Introduction
The Rejoice Ntini Website (‘‘platform’’) run as an extension of Concept Pro Incorporation Limited (www.conceptproinc.com) is committed to protecting and respecting your privacy.
We aim to promote higher success rate in linking up project developers/entrepreneurs with investors to create an equitable and better world through thriving individuals and corporates. We use personal information in the course of our investments (whether through grant funding or investment into a company or project). This includes information about the senior leadership team of a prospective or current investee (individual, company or organization), key individuals involved in a particular project, and even beneficiaries of our investments.
The purpose of this notice is to give Investee People information about:
1. what personal information we collect
2. sources of personal information
3. how we use your personal information (and the legal grounds for our use)
4. who we share your personal information with
5. when and where we transfer your personal information internationally
6. how we keep your personal information safe
7. how long we keep your personal information
8. your rights in respect of your personal information
9. who we are and how to get in touch.
This notice sets out the basis on which we will process your personal information. Please read this notice carefully so that you understand your rights in relation to your personal information.
This notice may be updated from time to time. We will post any revised notice on our website and will make reasonable efforts to provide you with a revised notice if we make any substantial updates. It is important you read this notice, so that you are aware of how and why we are using your personal information.
What personal information we collect
When we use the phrase personal information in this notice, we mean any information that relates to you or could be used to identify you. At its simplest, this could be your name and your job title. Personal information will also include any information provided in background checks that we run on you, as well as any feedback about you that we receive in relation to an investment.
As part of the assessment process, the personal information we collect includes (but is not restricted to):
1. Personal details: name, contact details (address, email addresses, phone numbers), gender, and passports (if we run a background check – see below for more information about these checks).
2. Relevant expertise: records of education and experience which are relevant to the investment.
3. Relationship with applicant: role or job title at the applicant, contract (if an independent contractor), years of service with the applicant, salary information (if relevant to the investment).
4. Information from background checks: information provided by third party agencies who run background checks in relation to fraud, sanctions and politically exposed people. We run these checks depending on the circumstances, but can be run on key shareholders or funders, directors or trustees, key partners, and senior leadership staff of applicants.
5. Opinions and findings of external assessors: opinions from external experts we use to assess the potential for applicants.
6. Information provided by applicants: applicants may provide additional information in support of their case for the potential investment. This may include information about the diversity of the applicant’s staff, for example.
During the administration of our investments, the personal information that we collect and use includes (but is not restricted to):
1. The personal information identified in the paragraph above in relation to successful applicants.
2. Reports from investees: any personal information provided in reports from investees, for example an update about the staffing for a particular project tied to an investment.
3. Information about any incidents: In the rare case of an incident arising with an investment (for example, allegations of fraud or other misconduct), the investee may provide us with information that includes the personal information of those individuals involved.
4. Promotional material: any personal information (for example, photographs and testimonials from beneficiaries) provided by an investee.
Please note that the provision of certain personal information to us is necessary for us to assess whether or not facilitate an investment. If an applicant or investee does not to provide us with this personal information, we may not be able to proceed with facilitating the investment.
Sources of personal information
Personal information is collected from but not limited to the list below:
1. Investees: the majority of your personal information is provided by potential investees during our assessment of potential investments, and the administration of successful investments.
2. Publicly available sources: for example, we may review the social media accounts of members of the senior leadership of potential investees.
3. Background check services: as part of the due diligence process in our assessment of potential investees.
4. Providers of sanctions and “politically exposed persons” screening lists.
How we use your personal information
Legal bases: Most commonly, we will use your personal information in the following circumstances:
1. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, legitimate interest in processing personal information to assess the prospects of success for proposed investment projects.
2. where it is necessary to comply with a legal obligation on us (for example, fraud reporting obligations).
Purposes of processing: We process personal information for the following purposes:
1. Assessing potential investments: we have a multi-stage assessment process which involves due diligence, internal analysis of the prospective investee and external expert input.
2. Administration of our investments: this includes monitoring the performance of the investees (whether through reports provided by the investees or audits), addressing any incidents which arise in relation to the investment, payment of the investment and ending the investment.
3. Operations: this includes allocating charity resources, strategic planning, project management, business continuity, compilation of audit trails and other reporting tools, maintaining records relating to our activities, budgeting, financial management and reporting and communications and IT systems.
4. Reporting to stakeholders: This platform may occasionally be funded by a number of donors and to whom we may have reporting obligations about our use of resources, use of donor funds and the impact made by the use of donor funds.
5. Compliance: Compliance requirements with legal and other requirements, such as record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation and managing any internal complaints or claims, conducting investigations and complying with internal policies and procedures.
6. Promotional Activities: This includes promotion of investments listed on the platform through case studies on our website, press releases, workshops and other public releases of information, interviews with media organisations and other promotions. This also includes fundraising undertaken in the development and presentation of funding proposals to potential investors.
