Effective date 1 November 2021, Version 1.0.0
Ayanza as a data processor
Ayanza operates Ayanza Platform, a web application designed to help people organize, track, manage their work, store documents and communicate with each other (“Ayanza Platform”). When you conclude an Agreement with Ayanza for provision of Ayanza Platform services and entrust Personal data to Ayanza, Ayanza will process this Personal data as a data processor in accordance with the Data Processing Addendum that is annexed to the Terms of Service. This includes the Personal data you upload to the Ayanza Platform as well as data of your Users.
Ayanza as a data controller
Anytime you are in a direct relationship with Ayanza such as when you create an Admin Account, you subscribe for any newsletters, book a coaching session or submit a CV via our career pages Ayanza acts as a data controller.
refers to the set of applications and systems provided by Ayanza to Customer
refers to a person that signs up to Ayanza Platform
refers to an account created by Customer in order to utilise the Service.
an identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
means any data that are processed by Ayanza which may be considered as Personal Data under applicable data protection laws
I. What Data Do We Process?
Ayanza Platform Services
When you create an Admin Account and use Ayanza Platform we may collect and process the following categories of data including Personal data:
information about what Module of the Service you use,
information about your use of Ayanza Services,
Any further information you share with us
When you visit Ayanza Platform, sign up for a newsletter, book a coaching session or onboarding session with Ayanza or contact Ayanza via our website we may collect and process the following categories of data including Personal data:
Identification details (name, surname)
Contact details, such as address, phone number, e-mail address
Newsletters you signed up for
Information about the company you work for and your work position
Any further information you share with us
When you apply for a job at Ayanza we may collect and process the following categories of Personal data:
Identification details (name, surname)
Contact details, such as address, phone number, e-mail address
Information from your CV, Cover Letter about your past positions, qualifications etc.
Any further information you share with us during the recruitment process
Criminal record, credit check (depending on the position you apply for)
How Do We Process Data?
Ayanza Platform Services
While using our Ayanza Platform you may also provide us with following information: IP address, time zone setting, operating system and platform, information about visits including the URL, the search terms, information about what you viewed or searched on our website, page response times, download errors, length of visits to certain pages, page interaction information, (such as scrolling, clicks, and mouse-overs) and the methods used to browse away from the page, browsing web pages.
In order to ensure that you can make full use of Ayanza Platform Services, we need to process information about your subscription and payment data.
By accessing and using Ayanza services, you enter into an agreement for provision of Ayanza Platform Services. The legal ground for processing this data is performance of contract or precontractual relations.
We may record our calls when you contact us regarding the use of Ayanza Platform or as our protentional client. Such call recordings help us provide you with the better services. We will only record the calls with your prior consent. You can withdraw your consent at any time by contacting us at: firstname.lastname@example.org
Ayanza may use your data for marketing purposes, i.e. if you sign up for our newsletter or other marketing communication. These communications shall strictly adhere to applicable legal regulations. Advertising and marketing materials of other parties shall be sent to you only if you opted in for these communications, via our website e-mail or otherwise. Legal ground for processing of your data for marketing purposes is consent.
If you apply for any open job positions at Ayanza through Ayanza website or other means, we will process personal data you provide us with for the purposes of evaluating your application and information contained therein to assess whether you are a suitable candidate for any of our positions. We may as well conduct pre-employment screening of job applicants to verify inter alia the truthfulness of the information contained in your CV and other documents you provide us with. For particular positions, you may be asked to provide us with your criminal record, or we may carry out a background check as well. The pre-employment screening is always done in such a way that its proportionality, adequacy, and compliance with applicable law is assured. The legal ground for processing this data is performance of contract or pre-contractual or your consent (as applicable).
We may keep your CV in our internal database in order to consider our future collaboration with you. The legal ground for processing such Personal data is your consent. You can withdraw your consent at any time in your Admin Account or by sending a message to email@example.com.
In some instances, legal regulations impose obligations on us under which we are obliged to process Personal data, such cases are for instance tax and accounting laws, AML laws and provision of some data to public authorities based on law. That means we may process your Personal data in order to ensure compliance with such obligations. Legal ground for processing such Personal data is compliance with legal obligations.
