PRIVACY POLICY

AfDB MicroGREEN Project Financial Grant Program

Effective Date: 20th September, 2025
Last Updated: 1st January, 2026


1. Introduction

The AfDB MicroGREEN Project Financial Grant Program (“MicroGREEN Project,” “Program,” “we,” “our,” or “us”) is a development finance initiative supported by the African Development Bank (AfDB) and its partners to promote sustainable, inclusive, and climate-responsive micro, small, and medium enterprises (MSMEs) across Africa.

We recognize that personal data protection is fundamental to trust, accountability, and transparency. This Privacy Policy outlines how we lawfully collect, use, manage, protect, and disclose personal information obtained through our website, grant application platforms, monitoring systems, and communication channels.

This policy is aligned with:

  • African Development Bank Data Protection and Privacy Principles

  • National data protection laws in participating countries

  • International best practices, including GDPR-inspired principles of lawfulness, fairness, and transparency


2. Definitions

For the purposes of this Privacy Policy:

  • “Personal Data” means any information relating to an identified or identifiable individual.

  • “Data Subject” means any individual whose personal data is processed under this Program.

  • “Processing” includes collection, storage, use, disclosure, transmission, or deletion of personal data.

  • “Controller” refers to the AfDB MicroGREEN Project entity responsible for determining the purposes and means of processing personal data.

  • “Processor” refers to any authorized third party that processes data on behalf of the Program.


3. Applicability and Acceptance

This Privacy Policy applies to:

  • All users of the AfDB MicroGREEN Project website

  • Grant applicants, beneficiaries, and co-applicants

  • Project coordinators, consultants, evaluators, and partners

  • Vendors and service providers interacting with the Program

By accessing our website, submitting applications, or engaging with the Program, you acknowledge that you have read, understood, and accepted this Privacy Policy.


4. Categories of Information Collected

We collect personal data strictly necessary for program administration, compliance, and development impact measurement.

4.1 Personal Identification Data

  • Full legal name

  • Date and place of birth

  • Gender (where legally required)

  • Nationality and country of residence

  • Government-issued identification numbers

4.2 Contact and Communication Data

  • Email address

  • Telephone numbers

  • Residential and business addresses

  • Emergency or alternative contact details

4.3 Business and Organizational Data

  • MSME name, sector, and registration status

  • Ownership and management structure

  • Business licenses and tax identification

  • Sustainability and environmental impact data

4.4 Financial and Transactional Data

  • Bank account or approved digital wallet information

  • Grant disbursement records

  • Source of funds declarations

  • Budget proposals and expenditure reports

4.5 Monitoring, Evaluation, and Impact Data

  • Progress reports

  • Performance indicators

  • Employment and environmental impact metrics

  • Photographic or documentary evidence (where required)

4.6 Technical and Digital Data

  • IP address and geolocation (non-precise)

  • Browser type and operating system

  • Login timestamps and usage logs

  • Cookies and analytics data


5. Purpose of Data Processing

Personal data is processed solely for legitimate program-related purposes, including:

  • Grant eligibility assessment and selection

  • Due diligence, compliance, and fraud prevention

  • Execution of grant agreements and payments

  • Program monitoring, evaluation, and reporting

  • Communication with applicants and beneficiaries

  • Regulatory, audit, and donor reporting obligations

  • System security and website optimization


6. Legal Grounds for Processing

Processing of personal data is conducted under one or more of the following lawful bases:

  • Explicit consent of the data subject

  • Performance of contractual or grant obligations

  • Compliance with AfDB policies and legal requirements

  • Legitimate interests related to development finance administration


7. Data Sharing, Transfers, and Disclosure

Personal data may be disclosed on a strict need-to-know basis to:

  • African Development Bank (AfDB) and affiliated entities

  • Development partners, donors, and co-financing institutions

  • Authorized national and regional coordinators

  • Auditors, evaluators, and compliance officers

  • Government or regulatory authorities when legally mandated

All third parties are required to comply with confidentiality and data protection obligations consistent with this Privacy Policy.


8. Cross-Border Data Transfers

Due to the multinational nature of the Program, personal data may be transferred across jurisdictions. Such transfers are safeguarded through:

  • Contractual data protection clauses

  • Secure IT infrastructure

  • Compliance with applicable cross-border data transfer regulations


9. Data Retention

Personal data is retained only for the duration necessary to:

  • Fulfill grant administration objectives

  • Meet legal, regulatory, and audit requirements

  • Support impact evaluation and reporting

Data will be securely archived or anonymized once retention obligations expire.


10. Data Security Measures

We apply robust safeguards to protect personal data, including:

  • Encryption of sensitive data

  • Access control and role-based permissions

  • Secure hosting environments

  • Continuous monitoring and vulnerability management

  • Staff training on data protection and confidentiality


11. Rights of Data Subjects

Subject to applicable law, data subjects have the right to:

  • Request access to personal data

  • Request rectification of inaccurate or incomplete data

  • Request erasure where legally permissible

  • Restrict or object to processing

  • Withdraw consent without prejudice

Requests will be addressed within a reasonable timeframe in accordance with legal obligations.


12. Cookies and Website Analytics

The website uses cookies to:

  • Ensure secure sessions

  • Analyze website performance

  • Improve navigation and user experience

Users may control cookie preferences via browser settings.


13. Children and Vulnerable Persons

The Program does not intentionally collect data from individuals under 18 years of age. Any such data identified will be promptly removed.


14. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of external platforms.


15. Policy Updates and Amendments

This Privacy Policy may be updated to reflect changes in:

  • Legal requirements

  • AfDB policies

  • Program operations

Revised versions will be posted on the website with updated effective dates.


16. Complaints and Dispute Resolution

Data subjects may lodge complaints regarding data protection practices through the Program’s designated contact channels. Complaints will be handled transparently and in accordance with AfDB grievance mechanisms.


17. Contact Details

AfDB MicroGREEN Project – Data Protection & Compliance Office
Email: policy@microgreenproject.org


18. Policy Commitment Statement

The AfDB MicroGREEN Project reaffirms its commitment to ethical data management, confidentiality, transparency, and accountability in advancing sustainable development, climate resilience, and MSME growth across Africa.

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