Privacy Policy

Definitions

For clarity and to ensure that our Privacy Policy is easily understood, we define the following terms:

• Personal Data: Information that can be used to identify, contact, or locate an individual. This may include but is not limited to Identity Data, Contact Data, Profile Data, Technical Data, Usage Data, Activity Data and Marketing and Communications Data. It does not include data where the identity has been removed (anonymous data).
• Service Data: Information that is needed to operate and manage our expert services, which may encompass Transactional Data, Relationship Data and all Data necessary for the performance of a contract
• Special Categories of Personal Data: Data that could reveal racial or ethnic origin, political opinions, religious or philosophical beliefs, or data concerning health or sexual orientation.
• Aggregated Data: Combined data that is not considered personal data in law as this data does not reveal the identity of an individual, used for analysis or reporting.
• Cookies: Digital files stored on a user’s device, used to record certain information about website visits.
• Direct Interactions: Engagements where users directly provide personal data to the organisation.
• Third Parties: External entities or service providers that we utilise in the operation of our service and website, and from which personal data might be stored or obtained.
• Legitimate Interest: A basis for processing where the interests of the data processor or a third party require the use of personal data.
• Legal Obligation: The necessity to process personal data to comply with our legal duty.
• Consent: Voluntary agreement to the processing of personal data.
• International Transfers: Movements of personal data outside the European Economic Area (EEA).
• Data Security: Protective measures to guard against unauthorised data access or loss.
• Data Retention: The time frame for which personal data is stored.
• Legal Rights of Data Subjects: Statutory rights granted to individuals in relation to their personal data.
• Data Breach: A security incident in which personal data is accessed or disclosed without authorisation.
• Website: The digital platform operated by Acume, encompassing the entire range of services, features, interactions, activities, and user engagements. Also referred to as “The Platform”.
• Services: The range of offerings provided by Acume. This includes free services such as content sharing, access to the open library, and general use of the platform, as well as paid expert services. The services extend to encompass all past, current, and future services provided by Acume, ensuring a broad and evolving spectrum of functionalities and support.

Purpose and Scope

Purpose

This Privacy Policy aims to provide you with a clear understanding of our practices regarding the collection, use, protection, and disclosure of your personal data as you engage with us in any form. Our commitment extends to ensuring transparency and responsibility in handling your personal data in any form of engagement with Acume.

Material Scope

• The policy applies without exception for all operations, transactions, personal data processing activities across our platform (including user account management, content sharing, and expert matchmaking), applications, tools, business processes, databases, and all electronic or physical files.
• It applies to data handling in electronic, physical, and cloud-based formats.

Personal Scope

• This policy covers all individuals interacting with our platform or services, including researchers, experts, users, partners, staff and Acume representatives and partners.
• Everyone engaging with Acume, regardless of their role, is encompassed by the principles and practices outlined in this policy.

Global application

• As a UK-based company serving a global audience, this policy applies to all users, irrespective of their geographical location.
• We adhere to robust data protection standards suitable for both local and international users.

Adherence to Stricter Laws

• Where local laws are more stringent than our policy, such laws will prevail.
• Our aim is to be compliant with the highest data protection standards, respecting both UK and global regulations.

Data Principles

Acume acknowledges the importance of your privacy and is dedicated to safeguarding your personal data with utmost integrity. Our commitment to data protection is fundamental to the way we operate and offer our services. Below we outline our core responsibilities:

Security and confidentiality

We prioritise the security and confidentiality of your personal data. Our measures include using third-parties to ensure stored data is encrypted at rest, stringent access controls, and regular security assessments to prevent unauthorised access or breaches. Your personal data is treated as confidential, and we will not disclose it unless you have explicitly consented to share it via your profile or as required by law.

Compliance

Our practices are designed to comply with the General Data Protection Regulation (GDPR), the UK Data Protection Act, and other applicable international privacy laws. We conduct our operations with a commitment to upholding your data rights and our legal obligations.

Transparency

We pledge to provide clear, accessible and accurate information about our data collection, usage, and processing activities. This Privacy Policy serves as your guide to our data handling practices and is available for your review at any time.

