Privacy Policy
1. Who we are
AFRISOVERA GLOBAL HOLDINGS LIMITED ("Afrisovera", "we", "us", "our") is a company incorporated in England and Wales under company number 17244459, with registered office at Office 19286, 182-184 High Street North, East Ham, London, E6 2JA.
We are the data controller for the personal data we collect through our website and services. We are registered with the UK Information Commissioner's Office (ICO) under registration number ZC263681.
Contact: privacy@afrisovera.com · Post: Data Protection, Afrisovera, Office 19286, 182-184 High Street North, East Ham, London, E6 2JA.
2. What this policy covers
This Privacy Policy explains what personal data we collect, why, how long we keep it, who we share it with, your rights, and how to complain.
It applies to anyone who visits afrisovera.com, signs up for an Afrisovera account, contacts us by email, uses the services on this site (such as the Afrisovera City project, Foundation and Shield), or interacts with us in any other way.
Our apps and games are not covered by this policy. Avena, Safehold and our games are run by Afrisovera Studios, a trading name of the same company, and are covered by the Afrisovera Studios privacy policy.
If you used the former Marketplace, Avena or Safehold pages on this site. The Marketplace has closed on afrisovera.com, and the Avena and Safehold pages have moved to Afrisovera Studios. We keep records of your past transactions for the periods in section 6, as the law requires, and you can still use all your rights in section 9 by emailing privacy@afrisovera.com.
3. What personal data we collect
| Category | Examples | Source |
|---|---|---|
| Identity data | Name, date of birth, nationality, photo (where required) | You provide |
| Contact data | Email address, phone number, postal address | You provide |
| Account data | Username, password (encrypted), account preferences | You provide |
| Transaction data | Purchases, payment transactions, order confirmations | You provide / generated |
| Financial data | No payments are taken on this site. For past purchases on the former Marketplace and Safehold pages: payment card information (processed and held by Stripe, never by Afrisovera) and the platform fee amounts we were shown | You provided it via Stripe |
| Assistant questions | The text you type into the “Ask Afrisovera” website assistant, used only to write the reply and not stored by us | You provide it |
| Verification data | ID document images, proof of address, KYC information | You provide (Tier 2 only) |
| Technical data | IP address, browser type, device information, time zone | Automatic |
| Usage data | Pages viewed, time on site, clicks | Automatic |
| Communication data | Emails, support messages, survey responses | You provide |
| Marketing data | Preferences for receiving marketing | You provide |
4. Lawful basis for processing (UK GDPR Article 6)
| Purpose | Lawful basis |
|---|---|
| Provide our services to you | Contract performance (Art. 6(1)(b)) |
| Verify your identity (KYC/AML) | Legal obligation (Art. 6(1)(c)) |
| Process payments | Contract performance (Art. 6(1)(b)) |
| Send transactional messages | Contract performance (Art. 6(1)(b)) |
| Send marketing communications | Consent (Art. 6(1)(a)) |
| Detect and prevent fraud | Legitimate interests (Art. 6(1)(f)) |
| Comply with legal requests | Legal obligation (Art. 6(1)(c)) |
| Improve our website and services | Legitimate interests (Art. 6(1)(f)) |
| Defend legal claims | Legitimate interests (Art. 6(1)(f)) |
5. Special category data and children
We do not intentionally collect special category data (health, race, religion, biometric data, etc.) except where strictly necessary and lawful (e.g. ID-document images for KYC).
Our services are not directed at children under 13. We do not knowingly collect personal data from anyone under 13.
