Asempa is fully committed to protecting and safeguarding the privacy of its Africa Confidential users. This notice informs visitors to the site what to expect when Asempa or its affiliated support providers collect information about them.
Asempa and its affiliate(s) hold very little sensitive or personally identifiable information about its visitors and users of the site.
What is ‘personally identifiable’ information?
Personally identifiable relates to the identification of a living person. This form of data includes but is not limited to: names, postal address, email address, date of birth and ethnicity.
Data Collection Practices
This notice outlines the following measures in which data is collected and used:
- Types of data we collect
- How data is utilised
- Why data is captured
- Retention period of data
Asempa’s Collection of Data
When collecting identifiable information, Asempa:
- Will not ask for personal information, unless truly needed for order processing and deliveries of communication and product services
- Explicitly does not share personal information unless needed to comply with the Law
- Will not store personally identifiable financial data such as credit card information on its operating systems. Legal exceptions to this apply. (see section ‘Transactional information’.
Information and Types of Data Asempa collects
Use of our services may require different forms of identifiable and non-identifiable data to be recorded, collected, utilised and stored by Asempa. Particular data is required in order to allow functionality of site services and communications by Asempa to its consenting users in various ways.
Registration forms, order forms and account preference forms found within the site will contain some fields marked ‘*’. These fields are required in order to fulfil a users request to receive services from Africa Confidential
Optional fields are not requirements. Entered at the free will of a user, the user infers consent to particular storage and usage of such provided data by Asempa.
Most information collected by Asempa and its website providers refer to users and subscribers of the Africa Confidential site. Visitors can use the site freely and will have no personally identifiable information recorded about them.
Types of identifiable data Asempa may collect
- Job title
- Sector Services
- Company name
- Company or Individuals’* physical address
- Company or Individuals’* telephone/mobile/fax number
- Company or Individuals’* e-mail address
- Company or Individuals’* country of residence
- Company or Individuals’* credit card information (secured in merchants profile)
- Other technical information (see further below)
* Individuals’ details in this section refer to non-corporate personal contact information.
Additional user data collected
- IP addresses/ranges
- Purchase history
- Subscription details
Asempa may record and analyse general movements of users within www.africa-confidential.com in the form of non-identifiable cookies. Analysis of user movements helps Asempa to identify areas of improvement to its online content.
Data and Cookies
How Asempa captures user data
Asempa and its business support providers may collect data in the following ways:
- Information provided via email, telephone, post, business card, agent
- Registration and payment processing forms in the website
- Consent box selections within users contact and marketing preferences
- Analytical cookies (non-identifiable) to track website traffic
- IP address capture recognition when logging into the site
How we may use captured data
Asempa may use data collected in order to -
- Provide all Africa Confidential users with a personalised service
- Provide and notify users about changes to the website and/or its services
- Fulfil processing of orders, registrations, trials and logging of enquiries
- Provide statistical login history reports to License-holding clients
- Monitor user compliance against the sites Terms and Conditions
- Monitor user view patterns to analyse content readership and impact
- IP tracking technology to identify account breaches and troubleshooting
- Alter and update user records for customer service and gratis purposes
- Maintaining continued service and infrastructural setup of the website
- Improve engagement with visitors, users and subscribers of this site
- Contact users on behalf of specially chosen third party Media Partners
- To provide necessary infrastructural* setup for subscriber/user access
IP Capture and its purposes
The collection and recognition of IP data is important and helps us to -
- Provide necessary infrastructural setup for Multi-User Licenses
- Investigate security breaches or misconduct of Asempa’s Terms
- Investigate potential fraudulent activity to or within the website
- Monitor subscriber login access history (e.g. date/time, usage, IP)
Disclosure of User Data
Asempa may disclose information in special cases it has reason to believe disclosing such information;
- Is reasonably necessary in order to comply with the Law
- Will enforce or apply Asempa’s Terms and Conditions of business
- Will protect the right of Africa Confidential users and subscribers
Asempa and its business support providers reserve their rights to fully corporate with requests to them by the Law.
