Angaza Ltd. (“Angaza,” “we” or “us”) is serious about protecting your privacy and the security of your personal data. This Angaza Privacy Policy (“Privacy Policy”) is incorporated as part of Angaza’s General Terms and Conditions (“Terms”) for use of our MindZu app (“MindZu”), our website (“Website”) and their respective services (“Services”).
This Privacy Policy informs our users about the types of personal data that we collect, process and use, the purposes for such collection, processing and use, and your rights and options regarding use of your personal data. Therefore, please read this Privacy Policy carefully.
Angaza Ltd. (which has its registered office at c/o Alliance Financial Services Ltd, Level 2, Standard Chartered Tower, Cybercity, Ebene, Republic of Mauritius) is the data controller and responsible entity in accordance with the European General Data Protection Regulations (“GDPR”).
Angaza collects, processes and uses your personal data exclusively in accordance with the provisions of this Privacy Policy and applicable data protection regulations.
Your personal data will be stored on servers in Ireland and will not be transferred outside the EU, except as required to provide necessary functionality of MindZu to you personally when you are not geographically present in the EU.
1. Personal Data
Under this Privacy Policy, personal data means any information concerning an identified or identifiable person (data subject; including legal entities). This includes, for example, information such as name, birth date, mailing address, e-mail address, phone number, name of the phone, IP address, device ID (such as UDID or IMEI or MAC address), credit card and or any other methods of payment, geolocation data, and information on app or website usage.
We will never ask for, store or process your credit card information as all payments are handled by the app store, and we never get to see your personal payment information.
The types of personal information that we will collect may include some or all of the following personal data, depending on how you decide to use MindZu, our Website or our Services:
- Information required for contact, including your full name, valid e-mail address, and country of residence, valid mobile phone number.
- Information on your use of MindZu, the Website, or Services, such as the scope of the data transfer, the location from which you access data as well as other connection data and sources that you retrieve. This is usually done by the use of so-called cookies. For more information on cookies, please see below.
- Registering for the free version of the MindZu app requires you to provide your mobile phone number. We will use this to verify your registration via a One Time Pin sent to you via SMS. Provision of your email address at this stage is optional. The collection and use of additional personal data begins only if you enroll for the complete curriculum. If you are living in India and are under the age of 18 years, your parent or legal guardian must agree to the Terms and Conditions of the App. Specifically it is assumed that you have requested and received the consent of your parent or legal guardian for you to use the App, and to allow us to collect and process on the App any necessary personal information about yourself or your parents or your guardian.
2. Use of Personal Data
We use your personal data for the following purposes:
· for the purposes for which you specifically provided it including, without limitation, to enable us to respond to your inquiries and process and fulfill your requests;
· to ensure MindZu serves to you the appropriate content for your stage in your learning journey;
· to track your progress through lessons, exercises and games, and to monitor and report to you your progress and performance data;
· to send you information about your relationship or transactions with us, including updates, notices, and additional information related to the company;
· to operate the MindZu app, the Website and Services and to improve your experience with us, including by presenting opportunities, products or offers tailored to you;
· to create aggregated and anonymized Non-Personal Data (as defined below);
· for our internal business purposes, such as data analysis, audits, developing new products, enhancing MindZu and our Website, improving our Services, identifying usage trends, and determining the effectiveness of our promotional campaigns;
· to comply with our obligations arising from any contracts between you and us;
· to enforce the Terms.
3. Collection of Non-Personal Information
3.1 “Non-Personal Information” is any information that does not reveal your specific identity, including aggregated and fully anonymized information.
3.2 We may collect Non-Personal Information in a variety of ways. For example, we may:
· collect information such as your phone type or computer type, your operating system, your screen resolution or your connection speed.
· collect demographic information, such as your location, as well as other information, when you voluntarily provide this information to us. Unless combined with personal data (as described above), this information does not personally identify you or anyone else.
3.3 Aggregating information. We may aggregate and anonymize personal data (as described above) so that the aggregated information does not personally identify you or anyone else. We will not combine Non-Personal Information with personal data (such as combining your name with your geographical location) unless required by law or you have specifically consented. If we combine any Non-Personal Information with personal data, we will treat the combined information as personal data.
3.4 Use and Sharing of Non-Personal Information. Because Non-Personal Information does not personally identify you, we may collect, use and disclose Non-Personal Information for any purposes. These include but are not limited to the following: operating and improving the MindZu app, the Website and Services, creating new Services and features, and transferring, communicating or otherwise making available Non-Personal Information to selected business partners and other third parties, based on our instructions and in accordance with this Privacy Policy and any other applicable data protection regulations.
4. Cookies, Targeting and Other Technologies
4.1 We may also collect information about your computer and/or mobile device, such as the operating system and browser type used. We use this information to manage and administer the MindZu app and our Website. We share this information in a fully anonymous form with our business associates. This information consists of statistical data about users’ activity on the MindZu app or the Website.
