Privacy

Introduction

The mission of PROINVEST (PI) through Com4Dev aplication is to provide institutional strengthening to ACP Intermediary Organisations (IOs). It is desired that the impact of its intervention is sustainable.

As stipulated in the financing agreement and the logical framework of the revised protocol of agreement between the EC and the CDE, ProInvest is to create a knowledge centre.

Based on the analysis above, and after all due considerations, internal and external, it has been estimated that in order for this centre to best address the situation described above, it should allow the knowledge to be more structured and easily shared amongst all actors of the investment process.

Web 2.0 approach and technologies now allow for the creation of versatile and, interactive systems that can contribute to addressing the current situation. It has therefore been decided, to better materialise the Community of actors of Private Sector Development in ACP countries (the PICC), and to equip it with interactive tools in order to allow its members to produce and access structured, dynamic and up to date knowledge. To materialise the Community an e-platform and a Business Intelligence System will be created to allow its members to:

This community intends to be perennial and live beyond the existence of PROINVEST

• Have a higher online visibility,
• Identify partners, expertise and donors,
• Network and formulate fundable projects,
• Get, generate and exchange information and best practices,
• Deliver information to their members and to potential investors in ACP countries.

Here are the three main types of information on Com4Dev:

Information about yourself that you share. This is the information that your connections, other professionals, and companies see about you. This includes your profile and your contributions to discussions on Com4Dev Groups, Answers, or other community features Com4Dev may offer. You have control over what you share, and you can update information at any time

Communication. We help you communicate with connections and other professionals. Some of this is one-to-one, some of it is in groups, and some of it is public discussion. You decide how much or how little you wish to communicate to individuals or groups.

Private activity. We also provide tools that you can use privately on Com4Dev (for example, searching) These actions and information are private and we don't share or distribute them to others on the website.

Of course, maintaining your trust is our top concern, so we adhere to the following principles to protect your privacy:

• We do not rent, sell, or otherwise provide your personally identifiable information to third parties for marketing purposes.
• We do not share any information you have not chosen to display on your Com4Dev profile to other parties, unless compelled by law, or as necessary to enforce our User Agreement or protect the rights, property, or personal safety of Com4Dev, its Users, and the public.
• All information that you provide will be protected with industry standard protocols and technology.

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page. By continuing to use the Com4Dev service after notice of changes has been sent to you or published on the Com4Dev website, you are consenting to the changes.

What Com4Dev's Privacy Policy Covers:

1. Information collected by Com4Dev.
2. How Com4Dev uses your information.
3. Your information choices.
4. Your obligations as a User.
5. Important information regarding service eligibility.
6. Security.

1. Personal Information Collected

   The mission of PROINVEST (PI) through Com4Dev is to provide institutional strengthening to ACP Intermediary Organisations (IOs). It is desired that the impact of its intervention is sustainable. To achieve this mission, Com4Dev makes services available through our website, and developer platform, to enable professionals to develop, maintain and enhance a network of contacts, seek experts and consultants, create, share, and distribute information in collaboration with one another (“Services”). By joining Com4Dev, you voluntarily and willingly provide us certain information, including personally identifiable information, which we collect in order to provide the Services. If you have any hesitation about providing information to us and/or having your information displayed on the Com4Dev website or otherwise used in any manner permitted in this Privacy Policy and the User Agreement, you should not become a member of the Com4Dev community; and, if you are already a member, you should close your account.

   We collect your personal information in the following ways:

   1. Registration

      In order to become a User, you must provide us the following information to create an account: name, email address, country, and password. Like other passwords, you should choose one that is known only by you. You acknowledge that this information is personal to you, and by creating an account on Com4Dev, you allow others, including Com4Dev, to identify you.

