Last Revised: May 1st 2020
EquaLife Group, LLC (“EquaLife”, “we”, “us”, or “our”) is firmly committed to protecting the confidentiality of your personal information, and we aim to be transparent with you about what we do with your personal information. This Privacy Policy describes how we may collect, use, process, and share your personal information through your online interactions with us, including but not limited to, your use of and access to the website located at http://www.equalifegroup.com/ and its associated services, including email newsletters, associated content distribution platforms, and public EquaLife social media accounts (collectively, the “Services”).
This Privacy Policy is incorporated into, and is subject to, our Terms. By using the Services, you accept and agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services or provide us with any personal information.
Capitalized terms used in this Privacy Policy and not defined herein shall have the definitions provided in our Terms.
For the purposes of the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), the data controller for the data you provide or that we collect in connection with the Services is EquaLife Group, LLC (of Delaware, USA).
Personal Information We Collect
We may collect information that you provide, including but not limited to:
If you connect to us from a social network, such as LinkedIn, we may collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, connections list, follower list, and any other information you have agreed it can share or that the social network provides to us.
We may use automated technology such as cookies and other tracking software to collect personal information from your computer system or mobile device. We may collect the following information:
We may also collect the time spent visiting, usage patterns, and the domain name of the website from which you linked to the Services.
How We Collect Your Personal Information
We may obtain personal information:
We may combine information from different sources. For example, we may combine information that we have collected offline with information we collect online, or we may combine information we get from a third party with information we already have. If you submit any personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Uses of Your Personal Information
We may use your personal information to:
To the extent legally permissible, we may anonymize and/or aggregate data about users of the Services and use and disclose it for any purpose, including product and service development and improvement activities.
Cookies and Other Tracking Methods
We may use “cookies”, or small text files that are stored on your computer’s hard drive. Cookies ensure that the Services and our Content is presented in the most effective manner for you and your computer.
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Services and use their features. Without these cookies, services you have requested, such as remembering your submitted information, cannot be provided.
Performance Cookies
These cookies collect anonymous information on how people use the Services. For example, we may use Google Analytics cookies to help us understand how individuals arrive at the Services, browse or use the Services, and highlight areas where we can improve such as navigation and marketing. The data stored by these cookies never shows personal details from which your individual identity can be established.
Functionality Cookies
These cookies remember choices you make such as the country from which you visit the Services, language, and search parameters. This data can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored. The information these cookies collect may be anonymized, and these cookies cannot track your browsing activity on other websites.
Targeting Cookies or Advertising Cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit, and that information is shared with other parties such as advertisers.
Social Media Cookies
These cookies allow you to share what you have been doing on the Services on social media, such as LinkedIn. These cookies are not within our control and are therefore subject to a third party’s rules and policies. Social media companies may have their own privacy policies, which we strongly suggest you review if you use those websites or apps.
We may use different kinds of cookies, including session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, and to determine ways to improve the Services and the investments, funding, and other services we offer. These cookies are deleted when you close your browser session. Persistent cookies are used to collect information such as IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.
You are always free to decline our cookies if your browser permits, but some parts of the Services may not work properly if you do. Check the “Help” menu of your browser to learn how to change your cookie preferences. To find out more about cookies, visit www.aboutcookies.org.
We may also use technologies like cookies, such as Google Analytics. We may use Google Analytics to collect anonymized statistics in order to improve the Services. We do not combine the information collected using Google Analytics with personal information. You can selectively disable Google Analytics by installing the opt-out component provided by Google on your browser. You can refer to the following links for more information: Google Analytics and privacy and Google Analytics opt-out browser.
Many web browsers allow for the use of a “Do Not Track” function to inform websites that you do not want your online activities tracked. Currently, we do not track your or any other users’ personal information over time and across third party websites. We therefore do not respond to browser “Do Not Track” signals.
Sharing Your Personal Information
We will only share your personal information as described in this Privacy Policy, or when you otherwise consent (to the extent required by law).
We may share your personal information with:
We do not sell, rent, or otherwise make personal information commercially available to any third party, except with your prior permission.
Additionally, we reserve the right to disclose to third parties non-personally identifiable information collected for any lawful purpose, including but not limited to, anonymized data.
