Privacy Policy

Our Services are designed to encourage lasting meaningful relationships and to promote economic, professional, and growth opportunities for our Members by enabling you and other community members to learn from each other, share experiences, find synergy, blog, poll, and find employment or employees, among other things.

Registered users of our Services are “Members” and unregistered users are “Visitors.” This Privacy Policy applies to both. Our Members share their professional identities, engage with their network, exchange knowledge and professional insights, share photos and memories, post and view relevant content, and learn and find business and career opportunities.

Content and data on some of our Services is viewable to Visitors.

We use the term “Designated Countries” to refer to countries in the European Union (EU),

European Economic Area (EEA), and Switzerland.

1.1. Services

This Privacy Policy applies to your use of Agbora.com, Agbora-branded apps, and any other Agbora-related sites, apps and communications (“Services”), including the offsite collection of data for those Services, such as our ads.

Agbora.com, Agbora-branded apps, and any other Agbora-related sites or apps, are owned and operated by Agbora, Inc., which is a Delaware corporation.

Agbora, Inc. will be the controller of your personal data provided to, or collected by or for, or in connection with, our Services.  You are entering into the User Agreement with Agbora, Inc. As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy, including any updates.

Agbora (“we” or “us”) can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge and agree that if you use our Services after we publish or send a notice about our changes to this Privacy Policy, then the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

You provide data to create an account with us.

Every Member has to register an account with us. To create an account, you provide data including, but not limited to, your name, photo, email address and/or mobile number, bio, employment and educational history, and a password.

Every Member’s account is associated with a profile page. You have choices about the information on your profile, such as your bio, education, work experience, skills, photo, and city, state, or area. Your profile information helps you to get more from our Services, including helping followers, contacts, and/or business opportunities find you. What information you decide to place on your profile is your choice.

Depending on your settings, a version of your profile may also be visible to users who aren’t logged in to Agbora and are searching for your profile on search engines like Bing, Google, etc.

We do not require Members to include sensitive data (e.g., race, ethnicity, political opinions, religious or philosophical beliefs, membership of a trade union, physical or mental health, sexual life or criminal record) in their Agbora profile. Posting such data is optional, but not required. If you choose to post any such data to your profile, understand that it may be visible to others as noted above.

Please do not post or add personal data to your profile that you would not want to be publicly available.

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, respond to a survey or poll, or share a post.

3.1. Information from Others

Others may post or write about you.

You and others may post content that includes information about you on our Services (e.g. as part of blog posts, feed updates, polls, or comments). We collect public information about you, such as professional-related news and accomplishments and make it available as part of our Services.

3.2. Service Use

We log your visits and use of our Services, including mobile apps.

We log usage data when you visit or otherwise use our Services, including our sites, app and platform technology, such as when you view or click on content or ads (on or off our sites and apps), perform a search, install one of our mobile apps, share articles, polls, or posts. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

3.3. Cookies, Web Beacons and Other Similar Technologies

We collect data through cookies and similar technologies.

As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy. You can control cookies through your browser settings and other tools.

3.4. Your Device and Location

We receive data from your devices and networks, including location data.

When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device will send us data about your location. Most devices allow you to prevent location data from being sent to us and we honor your settings.

3.5. Messages

If you communicate through our Services, we learn about that.

We collect information about you when you send, receive, or engage with messages in connection with our Services. For example, if you get an Agbora connection request or message, we track whether you have acted on it and will send you reminders. We also use automatic scanning technology on messages.

3.6. Workplace Provided Information

An employer (or other person or entity procuring our Services for your use) may provide us information about their employees or contractors who make use of these Services.

3.7. Sites and Services of Others

We get data when you visit sites that include our plugins, ads or cookies or log-in to others’ services with your Agbora account.

We receive information about your visits and interaction with services provided by others when you log-in with Agbora or visit other services that include our plugins, ads, cookies or similar technologies.

3.8. Other

We continue to improve our Services, which means we get new data and create new ways to use data.

Our Services are dynamic and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your account settings. We use the data that we have about you to provide, support, personalize and make our Services (including ads) more relevant and useful to you and others.