III. Cookies and Other Tracking Technologies on Our Websites
Additionally, cookies help us deliver online advertising that we believe is most relevant to you. Cookies are also used for profiling. Cookies can help us to understand how our website is being used, for example, by telling us if you get an error message as you browse. For more information about cookies please visit http://www.allaboutcookies.org.
We use the following types of cookies:
(i) essential (necessary) cookies, which are essential for the provision of access to our websites and for the provision of services explicitly requested by you, they enable core functionalities of the website such as marking your data inputs, network management and accessibility; (if these cookies are disabled, our website may not work properly);
(ii) analytical (performance) cookies help us to analyse how you navigate our websites and what content is relevant to our users, we are able to see user navigation in our platform (we monitor automatic events, custom events and event logging and save them in real-time database). Analytical and performance cookies are as well used for performance measurement and improvement.
(iii) functional cookies allow us to remember choices you have made in the past, like what language and currency you prefer, remember your name and email and automatically fill forms and allow for personalisation, such as live chats, videos and the use of social media;
(iv) advertising cookies, which help delivering tailored and customized advertising.
We may collect the following data via cookies:
IP address, gender, time zone, browser settings, operating system, information about website visits including the URL, search terms, information about what you viewed or searched on our website, page response times, download errors, length of visits to certain pages, page interaction information, (such as scrolling, clicks, and mouse-overs).
When you visit our websites, you shall be informed through a cookie banner placed at the bottom of the website that we collect cookies. The banner allows you to manage what kind of cookies can be collected by Ayanza. You can change the settings and withdraw your consent at any time through Privacy settings provided on the bottom of our websites.
When we collect essential cookies the legal ground for processing of this data is legitimate interest. It is not possible to disable these cookies through the Privacy settings as our websites might not function properly when you disable this type of cookies however if you still wish to do so you may follow the instructions below in the section Disabling cookies.
When we store data or gain access to data already stored in your terminal equipment such as your PC or mobile device for analytical, functional, or advertising purposes we only do so once you have given us your consent.
If you wish cookies not to be collected, you may restrict, block or delete the cookies at any time by modifying your browser configuration. Although each browser is parameterized differently, cookie configuration is normally located on the “Preferences” or “Tools” menu. If you turn off cookies, the functionality of our website may be limited (in the case of essential cookies you may not be able to access our website).
If you wish to prevent new cookies from being installed or if you wish to delete existing cookies you can find the instructions on the links below. The exact procedure depends on which browser you are using:
Internet Explorer: http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
Firefox: https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox#firefox:win10:fx93 / https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox?redirectslug=delete-cookies-remove-info-websites-stored&redirectlocale=en-US#firefox:win10:fx93
Google chrome: https://support.google.com/chrome/answer/95647?hl=en
For mobile devices you can limit tracking via the privacy setting on your device (disabling the advertising identifier), for instructions please see https://www.networkadvertising.org/mobile-choice/
Furthermore you can use a third party tool to opt out from targeted advertising, available third-party opt-out tools include the Digital Advertising Alliance, the Network Advertising Initiative, and the European Interactive Digital Advertising Alliance (Europe only).
To opt out from receiving cross-device site advertising (i.e. tracking a user across devices) you can access your device settings or visit and employ the controls described on the NAI’s Mobile Choices page.
We as well use so-called social plugins from the following social networks on our websites: (i) google.com, (ii) Facebook XXX (“plugins”), which are indicated by their logos on our websites. When you visit our websites, your browser establishes a direct connection with the servers on which these plugins run. The content of the plugins is transferred directly by Google / Facebook to your browser, which then integrates it into our website. Integration of the plugins causes Google / Facebook to receive the information that you have accessed on the corresponding page of our website. If you are logged with Google / Facebook, it will be able to assign your visit to your account on these social networks. Please note that an exchange of this information already takes place when you visit our website regardless of whether you interact with the plugin or not. If you do not want Google / Facebook to gather data about you via our website, you must log out of them before visiting our website.
