UPDATE MESSAGE: This Privacy Policy was last updated on 11 March 2019.
We have updated this policy to comply with the EU General Data Protection Regulations
We at Gebeya, Inc. (“Gebeya”, “we”, “us”, “Our”) respect your privacy which is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and, subject to your consent and/or requirements under applicable law, disclose personal information. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data. We are committed to conducting our business in accordance with these principles in order to ensure that the privacy of personal information is protected and maintained. Unless we state otherwise, this Privacy Policy applies when you visit or use the Gebeya marketplace and training websites, mobile applications, APIs or related services (the “Services”). By using the Services, you agree to the terms of this Privacy Policy. If you do not agree with this Privacy Policy or any other agreement that governs your use of the Service, DO NOT USE OUR WEBSITE.
1. Our Responsibilities
It is the policy of the Gebeya to maintain an environment that promotes ethical and responsible conduct in all online network activities by instructors, employees and students. Gebeya INC recognizes its legal and ethical obligation to provide a safe study environment in both its online and taught courses and to protect your personal information and Data in that regard. To this end, Gebeya reserves the right and recognizes its obligation to:
2. Data Collection
We collect certain data from you directly, like information you enter yourself, data about your participation in our marketplace and/ trainings, and data from third party platforms you connect with Gebeya. We also use third party analytics to collect some data, like information about your device.
Data You Provide
We may collect different data from or about you depending on how you use the Services. When you create an account and use the Services, including through a third party platform, we collect personal information which includes any information about you from which you can be identified. It does not include data where the identity has been removed (e.g., anonymized or aggregated data). The categories of Personal Information about you that we may collect, use, store or transfer (subject to your consent and/ requirements under applicable law) includes the following, some of which constitute Personal Information only when combined with personal identifiers:
How We Get Data About You
We use tools like cookies, web beacons, analytical services to analyze trends and administer the website, track users’ movement around the websites and to gather data referenced above.
3. Purpose of Information
Before or at the time of collecting personal information, we will identify the purposes for which information is being collected. These include but not limited to:
We will collect and use of personal information solely with the objective of fulfilling those purposes specified above by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.
4. Information Sharing and Disclosure
Depending on usage, we may share certain data about you with certain Gebeya talent, trainers, students, companies performing services for us or hiring talent from us, our business partners, analytics and data enrichment providers, your social media providers, companies helping us run promotions and surveys, and advertising companies who help us promote our Services. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways if it is aggregated or de-identified or if we get your consent. We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:
K. During a Change in Control: If Gebeya undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence).
L. After Aggregation/De-identification: We can disclose or use aggregate or de-identified data for any purpose.
M. With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy.
5. Data Retention
Gebeya retains personal data, as necessary, for the duration of the relevant business relationship. We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, Gebeya will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Choices and Rights” section of this Privacy Policy
6. Security of Information
Gebeya has implemented generally accepted standards of technology and operational security to protect personal data from loss or theft, unauthorized access, disclosure, copying, use or modification, alteration, or destruction. Only authorized Gebeya personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. All access to our Services is encrypted using industry-standard transport layer security technology (“TLS”). When you enter sensitive information, we encrypt the transmission of that information using secure socket layer technology (“SSL”). We also use HTTP strict transport security to add an additional layer of protection. Despite these precautions however, Gebeya cannot guarantee that unauthorized persons will not obtain access to your personal data.
7. Your Choices and Rights
8. International Transfers of Your Personal data
Information collected from you may be stored and processed in Ethiopia, Kenya, Djibouti, European Economic Area, the United States, or any other country in which we or agents or contractors maintain facilities, and by accessing our sites and using our services, you consent to any such transfer of information outside of your country. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country. If you reside in the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data to other jurisdictions in which we operate. By providing your personal data, you consent to any transfer and processing in accordance with this Policy.
9. Changes to our Privacy Policy
By using our Services, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our site.
10. Governing Law
Any claim relating to the Services shall be governed by the laws of the State of California without regard to its conflict of law provisions.
In any action between or among any of the parties, whether arising out of these or otherwise, each of the parties irrevocably and unconditionally (i) consents and submits to the exclusive jurisdiction and venue of the state and federal courts located in California; and (ii) waives any and all right to trial by jury in any legal proceeding arising out of or related to this agreement or any transactions contemplated hereby.
11. Contact Information
If you have any questions about our Privacy Policy, please contact us at: sales@gebeya.com