4.1. Services

Our Services help you connect with others, grow your circle and community, find and be found for work and business opportunities, stay informed, and be more productive.

We use your data to authenticate you and authorize access to our Services.

Stay Connected

Our Services allow you to connect with Africans, the African Diaspora, and others from around the world, and to foster an environment where professionals, talents, community members, and leaders can share memories, ideas, interests, and objectives in a network of trusted relationships.

To do so, you will “connect” with the Members who you choose, and who also wish to “connect” with you. You will also decide who can “follow” you, along with your updates and contributions. When you connect, you will be able to search each others’ connections and followers, based on selected privacy settings, in order to network further and exchange opportunities.

We will use data about you (such as profiles you have viewed or data provided through address book uploads) to suggest connections for you and others and enable you to invite others to become a Member and connect with you.

It is your choice whether to invite someone to our Services, send a connection request, or allow another Member to become your connection or follow you. When you invite someone to connect with you, your invitation will include your name, photo, network and contact information. We will send invitation reminders to the person you invited.

Stay Informed

Our Services allow you to stay informed about news, events and ideas regarding topics you care about, and from Members you respect and follow. Our Services also allow you to improve your skills, or learn new ones. We use the information about you to recommend relevant content across our Services, suggest skills you may have to add to your profile and skills that you might need to pursue your next opportunity.

So, if you let us know that you are interested in a new skill (e.g., by your activities on Agbora), we will use this information to personalize content in your feed, and suggest that you follow certain Members on our site. We use your content, activity and other data, including your name and picture, to provide notices to your network and others. For example, subject to your settings, we may notify others that you have updated your profile, posted a story or poll, added media, took a social action, or made new connections.

Growth

Our Services allow you to develop and grow your personal brand, explore careers, evaluate educational opportunities, and seek out, and be found for growth opportunities. Your profile can be found by those looking to hire or be hired by you. We will use your data to recommend jobs and opportunities, and show you and others who work at a company, in an industry, function or location or have certain skills and connections. We may use your profile and activity to recommend jobs to you and to others interested in your skill sets.

Productivity

Our Services allow you to collaborate with colleagues, search for potential clients, customers, partners and others to do business with. Our Services allow you to communicate with other influencers, professionals, talents, and community leaders, and schedule and prepare meetings with them.

4.2. Communications

We contact you and enable communications between Members. We offer settings to control what and how often you receive messages.

We will contact you through email, notices posted on our websites or apps, messages to your Agbora chat inbox, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, job suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

We also enable communications between you and others through our Services, including for example invitations, groups and messages between Members.

4.3. Advertising

We serve you tailored ads both on and off of our Services.

We may target (and measure the performance of) ads to Members, Visitors and others both on and off of our Services through a variety of ad networks and exchanges, using the following data, whether separately or combined:

• Data from advertising technologies on and off of our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
• Member-provided information (e.g., contact information, title and industry);
• Data from your use of our Services (e.g., search history, feed, content you read, who you follow or is following you, connections, groups participation, page visits, videos you watch, and clicking on an ad, etc.);
• Information from others (e.g. advertising partners, publishers and data aggregators);
• Information inferred from data described above (e.g., using job titles to infer age, industry, seniority, and compensation bracket; or names to infer gender).

We will show you ads called sponsored content which look like similar non-sponsored content, except that they are labeled ads or sponsored. If you take an action (such as like, comment or share) on these ads, your action is associated with your name and viewable by others, including the ad provider.

Info to Advertisers

We do not share your personal data with any third-party advertisers or (other than hashed or device identifiers, to the extent they are personal data in some countries) ad networks for their advertising without your separate permission. However, if you click on an ad, the ad poster will know you visited the page that you clicked on. Also, advertising partners can associate personal data collected by the advertiser directly from you with our cookies and similar technologies. In such instances, we seek to contractually require such advertisers to obtain your explicit, opt-in consent before doing so.

4.4. Marketing

We promote our Services to you and others.

We use data and content about Members for invitations and communications promoting membership and network growth, engagement and our Services.

4.5. Developing Services and Research

We develop our Services and conduct research.

Service Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help connect our members to each other and to economic opportunity.