For more information regarding how these social networks process your data in their privacy policies:
IV. Data Retention
Generally, Personal data shall be kept for as long as necessary for the purpose for which it was processed. For how long Ayanza will hold your Personal data will as well depend on the legal basis on which your data is processed. Shall the processing be based on legitimate interest your data will be processed for as long as the given legitimate interest of Ayanza is in place. For data kept based on legal obligations the data retention period is prescribed by applicable legal regulations. For data processed based on performance of a contract the data is processed for the duration of the contractual relationship and for an applicable limitation period. Shall the processing be based on your consent your Personal data shall be erased after you withdraw your consent. Please bear in mind that the same data may as well be processed based on more legal bases in which case your withdrawal of consent might not mean a full erasure of your data.
Ayanza shall neither collect an excessive amount of Personal data nor other information which is not relevant for the purposes for which the Personal data is collected.
If you create an Admin Account, we will process your data for the period of your registration with Ayanza. You can delete your Admin Account at any time. You can as well manage what data is processed about you via your Admin Account.
Ayanza shall not store data provided by you or collected automatically during the phone calls for a longer period than what is necessary, given the purposes for which they were provided or collected. Moreover, you can withdraw your consent to process your data at any time by sending the message to firstname.lastname@example.org in which case we will remove your data from our system.
Personal data of unsuccessful applicants that provided us with their consent for considering them for future positions at Ayanza is processed for the period for which the consent was given, whereas you may withdraw your consent at any time. Personal data of unsuccessful applicants that have not provided us their consent for retaining their Personal data are retained for as long as the given legitimate interest of Ayanza to protect itself from legal claims and effectuate the hiring process.
V. Data Sharing, Processors and Transfers to Third Countries
Your Personal data shall not be shared with any third party except for the following situations:
(a) data is necessary for provision of Ayanza Platform Services,
(b) based on your consent,
(c) entrusting of Personal data to processors who process Personal data on behalf of Ayanza,
(d) Ayanza is obliged to provide the Personal data on the basis of law or upon order by a public authority.
Categories of Processors
Ayanza uses trusted third-party providers that in some instances process Personal data on behalf of Ayanza and based on instructions provided by Ayanza. Ayanza may use the following categories of providers (sub-processors under GDPR):
hosting, data centre,
task management and communication tools,
IT tools / providers,
business administration tools,
recruitment and applicant verification providers,
legal, tax accounting, and audit services,
Transfers to Third Countries
Ayanza will transfer your data to countries outside the EU/European Economic Area only if such a transfer is GDPR compliant. That means, for instance, the provider is seated in a country for which the European Commission issued a decision that it provides an adequate level of Personal data protection, Standard Contractual Clauses issued by the European Commission and/or other transfer mechanisms are in place that ensure adequate safeguards with respect to the protection of privacy and fundamental rights and freedoms of individuals and, if necessary, additional measures are applied to ensure that the Data Subject is granted a level of protection essentially equivalent to that guaranteed by the GDPR.
You have a right to receive a copy of the Standard Contractual Clauses (“SCC”) we have concluded with our sub-processors that are established outside of the EU/EEA and that are used for transferring personal data outside of the EU/EEA. If you wish to obtain a copy of the SCCs applicable to a particular transfer of your Personal data, please contact us via email@example.com.
VI. Data Security
Ayanza is committed to ensure that your Personal data is stored securely. Therefore, Ayanza has adopted several adequate technical and organizational measures in effort to safeguard personal information collected through Ayanza services.
Ayanza protect your data, including but not limited to:
Using passwords and other access management and restricting access to your data (using multiple levels of internal system logs, enforcing strong password policy).
Using strong security IT tools (firewalls, antivirus/antimalware software etc.).
Implementing appropriate physical security of premises where the Personal data is stored such as implementing controls on premise entry.
These measures do not deprive you from your duties to undertake proper steps in order to secure your own Personal data. You should, inter alia, regularly change your passwords. On the other hand, you should not, inter alia, use predictable usernames and/or passwords, share your password with other persons, or grant access to your Admin Account and/or disclose your Personal data to other persons. Ayanza will never ask you for your password in any unsolicited communication. Please notify us immediately of any unauthorized use of your Admin Account or any other suspected breach of security.
