Privacy Policy

Last updated on: 03/09/2024

Introduction

VVOB in Rwanda is committed to protecting the privacy and security of your personal data. This privacy statement outlines our practices and the choices you can make about the way your personal data is collected online and how that personal data is used. We aim to ensure that your personal data is processed fairly, lawfully, and transparently, without adversely affecting your rights under data protection
regulation.

Personal Data Collection

At VVOB in Rwanda, we collect personal data in a few diverse ways—directly from you as well as passively through our website’s technology:

• Direct Collection: We collect personal data directly from you when you:
  • Register for any of our services.
  • Interact with us during events, workshops, and conferences.
  • Communicate with us directly via our contact forms, emails, etc.
• Indirect Collection: Our website automatically collects certain personal data to help us understand how visitors use our site, improve our service, and manage site security. This includes:
  • IP address and browser type: Collected passively when you visit our site.
  • Usage data: We collect personal data about the pages you visit, the time you spend on each page, and the links you click on.
  • Use of Tracking Technologies Microsoft Clarity: For analytics, without collecting personally identifiable information. Cookies: Detailed cookie use includes:
    • VISITOR_PRIVACY_METADATA: Manages user consent settings.
    • YSC and VISITOR_INFO1_LIVE: Tracks YouTube video interactions and preferences.
• Types of Personal Data Collected:
  • Identifying Information: First and last name, address details (containing street name, city of living, post-box).
  • Contact Information: Your Phone number, email address.
  • Technical Information: Your IP address.

This personal data helps us tailor and improve our interactions with you, ensuring you receive the most relevant and timely information about our programs and services.

Use of Collected Data

The data we collect serves various functions essential to our operations and helps us provide a tailored educational experience. Here’s how we utilize the informaiton collected:

• Service Provision: Your personal data is essential for us to provide the services you’ve requested or to respond to your inquiries. This includes registering for our programs, sending newsletters, and providing educational resources.
• Website Optimization and Analytics: We analyse data about how our services are used and how our website is navigated to continuously improve the functionality and user experience. This includes understanding user behaviour, optimizing our content layout, and enhancing site navigation to make our website more intuitive and user-friendly.
• Legal Compliance: We use your personal data to comply with legal obligations, such as maintaining records for compliance with educational regulations or responding to legal processes.
• Communication and Marketing: We may use your personal data to communicate with you about updates, new services, or upcoming events that may be of interest. We ensure that all such communications are provided with options to unsubscribe or opt-out to respect your preferences.
• Security: We monitor data collected to help protect our website and infrastructure from potential cyber threats or fraud.

Each use of your personal data is based on a legal basis, either because it is necessary for our contract with you, required by law, or because you have consented to the use of your personal data. We ensure all data processing respects your rights and offers transparency about how your data is used.

Sharing of Personal Data

VVOB is committed to maintaining the confidentiality of your personal data. However, there are circumstances under which we may share your data with third parties:

• Service Providers and Partners: We may share your data with trusted third-party service providers who perform services on our behalf, such as web hosting, data analysis, personal data technology and related infrastructure, customer service, email delivery, and auditing services. These third parties are authorized to use your personal data only as necessary to provide these services to us and are contractually obligated to keep your personal data secure.
• Legal Requirements and Safety: We may disclose your personal data if required by law, such as to comply with process specific criminal and/or tax law obligations of an obligatory nature.
• Business Transfers: In the event of a merger, acquisition, restructuring, bankruptcy, or other sale of all or a portion of our assets, personal data held by us about our website users may be among the transferred assets.
• Consent-Based Sharing: With your consent, we may also share your personal data with other third parties in ways not described in this privacy statement.

We take care to ensure that your personal data is processed, shared, and stored securely, maintaining compliance with data protection regulations.

Your Rights

As a user, you have legal rights concerning your personal data and the way it is collected and processed. These rights include:

• Right to Access: You have the right to request access to the personal data we hold about you. This allows you to receive a copy of the personal data we have about you in a structured, commonly used, and machine-readable format.
• Right to Rectification: You have the right to request that we correct any personal data you believe is inaccurate. You also have the right to request us to complete personal data you believe is incomplete.
• Right to Erasure (“Right to be Forgotten”): You may ask us to delete or remove personal data at any given time. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. The request for erasure of your data is limited by certain restrictions: we may need to retain your personal data as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention and enhancing safety and/or in the extent necessary to comply with legal, tax, reporting and auditing obligations.
• Restriction of Processing: You have the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information, (ii) the processing is unlawful and you oppose the erasure of your personal information, (iii) we no longer need your personal information for the purposes of the processing, but you require the personal information for the establishment, exercise, or defence of legal claims.
• Right to Object to Processing: You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground.
• Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.
• Right to Withdraw Consent: Where the basis of processing is your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to file a Complaint: You have the right to lodge a complaint with the person in charge of data protection within VVOB (see contact details below under section 9) and/or at the competent data protection authority about our collection and use of your personal data. For more personal data, please contact your local data protection authority.

