Our Policies

Read the policies that guide our working practices.

Legal

Data Protection

Compliance Manual

Safeguarding Policy

 

Legal

When you access the BFA Global website, sign up for our mailing lists to obtain newsletters and other emails concerning BFA Global and its related activities, including projects and anchor tenancies (“Mailing Lists”), register for access to publications (“Publications”), events  (“Events”) and/or webinars (“Webinars”) or make a job application (“Job Posting”), we and/or our service providers collect information as part of our interaction with you. This Privacy Policy (the “Policy”) tells you what information about you (“Information”) BFA Global (“BFA Global” or “we”) or our service providers collect when you interact with us via our Websites.

Please note that this Policy may change from time-to-time. We will post changes on this URL and note the effective date so that you are always aware of the Policy that applies to you. This Policy was last updated on October 23, 2018. Please check the Policy each time you visit this Website for the most current version. This Policy concerns only our Website, and does not concern any other third-party website, including sites to which our Website may link. If you do not wish us to collect, use, share, and protect your Information consistent with this Policy, immediately discontinue your access to and use of our Website and do not return.

Please note that this Policy is subject to our Terms of Use of our Website. Except as otherwise provided, terms defined in our Terms of Use of our Website have the same meaning in this Policy. If there is a conflict between our Terms of Use of our Website and this Policy, this Policy shall prevail. Please also note that there are special provisions if you register for the Mailing Lists, a Publication, an Event, or a Webinar, post and/or contribute contents to the Websites, apply for a Job Posting or share Publications with third parties. The additional Information that is provided in those instances is governed by the specific clauses in this Policy concerning the Mailing Lists, the Publications, the Events, the Webinars, and the Job Postings. These particular provisions are accepted by you when they register for our Mailing List, when you download a Publication, when they post and/or contribute contents to the Websites, when you register to access a Webinar or an Event, when you submit a job application, and when you share a Publication with a third party for the first time.

International Transfer

Third parties that process BFA Global’s data include The Rocket Science Group LLC (doing business as MailChimp), Automattic Inc. (doing business as WordPress), SquareSpace Inc., Zoom Video Communications Inc., and Google LLC, which are active participants in both the Swiss-US Privacy Shield Framework and the EU-US Privacy Shield Framework, as recorded here. Thus, our legal basis for transferring data internationally is the Data Processing Agreements with these data processors.

Your information may be transferred to – and maintained on – computers located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the US and choose to provide information to us, we transfer personal information to the US and process it there. Your consent to this Policy followed by your submission of such information represents your agreement to that transfer.

How we collect Information about you

Our website uses third-party technologies to help us gather aggregate information about the user experience, including analytic tools such as Google Analytics and WordPress Analytics. Accordingly, and depending on the Website, the web browsers used by you automatically send certain information to Google and/or WordPress. This includes, for example, the web address of the pages that you are visiting, your IP address, your device category and platform, and the duration of your visit. This information is collected by Google and WordPress on an aggregate and non-individual specific basis. Google and WordPress provide us with reports based on this information that we use to understand website traffic and web page usage.

If you chose to register for our Mailing List, a Publication, a Webinar, a Event, or apply for a Job on our Websites, we will use the Information provided by you only for that purpose, and not for any other purposes not explicitly consented to. Keep this in mind while reviewing the Information that we collect for the following services:

  • If you register for our Mailing List, we only collect, via MailChimp, your name, email address, your job title, and the company for which you are currently employed.
  • If you register to access an Event, and/or to download a Publication via the Websites, we only collect, via MailChimp or WordPress, your name, email address, your job title, and the company for which you are currently employed.
  • If you contact us using a contact form on our Websites, we only collect, directly or via MailChimp, WordPress or Google Drive, your name, and email address.
  • If you register for a Webinar via the Websites, we only collect, via Zoom, your name, email address, your job title, and the company for which you are currently employed.
  • If you post and/ or contribute contents to the Websites, we only collect [to be completed by Carmen once confirmed the process of how visitors can post]…
  • If you apply to a Job Posting, we only collect, via Google Forms, your name, email, current location, highest degree and major, name of awarding college/university, work experience, last or current place of employment, current skills, why you think you are the right fit for the position, CV, and any cover letter attachments.
  • If you share copies of Publications to a third party via email through social media plug-ins, we only collect [ to be completed by Carmen once confirmed the process of sharing publication]…