6. How long we keep your data
| Data category | Retention period |
|---|---|
| Account data | While your account is open + 6 years after closure |
| Transaction & financial records | 6 years from end of the relevant tax year |
| KYC / AML records | 5 years after end of relationship |
| Marketing data (consent-based) | Until you withdraw consent + 30 days |
| Website analytics | 26 months |
| Email correspondence | 2 years from last interaction |
| Legal claim records | Indefinitely while live; 6 years after closure |
7. Who we share your data with
| Recipient | Purpose |
|---|---|
| AI service providers (currently Cerebras, SambaNova, Mistral AI and Google), data processors under UK GDPR Article 28 | When you use the Ask Afrisovera assistant, your question and the last few messages of that conversation are sent to one of these providers to write the reply. We do not store the conversation; to prevent abuse we keep only a scrambled, non-reversible code of your connection’s IP address, deleted after 2 days. Please do not type personal details into the assistant. |
| Stripe Payments Europe, Ltd (FCA firm ref 900665), data processor under UK GDPR Article 28 | Processed and routed payments made on the former Marketplace and Safehold pages, and keeps the records of those past transactions; Afrisovera never held the principal. No new payments are processed on this site. Stripe is subject to its own Privacy Policy and FCA supervision. |
| Cloud hosting & email (e.g. Google Workspace, AWS) | Storing data, sending emails |
| Analytics (e.g. Google Analytics, with consent) | Understanding website usage |
| Identity verification services (e.g. Onfido) | KYC checks for Tier 2 |
| Professional advisers (accountants, solicitors, auditors) | Legal and accounting compliance |
| Government authorities (HMRC, ICO, courts, law enforcement) | Where legally required |
| Buyers in a corporate transaction | If Afrisovera is sold, restructured, or invested in |
We do not sell your personal data to third parties.
International data transfers
Where we transfer your data internationally, we use UK adequacy regulations, the International Data Transfer Agreement (IDTA), the UK Addendum to EU Standard Contractual Clauses, or other lawful transfer mechanisms.
8. Cookies and similar technologies
We use cookies on afrisovera.com. See our separate Cookie Policy for full details.
9. Your rights under UK GDPR
You have the following rights regarding your personal data. Most are free to exercise and we will respond within 1 month (extendable to 3 months for complex requests):
- Right to be informed: receive clear information about how we use your data (this policy)
- Right of access: request a copy of the personal data we hold about you
- Right to rectification: have inaccurate or incomplete data corrected
- Right to erasure: request deletion of your data (subject to legal retention requirements)
- Right to restrict processing: limit how we use your data in specified circumstances
- Right to data portability: receive your data in a structured, commonly-used, machine-readable format
- Right to object: object to processing based on legitimate interests or for direct marketing
- Rights related to automated decision-making and profiling
- Right to withdraw consent: where processing is based on consent
To exercise any right: email privacy@afrisovera.com.
10. How to complain
If you're not satisfied with our response, you can complain to the:
Information Commissioner's Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF
Helpline: 0303 123 1113
Website: https://ico.org.uk/make-a-complaint/
11. Data security
We take appropriate technical and organisational measures to protect your data, including encryption of data in transit (HTTPS / TLS), access controls, multi-factor authentication, regular security reviews, and incident response procedures.
If you believe your account has been compromised, contact us immediately at privacy@afrisovera.com.
12. Changes to this policy
We may update this policy from time to time. The "Last updated" date at the top reflects the current version. For material changes, we will notify registered users by email and post a prominent notice on the website.
13. Specific notes for Afrisovera services
Foundation (Talent Kids)
If you apply to or are sponsored by the Talent Kids program, we collect additional educational and personal information. We will provide a separate fair-processing notice at the point of collection.
Shield (Whistleblowing)
Reports made via Shield can be submitted anonymously. If you provide identity information when reporting, we treat it as confidential and only share it as necessary to investigate, or where required by law.
Apps and games
For Avena, Safehold and our games, including how to delete an app account, see the Afrisovera Studios privacy policy and studios.afrisovera.com/delete-account.
14. Contact us
For any privacy questions or to exercise your rights:
- Email: privacy@afrisovera.com
- Post: Data Protection, Afrisovera, Office 19286, 182-184 High Street North, East Ham, London, E6 2JA