Other Research

We seek to build various communities of trusted  and collaborative relationships, and to create economic opportunity for our members and to help them be more productive and successful. We use the data available to us to research social, economic and workplace trends such as jobs availability and skills needed for these jobs and policies that help bridge the gap in various industries and geographic areas. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish economic insights, presented as aggregated data rather than personal data.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys and you have choices about the information you provide.

4.6. Customer Support

We use data to help you and fix problems.

We use the data (which can include your communications) needed to investigate, respond to and resolve complaints and Service issues (e.g., bugs).

4.7. Aggregate Insights

We use data to generate aggregate insights.

We use your information to produce aggregate insights that do not identify you. For example we may use your data to generate statistics about our users, their interests, profession or industry, the number of ad impressions served or clicked on, or the demographic distribution of visitors to a site.

4.8. Security and Investigations

We use data for security, fraud prevention and investigations.

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

5.1. Our Services

Any information you include on your profile and any content you post or social action (e.g. likes, follows, comments, shares) you take on our Services will be seen by others.

Profile

Your profile is fully visible to all Members and customers of our Services.

Posts, Likes, Follows, Comments, Messages

Our Services allow viewing and sharing information including through posts, follows, likes and comments.

• When you share a post (e.g., an update, photo, video or blog), the default (which you can change) is to share it publicly to everyone. Others who are not your connections will be able to find (including through search engines) and see your post.
• When you like, comment on or share another’s post, others will see it, including the person who initiated the post.
• In a group, posts are visible to others in the group. Your membership in groups is public and part of your profile.
• Any information you share through companies’ or other organizations’ pages on our Services will be viewable by it and others who visit those pages.
• When you follow a person or organization, you are visible to others and that “page owner” as a follower. We provide aggregate insights about the followers and viewers to the respective page owners.
• We let senders know when you act on their message.

5.2. Communication Archival

Regulated Members may need to store communications outside of our Service.

Some Members (or their employers) need, for legal or professional compliance, to archive their communications and social media activity, and will use services of others to provide these archival services. We enable such archiving outside of our Services. For example, a financial advisor needs to archive communications with her clients through our Services in order to maintain her professional financial advisor license.

5.3. Related Services

We share your data across our different Services and Agbora-affiliated entities.

We will share your personal data with our affiliates to provide and develop our Services. We combine information internally across the different Services covered by this Privacy Policy.

5.4. Service Providers

We may use others to help us with our Services.

We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

5.5. Legal Disclosures

We may need to share your data when we believe it’s required by law or to protect your and our rights and security.

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Agbora, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

5.6. Change in Control or Sale

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

6.1. Data Retention

We keep most of your personal data for as long as your account is open.

We retain the personal data you provide while your account is in existence or as needed to provide you Services. Even if you only use our Services when looking for new contacts and opportunities every few years, we will retain your information and keep your profile open until you decide to deactivate and close your account. In some cases we choose to retain certain information in a depersonalized or aggregated form.

6.2. Rights to Access and Control Your Personal Data

You can access or delete your personal data. You have many choices about how your data is collected, used and shared.

We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts and communication controls. We offer access to the personal data we have about you.

6.3. Account Closure & Deactivation

We keep some of your data even after you close your account.

If you choose to close and deactivate your Agbora account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

Information you have shared with others (e.g., through messages, updates or group posts) will remain visible after you closed your account or deleted the information from your own profile or mailbox, and we do not control data that other Members copied out of our Services. Groups content associated with closed accounts will show an unknown user as the source. Your profile may continue to be displayed in the services of others (e.g., search engine results) until they refresh their cache.

7.1. Security

We implement security safeguards designed to protect your data, such as HTTPS. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

7.2. Direct Marketing and Do Not Track Signals

Our statements regarding direct marketing and “do not track” signals.

We currently do not share personal data with third parties for their direct marketing purposes without your permission.

You can contact us or use other options to resolve any complaints.

If you have questions or complaints regarding this Privacy Policy, please first contact us through Agbora.com or at contact@Agbora.com. If you feel you haven’t received a timely or satisfactory response, you can contact the applicable independent recourse below:

EU Data Protection Authorities (DPAs)

Swiss Federal Data Protection and Information Commissioner (FDPIC)