This privacy policy applies between you, the User of this Website and Acumentice Ltd., the owner and provider of this Website. Acumentice Ltd. takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which can be found here. Please read this privacy policy carefully.

Definitions and interpretation

In this privacy policy, the following definitions are used:

Data: collectively all information that you submit to Acumentice Ltd. via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws;

Cookies: a small text file placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

Data Protection Laws: any applicable law relating to the processing of personal Data, including but not limited to the Directive 96/46/EC (Data Protection Directive) or the GDPR, and any national implementing laws, regulations and secondary legislation, for as long as the GDPR is effective in the UK;

GDPR: the General Data Protection Regulation (EU) 2016/679;

Acumentice Ltd., we or us Acumentice Ltd., a company incorporated in England and Wales with registered number Acumentice Ltd. whose registered office is at Acumentice Ltd, 5-7 Tanner Street, London, SE1 3LE;

UK and EU Cookie Law - the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;

User or you - any third party that accesses the Website and is not either (i) employed by Acumentice Ltd. and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Acumentice Ltd. and accessing the Website in connection with the provision of such services; and

Website - the website that you are currently using, www.acumentice.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions. In this privacy policy, unless the context requires a different interpretation:

the singular includes the plural and vice versa;

references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

a reference to a person includes firms, companies, government entities, trusts and partnerships;

“including” is understood to mean “including without limitation”;

reference to any statutory provision includes any modification or amendment of it;

the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of Acumentice Ltd. and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

For purposes of the applicable Data Protection Laws, Acumentice Ltd. is the “data controller”. This means that Acumentice Ltd. determines the purposes for which, and the manner in which, your Data is processed.

Data collected

We may collect the following Data, which includes personal Data, from you:

name;

contact information such as email addresses and telephone numbers;

in each case, in accordance with this privacy policy.

How we collect Data

We collect Data in the following ways:

• data is given to us by you; and

• data is collected automatically.

Data that is given to us by you

Acumentice Ltd. will collect your Data in a number of ways, for example:

• when you contact us through the Website, by telephone, post, e-mail or through any other means;

• when you elect to receive marketing communications from us;

• when you use our services;

• when you complete our contact form;

in each case, in accordance with this privacy policy.

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Data that is collected automatically

To the extent that you access the Website, we will collect your Data automatically, for example:

• we automatically collect some information about your visit to the Website. This information helps us to make improvements to Website content and navigation, and includes your IP address, the date, times and frequency with which you access the Website and the way you use and interact with its content.

• we will collect your Data automatically via cookies, in line with the cookie settings on your browser. For more information about cookies, and how we use them on the Website, see the section below, headed “Cookies”.

Our use of Data

What We Do

What Data We Use

Our Lawful Basis

To register you as a new customer (a) Identity (b) Contact Performance of a contract with you

To manage our relationship with you, which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (c) providing services to you (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to partake in a prize draw, competition or complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business). With your permission and/or where permitted by law, we may also use your Data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. For the delivery of direct marketing to you via e-mail, we’ll need your consent, whether via an opt-in or soft-opt-in:

Soft opt-in consent is a specific type of consent which applies when you have previously engaged with us (for example, you contact us to ask us for more details about a particular product/service, and we are marketing similar products/services). Under “soft opt-in” consent, we will take your consent as given unless you opt-out.

For other types of e-marketing, we are required to obtain your explicit consent; that is, you need to take positive and affirmative action when consenting by, for example, checking a tick box that we’ll provide.

We will only use your Data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your Data for that purpose. If we do use your Data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.

If we need to use your Data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so. In some circumstances, where permitted or required by law, we may process your Data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

Who we share Data with

We will not share any of your Data with any third parties for any purposes, subject to the following exceptions:

If we sell, transfer, or merge parts of our business or assets, your Data may be transferred to a third party. Any new owner of our business may continue to use your Data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain Data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

We may sometimes contract with the following third parties to supply certain products and/or services.

Hubspot, CRM Software, USA

Mailchimp, Emails Software, USA

If any of your Data is shared with a third party, as described above, we will take steps to ensure that your Data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above.

If any Data is transferred outside of the EEA, we will take suitable steps in order to ensure that your Data is treated just as safely and securely as it would be within the UK and under the Data Protection Legisla;on, as explained above.

If we sell, transfer, or merge parts of our business or assets, your Data may be transferred to a third party. Any new owner of our business may continue to use your Data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain Data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

How and where we store your data

We will store or transfer some of your Data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your Data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.

Where we transfer your data to a third party based in the US, the data may be protected if they are part of the EU-US Privacy Shield. This requires that third party to provide data protection to standards similar to those in Europe. More information is available from the European Commission.

The security of your Data is essential to us and to protect your data, we take a number of important measures, including the following:

limiting access to your Data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your Data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

Keeping Data secure

We will use technical and organisational measures to safeguard your Data, for example:

access to your account is controlled by a password and a user name that is unique to you.

we store your Data on secure servers.

We are certified to ISO 27001. This family of standards helps us manage your Data and keep it secure.

Technical and organisational measures include measures to deal with any suspected data breach. If you suspect any misuse or loss or unauthorised access to your Data, please let us know immediately by contacting us via this e-mail address: info@acumentice.com.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Data retention

We will not keep your Data for any longer than is necessary in light of the reason(s) for which it was first collected. Your Data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data

How Long We Keep It

Contact Data includes billing address, delivery address, email address and telephone numbers. Whilst you are a client and three years after you are a client or three years after you make an enquiry with us.

Financial Data includes bank account and payment card details. 6 years.

Identity Data includes first name, last name or username. Whilst you are a client and three years after you are a client or three years after you make an enquiry with us.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us. 6 years.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. Whilst you are a client and three years after you are a client or three years after you make an enquiry with us.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Whilst you are a client and three years after you are a client or three years after you make an enquiry with us. Your rights

You have the following rights in relation to your Data:

Right to access – the right to request (i) copies of the information we hold about you at anytime, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is “manifestly unfounded or excessive.” Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

Right to correct – the right to have your Data rectified if it is inaccurate or incomplete.

Right to erase – the right to request that we delete or remove your Data from our systems.

Right to restrict our use of your Data – the right to “block” us from using your Data or limit the way in which we can use it.

Right to data portability – the right to request that we move, copy or transfer your Data.

Right to object – the right to object to our use of your Data including where we use it for our legitimate interests.

To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your Data (where consent is our legal basis for processing your Data), please contact us via this e-mail address: info@acumentice.com.

If you are not satisfied with the way a complaint you make in relation to your Data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during the period for which we hold it.

Links to other websites

This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

Acumenice Ltd. may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Acumentice Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us.

We may also disclose Data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Cookies

This Website may place and access certain Cookies on your computer. Acumentice Ltd. uses Cookies to improve your experience of using the Website. Acumentice Ltd. has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by this Website are used in accordance with current UK and EU Cookie Law.

Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Acumentice Ltd. to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.

You can find a list of Cookies that we use in the Cookies Schedule.

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.

It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

For more information generally on cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

Cookies

Below is a list of the cookies that we use. We have tried to ensure this is complete and up to date, but if you think that we have missed a cookie or there is any discrepancy, please let us know.

Standard browser cookies

General

You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

Acumentice Ltd. reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Acumentice Ltd. by email at info@acumentice.com.