   2. Profile Information

      Once you become a User, you may provide additional information in the Profile section describing your skills, professional experiences, educational background, group memberships, and networking objectives. Providing additional information about yourself beyond what is minimally required at registration is entirely up to you, but providing additional information enables you to derive more benefit from Com4Dev and facilitating your search for professional resources, information, and new opportunities. Any information you provide at registration or in the Profile section may be used by Com4Dev as described in the User Agreement and this Privacy Policy, including for the purpose of serving advertisements through the service. If you decide not to share certain information, you may not receive the full benefit of being a Com4Dev User.

   3. Contacts Information

      In order to connect with others on Com4Dev, you may use the Services to send invitations to their Com4Dev profiles.. Your connections will also have access to your email address.

      All information that you enter or upload about your contacts will be covered by the User Agreement and this Privacy Policy and will enable us to provide customized services such as suggesting people to connect with on Com4Dev.

   4. Customer Service

      We may collect information through the Com4Dev website in order to, among other things, accurately categorize and respond to customer inquiries and investigate breaches of our terms.

   5. Site Usage

      We may collect information about the fact that you use certain features and functionality of Com4Dev, interact with third party Platform Applications or participate in research initiatives like polling and surveys on Com4Dev.

   6. Cookies

      Like most websites, we use cookies and web log files to track site usage and trends, to improve the quality of our service, to customize your experience on Com4Dev. A cookie is a tiny data file that resides on your computer, mobile phone, or other device, and allows us to recognize you as a User when you return to the Com4Dev website using the same computer and web browser. You can remove or block cookies using the settings in your browser, but in some cases that may impact your ability to use Com4Dev. One type of cookie, known as a “persistent” cookie, is set once you’ve logged in to your Com4Dev account. The next time you visit the Com4Dev website, the persistent cookie will allow us to recognize you as an existing User so you will not need to log in before using the Services. In order to access or change any of your private information (like a credit card number) or to send a message to another User, however, you must log in securely again with your password even if your computer contains your persistent cookie. Another type of cookie, called a “session” cookie, is used to identify a particular visit to the Com4Dev website. Session cookies expire after a short time or when you close your web browser.

      In the course of optimizing the Services to our Users, we may allow authorized third parties to place or recognize a unique cookie on your browser. Any information provided to third parties through cookies will not be personally identifiable but may provide general segment information (e.g., your industry or geography, career field, or information about your professional or educational background) for greater customization of your user experience. Most browsers are initially set up to accept cookies, but you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Com4Dev does not store unencrypted personally identifiable information in the cookies.

   7. Log files, IP addresses and information about your computer and mobile device

      Due to the communications standards on the internet, when you visit the Com4Dev website we automatically receive the URL of the site from which you came and the site to which you are going when you leave Com4Dev. Com4Dev also receives the internet protocol (“IP”) address of your computer (or the proxy server you use to access the World Wide Web), your computer operating system and type of web browser you are using, email patterns, as well as the name of your ISP or your mobile carrier. We use this information to analyze overall trends to help improve the service. The linkage between your IP address and your personally identifiable information is not shared with third parties without your permission, except as described in Section 2.J (“Compliance with Legal Process”), below.

   8. Linked Accounts

      If you link your Com4Dev account to another account or service, or use other, third-party sites or services in conjunction with your Com4Dev account, we may collect information related to your use of third party sites and services accessed through Com4Dev or when you access Com4Dev through a third-party site or service.

   9. Rights to Access, Correct and Eliminate Information About You

      You have a right to access, modify, correct and eliminate the data you supplied to Com4Dev. If you update any of your information, we may keep a copy of the information that you originally provided to us in our archives for uses documented in this policy. You may request deletion of your information at any time by contacting Com4Dev customer service. We will respond to your request within 30 days.

2. Uses of personal information
   1. Consent to Com4Dev Processing Information About You

      The information you provide to Com4Dev may reveal, or allow others to identify, your nationality, ethnic origin, religion, gender, age, geography, or other aspects of your private life. By providing information to us for the purposes of creating your User account or adding any additional details to your Com4Dev profile, you are expressly and voluntarily accepting the terms and conditions of this Privacy Policy and Com4Dev’s User Agreement that allow Com4Dev to process information about you. Supplying information to Com4Dev, including any information deemed “sensitive” by applicable law, is entirely voluntary on your part. You have the right to withdraw your consent to Com4Dev’s collection and processing of your information at any time, in accordance with the terms of this Privacy Policy and the User Agreement, by changing your Settings, or by closing your account, but please note that your withdrawal of consent will not be retroactive.

