Privacy Policy – ALX Ventures

Last updated October 2024

This policy explains:

who we are
why we collect personal data
what kinds of personal data we collect
where we get it from
how we use it;
direct marketing;
who we might share it with;
how we store and secure it;
how long we keep it;
your rights; and
how to complain about our use of personal data.

WHO WE ARE

ALX Holdings Limited (“ALX”, “we”, “us”) is a company registered in Mauritius.

Business registration number: C213364

Registered office address: 5th Floor, The CORE Building, No. 62, ICT Avenue, Cybercity, Ebene, Mauritius

We act as a ‘controller’ of the personal data on our website (https://alx-ventures.com/privacy-policy/), “ALX Ventures” .

WHY WE COLLECT PERSONAL DATA

ALX Ventures is a community of passionate, courageous ‘doers’ where we help the world’s top entrepreneurs to fulfill their potential. At ALX Ventures, entrepreneurs receive guidance, training, and support in the early-age development of their business. We have the following programs (“ALX Ventures Programs” and each a
“Program”):

1. The Founder Academy

A comprehensive 3-month program offering video insights from successful African startup founders, live masterclasses and fireside chats, pitch deck and business plan templates, a vibrant community of peers, and the tools to validate, develop, and launch your innovative idea or prototype.

2. The Accelerator

An intense 3-month program tailored for businesses with a market presence seeking to boost revenue, secure growth financing, further enhance products, offering pitch events, seasoned mentorship, investor readiness support, and strategies to enhance sales and attract investors.

3. The Venture Fund

An upcoming exclusive co-investment vehicle that invests alongside other top-tier investors that back the strongest startups emerging from our ALX Ventures ecosystem, where portfolio companies will also continue to receive post-investment advisory support from our global network of experts.

Our Privacy Policy applies to any participant of ALX Venture Programs or visitors to the website or applications operated by us.

We never sell personal data to anyone for any purpose. We do not give personal data to others for their own use.

HOW WE USE PERSONAL DATA ABOUT YOU

Under the law, we must process your data lawfully, fairly, and transparently. We rely on one of the legal bases below for processing personal data, depending on what the data is and what we use it for:

our legitimate interests;
to comply with the law;
your consent; or
to perform our contract with you (providing the ALX Ventures Programs )

Why we process it	Type of personal data	Our legal basis
Providing and managing the Founder Academy, which includes: Enrolling you onto the Program and handling administrative matter Delivering the Program on a virtual basis *Delivering the Program in person	Identity data: your name, location, ID series and number, age, date of birth, gender, country of origin, municipality, city and country of residence, and social media handles (LinkedIn profile), position in your company Contact data: this includes emails, phone number, SMS, instant messages, social media exchanges and any other communications between us on (Telegram, WhatsApp, Instagram, or Facebook/Meta, Tiktok, LinkedIn), IP Address, user activity logs, device type, operating system Biographical: information about your background including your academic qualifications, employment history and any other information you share with us about you whether before, during or after the Program, such as CV, highest level of education, field of study, current, employment status, employer name and position in the organisation, number of years of work experience, internships and related data,financial household earnings, including data on shareholders/officers in your company Photographs & Media: we may record Program sessions containing your image (you are encouraged to enable your camera to facilitate participation) and voice. We may also take photos of you individually or as part of a group	to perform our contract with you (the Founder Academy)

Why we process it

Type of personal data

Our legal basis

Providing and managing the Founder Academy, which includes: *Enrolling you onto the Program and handling administrative matter *Delivering the Program on a virtual basis *Delivering the Program in person

Identity data: your name, location, ID series and number, age, date of birth, gender, country of origin, municipality, city and country of residence, and social media handles (LinkedIn profile), position in your company

Contact data: this includes emails, phone number, SMS, instant messages, social media exchanges and any other communications between us on (Telegram, WhatsApp, Instagram, or Facebook/Meta, Tiktok, LinkedIn), IP Address, user activity logs, device type, operating system

Biographical: information about your background including your academic qualifications, employment history and any other information you share with us about you whether before, during or after the Program, such as CV, highest level of education, field of study, current, employment status, employer name and position in the organisation, number of years of work experience, internships and related data,financial household earnings, including data on shareholders/officers in your company

Photographs & Media: we may record Program sessions containing your image (you are encouraged to enable your camera to facilitate participation) and voice. We may also take photos of you individually or as part of a group

to perform our contract with you (the Founder Academy)

