1. Background
Impact Capital Africa, (“Impact Capital Africa”, “ICA”, “we”, “us” or “our”), is an online and face to face resource for leaders in the development of the Zambian and African economy through investment. We operate a news and information website, publish regular briefings, provide consulting services, and organise invitation and ticketed events.
ICA is committed to respecting the privacy of every person who visits, registers with, or subscribes to our website, publications, events and other products or services. We will only collect and use information in ways that are useful to you and in a manner consistent with your rights and our obligations under the law.
ICA is the primary data controller of personal data collected through this website or that we may collect in different ways as described in this Privacy Policy. You can contact ICA directly by emailing [email protected].
This Privacy Policy applies to any and all data collected by us in relation to your use of our Site. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of our Privacy Policy is deemed to occur upon your first use of our Website. If you do not accept and agree with this Privacy Policy, you must stop using our Website immediately.
2. Our approach to your privacy
This Privacy Notice outlines the information we may collect about you in relation to your use of our products and services (“personal data”). It also explains the legal rights that you have in relation to your data and how you may exercise these rights.
We will process your data for the following lawful purposes: with your consent; to fulfil our obligations to you; and where there is a legitimate interest to do so.
Whenever possible, we rely on your consent to use your data for the purposes described in this Privacy Notice. We also process personal data to fulfil our contractual obligations to you, for example, when you register for any of our services, subscribe to a publication, sign-up for an event or purchase a product from us, we will need to process some of your personal data. This will also include details of the person/people responsible for payment (if different).
We may determine that processing your personal data serves both of our legitimate interests. This is the case in relation to many of our research, customer survey, sales, marketing, and advertising activities described in this Privacy Policy. These activities allow us to better understand your requirements, which in turn enables us to provide you with a better service.
We review the bases for our processing decisions carefully and you can object to these activities at any time (see ‘Section 7 Your rights’ of this Privacy Notice).
Our primary goal in collecting personal data from you is to give you a relevant customised experience of our products and services.
3. Data we Collect
Some data will be collected automatically by our Site, other data will only be collected if you voluntarily submit it and consent to us using it to contact us or receive new/updates from us. Depending upon your use of our Site, we may collect some or all of the following data:
From Newsletter Registration we collect the following data:
- Name and Email
From SME Referral Form we collect the following data:
- Name of your company
- Registration in Zambia
- Sector(s) of operation
- Countries of operation
- Company website URL
- Name
- Role
- Phone number
- Business description
- Years of operation
- Reason for raising capital
- Investment types
- Availability of audited accounts for the last 2 years
- Availability of Business Plan
- Requirement for technical assistance
If you register for an event through our website we may collect personal data including:
- Name
- Job title
- Company
- Address
- Telephone number
If you subscribe to or purchase one or more of our paid products or services, we will also ask for payment details. Credit/debit card payments are processed using a third-party supplier and we do not retain the credit card data. Address details may be shared with third party service providers engaged by us for order fulfilment, delivery, and payment collection. This personal data is used by us to complete subscription requests.
You can withdraw your data at any time by sending an email to [email protected].
Like many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”).
This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. This data is collected automatically.
4. How do we use your data?
All personal data is stored securely in accordance with the EU General Data Protection Regulation (GDPR). We will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the GDPR and other applicable relevant laws.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- You have given consent to the processing of your personal data for one or more specific purposes.
- Processing is necessary for compliance with a legal obligation to which we are subject.
We use your data to provide the best possible services to you. This includes:
4.1. Events & Conferences
If you have registered for an event through our website we may collect personal data including: name, job title, company, address, telephone number and email.
This information is necessary so that we can complete your registration for the event and provide you with relevant event materials.
We may also provide delegate details (e.g. name, email) to event sponsors and relevant partners who, subject to your consent, may contact you for their own advertising and marketing purposes.
4.2. Surveys, Market Research & Customer Feedback
We want to understand the needs of our readers and customers. We may therefore use the information you provide us – including your name and contact details – to contact you to request your feedback, or to participate in our customer and market research.
4.3. Public forums, message boards and blogs
Some of the pages on our website, notably Impact Starter, include facilities for generating content from users and may include message boards, blogs, or other facilities. This data is treated as commercially sensitive and is only shared within the ICA team, our partners, and registered users of the Impact Starter platform.
4.4. Additional Third-Party Disclosures
We may disclose your personal data to other third parties in the following situations:
- To third party partners with whom ICA has active contracts and who facilitate the investment process. Any details shared are treated in accordance with ICA’s Privacy Policy. As of the 13th October 2020 this includes: Prospero, the Accelerated Growth for SMEs (AGS) in Zambia programme, and iBAN.
- To third party development partners that may offer programmes or support that can benefit businesses seeking finance. By submitting your details to ICA through the online Referral Form you are agreeing that ICA may share your details with these partners, where ICA deem their programmes to be useful to your business.
- To third party partners who help us by providing services such as technology, marketing, advisory or other services. These third parties only receive encrypted data and may only process personal data to provide those services to us and our users.