VVOB engages to respond responds to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws within a reasonable timeframe, latest within one month of receipt of the request.

Data Security and Retention

Data Security:

VVOB is dedicated to ensuring the security of your personal data. We implement appropriate technical and organizational measures to protect personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. This includes:

• Encryption: Using encryption technologies to safeguard data during transmission and at rest.
• Access Controls: Limiting access to personal data to those employees, agents, and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
• Regular Audits: Conducting regular security assessments and audits to ensure our processes and protocols are up to date and effective.
• Incident Reporting and Prevention: Maintaining incident response plans to address potential data breaches and mitigate their effects.

Data Retention:

Our data retention policies are designed to ensure we do not retain personal data for longer than necessary in relation to the purposes for which it was originally collected, or for which it may lawfully be further processed. The length of time for which we retain data depends on the legal, regulatory, and operational requirements. Specifically:

• Service-Related Data: Data related to the provision of our services is generally retained for the duration of the service provision plus a period of up to six years to handle any post-service inquiries or claims.
• Marketing Data: Data used for marketing purposes is kept until you unsubscribe or request that it be deleted.
• Compliance Data: Data needed for compliance with legal obligations, resolution of disputes, and enforcement of our agreements may be held for the period required by law in the respective jurisdiction.

After this period, all personal data is securely deleted.

Use of Microsoft Clarity and AdWords

VVOB utilizes Microsoft Clarity, a web analytics tool, to understand better and improve user interactions on our website. Here’s how it works:

Data Privacy and Security: Microsoft Clarity collects personal data in a way that does not directly identify you. The data is anonymized and aggregated, ensuring compliance with GDPR guidelines. For more detailed personal data about Microsoft Clarity’s data handling practices, please visit the Microsoft Clarity Privacy

User Behaviour Insights: Microsoft Clarity provides insights into how users interact with our website, such as mouse movements, clicks, and scroll behaviour. This data helps us identify usability issues and improve the content layout and navigation.

Performance Metrics: We use data from Microsoft Clarity to evaluate the performance of our website and marketing campaigns, including the effectiveness of our AdWords campaigns. This analysis informs our strategies for enhancing user engagement and optimizing our marketing efforts.

Updates to Privacy Statement

We reserve the right to modify this Privacy Statement at any time in accordance with applicable law. If we do so, we will post the revised Privacy Statement and update the “Last Updated” date at the top.

In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Statement, you can request to stop using our offered services and/or unsubscribe from our marketing practices.

Contact Personal data

If you have any questions about this privacy statement or our treatment of your personal data, or if you wish to exercise any of your rights as described above, please contact us at:

• Email: info@africancentreforschoolleadership.org
• Phone: +250 785 179 179
• Mailing Address: VVOB in Rwanda, Stadium Road, Remera, P.O. Box 3776, Kigali, Rwanda
• Link: Contact Form

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the data protection authority in your country.

Cookie Policy

Our website uses cookies to enhance your browsing experience, analyze site traffic, and enable certain website functionalities. This Cookie Policy provides you with information about the types of cookies we use and the purposes for which they are used. Please read this policy in conjunction with our Privacy Statement.

What are cookies?

Cookies are small text files that are placed on your device by websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

Types of cookies we use

1. Strictly Necessary Cookies
   • VISITOR_PRIVACY_METADATA
     • Domain: .youtube.com
     • Path: /
     • Cookie Type: Third-party
     • Expiration: 6 months
     • Description: This cookie is used to store the user’s consent and privacy choices for their interaction with the site. It records data on the visitor’s consent regarding various privacy policies and settings, ensuring that their preferences are honoured in future sessions.
2. Targeting Cookies
   • YSC
     • Domain: .youtube.com
     • Path: /
     • Cookie Type: Third-party
     • Expiration: Session
     • Description: This cookie is set by YouTube to track views of embedded videos.
   • VISITOR_INFO1_LIVE
     • Domain: .youtube.com
     • Path: /
     • Cookie Type: Third-party
     • Expiration: 6 months
     • Description: This cookie is set by YouTube to keep track of user preferences for YouTube videos embedded in sites; it can also determine whether the website visitor is using the new or old version of the YouTube interface.
3. Analytics Cookies
   • We use Microsoft Clarity to understand how users interact with our website. This tool helps us analyse user behaviour, such as mouse movements, clicks, and scroll behaviour, to improve website functionality and user experience.

Managing Cookies, You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by setting or amending your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our site may be restricted.

Changes to the Cookie Policy We may update this Cookie Policy from time to time in response to changing legal, technical, or business developments. When we update our Cookie Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

Contact Us If you have any questions about our use of cookies or this Cookie Policy, please contact us using the contact information provided in our Privacy Statement.