Data Received by Asempa from Agencies
Users may wish to subscribe to Africa Confidential services via a subscription Agency. By pursuing a subscription order with an agent, users consent to the transfer of any relevant data such as those outlined previous to Asempa. This data is required in order to fulfil subscription requests and to generate access.
Persons given permission to access User Data
Subscriptions and Marketing Department staff at Asempa Limited.
Bluemania Limited - a website engineering and support provider - structurally and securely providing the smooth running of www.africa-confidential.com and is a nominated data processor.
Craft ICT Limited - a database management company - provides a securely stored subscription management system for Asempa providing the ability to catalogue subscription orders and user contact information.
Asempa provides fulfilment instructions to its print provider and mailing house to carry out deliveries for physical newsletters. Our suppliers ensure the safe-guarding of subscriber information and destroy all data after job completion.
Your User Rights & How to Exercise them
Under the new General Data Protection Regulations (GDPR; 2018) user and customer audiences are granted more informed and accessible control in how businesses contact and provide services to them.
The regulations aim to provide users with options to opt in, change and withdraw consent from business contact and services, the ability to access what data is held on file about them and information on how this data is being utilised.
You have rights as an individual to exercise in relation to information Asempa and its providers hold about you. You can read more about these rights here.
As a Data Controller, Asempa is responsible for fulfilling these rights to its users.
Personal Data - Subject Access Request
Users have rights to access data subjects held about them by the Data Controller (Asempa). Individuals can find out what personal information Asempa holds on them by making a ‘subject access request’ free of charge.
Asempa will deliver the request within 30 working days. Assistance provided by Asempa’s business support providers (Data Processors) may be necessary to carry out such requests.
Individuals making requests will receive the following information sets where appropriate:
- List/description of the users data
- List/description of the users account contact and marketing preferences
- Explanations to why we hold this data and what this is being used for
- Who the data has/may be disclosed to and why they may have access
- Detailing of any payment history relating to their online accounts
- Provide a copy of information in an easy-to-read format (data portability)
Amendment of Data Contact Preferences
Organisations must now seek permission of its users to keep in touch to offer users full control over their website experience and accounts preferences.
Users must take control over the following functions surrounding their data, such as -
- Deciding how they would like to be contacted (e,g. by e-mail, phone, SMS)
- Choose which marketing communications, if any, they wish to receive
- Select which forms of business product services they with to receive
- Indicate any other requirements they wish to/not to receive by the site
- Consenting to and withdrawing from browser cookies
- Passwords and the acts of updating and keeping them safe
Asempa’s www.africa-confidential.com site has made provisions for users to be able to alter their contact and marketing preferences from within an account. Asempa will communicate with users in the form of a return mail function that they have successfully updated their communication preferences. These preferences are saved against a users account for dissemination purposes.
You may contact Asempa to ask for more information on what these services are and how you can alter them to suit your requirements.
Withdrawal of Consent
Individual users of the site have the ability to withdraw their consent from Asempa and Africa Confidential communications and services should they wish.
Withdrawal of consent to marketing mails or email alerts provided by Africa Confidential does not automatically qualify user account erasure - so individuals may still be contacted by Asempa.
Right to Erasure
Individuals have the opportunity to exercise their ‘right to be forgotten’ by a business. This right provides individuals the opportunity to have all personally identifiable data relating to them deleted from a business’ systems.
To understand the circumstances in which a user can exercise their ‘right to be forgotten’ see more at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/right-to-erasure/
Asempa acknowledges users rights to be permanently removed from its systems upon legitimate request.
Erasure from our service operations will take place up to, but no more than 30 working days of exercising the erasure request.
Exceptions to this request include the retention of payment purchase history. All financial transaction records must be held for a period of 6 years as required by HMRC Regulations.
