site and process orders; and to track progress and participation in the BDA Programme.

For these additional purposes identified above, you can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the Site or the privacy setting of your mobile device. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.

You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to reject cookies, you may still use our Site though your access to some functionality and areas of our website may be restricted.

Certain features of the Site depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.

We use two types of cookies: session cookies (which are erased once you close the browser or shut down the device) and persistent cookies (which remain even after closing the browser or shutting down the device/application and which are activated each time you visit the Site). The session cookies use encrypted data to unambiguously authenticate you. The persistent cookies do not store account numbers or passwords.

We use both first party cookies (cookies that are set by us and serve mainly to enable basic functionality on our Site, including web analytics cookies that help us understand how users use our web pages and how we can improve their use) and third party cookies (these cookies are not set by us, but by our selected partners).

In addition, we also use social media cookies. Some pages on our Site allow you to “share” content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites set their own cookies on which we have no influence. To refuse their cookies, please follow the instructions on their websites. In addition, these websites have their own privacy policy, which you can find on the respective websites.

Our Site uses Google Analytics, an internet analytics service provided by Google, Inc., 1600 Amphitheater Parkway Mountain View, California, 94043, USA (“Google”). Google Analytics uses “cookies”, which are text files that are stored on your computer and used to analyze the use of the Site. For example, Google’s cookies allow us to know which pages our users are viewing, which ones are most popular, what time of day our Site are visited, if users have previously visited our Site, from which website users are redirected to our Site were and the like. The data generated by the cookies about your use of the Site will be transmitted to Google and may be stored by Google on servers in the United States.

Google Analytics uses an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. The non-truncated IP address are only exceptionally transmitted to Google’s servers in the US and then truncated there.

Google uses the data on behalf of the website operator to evaluate your use of the website, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google.

For more information about Google Analytics cookies, visit the Google Help pages and Privacy Policy:

Google Privacy Policy: https://policies.google.com/privacy

Google Analytics Help Center: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookies-usage

The IP address that your browser will pass on to Google Analytics will not be associated with any other data stored by Google. Through your browser settings, you can block cookies; however, this can lead to problems with the use of some functionalities of our website. Through the add-on “Google Analytics Opt-out” you can through your current web browser opt-out to the use of Google Analytics from then on: http://tools.google.com/dlpage/gaoptout?hl=en.

More information can be found here: https://support.google.com/analytics/answer/6004245.

 

  1. Minors

 

The BDA Programme and in particular the BDA Prize Competition is open to applicants of all ages. Minors (those under the age of 18, unless the age of consent is lower according to where you are located) should only provide Personal Data with parental or guardian consent. If you are a minor, you cannot submit an application without parental or guardian consent.   If a minor has provided us with Personal Data, the parent or guardian should contact privacy@anym.global if they have any concerns or to ask us to remove the information.

 

  1. Security Measures

 

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. We also employ commercially reasonable security methods to prevent unauthorized access to the Site, to maintain data accuracy and to ensure the correct use of the information we hold.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

For registered users of the Site, some of your information can be viewed and edited through your account, which is protected by a password; however, once you have submitted your application, you will not be able to edit your information. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.

 

  1. Your Right To Opt Out

 

You will receive marketing communications from us if you have requested information from us or otherwise used our Services and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the directions provided inside the opt-out links on any marketing message sent to you

Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of the provision of the Service or in relation to your application for the BDA Prize Competition unless you wish to withdraw your application.

 

  1. The Information We Do Not Intend To Collect

 

Some Personal Data such as your mental health condition, biometric information, sexual orientation, or medical history, is considered “sensitive” in some jurisdictions, and is subject to heightened regulation than the other types of Personal Data. We do not intend to collect such Sensitive Personal Data from you unless otherwise specified in this Privacy Policy and any such sharing of Sensitive Personal Data is entirely at your own sole discretion and risk.

Do not supply Personal Data about others unless you are authorized or required to do so by applicable law or contract and you consent to the Disclaimers and this Privacy Policy on behalf of yourself and the person(s) about whom you supply Personal Data (“Data Subject”). Before supplying Personal Data about others (except as otherwise allowed by law or contract), you must make available for the Data Subject’s review, and obtain their written consent to, said Disclaimers and Privacy Policy. By submitting any Personal Data about others, you represent and warrant that you are authorized to do so and that you did all of the foregoing before submitting the information. If applicable law allows you to supply the information without doing the foregoing, you represent and warrant that you have abided by such applicable law and that it allows us to receive and disclose the information under this Policy without any further action on our part. You agree to indemnify, defend and hold us harmless against any failure by you to comply with this paragraph.