   2. Com4Dev Communications

      As described in the User Agreement, we will communicate with you through email and notices posted on the Com4Dev website, messages to your Com4Dev inbox, or through other means available through the service. We may send you a series of emails that help inform new Users about the features of the Services, and we will also send you service messages relating to the functioning of the Services. We may also send you messages with promotional information directly or on behalf of our partners, unless you have opted out of receiving promotional information.

      You can change your e-mail and contact preferences at any time by logging into your account and changing your settings related to your email notification choices. If you wish, you can also opt-out of receiving promotional emails by sending a request to Com4Dev customer service through our customer service site.

      Please be aware that you cannot opt-out of receiving service messages from Com4Dev. Also, if we send communications to you via the carrier service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any service fees associated with your receipt of messages on your mobile device (including text messaging charges).

   3. User Communications

      Many communications you initiate through Com4Dev will list your primary email address and name in the header of the message. Your contact information will only be shared with another User if both of you have indicated that you would like to establish contact with each other.

   4. Customized Content

      We use information provided to us (or to third parties with whom it offers combined services) to customize your experience on our website. For example, when you login to your account, we will display the names of new Users who have recently joined your network or recent status updates from your connections.

   5. Sharing Information with Third Parties

      Com4Dev takes the privacy of our Users very seriously, and we do not sell, rent, or otherwise provide your personally identifiable information to third parties for marketing purposes. Further, we will only share your personally identifiable information with third parties to carry out your instructions or to provide the Services or information unless compelled by law, or as necessary to enforce our User Agreement or protect the rights, property, or personal safety of Com4Dev, its Users, and the public. For example, we use a credit card processing company to bill Users for subscription fees. These third parties do not retain, share, or store any personally identifiable information except to provide these services, and they are bound by confidentiality agreements limiting the use of your information.

      We also offer a "public profile" feature that allows Users to publish portions of their Com4Dev profile to the public internet. This public profile is what search engines will display when someone searches for your name. Users may opt-out of this feature by editing their account settings; however, Com4Dev does not warrant how often third-party search engines will update their caches, which may contain old public profile information.

      We may provide aggregated anonymous data about the usage of the Services to third parties for purposes that we deem, in our sole discretion, to be appropriate, including to prospective advertisers on Com4Dev.

   6. Working with Third Parties to Offer Services.

      We collaborate with third parties to offer services and functionality using Com4Dev developer tools such as our application programming interfaces (“APIs”). These third parties are either partners (“Com4Dev Partners”) with whom we have negotiated an agreement to provide services (“Combined Services”), or developers (“Platform Developers”) who have agreed to our API terms in our developer signup flow to build applications (“Platform Applications”). Both the negotiated agreements and our API terms and conditions contain restrictions on access, storage and use of your information.

      If you choose to use Combined Services or a Platform Application, you may be asked to confirm acceptance of the privacy policy and/or user agreement of the Com4Dev Partner or Platform Developer, which have not necessarily been reviewed or approved by Com4Dev. It is your choice whether or not to make use of Combined Services or Platform Applications and whether to proceed under any third party terms.

      Also, despite our agreements and technical steps taken to restrict access to and avoid possible misuse of information we may not screen or audit all Combined Services or Platform Applications. We also cannot guarantee that any Com4Dev Partner or Platform Developer will abide by our agreement. You agree that your use of Combined Services or Platform Applications is on an “as is” basis and without any warranty.