Purpose Limitation

We collect personal data solely for the purposes we have specified and guarantee its use in a manner that aligns with those purposes. We avoid any processing of your data that is not compatible with these disclosed purposes.

Diligent Data Handling

We handle your data diligently, ensuring secure access and imparting comprehensive data protection training to our team. This ensures that everyone involved in handling your data understands their responsibility towards maintaining its integrity.

Data Protection Measures

Our data protection measures are robust, encompassing both technical and organisational strategies to safeguard your personal data from any form of misuse or unauthorised disclosure

Responsiveness

We are committed to addressing your data privacy inquiries and requests without undue delay. Our dedicated team ensures prompt and appropriate action in response to your concerns.

Frequent Review and Improvement

We engage in regular evaluations of our data protection practices to adapt to emerging best practices and legislative changes, assuring continual improvement and up-to-date compliance.

By using our website or services, you signify your consent to the terms of this policy. We encourage you to read this document thoroughly to understand our data protection practices fully.

We recommend that you review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

It is also your responsibility to ensure that the personal data you provide to us remains accurate and up to date. Please inform us promptly of any changes to your personal data during your relationship with us.

The data we collect about you

At Acume, we are committed to maintaining a secure and transparent environment where academic and professional exchanges flourish. Our platform allows users to create, share, and engage with content in a variety of meaningful ways. Whether you are sharing or managing research summaries, participating as an expert advisor, hiring expertise, providing feedback, or simply browsing through the wealth of knowledge shared by others, we collect and utilise data to facilitate these interactions and enhance your experience.

Here are the types of Personal Data we may collect, use, or store include:

• Identity Data: Includes your name, professional title, organisation, affiliations, interests, nationality, country of residence, and other relevant demographics.
• Contact Data: Email addresses, billing addresses, and phone numbers to facilitate communication.
• Technical Data: Digital identifiers like IP addresses and browser specifications that relate to the devices and the technologies you use to interact with our services.
• Usage Data: Data on how you navigate and interact with our services, like page views and search patterns.
• Activity Data: Records of your actions within the platform, such as your reading history and content interactions.
• Marketing and Communications Data: Your preferences regarding Acume’s marketing and general communication preferences.
• Transactional Data: Financial-related information necessary for processing payments and transactions. Any information you provide to facilitate payments is subject to the third-party payment processor’s privacy policy, and we encourage you to review this policy before you provide any information to the payment processor.
• Relationship Data: Interaction records from our CRM, detailing service usage, and the identities of experts, clients, and feedback.
• Performance of Contract Data: Information necessary for the execution of contracts between users, and between users and Acume.

We also collect, use and share Aggregated Data such as statistical or demographic data for the purpose of refining our services. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

There may be instances that we collect some Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation or political opinions) in order to ensure diversity across the platform. We will not collect other forms of Special Categories of Personal Data that we do not need to create a diverse service (we will never need details about trade union membership, information about your sex life, nor any genetic and biometric data). All Special Categories of Personal Data will only be collected if you choose to provide it. We do not collect any information about criminal convictions and offences.

Control Over Publicly Shared Data

Acume places a high value on diversity and representation within our platform. As such, users have the opportunity to share a variety of information publicly, particularly when creating a profile or when being considered as an expert advisor. It is important for users to understand the following:

Public Profile Management

The information displayed publicly on your profile or during the expert advisor selection process is entirely within your control. You can choose what details to include, such as your nationality, professional background, and other Identity Data. Please only include information in your profile that you wish to share publicly, unless that information is explicitly stated that it will not be shared.

Special Categories of Personal Data

Our platform allows for the inclusion of Special Categories of Personal Data within your profile should you decide to provide this information, such as details regarding race or ethnicity. This is to foster an inclusive environment and promote diverse representation. However, we want to emphasise that sharing such sensitive information is completely voluntary and should be considered carefully, as it will be visible to other users and clients.

Expert Visibility

When acting as an expert advisor, any information that elect to include in your professional profile will also be available to potential clients who are seeking an expert. You have the autonomy to decide how much detail to provide and this may influence client engagement.