Legal Grounds for Processing
We may collect, use, process, and share your personal information in connection with any of the purposes set forth above on one or more of the following legal grounds:
Transfer and Storage of Personal Information
The information that you provide to us will be stored and processed in the United States and to the extent applicable, where our affiliates operate. If you are accessing the Services from other jurisdictions, including the European Economic Area, please be advised that you are transferring your personal information to us in the United States where data protection and privacy laws may be less stringent than the laws of your jurisdiction. BY USING THE SERVICES, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
Any international transfers of your personal information will be made pursuant to appropriate safeguards in accordance with the applicable laws and regulations, such as standard data protection clauses adopted by the European Commission. If you wish to inquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.
Security
We implement commercially reasonable physical, technical, and administrative security measures to protect your personal information. Nonetheless, no such measure is ever 100% effective; therefore, we do not guarantee that your personal information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such personal information. Please exercise caution when using the Internet or any form of electronic communication.
If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us at: inquiries@equalifegroup.com.
Retention
We will retain your personal information for as long as needed or (legally) permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include, without limitation: (a) the length of time we have an ongoing relationship with you and provide the Services to you; (b) whether there is a legal obligation to which we are subject; or (c) whether retention is advisable in light of our legal position (such as in regard to the enforcement of our Terms, applicable statutes of limitations, litigation, or regulatory investigations).
Your Rights
Depending on your jurisdiction, you may have certain rights regarding our collection, use, processing, and sharing of your personal Information. Your rights may depend on the laws which apply to you and us, but your rights may include the following:
If you have any questions regarding these rights, please contact us at: inquiries@equalifegroup.com. Please note that we may request additional information to verify, respond to, or fulfill any requests regarding your rights under applicable laws or regulations.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We try to ensure that your personal information is accurate and up to date, where relevant. Therefore, please advise us of any changes to your information through any of the contact methods specified below.
Emailing/Marketing Opt-Out
Where we process personal information for marketing purposes or with your consent, we process the data until you make us aware by unsubscribing to future contact. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your personal information so that we can respect your request in the future.
You can always opt out of any subscription for emails or other communications, including for marketing purposes, by clicking “Unsubscribe” at the bottom of the email, or by sending an email with the subject line “Unsubscribe” to: inquiries@equalifegroup.com. In your applicable request, please provide your name and the addresses where you no longer wish to be contacted. If you opt out of receiving marketing or other communications from us, we may still send you important service-related and other non-marketing communications, like responding to you by email if you send us a request or comment.
Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personal information for direct marketing purposes. We do not share personal information with other people or non-affiliated businesses for their direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send a letter to PO Box 38691-00623, Nairobi, Kenya. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.
Nevada Residents
Although we do not sell personal information, Nevada residents may have the right to submit a verified request directing us not to sell their personal information. If you are a Nevada resident, and would like to submit such a request, please send your request through any of the methods specified below.
Children
The Services are not directed to individuals under the age of sixteen (16), and EquaLife does not knowingly or specifically collect personal Information from users under the age of 16 and no one under age 16 is authorized to submit any information, including personal information, on the Services. If we determine that such information has been inadvertently collected on anyone under the age of 16, we will take the necessary steps to ensure that such information is deleted from our systems. If you are providing us with personal information of individuals under the age of 16, you represent that you have the appropriate authority to do so, and that you can demonstrate such authority to us upon request. If you are a parent or guardian and become aware that your child has provided us with information, please contact us using one of the methods specified below.
Third-Party Sites
As mentioned in our Terms, the Services may contain links, references, and other forms of connectivity to Third-Party Sites. This Privacy Policy does not apply to the information (including personal information) collected on any Third-Party Site over which we have no influence or control. We are not responsible for the privacy practices of Third-Party Sites. Accordingly, we recommend that you review the privacy notice and related policies posted on any Third-Party Sites.
Modification
EquaLife reserves the right to modify this Privacy Policy from time to time in its sole discretion, effective upon posting. In the event of such changes, we will post the changes on the Services and/or notify you via email. Any use of the Services after such changes shall be deemed an acceptance of those changes. You should periodically visit this page to review the current Privacy Policy so that you are aware of any such revisions to which apply to your personal information.
