Privacy Policy

UPDATE MESSAGE: This Privacy Policy was last updated on May 1st, 2021

We have updated this policy to comply with the EU General Data Protection Regulations

We at Gebeya, Inc. (“Gebeya”, “we”, “us”, “Our”) respect your privacy which is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and, subject to your consent and/or requirements under applicable law, disclose personal information. This Privacy Policy covers our data collection practices and describes your rights to access, correct, or restrict our use of your personal data. We are committed to conducting our business in accordance with these principles in order to ensure that the privacy of personal information is protected and maintained. Unless we state otherwise, this Privacy Policy applies when you visit or use the Gebeya marketplace and training websites, mobile applications, APIs or related services (the “Services”). By using the Services, you agree to the terms of this Privacy Policy. If you do not agree with this Privacy Policy or any other agreement that governs your use of the Service, DO NOT USE OUR WEBSITE.

1. Our Responsibilities

It is the policy of the Gebeya to maintain an environment that promotes ethical and responsible conduct in
all online network activities by instructors, employees and students. Gebeya INC recognizes its legal and
ethical obligation to provide a safe study environment in both its online and taught courses and to protect
your personal information and Data in that regard. To this end, Gebeya reserves the right and recognizes
its obligation to:

A. log network use and to monitor file server space utilization by Users, and assume no
responsibility or liability for files deleted due to violation of file server space allotments;

B. remove a user account on the network;

C. monitor the use of online activities. This may include real-time monitoring of network activity

and/or maintaining a log of Internet activity for later review;

D. provide internal and external controls as appropriate and feasible including the right to

determine who will have access to Gebeya owned equipment and, specifically, to exclude
those who do not abide by this Privacy Policy or our Terms and conditions.

E. restrict online destinations through software or other means.

F. provide guidelines and make reasonable efforts

2. Data Collection

We collect certain data from you directly, like information you enter yourself, data about your
participation in our marketplace and/ trainings, and data from third party platforms you connect with
Gebeya. We also use third party analytics to collect some data, like information about your device.

Data You Provide
We may collect different data from or about you depending on how you use the Services. When you
create an account and use the Services, including through a third party platform, we collect personal
information which includes any information about you from which you can be identified. It does not
include data where the identity has been removed (e.g., anonymized or aggregated data). The categories
of Personal Information about you that we may collect, use, store or transfer (subject to your consent and/
requirements under applicable law) includes the following, some of which constitute Personal Information
only when combined with personal identifiers:

A. Identity Data: Information we use to identify you, authenticate you as an authorized user of
the Services, communicate with you, and record any transactions you make. This includes first name, maiden name, last name, login/user ID and password details, marital status, title, date of birth, gender, and the user’s profile picture.

B. Contact Data: Includes billing address, postal address, email address, telephone number and

mobile phone number.

C. Technical Data: Includes internet protocol (IP) address, your login data, browser type and

version, time zone setting and location, browser plug-in types and versions, operating system
and platform and other technology on the devices you use to access our Services.

D. Usage Data: Includes information about how you use our Services.

E. Transaction Data: Includes details of the Services for which you have previously registered

and/or in which you have been enrolled.

F. Assessment Data: Information on your aptitude in certain technology-based subject areas and

your performance on General Assembly’s capabilities and learning needs assessments.

G. Profile Data: Includes your interests, preferences, website browsing history, demographic

information such as age, gender, education level, feedback and survey responses.

H. Marketing, Communications and Support Data: Includes your preferences with respect to receiving marketing from us and/or our third party partners and your communication preferences. If you contact us for support or to report a problem or concern (regardless of whether you have created an account), we collect and store your contact information, messages, and other data about you like your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means (which we cover below). We use this data to respond to you and research your question or concern, in accordance with this Privacy Policy.

3. How We Get Data About You

We use tools like cookies, web beacons, analytical services to analyze trends and administer the website,
track users’ movement around the websites and to gather data referenced above.