Informed Sharing

We encourage all users to make informed decisions about the personal details they share publicly. While we provide the means to showcase a diverse range of expert advisors, you retain full autonomy over your personal information on our platform.

We are committed to creating a secure space for all users to share their expertise and seek advice while ensuring respectful and fair representation. If you have any questions about the information on your profile or require assistance in managing your public data, please reach out to our support team.

Our Obligation to Collect Personal Data

Acume may be legally required to collect personal data as part of our contractual duties to you or in compliance with laws. If you are unable to provide the requested data, it might affect our ability to deliver on our contractual promises. In such cases, we reserve the right to suspend or cancel services provided to you, according to our terms and conditions. We commit to promptly informing you should such a situation arise. Be assured that our compliance with any legal demands for data collection is rigorously reviewed internally to ensure alignment with our commitment to human rights and the principles we steadfastly uphold.

Our Obligation to Share Personal Data

At Acume, we rigorously uphold the principles of human rights throughout our operations. We are committed to protecting the privacy and safety of our users, which includes individuals, NGOs, and organisations worldwide, with particular vigilance for those who advocate for freedom and human rights or reside in regions facing socio-political complexities.

When handling data requests from government entities and law enforcement officials, we engage in a robust internal review process. This process involves a meticulous evaluation of the human rights implications of each request, ensuring that our response aligns with international standards and the ethos of human rights.

For our partners and users in regions known for human rights challenges or those who face unfair persecution, including activists, NGOs, and civil society organisations, we will prioritise the safety and rights of our users. When necessary, we will refuse requests that could jeopardise their security. Our policy is to be transparent about the nature and frequency of such data requests, notifying affected users when legally permissible and possible to do so.

Our approach is not one of non-cooperation with legal authorities but one of principled evaluation, ensuring that every compliance decision we make upholds our users’ rights and freedoms and reflects our dedication to human rights advocacy.

Data Collection

We use different methods to collect data from and about you including through:

Direct Interactions

You actively engage with us when you:

• Apply for our services.
• Create an account or use our platform.
• Book a consultation.
• Subscribe to our services or publications.
• Request marketing materials.
• Provide feedback or communicate with us through various channels including phone, email, or in-person interactions.
• When you engage with us on social media or other platforms or events.

Through these interactions, you may provide us with Identity and Contact Data, such as your name, email address, phone number, professional details, and other personal identifiers.

Automated Technologies

As you navigate our website and services, we automatically collect certain types of Technical Data, including:

• Your device’s IP address.
• Browser type and version.
• Browsing actions and patterns on our site.

We gather this information using cookies, server logs, and other similar technologies to understand how you use our platform and to enhance user experience.

Third Parties and Publicly Available Sources

We may receive Personal Data about you from:

• Analytics Providers: Services such as Google, potentially based outside of the UK, may supply us with insights regarding user engagement and site interaction.
• Public Data Sources: This encompasses a range of publicly accessible resources, including social media platforms, academic publications, professional databases, and other online and offline presences where individual data is available.
• Collaborative Partners: We gather relevant information through our collaborations with various organisations, which may include educational institutions, governmental bodies, NGOs, marketing affiliates, and media outlets.
• Social Media and Online Searches: Interactions on social media and information gleaned from web searches contribute to the data we collect, helping us to understand and respond to user trends and preferences.

We may also derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your location based on your IP address or infer reading preferences based on your reading history.

In every instance, the collection and use of data from third parties are conducted with strict adherence to our Privacy Policy and applicable data protection laws.

Data Usage

We process your personal data responsibly and ethically, in alignment with both legal requirements and our commitment to upholding human rights, and will only use your data to perform essential business operations.

Most commonly, we will use your personal data in the following circumstances:

Performance of Contract

We process personal data to fulfil our contractual obligations to you. This includes:

• Registering and managing your account.
• Delivering the services you are using or have requested, which includes but not limited to: publishing and distributing user-generated content, personalising the posts you see and delivering expert services
• Providing customer support and responding to your inquiries.