How to Contact Us
If you have any questions regarding this Privacy Policy or our privacy practices, please contact us at:
Email: inquiries@equalifegroup.com
Mailing Address:
EquaLife Group
P.O. Box 38691-00623
Nairobi, Kenya
EquaLife Group, LLC (“EquaLife”, “we”, “us”, or “our”) is firmly committed to protecting the confidentiality of your personal information, and we aim to be transparent with you about what we do with your personal information. This Privacy Policy describes how we may collect, use, process, and share your personal information through your online interactions with us, including but not limited to, your use of and access to the website located at http://www.equalifegroup.com/ and its associated services, including email newsletters, associated content distribution platforms, and public EquaLife social media accounts (collectively, the “Services”).
This Privacy Policy is incorporated into, and is subject to, our Terms. By using the Services, you accept and agree to the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Services or provide us with any personal information.
Capitalized terms used in this Privacy Policy and not defined herein shall have the definitions provided in our Terms.
For the purposes of the General Data Protection Regulation (EU) 2016/679 (the "GDPR"), the data controller for the data you provide or that we collect in connection with the Services is EquaLife Group, LLC (of Delaware, USA).
Personal Information We Collect
We may collect information that you provide, including but not limited to:
- Personal and contact information, such as your name, address, telephone number, email address, electronic signature, and federal or state issued professional identification;
- Financial information, such as bank account number;
- Employment information, such as job title, professional experience, education, performance history, training records, income, salary, and compensation; and
- Information you provide to us when you submit questions, business plans, materials, comments, suggestions, ideas, graphics, and other information through the Services or via email.
If you connect to us from a social network, such as LinkedIn, we may collect personal information from the social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, connections list, follower list, and any other information you have agreed it can share or that the social network provides to us.
We may use automated technology such as cookies and other tracking software to collect personal information from your computer system or mobile device. We may collect the following information:
- Internet Protocol (IP) address or other device identifier;
- Browser type and version;
- Browsing information, such as pages you view and the links you click, and whether you access the Services via a social media website;
- Time zone setting;
- Browser plug-in types and versions; and
- Operating system and platforms
We may also collect the time spent visiting, usage patterns, and the domain name of the website from which you linked to the Services.
How We Collect Your Personal Information
We may obtain personal information:
- When you provide it directly, such as via Submissions or when you email us;
- Automatically when you visit or use the Services (such as from cookies);
- From third parties (such as from social media websites and recruiting agencies); and
- From our affiliates and partners (such as from investors and portfolio companies).
We may combine information from different sources. For example, we may combine information that we have collected offline with information we collect online, or we may combine information we get from a third party with information we already have. If you submit any personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Uses of Your Personal Information
We may use your personal information to:
- Operate our business (including to provide and personalize the Services and our services and financing);
- Respond to your Submissions (including about investments and our financing offerings), provide user support, and otherwise communicate with you (including to provide you with news, announcements, invitations, and other information about us);
- Analyze and learn about how the Services are accessed and used, evaluate and improve the Services (both in terms of content and ease of use), and monitor and measure the effectiveness of our marketing;
- Validate your ability to receive certain funding, services, and information that may only be suitable for/accessible to businesses and/or individuals meeting certain eligibility or other criteria;
- Ensure the security and integrity of the Services or our Content;
- Manage our vendor and partner relationships;
- Enforce our Terms and other legal terms and policies;
- Protect our and others’ interests, rights, and property (such as to protect our copyrighted materials); and
- Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts, and law enforcement requests.
To the extent legally permissible, we may anonymize and/or aggregate data about users of the Services and use and disclose it for any purpose, including product and service development and improvement activities.
Cookies and Other Tracking Methods
We may use “cookies”, or small text files that are stored on your computer’s hard drive. Cookies ensure that the Services and our Content is presented in the most effective manner for you and your computer.
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Services and use their features. Without these cookies, services you have requested, such as remembering your submitted information, cannot be provided.
Performance Cookies
These cookies collect anonymous information on how people use the Services. For example, we may use Google Analytics cookies to help us understand how individuals arrive at the Services, browse or use the Services, and highlight areas where we can improve such as navigation and marketing. The data stored by these cookies never shows personal details from which your individual identity can be established.
Functionality Cookies
These cookies remember choices you make such as the country from which you visit the Services, language, and search parameters. This data can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored. The information these cookies collect may be anonymized, and these cookies cannot track your browsing activity on other websites.
