AMI – African Management Initiative (“AMI”), the provider of online and blended educational and social learning services aimed at companies in various African countries, respects the privacy rights of individuals and is committed to handling Personal Data responsibly, in accordance with applicable law and this Policy.
In this Policy, “Personal Data” means information which relates to an individual and which identifies that individual, either directly or indirectly (together with other information that is reasonably likely to come into AMI’s possession), such as your name, email address or account details.
PROCESSING PERSONAL DATA
AMI observes the following principles when processing Personal Data:
- Fairness:AMI will process Personal Data fairly and lawfully.
- Purpose: AMI will process Personal Data for the following purposes:
- Where necessary for the provision of AMI’s services to you (or your company or sponsor, if you are a part of an institutional programme) or otherwise for the performance of a legal relationship between AMI and you (such as to administer your membership or provide support).
- Where necessary for complying with an obligation imposed on AMI by applicable law.
- Where AMI has a legitimate interest that, on balance, justifies the processing (such as to improve the quality of AMI’s services).
- For other purposes (such as providing notifications on course progress, messages, or other relevant notifications to you), you can opt out of these notifications in your personal settings.
- Records of your participation in Programmes, Online Communities, Courses, may be used for researching online education. In the interests of this research, you may be exposed to slight variations in the course materials that will not substantially alter your learning experience. All research findings will be reported at the aggregate level and will not expose your personal identity.
- AMI will also compile aggregate statistics regarding the use of the Site and AMI’s services, studying the impact of AMI’s services and platform optimisation.
- Proportionality:AMI will limit the processing of Personal Data to that which is adequate, relevant and not excessive in relation to the purposes for which AMI collects and uses it.
- Protection:AMI will not share your Personal Data with any other party, with the exception of 3rd Parties used to deliver critical services in the platform (such as processing or transmission of Personal Data for you), or, in the case of a company or sponsored programme, the client or sponsor responsible for the learning programme through which you have be granted a License to use AMI learning platform and services.
- Term: AMI retains personal data for no longer than is reasonably necessary to provide critical services and be prepared to provide services, should you so choose. As such, AMI retains Personal Data for a period of 10 years after you have used AMI Services or signed into the AMI platform. After this period, your details will be pseudonymised or removed and you will no longer hold an account on the AMI site. You can request your account and details to be removed at any time.
SOURCES OF PERSONAL DATA
In order to benefit from AMI services, you will need to register on the Sites and create a profile. Registration on the Sites requires the provision of such Personal Data as username, first and last name, phone number and email address. You can further voluntarily choose to provide additional Personal Data, such as your education, work experience, photo, accomplishments on the Sites, etc. As part of your registration, you decide whether to make your expanded profile available to other users of the Sites. As you use AMI online educational and social learning services, AMI will collect Personal Data regarding your programmes, subscriptions, membership details, courses completed, competency valuations and other activities on the Sites. You may be asked, throughout an AMI Programme to submit information in Programme surveys, including self-assessment of competence and feedback on AMI Content and Services.
The principal source of Personal Data is you. AMI does not receive Personal Data from third party sources, except where you voluntarily decide to create your profile using your Facebook, LinkedIn or Google plus account (in which case your social profile data will be imported from these accounts).
LAWFUL BASIS FOR COLLECTION OF DATA
AMI collects user data only under the following legal means:
- Contract:Our Terms of Service, Service Level Agreements and Contract with clients and sponsors of AMI programmes require that we collect Personal Data in order to provide the reporting necessary to fulfill our obligations.
- Legitimate Interests:AMI is committed to improving the learning experience for all Users. As such, we require the ability to analyse data on performance, achievements, and core behaviours of users within our system. This data is not shared outside of AMI, unless for research purposes, whereby it is anonymized prior to being shared.
SHARING AND/OR TRANSFERRING PERSONAL DATA
AMI may share or transfer Personal Data in the following circumstances:
- Like many organizations, we use third-party suppliers (such as data center operators) to collect, use and otherwise process Personal Data on our behalf. Our practice is to require such third parties to handle Personal Data in accordance with AMI’s privacy and security policies and applicable law.
- Personal Data will only be shared for a third-party research purposes with the express written consent of the affected individuals.
Some of these recipients could be located in foreign countries, both within and outside the European Union (EU). Some of these countries do not have specific data protection laws and so may provide less legal protection for your Personal Data. In these instances, AMI will process your Personal Data in the manner described by this Policy and in accordance with applicable law.
SENSITIVE PERSONAL DATA
As a general rule, AMI does not collect “Sensitive Personal Data” through the Site. “Sensitive Personal Data” means Personal Data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, sex life, health or medical records and, if permitted by applicable law, criminal records. By volunteering unsolicited sensitive Personal Data to us (e.g., by submitting your full profile or pictures online), you expressly consent to your Personal Data being used as described in this Policy.
DATA SECURITY AND INTEGRITY
AMI uses various technological and procedural security measures in order to protect the Personal Data that we collect, use or transfer from loss, misuse, alteration or destruction. AMI has comprehensive data protection processes in place to protect all client and user data.
However, you should be aware that, due to the open and unsecured character of the Internet, AMI cannot be responsible for the security of transmissions of the Personal Data over the Internet. We commit to communicating any breach of data immediately to any and all affected users, should such a breach ever occur and purpose to inform all the affected users within twenty four (24) hours of the reported breach of the remedial action taken to remedy the breach.
You have a number of legal rights in relation to the personal information that we hold about you and you can exercise your rights by contacting us using the details set out below.
Depending on applicable law, these rights may include:
- Obtaining information regarding the processing of your personal information and access to the personal information which we hold about you;
- Requesting that we correct your personal information if it is inaccurate or incomplete;
- Requesting that we erase your personal information in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled to retain it;
- Objecting to, and requesting that we restrict, our processing of your personal information in certain circumstances;
- In some circumstances, receiving some personal information in a structured, commonly used and machine-readable format and/or requesting that we transmit that information to a third party where this is technically feasible. Please note that this right only applies to personal information which you have provided to us;
- Withdrawing your consent, although in certain circumstances it may be lawful for us to continue processing without your consent if we have another legitimate reason (other than consent) for doing so; and
- Lodging a complaint with the relevant data protection authority, if you think that any of your rights have been infringed by us. We can, on request, tell you which data protection authority is relevant to the processing of your personal information.
ACCESSING, CORRECTING, UPDATING AND DELETING PERSONAL DATA
If you would like to request a copy of your Personal Data, then please send an email together with a proof of your identity (such as passport or identity card) to firstname.lastname@example.org. Also, if you consider your Personal Data to be incorrect, write to us indicating the error made and the proposed amendment and if you wish to have it deleted, then please send an email containing that request. Both requests should be accompanied by proof of your identity (such as passport or identity card) to email@example.com.
You can unsubscribe from any AMI communications either by clicking ‘unsubscribe’ on the communication itself (and following any steps requested) or by logging in to the platform and changing your mail preferences in your settings.
NOTIFICATION OF CHANGES TO THIS POLICY
This Policy was last updated on 25th September, 2020. AMI will inform you of updates to this Policy by contacting you or by posting updates on its Sites.
You can delete your data at any time by contacting us through firstname.lastname@example.org, or by deleting your account in your settings.
Effective Date: October 14, 2020.