Legitimate Interests

We use personal data for our legitimate business interests, which include:

• Improving and maintaining our services, including fixing any bugs or errors in our Services, while personalising your experience.
• Analysing how our services are used to continuously enhance performance.

• Monitor and analyse trends, usage, and activities in connection with our Services.
• Delivering relevant recommendations based on what we predict you may want or need, or what may be of interest to you.

Compliance with Legal Obligations

We may process personal data to comply with our legal obligations, including:

• Ensuring network and information security.
• Preventing fraud or illegal activities.
• Maintaining records of consents and managing opt-out preferences.

Providing Marketing and Communications

You will receive marketing communications from us if you have requested information from us or requested services from us and you have not opted out of receiving that marketing.

We use personal data to deliver marketing, which include:

• Communicating with you about updates, new content, and services that might interest you.
• Managing subscriber records and promptly honour opt-out requests.
• Tailor marketing communications to align with your interests and interactions with our services.
• Evaluate the performance of our communications based on user engagement and feedback.

We do not share your details with third-party organisations for the purpose of marketing. 

Opting Out 

You have full control over your marketing preferences and can opt out of communications at any time by clicking the unsubscribe link in the footer or by contacting us. If you opt out, we may still send you administrative emails, such as a confirmation of your communication preferences and emails regarding ongoing business relations.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service experience. 

Cookies

The Website and Services use “cookies” to help personalise your online experience and helps us to improve our services. A cookie is a text data file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. They help us to see which areas and features of our Services are popular, and count visits. 

We also work with third party analytics providers who use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, and links clicked. This information may be used by Acume to, among other things, collect, analyse and track data, to determine the popularity of certain content, deliver content targeted to your interests, and better understand your online activity. 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Alternative Purpose

Where it is necessary to carry out any other purpose described to you at the time the information was collected.

With Your Consent

When we have your consent to do so (for example, when you opt in to receive non-administrative communications from us).

When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time. We will only send out marketing communications via email or text with your full consent, and you retain the right to withdraw consent to marketing at any time by contacting us.

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data Disclosure

We share personal information in the following circumstances or as otherwise described in this policy:

With your consent

We may share personal information with your consent or at your direction.

Internally

• Team: Personal information is shared only on a ‘need-to-know’ basis across team members to facilitate efficient service delivery and operational management. Access to personal data within our team is limited to those who require it to perform their job duties effectively. This includes, but is not limited to, providing support to our users, managing our expert network, and improving our services.

External Third Parties

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

• Partners: Personal information may be shared among our partners, affiliates, and subsidiaries. This includes companies under Acume’s current or future control and ownership.

• Other Users: For example, if you use our Services to publish content, post comments or send private notes, certain information about you will be visible to others, such as your name, photo, email, bio, other account information you may provide, and information about your activities on our Services (e.g., your interests, followers and who you follow, recent posts, and comments).
• Service Providers, Vendors and Consultants: only when they need access to personal information in order to perform services for us, such as companies that assist us with web hosting, storage, and other infrastructure, analytics, payment processing, fraud prevention and security, customer service, communications, and marketing. These third parties are prohibited from using your Personal Information except for the designated purpose, and they are required to maintain the confidentiality of your information. We do not authorise them to use or disclose Personal Information for their own marketing or other purposes. We do not share Personal Information with unaffiliated third parties.
• Legal and Professional Advisors: We might share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
• If a change happens to our business: Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses, be acquired, or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We also share aggregated or de-identified information that cannot reasonably be used to identify you.

In accordance with the law

• Law Enforcement and Legal Disclosures: We may be required to share personal information with law enforcement, judges, and courts when legally mandated. Such disclosures will be conducted in strict compliance with the law and after a comprehensive internal review to ensure the request is legitimate and proportionate.
• Judicial and Administrative Processes: If we are to disclose your personal information in response to judicial or administrative processes, we aim to provide you with prior notice, when permissible, to allow you the opportunity to legally challenge such requests.
• Protecting Rights and Legal Compliance: We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Acume, our users, the public, or others.

