Last updated August 2018
At ThirdWay Africa we are committed to protecting the privacy and processing of your personal information. In this policy, we set out how we collect and use your personally identifiable information and personal data, including information that you provide to us. When we refer to ‘we’ (or ‘our ’or ‘us’) that means ThirdWay Africa Partners LLP and all its wholly-owned subsidiaries. Our registered address is in the UK but we operate and have offices all over the world. For EU data protection purposes, when we act as a controller in relation to your personal data, ThirdWay Africa Capital LTD, is our representative in the European Union.
What is personal data?
Personal information is personal data as defined by the EU’s General Data Protection Regulation (GDPR) and the Data Protection Act 2018 as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social
identity of that natural person”.
When we say ‘personal data’ we mean identifiable information about you, like your name, email, address, blog comments and so on. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply. Check out our terms & conditions for more information on how we treat your other data.
What does this policy apply to?
What information do we collect about you?
We may also automatically collect and store certain anonymised information such as statistics about your activities on our website. We use a third-party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interact with our website. This information is only processed anonymously. We do not make any attempts to find out the identities of visitors to our website. If we do want to collect personally identifiable information through our website, we will be up front about this. We may also have access to technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. For further information on cookies, please our Cookies policy below.
How will we use the information about you?
We may use the personal information we collect from you to:
– Send you our e-newsletter. We collect information about you to send you our e-newsletter, storing your data until your request us to delete it. Consent will be obtained when you submit your data to us through the sign-up or updating your profile forms
– Provide you with information you have requested. Consent will be obtained when you submit a request
– Improve your user experience with our website. We use your information collected from the website to store your website preferences. Your consent will be obtained when you click on the banner to accept certain cookies
– Help us optimise our customer relationship management
– Comply with applicable legal requirements and respond to requests for information from regulated bodies or government agencies. We would collect this data on a legal basis to comply with a legal obligation
ThirdWay Africa will not use personal information in a way that is incompatible with the purpose for which it has been collected or subsequently authorised by you.
Who might we share your information with?
ThirdWay Africa will only share personal information to the extent needed to perform the uses listed above and will take steps to safeguard personal information. For example, our vendors and partners are required to keep such personal information confidential and not to use it other than for the purposes intended. ThirdWay Africa does not sell or rent personal information to third parties.
We may on occasion be required to share your information with the following categories of recipients (a) ThirdWay Africa’s group of companies for data processing activities;(b) service providers (partners/third parties) to enable the performance of our activities by adopting appropriate legal measures; (c) regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations.
How do we keep your data safe?
We will employ reasonable precautions to protect personal information from loss, misuse, unauthorised access, disclosure, alteration, or destruction. Such measures may include the use of restricting access to personal information to those with a legitimate interest in
receiving the information.
Employees who have access to personal information receive privacy training and are advised that they are responsible for fully complying with the privacy principles in this policy and instructed that violations of these principles shall result in appropriate discipline up to and including termination.
International data transfers
When we share data, it may be transferred to, and processed in, countries other than the country you live in – such as to the United States, where our e-newsletter provider is located.
For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data (like the US), or to a third party where we have approved transfer mechanisms in place to protect your personal data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
It is your personal data and you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in our e-newsletter or send us an e-mail to: email@example.com
You also have rights to:
– know what personal data we hold about you, and to make sure it’s correct and up to date
– access, correct, amend or delete that information
If you consent to receive our e-newsletter, any information we use for this purpose will be kept with us until you notify us that you no longer wish to receive this information.
– There is no statutory or contractual requirement for you to provide your data to us and you are not obliged to do so. However, please note that we may not be able to provide you with the services you have requested, such as to receive our newsletter, if you do not provide your contact details. As set out in our cookies policy, our website may not be able to function fully if you do not agree to certain cookies being set on your computer.
– We won’t sell your data or share it for commercial purposes.
– We do not undertake automated decision-making or profiling on your data.
– If you think your data rights have been breached, you are able to raise a complaint with the Information Commissioner (ICO). You can contact the ICO at Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or by telephone on 0303 123 1113 (local rate) or 01625 545 745.
Most websites use a small text file called a cookie to store your website preferences in your web browser e.g. to check if you are logged in, to remember what items you have in your shopping basket etc. Many websites also have third party applications which set their own third party cookies e.g. an interactive Google map.
This page sets out the cookies our website uses and what they are used for. It also specifies whether these cookies are first party (set by this website) or third party (set by another website).
Be aware that some areas of this website will not function correctly if you do not accept cookies from this website.
Description: Google Analytics/Website Optimizer – We use these cookies to monitor visits to our website and how visitors interact with our website in order to make improvements that will benefit our visitors. Google stores this activity anonymously on its servers.
The cookies have variable persistence.
You can learn more here: http://www.google.com/analytics/learn/privacy.html
THIRD PARTY COOKIES
Cookies: guest_id, __utma, __utmz, __utmv, k_, twitter_sess, pid
Description: Twitter – For our user’s convenience, our website uses the Twitter share plugin.
This third party plugin installs these third party cookies to allow the use of the plugin and to track how the plugin is used across the internet.
The cookies have variable persistence.
You can learn more here: http://twitter.com/privacy