4.2 The Website uses cookies. Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide web services and functionalities for the users. For example, they enable us to improve your experience on the Website and offer you a better and more customized service. Cookies enable the Website to remember your actions and preferences (such as login, language, font size and other display preferences) so that you don’t have to re-enter them each time you use the Website.
4.3 Cookies may be either “persistent” cookies or “session” cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
4.4 We use the following types of cookies:
· Strictly Necessary Cookies: These cookies are essential in order to carry out a request initiated by you, for example by remembering information provided by you as you move through the site to and managing your logged-in status during the session. You cannot opt out of these cookies as the Website cannot function properly without them.
· Performance Cookies: These cookies allow us to collect data relating to your use of our Website, including the content on which you click while browsing on our Website, in order to collect and record information about what you viewed on our Website, to measure the effectiveness and consumer interaction with the Website and improve our Website over time and to help us understand the size of our audience and traffic patterns. These cookies may be provided by our third-party analytic tool provider but are only used for purposes related to our Website.
· Targeting Cookies: These cookies remember information regarding your use of our Website and other websites so that we can serve promotional and other targeted information to you specific to your interests on our and other websites.
· Social Sharing Cookies: These cookies provide access to social networks and may collect personal information in relation to your use of these networks. We have no control for how the social networks may collect and use your personal information and their use is subject to the social network’s privacy policy.
4.5 Changing the Browser Setting
If you do not wish to use the cookie technologies described here, you can set your browser to not accept cookies. Please note that in this case, you may only be able to use our Website and Services in a restricted way or not at all.
5. Google Analytics
5.1 Google Analytics: As mentioned above, Angaza uses Google Analytics, a third-party analysis service provided by Google Inc. (“Google”). Google Analytics uses “performance cookies” to analyze how you use the Website, App and Services. The information generated by the cookie about your use of the Website, App and Services (including your IP address) will be transmitted to and stored by Google on servers in the United States. Our Website uses Google Analytics with the expansion ‘_anonymizeIp()’; therefore, only abbreviated IP addresses will be further processed, so that a direct connection to the individual user is eliminated. Your IP address will be shortened beforehand by Google (i.e. the last octet of the IP address will be anonymized) within member states of the European Union or in other signatory states of the Treaty on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google Server in the USA and shortened there. Google will use this information on behalf of the Website operator for the purpose of evaluating your use of the Website and Services, compiling reports on Website activity, and providing other services to Website operators relating to Website activity and Internet usage. Google will not associate the IP address transmitted under Google Analytics by your browser with other data held by Google. You may prevent the use of Google Analytics by disabling cookies in the browser’s set up screen. You may prevent the storage of cookies by selecting the appropriate settings on your browser software; however, we must advise you that in this case, you might not be able to use all functions of this Website to the full extent. You may prevent Google from recording the data generated by the cookie and pertaining to your use of the Website and Services (including your IP address), or processing these data by downloading and installing the following browser plug-in available through Google at the following link: http://tools.google.com/dlpage/gaoptout.
5.2 Google’s Privacy Notice is located at https://policies.google.com/privacy. An opt-out cookie will be set on the computer, which prevents the future collection of your data when using the Website and Services: <a href=”javascript:gaOptout()”>Disable Google Analytics</a>.
6. Data Security
Unfortunately, the transmission of information over the Internet is not completely secure. Although we have appropriate measures in place to protect your personal data, we cannot guarantee the security of the data transmitted via our Website. Any of your data transfers will be at your own risk. No one can guarantee absolute protection. However, we will protect the confidentiality, availability and the integrity of your personal data and our App and Website and other systems from the loss, destruction, access, alteration or dissemination of your data by unauthorized persons through technical and organizational measures.
7. Sharing Personal Data
We will not share your personal data with third parties except as set out in this Privacy Policy and the Terms unless you have agreed to the data disclosure or we are entitled to disclose the data on the basis of legal regulations. For example, the following may be the case:
7.1 In the case of a contemplated sale or purchase of Angaza or individual assets, we may disclose your personal data to the potential purchaser or seller.
7.2 If the disclosure of your personal data is necessary to comply with the Terms, or to protect the rights, property or safety of Angaza, our users or third parties.
7.3 Insofar as a disclosure is necessary to fulfill legitimate prevailing interests of Angaza.
8. Links to Third Party Websites
The MindZu app and the Website may from time to time contain links to and from third party websites. If you follow a link to one of these websites, please note that these websites are subject to their own privacy regulations and we cannot assume any responsibility or guarantee for third-party data protection conditions. Please make sure that you are aware of the applicable privacy policy before sending personal data to these websites.
9. Changes to this Privacy Policy
We reserve the right to change this Privacy Policy at any time with effect for the future. A current version is available on the MindZu app and on the Website. We will inform you by appropriate means of any changes to this Privacy Policy and will require your consent to those changes.
This Privacy Policy is dated: 8 November 2018.
10. Your Rights and Contact Information
You may view your personal data at any time free of charge and request their correction and / or deletion and / or blocking. For this purpose and / or for more information, please contact us at support@Angazagroup.com. Should you have any questions, comments or inquiries concerning our collection, processing and use of your personal data, please contact us as indicated above.