Why we process it	Type of personal data	Our legal basis
	Program data: status of the Program, participant performance data (such as: Program completion, milestones, tests, modules completed, modules started, peer review process), preferred ALX City Hub, technical data (such as IP address, location, the browser and platform/device being used, usage metrics)
Providing and managing the Acceleration Program, which includes: Enrolling you onto the Program and handling administrative matters Delivering the Program on a virtual basis *Delivering the Program in person	Identity data Contact data Biographical data Program data Photographs & Media	to perform our contract with you (the Acceleration Program)
Providing and managing the Venture Fund	Identity data Contact data Biographical data Photographs & Media	to perform our contract with you (the Venture Fund)
Obtaining your feedback on the ALX Ventures Program and how it has benefited you e.g., Program surveys, focus groups	Identity data Contact data Biographical data Program data	Your consent to be part of the survey
Data analysis, reporting and statistics regarding the ALX Ventures Programs	Identity data, Contact data Biographical data Program data Data are aggregated for this purpose.	Legitimate interest

Why we process it	Type of personal data	Our legal basis
Commercial communication with you (marketing) sending commercial communications to participants, extending invitations to masterclasses and workshops, promoting events, newsletters or other commercial information, awarding, presenting initiatives and career opportunities	Identity Contact data Biographical data Program data Data on outreach and deliverability of communications: advert engagement data (e.g. views, clicks, keywords used, posts engaged with, sentiment reports, impression count) Website Conversion Actions (e.g. form fills, link clicks) and user traffic source. *browsing patterns (e.g. device type, operation system, number of sessions, pages viewed, time spent on website, link engagement, bounce rate)	Our legitimate interest for direct marketing to existing participants Consent for direct marketing to other individuals
Organising marketing events and webinars	Identity data Contact data Biographical data Photographs & Media	Our legitimate interest for direct marketing to existing participants Consent for direct marketing to other individuals
Compliance with legal requests from public authorities, with our legal obligations, or for our legal claims	all the personal data we collect for the ALX Ventures Programs	To comply with the law and for our legitimate interest
For reorganization of our business (such as transfers, mergers, spin-off)	all the personal data we collect for the ALX Ventures Programs	Our legitimate interest
For internal collaboration and communication	all the personal data we collect for the ALX Ventures Programs	Performance of a contract and our legitimate interest to improve our ALX Ventures Programs and your experience

We do not collect any “special categories” of personal data as defined in the Data Protection Act 2017 (Mauritius) or the GDPR (European Union)

Some of your legal rights will depend on which legal basis we rely on for processing. Please see the Your Rights section below.

DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from or market to children under 18. By using the ALX Ventures Programs or our services, you represent that you are at least 18 or the parent or guardian of such a minor and consent to such minor dependent’s use of the ALX Ventures Programs or our services. If we learn that personal information from users less than 18 years of age has been collected, we will take reasonable measures to delete such data from our records promptly. If you become aware of any data we have collected from children under age 18, please contact us at [email protected].

WHERE WE GET YOUR PERSONAL DATA FROM

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when applying for ALX Ventures Programs and services, expressing an interest in obtaining information about us or our products and services, when participating in activities initiated by us (such as posting messages in our online forums or entering competitions, contests or giveaways) or otherwise contacting us.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

The personal information we collect depends on the context of your interactions with us, the choices you make and the products and features you use, as detailed above.

Other personal data resulted from your use of the ALX Ventures Platforms or attending our events and other activities, as described above.

DIRECT MARKETING

If you are an existing or previous member of part of ALX ecosystem, we may send you promotional emails about initiatives or services that are similar to what you have done with us before. You have the right to opt out of receiving these emails at any time by:

contacting us by email at [email protected]; or
using the ‘unsubscribe’ link at the bottom of the email.

However, we will still need to send you service-related emails that are necessary for the administration of your Program.

In all other circumstances, we will only send marketing emails to your individual email if you have explicitly opted in to our marketing list in advance.

We never sell personal data to anyone for any purpose. Also, we will not give your data to others for their own use without your permission.

WHO WE SHARE PERSONAL DATA WITH

We may need to process your data or share your personal information in the following situations:

I. We may share your data with third-party vendors, service providers, consultants, contractors or agents who perform services for us or on our behalf and require access to such information to do that work, such as:

IT maintenance and service providers, providers of software applications through which our IT systems and document management activities are carried out (including Google workspace, especially for e-mail end document storage), as well as the hosting of these software applications,
data analysis, data statistics, surveys/feedback, customer service. We may allow selected third parties to use tracking technology on ALX Venture Programs or on the services, which will enable them to collect data about how you interact with our platforms over time. This information may be used to, among other things, analyse and track data, determine the popularity of certain content and better understand online activity.
service providers which we use for payment processing, for lead generation and for marketing communications, call center services, third-party advertisers to serve ads, of workflow (CRM), productivity software solutions, e-mail delivery and e-mail outreach service providers, email validation service providers, providers of self-service ticketing platform for live experiences, providers of video-conference solution or of the asynchronous video interview solution.
service providers for our administrative / secretarial services, internal organisational flows, such as our digital productivity, collaboration, and organisational app, video-conferencing solutions and calendar application services.