 

  1.  Terms Applicable to Individuals from the European Union

 

If you use our Site or Services covered by this Privacy Policy from a country that is a Member State of the European Union please read our supplemental terms available at the end of our Privacy Policy

 

  1. International transfers

 

Whenever we transfer your personal data to another jurisdiction, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your Personal Data where there are appropriate safeguards in place with respect to the security and protection of personal data;
  • We will only transfer your Personal Data where there are appropriate safeguards in place with respect to the security and protection of Personal Data and to countries that are deemed to provide an adequate level of protection for personal data; or
  • Where the transfer is necessary for the performance of a contract between us or between you and our appointed data processor.

We will only transfer your Sensitive Personal Data, with your consent (please see Clause 13 below) and where there are appropriate safeguards in place with respect to the security and protection of personal data.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data to another jurisdiction.

 

  1.  Your Particular Consent

 

You are giving us the following particular express, voluntary, and informed consent to a few activities relating to your Personal Data that is disclosed in furtherance of our mission and operations, or for a purpose directly related to such purpose:

  1. Consent to International Transfer and Disclosure of Personal Data (including Sensitive Personal Data). We are involved in programs and activities in a variety of countries. You agree that BDA and those with whom we share your Personal Data, including your Sensitive Personal Data (“Recipients”) may disclose and transfer your Personal Data worldwide to our affiliates, sponsors and partners, and any other third party service providers for any purpose to further our mission and operations.  We require all Recipients to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow Recipients to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
  2. Consent to Electronic Notice If There is a Security Breach: We will safeguard your Personal Data and prevent such information from unauthorized access, disclosure, or use. If we or a Recipient is required to provide notice of unauthorized access to or other invasion of certain security systems, you agree that we (or they) may do so when required (or voluntarily) by posting notice on our Site or sending notice to any email address we have for you, in our (or their) good faith discretion. You agree that notice to you will count as notice to others for whom you are acting, and agree to pass the notice on to them.
  3. Storage of Personal Data: Our servers are currently located in Dubai and for this reason we may store your Personal Data including your Sensitive Personal Data outside of the region or country that you may submit or use it in.

 

  1. Retention Period

 

We keep Personal Data for as long as we think is necessary or advisable and we reserve the right to retain it to the full extent not prohibited by law. We may discard Personal Data in our discretion, so you should retain your own records, and not rely upon our storage of any Personal Data, content, or other data.  To determine the appropriate retention period for your Personal Data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Subject to applicable laws and regulations, you may have the right to inquire and request for a review of, request a copy of, make supplements or corrections to, discontinue collection, processing or use of, or request to delete some or all of your Personal Data at our possession. Please contact us if you have any inquiries as to what information we have concerning you, and submit your new information if your Personal Data has changed.

In some circumstances we will anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

  1. Changes To This Privacy Policy

 

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on the Site. Once posted on the Site, the new Privacy Policy will be effective immediately. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

 

  1. Contact Us

 

You may write to us at privacy@anym.global for any privacy concerns and requests relating to these Disclaimers, this Privacy Policy, or our Site and Services.

 

ANNEX:  Terms Applicable to Individuals from the European Union ONLY

 

These additional terms set out here are in addition to our Privacy Policy and apply only if you use our Site or Services covered by this Privacy Policy from a country that is a Member State of the European Union, and supplements the information in this Privacy Policy.

  1. Your Rights

The data protection laws of the European Economic Area and other territories grant their citizens certain rights in relation to their Personal Data. If you are a resident of the European Economic Area, you have the following rights in relation to your Personal Data which you can exercise at any time by contacting us using the contact details provided under the HOW TO CONTACT US section below or by following the instructions provided below:

(a) Right of Access.

You have the right to access your Personal Data that we hold about you, (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained.

(b) Right to Rectification.

If your Personal Data is inaccurate or incomplete, you can change the information you provided by contacting us.

(c) Right to Erasure.

You have the right to request deletion of your Personal Data.

(d) Right to Complain. You also have the right to lodge a complaint at a supervisory authority. For more information, please contact your local supervisory authority.

If we have collected and process your personal information with your consent, then you have the right to withdraw your 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.

(e) Right to Opt Out Of Marketing. You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” link in the marketing e-mails we send you.

  1. International Transfers of Personal Data

Our business may require us to transfer your Personal Data to countries outside of the European Economic Area (“EEA”), including to countries that may not provide the same level of data protection as your home country such as Australia and China. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement appropriate measures to ensure your Personal Data will remain protected in accordance with this Privacy Policy, such as standard contractual clauses. A copy of those clauses can be obtained by contacting us at privacy@africabusinessheroes.org.

  1. Legal Basis for Data Processing

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect and process Personal Data about you only where it is: necessary for the performance of any contract between you and BDA (for example, to provide you with the services you request and to identify and authenticate you so you may use the Site); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent.

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Site and/or other Services, manage our relationship with you and communicate with you as necessary to provide our Services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Site and our Services, undertaking marketing, or for the purposes of ensuring the security of our Site. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Site.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us at privacy@anym.global