Filing of Accounts
Please see the below criteria(s) for how long we retain data for and why.
- Asempa must keep transactional history for a period of up to 6 consecutive years as required by HMRC Regulations
- Asempa staff categorically do not keep records of sensitive information
- Credit card payment details handled by Asempa’s Subscriptions staff will be safely destroyed
Your data is filed on various systems; paper, website and subscriptions database.
All records on our subscriptions database is kept for a maximum of 5 years.
Unless an individual expresses their right to be removed from our databases, details will remain present until the record hits is retention expiry.
If a user expressly insists on their right to erasure from the business, any files pertaining to a user on the subscriptions database will be erased of all personally identifiable information and subsequently assigned an ‘erasure’ number.
The only information Asempa will keep on record is the erasure record number, subscription type, year, price and duration of purchase.
Paper records will also be kept for a period of 5 years and will be subject to the above measures.
Our accounting team reserves the explicit rights to hold transaction information for a period of up to 6 years, as lawfully requested by HMRC.
Subscriber records will be held by our websites system up until the point of expiry of a subscription. Once access is removed from the site, individuals will need to sign up Africa Confidential’s free account service should they wish to continue receiving alerts.
Free account holders who have purchase history have the ability to close their accounts and remove all information pertaining to them from the site.
If a user wishes to exercise their right to erasure, they will be subject to the filing measures aforementioned in sections ‘Paper Records’ and ‘Subscriptions Database’.
Online purchases will also be subject to retention under HMRC Regulations for a period of up to 6 years.
Asempa intends to maintain full transparency over its data is used and collected and takes any form of complaint against our providers or us very seriously.
We encourage users to bring to our attention any questions they may have with regards to the way their data may be being handled. Asempa will look to provide solutions and other means as a way of best practise with users interests at heart.
Individuals also have the right to lodge complaints against Asempa to the Information Commissioner’s Office (ICO; UK data protection regulator). Please visit the ICO website for further information on how to address data complaints.
Third Party Information
Asempa does not knowingly provide third party organisations with statistical information via the monitoring of clicks within third party emails or other links.
Asempa does not partner with or have special relationships with any ad server companies. No personally identifiable information will ever be passed to such.
3rd Party Marketing platforms
From time-to-time Asempa may send out email marketing campaigns via another e-communication platform, such as Dotmailer or Mailchimp. Asempa will use data that meets compliance required under the rule of Law.
Security & Data Processing
Asempa and its providers have appropriate security measures in place to safely, securely and compliantly collect any user data recorded within the site or by its Subscriptions Department.
Asempa uses WorldPay as its secure online merchant to process payment orders. Users can visit https://www.worldpay.com/uk for more information.
Asempa’s business support providers have facilities in place to inform staff of any potential breach or virus, which poses considerable threat to users data in a prompt and compliant manner.
Asempa will take necessary steps to inform users of significant and evidential breaches to their data within 72 hours of being notified of the breach.
Data Controller and Data Processors
The Data Controller for www.africa-confidential.com is Asempa Limited (‘Asempa’), a limited company registered in England and Wales, company number 05872814, whose registered office is at Vine House, Fair Green, Reach, Cambridge CB25 0JD, UK.
Data Processors providing business support operations for Asempa can be reached by requesting full disclosure from Asempa to provide where necessary.
Asempa and its support providers are bound to statements and agreements to ensure all relevant user data is captured and handled in a compliant manner
For questions surrounding the collection and handling of data, please contact:
By email: firstname.lastname@example.org
By phone: +44 (0)1638 743 633
Data Protection Asempa Limited Vine House, Fair Green, Reach, Cambridgeshire, CB25 0JD, UK
Changes to this policy
Changes to this policy will be to reflect any changes in our privacy practices as a result of one or more of the following; changes to legislation, best practice, website development and administrative practises.
This current policy is effective from 24/05/2018
Users are reminded to review Asempa’s Terms & Conditions and Cookies Policy.