Such third-party service providers are also not allowed to reuse your personal data for their own purposes.

II. We sometimes share personal data with third parties as part of providing our services or to comply with our legal duties. These third parties can include:

public authorities. We may share your information with law enforcement agencies, public authorities or other organizations, if legally required to do so. This includes tax authorities, auditors, various categories of consultants or institutions with powers to carry out inspections and controls our activity and assets, who request us to provide information, by virtue of our legal obligations, courts, public notaries, bailiffs, official company registry;
group and affiliated companies. We may share your information within entities affiliated to us by common control, management or ownership;
business partners. We may share your information to offer you certain products, services or promotions. We do this when we work together with our partners on a common purpose; or
third party acquirers/potential acquirers and to their auditors and consultants. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

HOW WE STORE AND SECURE PERSONAL DATA

The ALX Ventures Program data is held in our systems, which mostly use AWS cloud and host data in the United States of America. Generally, we only store data with a provider if we are satisfied they protect it with robust policies and cybersecurity measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the services within a secure environment.

All external processors have contracts with us. They are required not to reuse your personal data for their own purposes unless they observe the applicable privacy requirements.

TRANSFERRING YOUR PERSONAL DATA TO OTHER COUNTRIES

Generally, we try to keep your data in the country of origin. However, some of our technical service providers host data in the United State of America (such as AWS, HubSpot, SuperSet, SalesForce, Google Suite). Also, sometimes we need to send personal data to other countries, such as when we send data to another office / local hub in our corporate group (Egypt, Kenya, South Africa, Malawi, Nigeria, Ghana, Ethiopia, Morocco, Romania, Rwanda, USA, UK).

We take note here of the adequacy decision of the European Commission for the EU-U.S. Data Privacy Framework, which concludes that the United States ensures an adequate level of protection – comparable to that of the European Union – for personal data transferred from to US companies under the new framework. AWS, HubSpot, SalesForce, Google are already part of the EU-U.S. Data Privacy Framework.

When we send data to a country that does not have “adequate” data protection laws according to the European Commission, we will only send the data after agreeing to the standard data protection contract clauses approved by the EC. You can see a copy of these standard clauses on the EC website here: Standard Contractual Clauses (SCC) (europa.eu). We will also take supplementary measures, if necessary, to compensate for any lack of protection afforded by the laws of the recipient country.

If you would like further information about data transfers to other countries please contact us.

HOW LONG WE KEEP PERSONAL DATA

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law (such as tax, accounting or other legal requirements).

Generally, when we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If you have any questions in this regard, or any concerns about how long we keep your information for, please contact us using the details below.

YOUR RIGHTS

You can ask us to:

provide you with a copy of your personal data;
correct mistakes in data we hold about you;
delete your personal data from our records (subject to some exceptions in the Data Protection Act 2017 or another applicable privacy law);
restrict the processing of your personal data in some circumstances, such as where you contest the accuracy of the data; and
in certain situations, provide you with a copy of the personal data you provided to us in an easily portable format.

You can object:

at any time to your personal data being processed for direct marketing;
in certain other situations, to our continued processing of your personal data, such as where we carry out processing based on our legitimate interests.

If we are relying on your consent (permission) to use your personal data, you can withdraw your consent any time. However, in some cases if you withdraw consent:

we may still process your personal data without your consent as required or permitted by law, for example to defend our legal rights or to obey a legal requirement to keep the data; or
we may no longer be able to provide you with goods or services (we’ll let you know when this would be the case)

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the ALX Africa Platform or Services, you have the right to request removal of unwanted data that you publicly post on the ALX Africa Platform. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or
comprehensively removed from our systems.

COMPLAINTS

If you wish to complain about our use of personal data, we would appreciate the chance to deal with your concerns first. If you still wish to complain, please consult the Mauritius Data Protection Office website at https://dataprotection.govmu.org/

If you are resident in the EEA (which includes the EU), the GDPR also gives you right to lodge a complaint with your local data protection regulator

HOW TO CONTACT US

Please contact us by post, email, or telephone if you have any questions about either this policy or the information that we hold about you:

Privacy Team

ALX Holdings Limited

5th Floor, The CORE Building,

No. 62, ICT Avenue, Cybercity,

Ebene, Mauritius

[email protected]

or our

Data Protection Officer

dpo@alxafrica.com