This privacy policy describes how PIN will collect and use your personal information when you interact with us online or when we otherwise collect and use your personal information. Paradigm Initiative has regional offices located in Cameroon, Kenya, Nigeria, Zimbabwe and Zambia. You can learn more about where we are located on our Contact Us page. The personal information we collect through the website or otherwise may be used by any of our family of offices in line with the purposes set out in this privacy policy. When we refer to PIN in this privacy policy, we include all PIN offices.
In some instances, other data protection laws may apply. Please see section 10 for information about the transfer of your personal information.

We may obtain your personal information from a number of sources including:

• • When you give it to us directly. For example, if you provide us with your email address to sign up to receive our news updates.
  • When we obtain it indirectly. Your personal information may be shared with us by third parties such as recruitment agencies when we are recruiting staff. We will notify you when we receive personal information about you from them, and tell you how and why we intend to use that personal information.
  • When it is publicly available. Your personal information may be available to us from external publicly available sources. This includes information available on government websites or non-PIN offices or institutional websites.
  • When you visit our website. Our website uses cookies and other tracking technologies to improve your experience of our website—this can involve collecting personal information.

We may collect, store, and otherwise process the following kinds of personal information:

• • your full name and contact details, including email address, postal address, and telephone number;
  • profile information and user name if you register on our website;
  • information you provide in connection with your application for a fellowship, or job which may include date of birth, biographical information, education and work experience, information about family members, employment information, passport, dietary information, images of your signature, expenses, amount and intended purpose of grants you are involved in, and information about your participation in a specific program;
  • information you provide when you are considered for a board role which may include education and work experience, information about family members, employment information, potential conflicts of interest, and expenses;
  • information you provide when you are considered as a contractor which may include education and work experience, employment information, images of your signature, and information about the services you may provide to PIN;
  • information about your use of our information and communications systems;
  • financial information including bank details, payment card details;
  • your communication preferences;
  • information about your professional status and role; and
  • information you provide to us through Forums (see below).

We will also collect certain information automatically every time you interact with our website. We do this through server log files, cookies, and pixel tags. While the information obtained may not be personal information under the laws of the country you are based in, we recognize that there are certain laws where this information is likely to be personal information.
For instance, we identify and log the Internet Protocol (IP) address of the device you use to access our website automatically in our server log files whenever you visit our website, along with the time of your visit and pages you visit. While the intention of such a practice is to calculate website usage levels and to help us diagnose problems with the website’s servers, we recognize that an IP address is also an online identifier which can be used to create profiles of individuals behind devices. Thus, if we combine non-personal information with personal information, we will treat the combined information as personal information as long as it is combined.

Certain countries have laws that recognize particular types of personal information as more sensitive and therefore requiring greater protection. We collect these types of personal information in limited circumstances. We may collect personal information, for instance, about criminal convictions and offenses. Paradigm Initiative may collect sensitive information if there is a valid reason to do so with the consent of the individual. If any such information is collected, PIN will be responsible for keeping the information confidential unless called upon to disclose the information under a warrant issued by a court of law.

We will only collect and use this sensitive information if there is a valid reason for doing so and where the law allows us to. For instance, there are stricter rules about the collection and use of sensitive information where some laws apply. When we collect sensitive information or criminal conviction data about you and we are required to tell you what our lawful basis is for doing so, we will set this out.

PIN will use your personal information:

• • to fulfill your requests to submit an application or register on the website;
  • to allow us to review, evaluate and administer other PIN programs;
  • to enable us to monitor progress and completion of those programs;
  • to enable us to monitor and manage conflicts of interest;
  • to enable us to manage governance transactions;
  • to contact you if you are involved in a project we are administering;
  • to contact you to make recommendations, proposals, or notices to you about opportunities you may potentially be interested in;
  • to make administrative and marketing communications;
  • to enable you to use our online services (e.g., our forums, message boards, blogs);
  • to administer any financial transaction between us;
  • to register you for an event and any administration associated with the event;
  • to contact you for our advocacy purposes and to inform you of events or publications we think you may potentially be interested in;
  • for research purposes so that we can identify key trends of findings in connection with our programs and projects;
  • to satisfy legal obligations which are binding on us;
  • for the prevention of fraud or misuse of service; and
  • for the establishment of, defense against, or enforcement of legal claims.

Under certain laws, we are required to rely on one or more lawful grounds to collect and use the personal information that we have outlined above. We consider the grounds listed below to be relevant:

• • Legal obligation: Where the processing of your personal information is necessary for us to comply with a legal obligation to which we are subject (e.g., because we have to provide information to tax authorities).
  • Contractual relationship: Where it is necessary for us to use your personal information in order to perform a contract to which you are a party (or to take steps at your request prior to entering a contract).
  • Legitimate interests: We rely on this basis where applicable law allows us to collect and use personal information for our legitimate interests and the use of your personal information is fair, balanced, and does not unduly impact your rights. For instance, it is in our legitimate interest to use personal information in association with planning of, delivery of, and monitoring of our programmatic work.
  • Consent: We may obtain your consent to use your personal information in certain circumstances (e.g., to send you email marketing). We will ensure that when we obtain your consent, you are free both to give it and to decline to give it. Additionally, you may always withdraw your consent at any time without any further detriment to you.