 

How we use cookies and web beacons

When you access our Websites, we or the companies that host our Websites – such as Squarespace and WordPress, and Google Analytics – may place small data files called “cookies” on your computer to track how the Websites are used. These cookies are encoded so that only we can interpret the information stored in them. Each time you access our Websites, you will be prompted to accept our cookie policy. You are free to decline cookies if your browser permits, in which case information will not be collected from the cookies.

Emails sent to our Mailing List and our Websites may contain electronic images known as web beacons (sometimes called single-pixel gifs) and are used along with cookies to compile aggregated statistics to analyze how these emails and Websites are used.

How we protect and store Information

Throughout this Policy, the term “Information” is used to describe non-public information that can be associated with a specific person and can be used to identify that person. This useage does not include information that has been anonymized so that it does not identify a specific user.

We store and process Information on our servers in the United States and other locations where Google data centers are located and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable legislative and regulatory standards. We use computer safeguards such as firewalls and authorize access to Information only for those employees who require it to fulfill their job responsibilities.

We use contemporary technologies and maintain rigorous security standards and procedures with a view to preventing unauthorized access to all Information. However, you should note that our third-party service providers hold the data they collect on the basis of their own privacy policies  (as set out here: MailchimpZoomWordPressSquarespace, and Google), and they have their own security standards and procedures with a view to preventing unauthorized access to this data. You are strongly advised to read these third-party provider’s privacy policies and satisfy yourself as to the adequacy of their security standards and procedures before accessing our Websites.

Messages and information passing over the Internet may not be secure and can be intercepted by third parties or incorrectly delivered. The confidentiality of such communications cannot, therefore, be guaranteed and you should not divulge personal information over the Internet unless you are using secure or encrypted communications technology. We will, however, inform you if any data breaches occur as soon as practicable once we become aware of any such breach.

How we use the Information collected

We collect Information to provide you with a secure, seamless, and simple user experience and to comply with all legal regulations. We do not use Information to make automated decisions. All Information will be treated by us with the utmost confidentiality. The lawful basis for this processing is that in each case we gather consent from you to process your personal data for one or more specific purposes. We will store Information until that Information is no longer relevant for the original service provided. For instance, if we decide to stop sending emails to our Mailing List, we will stop storing Information provided to us for the purpose of subscribing to the Mailing List. We use Information to:

  •       {enable you to post content to the Website;}
  •       enable you to register for an Event
  •       enable you to apply for a Job Posting
  •       allow you to read content on the Websites
  •       provide you access to Webinars on the Websites and other third party websites
  •     enable us to let you send copies of Publications to third parties via third party social media plug-ins
  •       provide you with newsletters and other emails related to BFA Global and its related activities if requested
  •       provide you with Publications if requested
  •       resolve disputes and troubleshoot problems
  •   monitor potentially prohibited or illegal activities and enforce the Terms of Use of the Websites
  •       customize, measure, and improve the content and layout of the Websites;
  •     customize, measure, and improve our newsletters, Webinars, and Publications, including the posting of invitations to third party events
  •     send you information in regards to matters that are relevant to you as Mailing List subscribers (such as service and newsletter update notices)
  •       compare information for accuracy and verify it with third parties

How we share Information with other parties

We may share Information with:

  •       Members of the BFA Global corporate family to help detect and prevent potentially illegal acts, provide joint service offerings, and for other business purposes. However, our corporate affiliates will not use this Information to market their services unless approved by you.
  •       Third-party service providers under contract that assist with parts of our business operations such as marketing and technology services, including MailChimp (Mailing List distribution), Google Analytics, WordPress Analytics and Squarespace (in regard to Website visits), Zoom (Webinars), and Google Forms (Job Postings). Pursuant to our Terms of Use of the Websites, these service providers only use Information in connection with the services they perform for us and not for their own benefit.
  •       Third-party service providers and other independent contractors that we partner with that allow you to click through from our Websites to their own websites in order to facilitate the sharing of Publications. In this case we will only provide the data inputted by you, namely the shared Publication and your IP address. This data will be held by the third-party provider for the purposes set out in that third-party provider’s privacy policy. You are strongly advised to read the chosen third-party provider’s privacy policy and satisfy yourself as to the purposes for which the third-party provider will use your Information before sharing Publications. We have no responsibility for the uses to which a third-party provider puts your Information once you have used the third-party plug-in.
  •       Companies that we plan to merge with or be acquired by. (Should such a combination occur, we shall require that the new combined entity follow this Policy with respect to Information.)
  •       Law enforcement, government officials, or other third parties when:

o We are compelled to do so by a subpoena, a court order, or a similar legal procedure

o We are required to do so to comply with the law

O We believe in good faith that the disclosure of Information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms of Use of Websites

  •       Other third parties with your consent.
  •     We will not sell or rent any of your Information to third parties in the normal course of doing business and only share Information with third parties as described in this Policy.

Accessing or changing Information and contacting us

You have the right to request the following from us:

  •       A copy of all Information relating to you held by us
  •       Whether or not personal data is being processed
  •       The purposes of the processing
  •       The categories of data concerned
  •       The recipients to whom the data have been or will be disclosed
  •       The period for which the personal data will be stored
  •     To have any inaccurate Information rectified or erased, including any contents that you have posted or contributed to the Websites
  •       To have Information taken off a direct marketing or direct mailing list

If you wish to make such a request or have questions or concerns regarding this Policy, you should contact the Data Protection Officer at Bankable Frontier Associates, LLC, using any of the following:

  •       Address: 20 University Rd, Suite #500, Cambridge, MA 02138
  •       Telephone: + 1 506 686 7506
  •       Email: privacy@bfaglobal.com

You should endeavor to give as much detail as possible in your correspondence, which will help to identify you (e.g., name and email address) and locate all the information that we may hold.

In addition, you may at any time request that your contributions to the Websites be deleted by sending an email to the following address: privacy@bfaglobal.com/

If you wish to unsubscribe from a Mailing List, you may do so by clicking on the “unsubscribe” hyperlink found on the bottom of each newsletter and following the procedure indicated, in which case we will remove your email address from our Mailing List database within 48 hours upon receipt of such notice from you.

You also have the right to lodge a complaint with a supervisory authority regarding our data processing.

Data Protection

BFA Global is committed to ensuring an adequate level of personal data protection at all BFA Global offices. Social, cultural, and regulatory differences between the country offices shall not affect the adequate level of personal data protection. BFA Global employees, clients, vendors, and partners can rely on the promise that BFA Global will treat personal data in all offices in an equally secure and responsible way.

The objective of the Data Protection Policy is to provide adequate protection for the transfers and processing of personal data by BFA Global offices. BFA Global can only achieve this goal of providing an adequate level of data protection if all BFA Global offices and every single employee, consultant, agent, and vendor accept the policy as binding. It is the duty of all BFA Global offices, consultants, vendors, agents, and employees to always abide by the Rules.

BFA Global acknowledges that maintaining an adequate level of personal data protection demands continuous efforts of all BFA Global stakeholders. BFA Global will ensure compliance with the Rules. The audit scheme, which is part of the Rules, helps BFA Global to monitor the personal data protection processes.

DATA PROTECTION BINDING CORPORATE RULES

BFA GLOBAL LTD KENYA DATA PROTECTION POLICY

Compliance Manual

BFA Global Compliance Manual

 

 

Safeguarding Policy

BFA Global Safeguarding Policy