Targeting Cookies or Advertising Cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as to help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit, and that information is shared with other parties such as advertisers.
Social Media Cookies
These cookies allow you to share what you have been doing on the Services on social media, such as LinkedIn. These cookies are not within our control and are therefore subject to a third party’s rules and policies. Social media companies may have their own privacy policies, which we strongly suggest you review if you use those websites or apps.
We may use different kinds of cookies, including session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, and to determine ways to improve the Services and the investments, funding, and other services we offer. These cookies are deleted when you close your browser session. Persistent cookies are used to collect information such as IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.
You are always free to decline our cookies if your browser permits, but some parts of the Services may not work properly if you do. Check the “Help” menu of your browser to learn how to change your cookie preferences. To find out more about cookies, visit www.aboutcookies.org.
We may also use technologies like cookies, such as Google Analytics. We may use Google Analytics to collect anonymized statistics in order to improve the Services. We do not combine the information collected using Google Analytics with personal information. You can selectively disable Google Analytics by installing the opt-out component provided by Google on your browser. You can refer to the following links for more information: Google Analytics and privacy and Google Analytics opt-out browser.
Many web browsers allow for the use of a “Do Not Track” function to inform websites that you do not want your online activities tracked. Currently, we do not track your or any other users’ personal information over time and across third party websites. We therefore do not respond to browser “Do Not Track” signals.
Sharing Your Personal Information
We will only share your personal information as described in this Privacy Policy, or when you otherwise consent (to the extent required by law).
We may share your personal information with:
- Our partners and affiliates necessary to contact you or provide you with requested information or updates;
- Outside contractors, service providers, advisors, auditors, vendors, consultants, or others engaged by us to assist in providing financial or operational activities on our behalf, including technical and processing services and analysis of the Services and their performance;
- Third parties providing services for money laundering and terrorist financing checks, credit risk reduction, and other fraud and crime prevention purposes, and companies providing similar services, including financial institutions, accounting and law firms, and credit reference agencies;
- Courts, law enforcement authorities, regulators, government officials, or other third parties when obligated or permitted to do so by law or if we have a good faith belief that such disclosure is necessary for the establishment, exercise, or defense of a legal or equitable claim, to comply with a current judicial proceeding, court order, or legal process served on us or to investigate, prevent, or resolve any suspected or actual unlawful activities, such as potential fraud, or a perceived irregularity in any audits of the accuracy of any documentation or information submitted to us by you or on your behalf, as we deem appropriate;
- A successor entity or potential buyer in connection with a proposed or actual corporate merger, acquisition, consolidation, reorganization, bankruptcy, joint venture, disposition of all or any portion of our business, assets, or stock (e.g., via sale, assignment, or transfer), or other corporate change; and
- Third parties, to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others.
We do not sell, rent, or otherwise make personal information commercially available to any third party, except with your prior permission.
Additionally, we reserve the right to disclose to third parties non-personally identifiable information collected for any lawful purpose, including but not limited to, anonymized data.
Legal Grounds for Processing
We may collect, use, process, and share your personal information in connection with any of the purposes set forth above on one or more of the following legal grounds:
- Because it is necessary for us to do so to perform your instructions or another contract with you or your organization;
- To comply with our legal obligations, as well as to keep records of our compliance processes or tax records;
- Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided that those interests are not overridden by your interests or fundamental rights and freedoms; or
- Because you have expressly given us your consent to process your personal information in that manner.
Transfer and Storage of Personal Information
The information that you provide to us will be stored and processed in the United States and to the extent applicable, where our affiliates operate. If you are accessing the Services from other jurisdictions, including the European Economic Area, please be advised that you are transferring your personal information to us in the United States where data protection and privacy laws may be less stringent than the laws of your jurisdiction. BY USING THE SERVICES, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
Any international transfers of your personal information will be made pursuant to appropriate safeguards in accordance with the applicable laws and regulations, such as standard data protection clauses adopted by the European Commission. If you wish to inquire further about these safeguards used, please contact us using the details set out at the end of this Privacy Policy.
Security
We implement commercially reasonable physical, technical, and administrative security measures to protect your personal information. Nonetheless, no such measure is ever 100% effective; therefore, we do not guarantee that your personal information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such personal information. Please exercise caution when using the Internet or any form of electronic communication.
