Last updated October 2024
This policy explains:
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.
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:
| 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].
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.
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:
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.
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:
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:
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.
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.
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.
You can ask us to:
You can object:
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:
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
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
or our
Data Protection Officer
or our
EU Representative
Kinstellar SPARL
8 – 10 Nicolae Iorga, Sector 1,
010434 Bucharest, Romania
This privacy policy was published in October 2024. We periodically review this policy, and we will publish any changes on this website.