4. Purpose Of Information

Before or at the time of collecting personal information, we will identify the purposes for which
information is being collected. These include but not limited to:

 

A. identify the user/user account, give the user access to complete the registration process on the
portal and access our Services

B. enable and deliver the Services

C. to manage our relationship with you

D. promptly inform the user of any updates or changes to our policies and services,

E. furnish the user with feedback on their participation and performance in the use of our Services

F. assess and mark the users’ coursework and examinations

G. grant the user access to the portal, to enable the user to complete and submit reviews and/or

submit completed questionnaires/surveys.

H. make our services and the portal’s content available to the user and also continue to modify, maintain and enhance the user’s experience

I. intermittently upgrade the user experience and functionality of our Services while providing related customer services.

J. manage and protect the Services (including troubleshooting, data analysis, testing, system review).

K. endeavor to respond to the users’ queries/enquiries and forward information requested by the user via electronic mail, sms or other marketing channels.

 

We will collect and use of personal information solely with the objective of fulfilling those purposes specified above by us and for other

5. Information Sharing And Disclosure

Depending on usage, we may share certain data about you with certain Gebeya talent, trainers, students,
companies performing services for us or hiring talent from us, our business partners, analytics and data
enrichment providers, your social media providers, companies helping us run promotions and surveys,
and advertising companies who help us promote our Services. We may also share your data as needed for
security, legal compliance, or as part of a corporate restructuring. Lastly, we can share data in other ways
if it is aggregated or de-identified or if we get your consent. We may share your data with third parties
under the following circumstances or as otherwise described in this Privacy Policy:

A. With Gebeya Talent: We share data about you or your company with Gebeya Talent retained
for your engagement or retained to deliver projects for which you have sought our technical
intervention.

B. With Hiring Companies: We share data that we have about you with hiring companies
seeking to engage Gebeya Talent with your specific competence or skill set.

C. With Your Instructors: We share data that we have about you with instructors or teaching
assistants for courses you enroll in or request information about, so they can improve their
courses for you and other students. This data may include things like your city, country,
browser language, operating system, device settings, If we collect additional data about you
(like age or gender), we may share that too

D. With Service Providers, Contractors, and Agents: We share your data with third party
companies who perform services on our behalf, like data analysis, marketing and advertising
services (including retargeted advertising), email and hosting services. These service providers
may access your personal data and are required to use it solely as we direct, to provide our
requested service.

E. With Business Partners: We have agreements with other websites and platforms to distribute
our Services and drive traffic to Gebeya.

F. With Analytics and Data Enrichment Services: As part of our use of third party analytics,
we share certain contact information and data (as detailed in Section 1), or de-identified data
as needed. De-identified data means data where we have removed things like your name and
email address and replaced it with a token ID. This allows these providers to provide analytics
services or match your data with publicly-available database information (including contact
and social information from other sources). We do this to communicate with you in a more
effective and customized manner.

G. To Power Social Media Features: The social media features in the Services (like the
Facebook Like button) may allow the third party social media provider to collect things like
your IP address and which page of the Services you’re visiting, and to set a cookie to enable
the feature. Your interactions with these features are governed by the third party company’s
privacy policy. In this regard and to the full extent permitted by law, Gebeya shall have no
obligation or liability of any kind, including without limitation transfers, omissions, or
disclosure, with respect to the third party’s access to or use of your data.

H. To Administer Promotions and Surveys: we may share your data as necessary to administer,
market, or sponsor promotions and surveys you choose to participate in, as required by
applicable law (like to provide a winners list or make required filings), or in accordance with
the rules of the promotion or survey.

I. For Advertising: If we decide to offer advertising in the future, we may use and share certain
Data with third party advertisers and networks to show general demographic and preference
information among our users.

J. For Security and Legal ComplianceWe may disclose your data to third parties if we (in our
sole discretion) in good faith believe that the disclosure.

a. Permitted or required by law;

b. Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;

c. Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;

d. Reasonably necessary to enforce our Terms of Service, Privacy Policy, and other legal
agreements

e. Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or
rule or regulation), or security or technical issues; or

f. Reasonably necessary in our discretion to protect against imminent harm to the rights,
property, or safety of Gebeya, our users, employees, members of the public, or our
Services.

g. We may also disclose data about you to our auditors and legal advisors in order to assess
our disclosure obligations and rights under this Privacy Policy.