We may make available certain interactive services through our website such as message boards, blogs, and wikis (Forums). You will be able to post information and materials to Forums.
Any information (including personal information) that you post in a Forum becomes public information and may be available to other visitors to our website and to the general public. In addition, your name may be available in association with any posting you make. Information regarding your Forum activities is also available for other users to view.
Please exercise caution and discretion when posting information (including personal information) in a Forum. In particular, please do not post personal information about other individuals unless you are confident that they would not object to their personal information being used in this way. If you post any personal information relating to other people, you represent that you have the authority to do so and to permit us to use the information in accordance with this privacy policy. PIN IS NOT RESPONSIBLE FOR THE USE BY OTHERS OF THE PERSONAL INFORMATION THAT YOU DISCLOSE IN FORUMS.

Personal information collected by PIN (through the website or otherwise) may be shared between any of our family of offices in line with the purposes set out in this privacy policy in section 6.
Apart from where set out in this privacy policy, PIN will not sell, rent, or lease your personal information to other third parties. However, we may ask third-party processors to assist us or we may disclose your personal information to selected third-party processors (such as agents or sub-contractors) for the purposes outlined in section 6. The third party in question will be obligated to use any personal information they receive in accordance with our instructions.
For instance, we use a third-party marketing automation platform to assist with managing email addresses and sending emails to our subscribers. When you sign up to receive email updates from us and provide us with your email address, you will receive an automated email originating from this third party confirming your subscription and providing you with a link to unsubscribe from the list.
We may also engage third parties to assist us with website hosting, data analysis, transaction processing, and other administrative services.
We reserve the right to disclose your personal information to third parties:

• • in the event that we buy or sell any business or assets, in case we are required to, we will disclose your personal information to the prospective buyer or seller or such business or assets;
  • if substantially all of our assets are acquired by a third party, personal information held by us may be one of the transferred assets;
  • for auditing purposes;
  • to enforce our Terms & Conditions;
  • to protect any PIN operations including the rights, safety, and property of PIN and our staff;
  • if we are under any legal obligation to do so (e.g., to comply with legal process or requests from government authorities);
  • to permit us to pursue available remedies or limit the damages that we may sustain; and
  • in connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise, or defend our legal rights.

Certain countries have rules around the transfer of personal information and require us to ensure that personal information remains protected according to appropriate standards.
If you have any questions about the transfer of your personal information, please contact us using the details in section 17.

PIN takes reasonable technical and organizational precautions to prevent the loss, misuse, or alteration of your personal information. We restrict access to those who have a need to know and we train staff in handling the information securely. Unfortunately, there is no such thing as perfect security in the online environment. As a result, we cannot and do not guarantee the security of any information you transmit to us through or in connection with the website.
If you believe that your interaction with us is no longer secure (e.g., you consider that the security of any account you might have with us has been compromised) please immediately notify us by contacting us at datagovernance@paradigmhq.org

We will keep your personal information for as long as necessary:

• • to comply with any statutory or regulatory requirements we are subject to under applicable law;
  • to fulfill the purposes for which the personal information was collected; or
  • to defend our or a third party’s legal rights.

If you have any questions about the retention periods for holding your personal information, please contact us using the details in section 17 below.

Our website is not intended to be used by individuals who are under the age of twelve (12). If you are under the age of twelve (12), please do not provide personal information to us or through our website.

Please note that we will honor your requests to exercise your rights to the extent possible and required under applicable law.
You have the right to:

• • ask us for confirmation of what personal information we hold about you, and to request a copy of that information; if we are satisfied that you have a legal entitlement to see this personal information, and we are able to confirm your identity, we will provide you with this personal information;
  • withdraw your consent at any time if we have relied on consent as the lawful ground to use your personal information;
  • request that we delete the personal information we hold about you, as far as we are legally required to do so;
  • ask that we correct any personal information that we hold about you which you believe to be inaccurate;
  • object to the processing of your personal information where we (i) process on the basis of the legitimate interests ground; (ii) use the personal information for direct marketing; or (iii) use the personal information for statistical purposes;
  • ask for the provision of your personal information in a machine-readable format 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 party; and in either instance, we are processing it using automated means; and
  • ask for processing of your personal information to be restricted if there is disagreement about its accuracy or legitimate use.
• Please note that you also have the right to lodge a complaint with your local data protection authority about how we use your personal information. Please always consider raising your concern with us first by contacting us using the contact details in section 17 below.
• Your choices regarding our use and disclosure of your personal information
  We give you choices regarding our use and disclosure of your personal information for marketing purposes. You may opt-out from:
  • Receiving electronic communications from us: If you no longer want to receive marketing-related emails or text messages from us on a going-forward basis, you may opt-out by sending an email to admin@paradigmhq.org or by regular mail using the address provided in section 17. You may also opt out of our email updates by using the unsubscribe link at the bottom of these emails.
• We will try to comply with your request(s) as soon as reasonably practicable.

The website may contain links to third-party websites. These linked websites are not under PIN’s control and we are not responsible for the privacy practices or the contents of any such linked website, or any link contained in any linked website. We provide such links only as a convenience, and the inclusion of a link on the website does not imply endorsement of the linked website by PIN. If you provide any personal information through any such third-party website, your interaction will occur on such third-party’s website, not on our website, and the personal information you provide will be collected by, and controlled by, the privacy policy of that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.

PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

PIN may update this privacy policy by posting a new version on our website. If we update this privacy policy in a way that significantly changes how we use your personal information, we will bring these changes to your attention. Otherwise, we would recommend that you periodically review this privacy policy to be aware of any other revisions.

PIN’s Data Governance Group is responsible for monitoring compliance with relevant legislation in relation to personal information. You can contact the Data Governance Group if you have any questions about this privacy notice or our treatment of your personal information:
Email: datagovernance@paradigmhq.org
Registered address: 374 Borno Way, Yaba, Lagos,  Nigeria