      If you, your connections, members of your network, or other Users of Com4Dev use or interact with any Combined Service or Platform Application, the Com4Dev Partner or Platform Developer may access and share certain information about you with others, such as your profile information and information visible only to your connections. This includes information about your connections by virtue of you being connected to others. However, because a Combined Service or Platform Application can make calls on behalf of the User interacting with it to access non-public information, the level of detail accessible by the Combined Service or Platform Application through Com4Dev is constrained by the same settings that govern visibility of your data to that User on Com4Dev. For example, assuming you have not already given a Platform Developer’s application permission to access your information, your non-public profile information should not be visible to someone using the same Platform Application if it is not otherwise accessible to that person on Com4Dev.

      Please also note that because of our relationship with certain Com4Dev Partners and Platform Developers, permission to access certain account information may be automatically granted to provide the combined services or functionality.

      To revoke permission granted to a Combined Service or Platform Application at any time, please visit the settings page. If the relevant Platform Developer or Application, or Com4Dev Partner is not listed under Authorized Applications, go directly to the Application Details page for the Platform Application you wish to uninstall. Note, however, that even if you revoke the permission granted a third party, your connections, other members of your network, or other Users of Com4Dev may still be using the Platform Application, so the Platform Application or Combined Service may still have access to certain information about you, just as those Users do. That is why it is important to only connect to Users you know and trust. To report any suspected misuse of information, contact Com4Dev’s customer service. Com4Dev is not responsible for your use of or inability to use any Combined Service or Platform Application, including the content, accuracy, or reliability of applications and the privacy practices or other policies of Com4Dev Partners or Platform Developers.

   7. Polls and Surveys

      Polls and Surveys may be conducted by Com4Dev, Com4Dev Users or third parties. As a User, you may be invited to participate in polls and surveys from the Com4Dev website. Your selection may be random, or it may be based on your non-personally identifiable information, such as job title, geography, company size and/or industry. Whether or not you decide to participate in a poll or survey is completely up to you.

      After you complete a poll, you will be given access to the aggregate responses of the poll on a results page.

      We may use third parties to deliver incentives to you to participate in surveys or polls. If the delivery of incentives requires your contact information, you may be asked to provide personally identifiable information to the third party fulfilling the incentive offer, which will only be used for the purpose of delivering incentives and/or verifying your contact information. It is up to you whether you provide this information, or whether you desire to take advantage of an incentive.

      We will not disclose any personally identifiable information to any third parties in connection with the conduct of any polls or surveys. Your consent to use any personally identifiable information for the purposes set forth in the poll or survey will be explicitly requested by the party conducting it. You may opt-out of participating in Surveys by changing your settings to stop receiving these inquiries and requests.

   8. Search

      We offer search services to help find information and learn more about other Users. Com4Dev search also allows Users to find companies, and contributions to the community aspects of the Com4Dev Services, such as Groups and Answers that will help Users more effectively use Com4Dev. We use information from User profiles and contributions to Groups and Answers to inform and refine our search service.

   9. Answers, Groups, and other Services

      If you post on the Answers section of Com4Dev, participate in Com4Dev Groups, or import a blog, you should be aware that any personally identifiable information you choose to provide there can be read, collected, or used by other Users of these forums, as well as Platform Developers and other third parties, and could be used to send you unsolicited messages. Com4Dev is not responsible for the information you choose to submit in these forums.

   10. Compliance with Legal Process

       It is possible that we may need to disclose personal information, profile information and/or information about your activities as a Com4Dev User when required by any legal process, or if Com4Dev has a good faith belief that disclosure is necessary to (a) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (b) to enforce the User Agreement, to investigate and defend ourselves against any third party claims or allegations, or to protect the security or integrity of our site; and/or (c) to exercise or protect the rights, property or personal safety of Com4Dev, our Users, employees, or others.

   11. Disclosures to others

       We may also disclose your personal information and other information you provide to another third party as part of a reorganization or a sale of the assets of Com4Dev Corporation, a subsidiary or division. Any third party to which Com4Dev transfers or sells Com4Dev’s assets will have the right to continue to use the personal and other information that you provide to us.