K. During a Change in Control: If Gebeya undergoes a business transaction like a merger,
acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or
some of its assets, we may share, disclose, or transfer all of your data to the successor
organization during such transition or in contemplation of a transition (including during due
diligence).

L. After Aggregation/De-identification: We can disclose or use aggregate or de-identified data
for any purpose.
M. With Your Permission: With your consent, we may share data to third parties outside the
scope of this Privacy Policy.

6. Data Retention

Gebeya retains personal data, as necessary, for the duration of the relevant business relationship. We may also retain personal data for longer than the duration of the business relationship should we need to retain it to protect ourselves against legal claims, use it for analysis or historical record-keeping, or comply with our information management policies and schedules. If you request that we delete your personal data, Gebeya will make reasonable attempts to delete all instances of the information in their entirety. For requests for access, corrections, or deletion, please refer to the “Your Choices and Rights” section of this Privacy Policy

7. Security Of Information

Gebeya has implemented generally accepted standards of technology and operational security to protect personal data from loss or theft, unauthorized access, disclosure, copying, use or modification, alteration, or destruction. Only authorized Gebeya personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. All access to our Services is encrypted using industry-standard transport layer security technology (“TLS”). When you enter sensitive information, we encrypt the transmission of that information using secure socket layer technology (“SSL”). We also use HTTP strict transport security to add an additional layer of protection. Despite these precautions however, Gebeya cannot guarantee that unauthorized persons will not obtain access to your personal data.

8. Your Choices And Rights

A. Where granted by local law, you may have the right to request access to the personal data that we have collected about you for the purposes of reviewing, modifying, or requesting deletion of the data. You may also have the right to request a copy of the personal data that we have
collected about you and to have any inaccuracies in that data corrected. In certain circumstances, you may also request that we cease processing your personal data.

B. If you would like to make a request to access, review, or correct the personal data we have

collected about you, or to discuss how we process your personal data, please contact us at sales@gebeya.com. To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your personal data. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Different laws may prevent us from providing access to your personal data or otherwise fully complying with your request depending upon the circumstances and the request, such as for example, where producing your information may reveal the identity of someone else. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law, and/or deny your requests where they may be manifestly unfounded, and/or excessive, or otherwise objectionable or unwarranted under applicable law

a. In addition, and where granted by local law, you have the legal right to lodge a complaint
with a competent data protection authority.

b. You may also unsubscribe from mailing lists or any registrations with any of the Services.

To do so, please contact us at the address provided at the bottom of this Privacy Policy.

c. Right to be forgotten: If you are located in the European Economic Area (“EEA”), in

addition to the rights described above, you may contact us at the contact information
provided below to

(1) request a restriction on the processing of your personal information,

(2) object to the processing of your personal information,

(3) exercise your rights to be forgotten or

(4) exercise other rights with respect to your personal information.

9. International Transfers Of Your Personal Data

Information collected from you may be stored and processed in Ethiopia, Kenya, Djibouti, European Economic Area, the United States, or any other country in which we or agents or contractors maintain facilities, and by accessing our sites and using our services, you consent to any such transfer of information outside of your country. Such countries may have laws which are different, and potentially not as protective, as the laws of your own country. If you reside in the EEA or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your personal data to other jurisdictions in which we operate. By providing your personal data, you consent to any transfer and processing in accordance with this Policy.

10. Changes To Our Privacy Policy

By using our Services, you consent to the collection, use, and storage of your personal data by us in the manner described in this Privacy Policy and elsewhere on the Sites. We reserve the right to make changes to this Privacy Policy from time to time. We will alert you to any such changes by updating this Privacy Policy. If we make material changes to this Privacy Policy that increase our rights to use personal data that we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominently posting information about the changes on our site.

11. Governing Law

Any claim relating to the Services shall be governed by the laws of the State of Delaware without regard to its conflict of law provisions. In any action between or among any of the parties, whether arising out of these or otherwise, each of the parties irrevocably and unconditionally (i) consents and submits to the exclusive jurisdiction and venue of the state and federal courts located in Delaware; and (ii) waives any and all right to trial by jury in any legal proceeding arising out of or related to this agreement or any transactions contemplated hereby.

12. Contact Information

If you have any questions about our Privacy Policy, please contact us at: sales@gebeya.com