- Where we are required by law or regulation to do so. In each case we will seek, where practicable, to minimise the amount of data that is disclosed.
- If required to protect the rights and interests of other users and/or ICA and its affiliates (including our employees, agents, and contractors). This may include exchanging information with other companies and organisations for the purposes of fraud protection.
- In certain circumstances we may be legally required to share certain data held by us, which may include your personal information, for example, where we are involved in legal proceedings, where we are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of us.
- We may contract with third parties to provide you efficient services. These may include search engine facilities and Google analytics. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take your consent and take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of our Site including data on traffic, usage patterns and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties. Data will only be shared and used within the bounds of the law.
4.5. Email Tracking
We may include small pixel tags (small image files) within the emails we send you in order to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. We may also collect browser, location and the device used to engage with our email communications. This information allows us to better understand whether we are meeting our users’ needs and how we can improve our communications. No other information is collected. You can opt out of receiving our direct marketing emails either by following the instructions in each email, or by contacting us (see the “Who We Are” section of this Privacy Notice).
5. How and Where Do We Store Your Data?
We have a data retention policy that ensures we do not use or store your personal data for longer than necessary. We consider the following issues to determine retention periods:
- Guidance from the UK Information Commissioner or other regulatory agency, or industry best practice recommendations;
- The business rationale for collection and expiry of the purpose for which personal data was collected;
- Our ongoing ability to ensure the accuracy of the data; and
- Legal and regulatory requirements.
We may occasionally need to keep personal data for either shorter or longer periods than specified in our retention policy. In such circumstances, application of the retention period to the data will be temporarily suspended. The suspension of an applicable retention period will be carried out in a manner that respects the rights and interests of all persons concerned.
6. Security
ICA is committed to keeping your personal data secure and we will take appropriate technical and organisational measures to protect your personal data from loss, unauthorised use, disclosure, or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk. We have therefore implemented information security policies and rules, staff training on information security, and technical measures to ensure the integrity of data that we have under our control.
All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.
We employ appropriate technical and standard security procedures and processes to safeguard the confidentiality of users’ personal information. Our employees, agents and associates, do everything in their reasonable control to protect your information.
Any of our employees, agents, or partners who may have access to or maintain sensitive personal information, have entered into confidentiality agreements in order to ensure the privacy of such user information prior to sharing that information. Internally, access to all users’ information is restricted to those who need access in order to for their job responsibilities and have entered into a confidentiality agreement.
7. Your rights
You have certain rights in relation to your personal data which include the following:
7.1. Access and portability
You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.
You may request access to any personal data of yours for which ICA is responsible as controller. Unless there are legal or regulatory reasons for not doing so, we will confirm whether we process any of your personal data and if we do, we will provide you with the following information: the purposes of the processing, the categories of personal data, any recipients of your personal data, the applicable retention period and the data source. Copies of your personal data will be made available to you in a structured, machine-readable format.
You may withdraw your consent for us to use your personal data at any time by contacting us using the details set out and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide the best possible services to you.
7.2. Rectification, Restriction, Objection
You have the right to request that ICA rectify any errors in the personal data that we process. In some circumstances, you may also be able to ask for the erasure of personal data, and/or request that the processing of your personal data be restricted. You may also object to the processing of your personal data for sales or marketing purposes.
7.3. How to Exercise Your Rights
To exercise any of these rights, please contact us by email at the following addresses:
Email: [email protected]
We may need to check your identity prior to processing a request.
ICA will do our best to respond to any questions and address any of your concerns. You are also able to register any complaints regarding the processing of your personal data directly with the UK Information Commissioner.
8. Linked Websites
This Site may contain links to other websites. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage users to be aware when they leave this Site and to read the privacy statements of each website they visit that collects personal information. While we carefully choose the websites to link to, this Privacy Notice applies solely to information collected on our own Site.
9. Contacting Us
If you have any questions about our Site or this Privacy Policy, please contact us by email at [email protected]. Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.
10. Changes to Our Privacy Policy
This Privacy Policy is effective as of 09 February 2021 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time as we deem necessary or as may be required by law. Your continued use of our Site after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.
If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.
11. Business or Asset Sale
If we sell a business or assets, we may need to disclose your personal data to the prospective buyer of such business or assets.
If ICA is sold, sells our assets, or is acquired by a third party, then personal data about our customers will be acquired by that third party. A transfer of your personal data in these circumstances would be necessary so that the services you have contracted for can still be delivered, or so that you can continue to enjoy the benefits of our free and paid products and services. You will receive notice if a new controller assumes responsibility for your personal data.
12. Lead Generation and Scoring
We occasionally use the services of trusted third parties in order to ensure that the personal data we use for advertising and marketing purposes is accurate and up to date. To do this, we transfer personal data of individual leads (such as name, email, job title, location, and phone number) to these third parties who conduct research to verify the data – primarily against public information.
We may also use algorithmic software technology to help us improve the quality and relevance of marketing activities. The personal data analysed by the software includes email address, phone number, job title, address, purchase history and account information. This allows us to provide meaningful offers that are relevant to your specific profile.