3. Your Information Choices
   1. Accessing and Changing Your Account Information

      You can review the personal information you provided to us and make any desired changes to the information you publish, or to the settings for your Com4Dev account including your email and contact preferences, at any time by logging in to your account on the Com4Dev website. Please be aware that even after your request for a change is processed, Com4Dev may, for a time, retain residual information about you in its backup and/or archival copies of its database.

   2. Default Settings

      Because the mission of Com4Dev is to connect the world’s professionals to enable them to become more productive and successful, we have established what we believe to be reasonable default settings that we have found most professionals desire. Because Users may use and interact with Com4Dev in a variety of ways, and because those uses may change over time, we designed our settings to provide our users granular control over the information they share. We encourage our Users to review their account settings and adjust them in accordance with their preferences.

      Com4Dev accounts are also defaulted to allow Users to be contacted to participate in polls, surveys and partner advertising. Click here to change these settings.

   3. Closing Your Account

      You can close your account through the Com4Dev customer service site. If you close your Com4Dev account, we will remove your name and other personally identifiable information from our publicly viewable database. If you close your account, we have no obligation to retain your information, and may delete any or all of your account information without liability. However, we may retain certain data contributed by you if Com4Dev believes it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law. Com4Dev may also retain and use your information if necessary to provide the Services to other Users. For example, just as an email you may send to another person through an email service provider resides in that person’s inbox even after you delete it from your sent files or close your account, emails you send on Com4Dev to other Users, as well as your contributions to Com4Dev Answers or Groups, may remain visible to others after you have closed your account. Similarly, other information you have shared with others, or that other Users have copied, may also remain visible. Com4Dev disclaims any liability in relation to the deletion or retention (subject to the terms herein) of information or any obligation not to delete the information. Com4Dev does not control when search engines update their cache, which may contain certain public profile information that has since been removed from Com4Dev’s publicly viewable database.

   4. Memorializing Accounts

      If we learn that a User is deceased, we may memorialize the User’s account. In these cases we may restrict profile access, remove messaging functionality, and close an account if we receive a formal request from the User’s next of kin or other proper legal request to do so.

4. Your Obligations As a User, you have certain obligations to other Users. Some of these obligations are imposed by applicable law and regulations, and others have become commonplace in user-friendly communities of like-minded members such as Com4Dev:
   • You must, at all times, abide by the terms and conditions of the then-current Privacy Policy and User Agreement. This includes respecting all intellectual property rights that may belong to third parties (such as trademarks or photographs).
   • You must not download or otherwise disseminate any information that may be deemed to be injurious, violent, offensive, racist or xenophobic, or which may otherwise violate the purpose and spirit of Com4Dev and its community of Users.
   • You must not provide to Com4Dev and/or other Users information that you believe might be injurious or detrimental to your person or to your professional or social status.
   • You must keep your username and password confidential and not share it with others.
   Any violation of these guidelines may lead to the restriction, suspension or termination of your account at the sole discretion of Com4Dev.
5. Important Information
   • Children and Minors

     Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.

   • Changes to this Privacy Policy

     We may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way we treat your personally identifiable information, or in the Privacy Policy document itself, we will display a notice on the Com4Dev website or send you an email, as provided for above. Unless stated otherwise, our current Privacy Policy applies to all information that Com4Dev has about you and your account.

     Using the Com4Dev Services after a notice of changes has been sent to you or published on our site shall constitute consent to the changed terms or practices.

6. Security

   In order to help secure your personal information, access to your data on Com4Dev is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and the Com4Dev website. To protect any data you store on our servers, Com4Dev also regularly audits its system for possible vulnerabilities and attacks, and we use a tier-one secured-access data center. However, since the internet is not a 100% secure environment, we cannot ensure or warrant the security of any information you transmit to Com4Dev. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails, instant messaging, and similar means of communication with other Users of Com4Dev are not encrypted, and we strongly advise you not to communicate any confidential information through these means.