If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us at: inquiries@equalifegroup.com.
Retention
We will retain your personal information for as long as needed or (legally) permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include, without limitation: (a) the length of time we have an ongoing relationship with you and provide the Services to you; (b) whether there is a legal obligation to which we are subject; or (c) whether retention is advisable in light of our legal position (such as in regard to the enforcement of our Terms, applicable statutes of limitations, litigation, or regulatory investigations).
Your Rights
Depending on your jurisdiction, you may have certain rights regarding our collection, use, processing, and sharing of your personal Information. Your rights may depend on the laws which apply to you and us, but your rights may include the following:
- To request access to and/or details of the personal information we hold about you and how we process it;
- To have the personal information we hold rectified or deleted, to restrict our processing of that information, to stop unauthorized transfers of your personal information to a third party and, in some circumstances, to have personal information relating to you transferred to another organization;
- To lodge a complaint in relation to our use of your personal information with a local governmental or supervisory authority
If you have any questions regarding these rights, please contact us at: inquiries@equalifegroup.com. Please note that we may request additional information to verify, respond to, or fulfill any requests regarding your rights under applicable laws or regulations.
If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your personal information to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.
We try to ensure that your personal information is accurate and up to date, where relevant. Therefore, please advise us of any changes to your information through any of the contact methods specified below.
Emailing/Marketing Opt-Out
Where we process personal information for marketing purposes or with your consent, we process the data until you make us aware by unsubscribing to future contact. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your personal information so that we can respect your request in the future.
You can always opt out of any subscription for emails or other communications, including for marketing purposes, by clicking “Unsubscribe” at the bottom of the email, or by sending an email with the subject line “Unsubscribe” to: inquiries@equalifegroup.com. In your applicable request, please provide your name and the addresses where you no longer wish to be contacted. If you opt out of receiving marketing or other communications from us, we may still send you important service-related and other non-marketing communications, like responding to you by email if you send us a request or comment.
Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request a list of all third parties to which we, during the immediately preceding calendar year, have disclosed certain personal information for direct marketing purposes. We do not share personal information with other people or non-affiliated businesses for their direct marketing purposes. We are only required to respond to a customer request once during any calendar year. To make such a request you should send a letter to PO Box 38691-00623, Nairobi, Kenya. Please be aware that not all information sharing is covered by the California privacy rights requirements and only information sharing that is covered will be included in our response.
Nevada Residents
Although we do not sell personal information, Nevada residents may have the right to submit a verified request directing us not to sell their personal information. If you are a Nevada resident, and would like to submit such a request, please send your request through any of the methods specified below.
Children
The Services are not directed to individuals under the age of sixteen (16), and EquaLife does not knowingly or specifically collect personal Information from users under the age of 16 and no one under age 16 is authorized to submit any information, including personal information, on the Services. If we determine that such information has been inadvertently collected on anyone under the age of 16, we will take the necessary steps to ensure that such information is deleted from our systems. If you are providing us with personal information of individuals under the age of 16, you represent that you have the appropriate authority to do so, and that you can demonstrate such authority to us upon request. If you are a parent or guardian and become aware that your child has provided us with information, please contact us using one of the methods specified below.
Third-Party Sites
As mentioned in our Terms, the Services may contain links, references, and other forms of connectivity to Third-Party Sites. This Privacy Policy does not apply to the information (including personal information) collected on any Third-Party Site over which we have no influence or control. We are not responsible for the privacy practices of Third-Party Sites. Accordingly, we recommend that you review the privacy notice and related policies posted on any Third-Party Sites.
Modification
EquaLife reserves the right to modify this Privacy Policy from time to time in its sole discretion, effective upon posting. In the event of such changes, we will post the changes on the Services and/or notify you via email. Any use of the Services after such changes shall be deemed an acceptance of those changes. You should periodically visit this page to review the current Privacy Policy so that you are aware of any such revisions to which apply to your personal information.
How to Contact Us
If you have any questions regarding this Privacy Policy or our privacy practices, please contact us at:
Email: inquiries@equalifegroup.com
Mailing Address:
EquaLife Group
P.O. Box 38691-00623
Nairobi, Kenya