There may be more than one purpose for which we wish to use your personal information in any particular circumstance. For example, if you are a member of the senior leadership team of an applicant we may use your personal information to assess the investment, and then we may continue to use your personal information in order to then administer that investment.
Stakeholders we share your personal information
We share personal information with the relevant investee (or prospective investee) where appropriate. For example, when we provide feedback as part of the assessment process.
We share your information with selected unaffiliated recipients. The categories of recipients among others include:
1. Partners: these include co-investors, who might also support an applicant project;
2. Reviewers/Assessors: experts who help us to assess the investment application and the prospects of success;
3. Professional Advisors: accountants, auditors, lawyers, insurers, bankers, and other outside professional advisors in all of the countries who collaborate with us;
4. Service Providers: companies that provide products and services to us, including those we use to support our operations;
5. Background check agencies: for example, credit reference agencies or Know Your Customer agencies, Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF);
6. Stakeholders: our investors, that provide funding for the purposes of grants and investments.
7. Public and Governmental Authorities: entities that regulate or have jurisdiction over our operations, such as regulatory authorities, public bodies, and judicial bodies, including to meet national security or law enforcement requirements; and
8. Third Parties in Corporate Transactions: in connection with any proposed or actual reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of investments (including in connection with any bankruptcy or similar proceedings).
Storage of your personal data
We may transfer your personal data to, or store it in, a destination outside of the jurisdiction of the entity to which you provided it or the jurisdiction in which you are located. This is because the platform is a global network, with interest groups located in various jurisdictions, which use service providers based in a number of locations worldwide.
Special events
We may collect information from you when we organize special events to which you express interest, participate, or subscribe, to enable us to better service your needs during your attendance at such events or future events. We may take photographs at our events and it is possible that such photographs will include your image. We take such photographs for use in promotional materials for future events and we may upload these photographs to our website or microsites that we create for such events and/or as part of press releases or social media posts.
Photographs
We use photographs we take at events to promote future events. Such photographs may include your image where you attend an event and we may publish these photos on our website, microsite, or as part of a press release or in a social media post.
Period for which we store your personal data
We will store your personal data for only so long as is necessary to fulfil the purposes described above. We regularly assess our need to retain personal data by reference to the purposes for which it was collected. Once our relationship with you has come to an end, we will retain the personal information for a period of time that enables us to maintain business records for analysis or audit purposes, comply with record retention requirements under applicable laws, defend or bring existing legal claims, and/or deal with any complaints about our services. Where it is no longer necessary to retain the data (and where legal obligations do not mandate further retention) we will delete your personal data.
How we keep your personal information safe
The platform as an extension of Concept Pro Incorporation Limited takes reasonable technical and organisational measures to safeguard your personal information against loss, theft and unauthorised use, access or modification.
We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.
Your rights
When we use your personal information, you have the right to:
1. Ask us for confirmation of what personal information we hold about you, and to request access to a copy of that information. If we are satisfied that you have a right to see this personal information, and we are able to confirm your identity, we will, except where an exemption applies, provide you with this personal information.
2. Request that we erase the personal information we hold about you, as far as we are legally required to do so.
3. Ask that we correct any personal information that we hold about you which you believe to be inaccurate.
4. Ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.
There are other rights which are unlikely to apply to our use of your personal information. For example, the right to ask for the provision of your personal information in a machine-readable format (the data portability right) to either yourself or a third party, provided that the personal information in question has been provided to us by you, and is being processed by us: (i) in reliance on your consent; or (ii) because it is necessary for the performance of a contract to which you are a party; and in either instance, we are processing it using automated means.
In the event that we rely on consent as the legal basis to use your personal information, you have a right to withdraw your consent at any time.
Opting out
If you do not wish to receive certain communications from us you may opt out by: (i) declining the service offered, or (ii) informing us that you no longer wish to receive such communications. We will comply with such requests unless such communications from us are required by law or do not require your consent under applicable laws. Your opting out may restrict our ability to provide you with the full extent of our services.
Who we are and how to contact us
The platform is an extension of Concept Pro Incorporation Limited (www.conceptproinc.com) which is a company established under the Companies Act of the Republic of Zambia.
Questions, comments and requests regarding this notice are welcomed and should be addressed to info@rejoicentini.com.
Changes in the Privacy Statement
Any changes we make to this privacy statement in the future will be posted on this page. We reserve the right to modify this privacy statement at any time, so please check back periodically to see any updates or changes to our privacy statement. If we make material changes to this policy, we will notify you by email, or by means of a notice on our website home page.
© Copyright Rejoice Ntini 2024.
The platform operates on a zero-tolerance approach to bribery and corruption in our activities or in any programmes or projects that we support. So-called “facilitation payments” are also prohibited by our Anti-Corruption and Integrity Policy.