VII. Your rights
Where EU General Data Protection Regulation 2016/679 (“GDPR”) applies to the processing of your Personal data you are entitled under the GDPR to the following rights:
Right of access
You are entitled to be informed inter alia about what Personal data Ayanza processes about you, for what purposes, who are the recipients of your Personal data. If you would like to obtain such information, please contact us via our email firstname.lastname@example.org. If your Personal data is processed by us we will provide with the following information:
purposes of processing such data,
the categories of Personal data concerned,
the recipients or categories of recipients of your Personal data,
where possible the period for which your Personal data will be stored, or at least criteria that determine that period,
the existence of the right to request from the controller rectification or erasure of Personal data or restriction of processing of Personal data concerning the Data Subject or to object to such processing,
the right to lodge a complaint with the supervisory authority,
information about the source of your Personal data, that are not collected directly from you and
information about existence of automated decision-making, including profiling under Article 22 (1) and (4) GDPR
Right to rectification
You have a right for any of your incomplete, inaccurate, or out-of-date Personal data to be rectified. If you would like to exercise this right, please contact us email@example.com.
Right to erasure (‘right to be forgotten’)
You are entitled to erasure of certain Personal data that we have collected and processed about you without undue delay. Please be aware that Ayanza might be allowed or even obliged to keep some of the Personal data despite your deletion request. This includes mainly situations where we need to process your Personal Data for compliance with legal obligations or for the establishment, exercise and defence of legal claims. If you wish to exercise this right, please contact as via following email address firstname.lastname@example.org.
Right to restriction of processing
In given cases such as
where the accuracy of the Personal data is contested by you, for a period enabling us to verify the accuracy of Personal data,
the processing is unlawful, and you oppose the erasure of your Personal data and request the restriction of their use instead,
we no longer need your data for the purposes of processing, but your Personal data are required for the establishment, exercise, or defence of legal claims,
you have objected to processing in connection with the profiling pending the verification whether our legitimate grounds override yours
you may ask for a restriction of the processing. If you would like to exercise this right contact us at email@example.com.
Right to data portability
You have a right to receive Personal data you provide us with in a structured, commonly used, and machine-readable format and have it transmitted to another controller where technically feasible. Please be aware that only data you have provided us with, and we process as a controller on the basis of your consent or performance of contract is covered by the right to data portability. If you would like to obtain your Personal data in such form, please contact us via our email firstname.lastname@example.org.
Right to object
You are entitled to object, on grounds relating to your particular situation, at any time to processing of Personal data that concerns you and is carried out in public interest or for the purposes of legitimate interests pursued by Ayanza, including profiling.
The exercise of your rights may be limited shall Ayanza be obliged to keep any of your Personal data for the purpose of compliance with legal obligations, for the establishment, exercise or defence of legal claims or any other compelling reasons as provided by the relevant data protection law. If you would like to exercise this right contact us at email@example.com.
Right to not be subject to automated decision making
You have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This does not apply if the decision:
is necessary for entering into, or performance of, a contract between you and Ayanza
is authorised by law and the law lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or
is based on your explicit consent.
Right to file a complaint
If you feel that your data has been processed unlawfully, contact us and we will undertake to resolve the problem. Under GDPR you have the right to lodge a complaint with your local supervisory authority (for contact details please see: https://edpb.europa.eu/about-edpb/board/members_en ).
VIII. California Consumer Privacy Act of 2018 (“CCPA”) Notice
Consumers residing in California have some additional rights in respect to their personal information under the California Consumer Privacy Act or (“CCPA”). If you are a California resident, this section applies to you and supplements the above policy.
Your Californian Consumer Rights
Where the California Consumer Privacy Act of 2018 Assembly Bill No. 375 (“CCPA”) applies to the processing of your data you are entitled to the following rights:
Right to notice
Right of access
You are entitled to be informed about what Personal data Ayanza processes about you, for what purposes and who are the recipients of your Personal data.
Right to request deletion
You are entitled to the erasure of certain Personal data that we have collected and processed about you. Please be aware that Ayanza might be allowed or even obliged to keep some of the Personal data despite your deletion request.
Right to receive equal services
You have a right to not be discriminated against even if you exercise any of your CCPA rights.
X. Contact Details