At Acumen Technologies ("Acumen") we recognize that privacy is important. This Policy applies to all of the products, services and websites offered by Acumen or its subsidiaries or affiliated companies (collectively, Acumen "services"). If you have any questions about this Policy, please feel free to contact us through our website or write to us at Privacy Matters, c/o ACF Consultants Ltd, 28 King Street, London EC2V 8EH, UK.
Information we collect and how we use it
We offer a number of services that do not require you to register for an account or provide any personal information to us. In order to provide our full range of services, we may collect the following types of information:
- Information you provide - When you sign up for an Acumen Account or other Acumen service or promotion that requires registration, we ask you for personal information (such as your name, email address and an account password). For certain services, such as our open enrollment programs (www.acfacademy.com) , we also request credit card or other payment account information which we maintain in encrypted form on secure servers. We may combine the information you submit under your account with information from other Acumen services or third parties in order to provide you with a better experience and to improve the quality of our services. For certain services, we may give you the opportunity to opt out of combining such information.
- Log information - When you use Acumen services, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, Internet Protocol address, browser type, browser language, the date and time of your request and one or more cookies that may uniquely identify your browser.
- User communications - When you send email or other communication to Acumen, we may retain those communications in order to process your inquiries, respond to your requests and improve our services.
- Affiliated sites - We offer some of our services in connection with other web sites. Personal information that you provide to those sites may be sent to Acumen in order to deliver the service. We process such information in accordance with this Policy. The affiliated sites may have different privacy practices and we encourage you to read their privacy policies.
- Links - Acumen may present links in a format that enables us to keep track of whether these links have been followed. We use this information to improve the quality of our search technology, customized content and advertising. For more information about links and redirected URLs, please see our FAQs.
- Providing our products and services to users, including the display of customized content;
- Auditing, research and analysis in order to maintain, protect and improve our services;
- Ensuring the technical functioning of our network; and
- Developing new services.
You can find more information about how we process personal information by referring to the privacy notices for particular services.
Acumen processes personal information on our servers in the United Kingdom and in other countries. In some cases, we process personal information on a server outside your own country. We may process personal information to provide our own services. In some cases, we may process personal information on behalf of and according to the instructions of a third party, such as our advertising partners.
Choices for personal information
When you sign up for a particular service that requires registration, we ask you to provide personal information. If we use this information in a manner different than the purpose for which it was collected, then we will ask for your consent prior to such use.
If we propose to use personal information for any purposes other than those described in this Policy and/or in the specific service notices, we will offer you an effective way to opt out of the use of personal information for those other purposes. We will not collect or use sensitive information for purposes other than those described in this Policy and/or in the specific service notices, unless we have obtained your prior consent.
You can decline to submit personal information to any of our services, in which case Acumen may not be able to provide those services to you.
Acumen only shares personal information with other companies or individuals outside of Acumen in the following limited circumstances:
- We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
- We provide such information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of processing personal information on our behalf. We require that these parties agree to process such information based on our instructions and in compliance with this Policy and any other appropriate confidentiality and security measures.
- We have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process or enforceable governmental request, (b) enforce applicable Terms of Service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against imminent harm to the rights, property or safety of Acumen, its users or the public as required or permitted by law.
We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who searched for a particular term, for example, or how many users clicked on a particular advertisement. Such information does not identify you individually.
Please contact us at the address below for any additional questions about the management or use of personal data.
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.
We restrict access to personal information to Acumen employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
Acumen processes personal information only for the purposes for which it was collected and in accordance with this Policy or any applicable service-specific privacy notice. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed to provide or improve our services. We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.
Accessing and updating personal information
When you use Acumen services, we make good faith efforts to provide you with access to your personal information and either to correct this data if it is inaccurate or to delete such data at your request if it is not otherwise required to be retained by law or for legitimate business purposes. We ask individual users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort. Some of our services have different procedures to access, correct or delete users' personal information. We provide the details for these procedures in the specific privacy notices or FAQs for these services.
Acumen regularly reviews its compliance with this Policy. Please feel free to direct any questions or concerns regarding this Policy or Acumen's treatment of personal information by contacting us through this web site or by writing to us at Privacy Matters, c/o ACF Consultants Ltd, 28 King Street, London EC2V 8EH, UK. When we receive formal written complaints at this address, it is Acumen's policy to contact the complaining user regarding his or her concerns. We will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between Acumen and an individual.
Changes to this policy
If you have any additional questions or concerns about this Policy, please feel free to contact us any time through this web site or at Privacy Matters, c/o ACF Consultants Ltd, 28 King Street, London EC2V 8EH, UK.
25th April 2014