Effective February 24, 2019

 

Your Privacy’s Important!

Our mission is to connect Africans and the African Diaspora, including African Americans and African Immigrants from around the world, and to foster an environment where our influencers, professionals, talents, community members, and leaders can share memories, ideas, interests, and objectives in a network of trusted relationships. 

 

We are committed to protecting the privacy and security of your personal information and to be transparent with you about the data we collect about you and how it is used and shared. The information you share with us allows us to provide you with the best possible experiences with our Services (as described below).

 

This Privacy Policy applies when you use our Services. By using our Services, you consent to our use of your data under this Privacy Policy.

 

This Privacy Policy informs you of our policies regarding the collection, use and disclosure of personally identifiable information we receive from users of our Services that can be used to identify or contact you, including, but not limited to, your name.

 

1.   Introduction

We are a social network and online platform for influencers, professionals, talents, and community members and leaders. Our Services are designed to encourage lasting meaningful relationships and to promote economic and professional opportunities for our Members by enabling you and other community members to learn from each other, find synergy, influence others, blog, poll, raise capital through community donations, 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, post and view relevant content, 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 Nexus Imagine Corp., with its principal place of business at [_].

 

Nexus Imagine Corp. 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 Nexus Imagine Corp. 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 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.

 

2.   Information We Collect

 

2.1.                  Information You Provide to Us

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, email address and/or mobile number, employment information, and a password. [If you register for a premium Service, we ask you for payment (e.g., credit card) and billing information.]

 

Every Member’s account is associated with a profile page. You have choices about the information on your profile, such as your education, work experience, skills, photo, and city or area. Your profile information helps you to get more from our Services, including helping recruiters and 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. If you choose to post any such data to your profile, understand that it is 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.

 

3.   Posting and Uploading

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 send invitations. [If you opt to import your address book, we receive your contacts (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list). If you sync your email or calendars with our Services, we will collect your “email header” and calendar meeting information (e.g. times, places, attendees and contacts).]

 

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, comments, or videos). We collect public information about you, such as professional-related news and accomplishments (e.g., patents granted, professional recognition, conference speakers, projects, etc.) and make it available as part of our Services.

 

Others may sync their contacts or calendar with our Services.

 

We receive personal data about you when others import or sync their address book or calendar with our Services, or send messages using our Services (including invites or connection requests).

 

Customers and partners may provide data to us.

 

We receive personal data about you when you use the services of our customers and partners, such as prospective employers and applicant tracking systems providing us job application data.

 

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 apply for jobs. 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. You can also opt out from our use of cookies and similar technologies that track your behavior on the sites of others for third party advertising.

 

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, 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. For example, we will get contact information for “Company Page” administrators and for authorizing users of our premium Services, such as our recruiting, sales or learning products.

 

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.

 

4.   How We Use Your Data

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 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, build a community, find and be found for work and business opportunities, stay informed, get training 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 and the African Diaspora, including African Americans and African Immigrants from around the world, and to foster an environment where our influencers, 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. When you connect, you will be able to search each others’ connections 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 or partner integrations) to suggest connections for you and others (e.g. Members who share your contacts) 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. 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. 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, suggest that you follow certain Members on our site, or watch related learning content to help you towards that new skill. 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 blog or poll, took a social action, made new connections or were mentioned in the news.

 

Growth

 

Our Services allow you to 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 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 you to recruiters.

 

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 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 invitationsgroups and messages between Members.

 

4.3.                  Advertising

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

 

We 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, clicking on an ad, etc.), including as described in Section 1.3;
  • 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.

 

Ad Choices

 

We adhere to self-regulatory principles for interest-based advertising and participate in industry opt outs from such ads. This does not opt you out of receiving advertising - you will continue to get generic ads or ads by advertisers not listed with these self-regulatory tools. You can also opt out specifically from interest-based advertising served through our platform for third parties.

 

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 professionals to each other and to economic opportunity.

 

Other Research

 

We seek to create economic opportunity for members of the global workforce 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 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.   How We Share Information

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, video or blog), the default (which you can change) is to share it publicly. 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 unless you change the default settings.

 

  • 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, subject to your settings where applicable.

 

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.               Others’ Services

You may link your account with others’ services so that they can look up your contacts’ profiles or post your shares on such platforms. Subject to your preference, other services may look-up your profile.

 

When you opt to link your account with other services, personal data will become available to them. The sharing and use of that personal data will be described in, or linked to, a consent screen when you opt to link the accounts. For example, you may link your Twitter or WeChat account to share content from our Services into these other services, or your email provider may give you the option to upload your agbora contacts into its own service. You may revoke the link with such accounts.

 

Subject to your settingsexcerpts from your profile will appear on the services of others (e.g., search engine results, mail and calendar applications that show a user a “mini” agbora profile of the person they are meeting or messaging, social media aggregators, talent and lead managers). “Old” profile information remains on these services until they update their data cache with changes you made to your profile.

 

5.4.               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.

5.5.               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 to not to disclose or use it for other purposes.

 

5.6.               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.

 

5.7.               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.   Your Choices & Obligations

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 a new job every few years, we will retain your information and keep your profile open until you decide to 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 to advertising opt-outs and communication controls. We offer access to the personal data we have about you.

6.3.               Account Closure

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

 

If you choose to close your abora 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.   Other Important Information

7.1.               Security

We monitor for and try to prevent security breaches. Please use the security features available through our Services.

 

We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. 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. Learn more about this and about our response to “do not track” signals.

 

7.3.               Contact Information

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: