Privacy Policy

Introduction
The Education Outcomes Fund for Africa and the Middle East—A project of the New
Venture Fund (“EOF”, “we”, “our”, “us”) are committed to protecting and respecting
your privacy. As a data controller, may collect, use, share and protect
information that we obtain about you directly or indirectly in accordance
with applicable data privacy laws.


This policy sets out the basis on which we will process any personal data or usage
information we collect from you, or that you provide to us, in connection with your
use of our Website at www.educationoutcomesfund.org the “Website”). Please read
this policy carefully so that you understand your rights in relation to your personal
data, and how we will collect, use and process your personal data. If you do not
agree with this Privacy Policy in general or any part of it, you should not access the
Website.


1. What types of information do we collect and how we use it?
Information you give us. You may provide information via filling in forms or
applications on our Website (www.educationoutcomesfund.org), when you apply for
funding from us, attend an event we are hosting/presenting at, apply for a job with
us, create an account on the Website or by contacting anyone on our staff via email,
telephone, instant chat, social media or otherwise. This includes information
provided when you register or sign up for our newsletters, events, or publications on
the Website and/or when you provide us with feedback on our services or complete
surveys. The information that you give us may include your first and last name,
company address, email address, phone number, gender and job title. You must
ensure that the information you provide to us is accurate and complete and that all
registration details (where applicable) contain your real name, address and other
requested details. You should notify us of any changes to these as soon as you are
able so that we can update our records.


As it is in our legitimate interests to be responsive to you and to ensure the proper
functioning of our Website and organisation, we will use the information you give us
to:

  •  enable us to process, review and assess any application for funding you may

  • make to us and to decide whether or not to seek to enter into an agreement to make funding available to you;

  • carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services you seek from us;

  • communicate with you;

  • sign you up for our newsletters;

  • notify you about changes to our services;

  • identify our users;

  • administer and provide services and customer support per your request;

  • personalise our services for you;

  • enforce our Website terms and conditions;opted-in to marketing, communicate with you about events and other news and information we think will be of interest to you; or
    provide third parties with statistical information about our users (but those
    third parties will not be able to identify any individual user from that
    information).


    Technical usage information. we collect the information sent to us by your computer, mobile phone, or other access device.

 

This information includes:

  • your IP address;

  • device information including, but not limited to, identifier, name, and type of operating system;

  • mobile network information; and standard web information, such as your browser type and the pages you access on our Website.

 

We collect this information in order to:

  • personalise our Website to ensure content from the Website is presented in the most effective manner for you and your device;

  • monitor and analyse trends, usage and activity in connection with our Website and services to improve the Website;

  • administer the Website and for internal operations, in order to conduct

  • troubleshooting, data analysis, testing, research, statistical and survey analysis;

  • keep the Website safe and secure; and measure and understand the effectiveness of the content we serve to you and others.


2. Do we use cookies?
We use cookies to collect information about your browsing activities over time and
across different websites following your use of our services. They allow us to
recognise and count the number of users and to see how users move around the
Website when they are using it. This helps us to improve the services we provide to
you and the way the Website works. You can find more information about cookies
and how to manage them at http://www.allaboutcookies.org/. For more information
about cookies, please refer to our Cookies Policy.


We plan to use Google Analytics which is a web analytics tool that helps us
understand how users engage with the Website. Like many services, Google
Analytics uses first-party cookies to track user interactions as in our case, where
they are used to collect information about how users use our site. This information is
used to compile reports and to help us improve our Website. The reports disclose
website trends without identifying individual visitors. You can opt out of Google
Analytics without affecting how you visit our site – for more information on opting out
of being tracked by Google Analytics across all websites you use, visit this Google
page.

 

3. How do we share your personal data

 

We do not sell, rent or lease your personal information to others except as described
in this Privacy Policy. We share your information with selected recipients. These
categories of recipients include [1] :

 

  • Our fiscal sponsor, the New Venture Fund

  • business partners, reviewers, advisers, service providers and sub-contractors
    for the performance of any arrangement we enter into with them or with you
    including, without limitation, in order to enable us to process and assess any
    application for funding that you may make to us and in order to enable us to
    organise events and to produce publications, newsletters and updates;

  • to the extent that you have checked the boxes on the form or application we
    use to collect your information, such potential third-party
    funders or other
    potential third-party providers of support to you as we may, in our absolute
    discretion, consider to be appropriate;

  • cloud storage providers located in the European Union (EU) and USA, to
    store the personal data you provide and for disaster recovery services, as well
    as for the performance of any 
    contract, we enter into with you;

  • to the extent necessary, in the event of a reorganisation and/or restructuring
    of our business;

  • IT Services providers that provide us with SaaS services, including Salesforce
    who we use to store our customer relationship management information, etc.;

  • analytics and search engine providers located in EU and USA that assist us in
    the improvement and optimisation of the Website; and

  • credit reference agencies or Know Your Customer agencies located in the EU
    and
    USA for the purpose of assessing your credit score and conducting
    background checks where this is a condition of us entering into a contract with
    you.

 

 

We will share your information with law enforcement agencies, public authorities or
other organisations if legally required to do so, or if we have a good faith belief that
such use is reasonably necessary to:

 

  • comply with a legal obligation, process or request;

  • enforce our terms and conditions and other agreements, including
    investigation of any potential violation thereof;

  • detect, prevent or otherwise address security, fraud or technical issues; or

  • protect the rights, property or safety of us, our users, a third party or the public
    as required or permitted by law (exchanging information with other companies
    and organisations for the purposes of fraud protection and credit risk
    reduction).

 


We will also disclose your information to third parties:

  • in the event that we sell any business or assets, in which case we will disclose  your data to the prospective buyer of such business or assets; or

  • if we or substantially all of our assets are acquired by a third party, in which

  • case information held by us about our users will be one of the transferred assets.

  • Our fiscal sponsor, the New Venture Fund

  • business partners, reviewers,

 

We shall not under any circumstances sell your information to any person for any
purpose.


Comments, blogs and other information that you may post on our Website from time
to time will be displayed publicly and to other users of, and visitors to, our Website.
We recommend that you take great care in disclosing information that may identify
you or anyone else. We are not responsible for the protection or security of any
information that you post in public areas.

 


4. Where do we store your personal data?
The information that we collect from you will be transferred to and stored
at/processed in the European Economic Area (“EEA”), United States and, if
applicable to your funding application, other relevant countries outside the EEA. Your
personal data is also processed by staff operating outside the EEA who work for us
or for one of our suppliers. Such staff are engaged in, among other things the
processing, review and assessment of any application that you may make to us for
funding, the negotiation, conclusion and monitoring of funding instruments, the
processing of payments and the provision of other services in respect of any of our
activities. We will take all steps reasonably necessary to ensure that your personal
data is treated securely and in accordance with this policy. When your data is
processed outside the EEA EOF will ensure that one of the following will apply:

​​

  • White Listed Countries: The country where the processing takes place has been found to have an adequate level of protection for personal data under Commission Decision 2000/518/EC of 26 July 2000.

  • Privacy Shield: The processor complies with the US Department of Commerce’s EU-US Privacy Shield and has certified that we adhere to the EU-US Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. For more information about the EU-US Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield Website.

  • Standard Contractual Clauses: Your information will be accessible from and will be transferred to other companies or affiliates of our corporate group located in the USA by way of the standard contractual clauses approved by the European Commission (see below), which we have duly executed.

  • Consent: Should the preceding not apply, EOF will contact you to get your explicit consent. You may withdraw your consent at any time by emailing Jared Lee at jared@edufundmea.org


When we transfer your personal data outside the EEA, we have entered into standard data protection clauses adopted pursuant to the European Commission Decisions 2004/915/EC and 2010/87/EU. Please contact Jared Lee at
jared@edufundmea.org should you wish to examine this.


5. The security of your personal data

Unfortunately, the transmission of information via the internet or email is not
completely secure. EOF will take all appropriate technical and organisational

measures to safeguard your personal data against loss, theft and unauthorised use,
access or modification. Although we will do our best to protect your personal data,
we cannot guarantee the security of your information transmitted through the
Website or over email; any transmission is at your own risk.


Where we have given you (or where you have chosen) a password which enables
you to access certain parts of our Website, you are responsible for keeping this
password confidential and we ask you not to share any such password with anyone.
We will, from time to time, host links to and from the websites of our affiliates or third
parties. If you follow a link to any of these websites, these websites will have their
own privacy policies and we do not accept any responsibility or liability for these
policies. Please check these policies before you submit any information to those
websites.

 


6. How long do we store your personal data?


We will retain your information as follows:

  • if you apply for funding we will keep your data for up to 10 years;

  • if you contact us via email we will keep your data for up to 10 years; and

  • your technical usage information for 6 months;

  • data on your use of our Website for 6 months; and

  • after you have terminated your use of our Website, we will store your

  • information in an aggregated and anonymised format.

 

7. Your rights

In certain circumstances you have rights in relation to the personal data we hold
about you. We set out below an outline of those rights and how to exercise those
rights. Please note that we will require you to verify your identity before responding
to any requests to exercise your rights by proof of identification. To exercise any of
your rights, please email jared@edufundmea.org. Please note that for each of the
rights below we may have valid legal reasons to refuse your request, in such
instances we will let you know if that is the case.

 

  • AccessYou have the right to know whether we process personal data about
    you, and if we do, to access data we hold about you and certain information
    about how we use it and who we share it with.

  • Correction: You have the right to require us to correct any personal data held
    about you that is inaccurate and have incomplete data completed.

  • Erasure: You may request that we erase the personal data we hold about you
    in the following circumstances: where you believe it is no longer necessary for
    us to hold the personal data, we are processing it on the basis of your consent
    and you wish to withdraw your consent, we are processing your data on the
    basis of our legitimate interest and you object to such processing, you no
    longer wish us to use your data to send you marketing or you believe we are
    unlawfully processing your data). Please provide as much detail as possible
    on your reasons for the request to assist us in determining whether you have
    a valid basis for erasure.

  • Restriction of Processing to Storage Only: You have a right to require us
    to stop processing the personal data we hold about you other than for storage
    purposes in the following circumstances: you believe the personal data is not
    accurate for the period it takes for us to verify whether the data is accurate,
    we wish to erase the personal data as the processing we are doing is unlawful
    but you want us to simply restrict the use of that data; we no longer need
    the
    personal data for the purposes of the processing but you require us to retain
    the data for the establishment, exercise or defence of legal claims; and you
    have objected to us processing personal data we hold about you on the basis
    of our legitimate interest and you wish us to stop processing the personal data
    whilst we determine whether there is an overriding interest in us retaining
    such personal data.

  • Objection: You have the right to object to our processing of data about you
    and we will consider your request. Please provide us with detail as to your
    reasoning so that we can assess whether there is a compelling overriding
    interest in us continuing to process such data or we need to process it in
    relation to legal claims.

 

8. Withdrawal of Consent
Where you have provided your consent to us processing your personal data, you can
withdraw your consent at any time by contacting us at  jared@edufundmea.org or
clicking on the opt-out or unsubscribe link in our communications.


9. Complaints
In the event that you wish to make a complaint about how we process your personal
data, please contact us in the first instance at  jared@edufundmea.org and we will
endeavour to deal with your request as soon as possible. This is without prejudice to
your right to launch a claim with the Information Commissioner’s Office or the data
protection supervisory authority in the EU country in which you live or work where
you think we have infringed data protection laws.


10. Changes to the Policy
Any changes we will make to this policy in the future will be posted on this page.
Please check back frequently to see any updates or changes to this policy.


11. Our Contact Details
Questions, comments and requests regarding this policy are welcomed and should
be addressed to Jared Lee at  jared@edufundmea.org