International Transfers

We recognise that our users come from all over the globe, and accordingly, personal data may be processed outside the country where you reside. This means we may transfer data to countries with different data protection laws. Our commitment to protecting your information does not change, no matter where it is processed.

When we transfer and store your data internationally, we ensure it is protected by applying safeguards:

Adequate Protection: We only transfer personal data to countries recognised by the UK and the EU as providing adequate protection or where we can be certain that equivalent levels of data protection are in place.

Standard Contractual Clauses: For countries without such recognition, we rely on agreements that use standard contractual clauses approved by the European Commission or other relevant authorities to ensure your data is still treated with the utmost care.

Your Rights Regarding International Transfers:

• Transparency: You have the right to be informed about the safeguards in place for data transfers to any country outside the European Union or to international organisations like the UN.
• Inquiries: Should you wish to understand more about these international data transfers and the specific mechanisms we use, please reach out to us using the contact details provided in our Privacy Policy.

By engaging with our Services, you acknowledge and consent to these transfers, recognising that while the data protection laws may vary from your country, your personal information will be handled with respect and safeguarded accordingly

Data Security and Integrity

At Acume, safeguarding your personal data is of paramount importance. We employ robust security measures designed to prevent your personal data from being lost, misused, accessed without authorisation, disclosed, altered, or destroyed.

• Access Control: Access to your personal data is strictly limited to personnel and third parties who need the information to perform their job responsibilities. They are contractually bound to confidentiality and may only process your personal data on our explicit instructions.
• Technical Safeguards: We continuously improve security technologies and protocols to ensure the integrity of our systems.
• Vigilance: Despite these measures, the inherent nature of the internet means that absolute security cannot be guaranteed. We are vigilant to the reality of data transmission risks and are prepared to apply immediate corrective actions where needed.

Response to Breaches

• Incident Response: Should there be any indication of a data breach, we will act swiftly in accordance with our established incident response protocols.
• Notification: You will be promptly informed of any suspected breach that could impact your personal data, along with details of the action we have taken in response.
• Regulatory Communication: We will also communicate any breaches to the relevant regulatory bodies in compliance with legal requirements.

Communication in Case of a Breach

• Transparency: In the unfortunate event of a data breach, we will provide clear communication through our website and direct email notifications to affected individuals.
• Support: Our team will be on hand to guide you through any necessary steps you may need to take to further protect your data.

By using our services, you recognise the efforts we make to protect your data and understand the limitations of data security on the internet. We are committed to continuous improvement in our security protocols and to providing transparent communication about any security incidents.

Data Retention and Your Rights

Retention Period

At Acume, we retain your personal data only for as long as necessary to fulfill the specific purposes for which it was collected, as well as to comply with our legal and regulatory obligations. Retention periods vary depending on the type of data and the reasons for which it is processed.

Criteria for Retention

The criteria used to determine data retention include:

• Service Provision: Data is kept as necessary to deliver our services efficiently.
• Legal Compliance: We adhere to legal and regulatory requirements concerning data retention.
• Dispute Resolution: We may retain data if it is necessary for resolving disputes or addressing complaints.

Data Anonymisation

We anonymise your data when it is no longer needed for direct association with you, which may then be used for research or statistical analysis indefinitely.

Your Rights

You have specific rights regarding your personal data, which include:

• Access, Correction, and Erasure: You can request access to, correction of, or erasure of your personal data.
• Processing Objections and Restrictions: You can object to processing or request a restriction on processing your personal data.
• Data Portability: You may ask for a copy of your personal data in a portable format.
• Consent Withdrawal: You can withdraw consent at any time, impacting your ability to use our services.

Please Note: Withdrawing consent or objecting to the processing of your personal data may affect your ability to access and use our services since processing is necessary to deliver the services you have requested.

Exercising Your Rights

To exercise any of these rights, please reach out to us at admin@acume.org. We aim to respond to all legitimate requests within one month and will do so without any undue delay.

No Fee for Rights Access

Accessing your personal data is generally free, but we reserve the right to charge a reasonable fee or refuse requests that are clearly unfounded or excessive.

What We May Need from You

To confirm your identity and ensure your right to access your personal data or exercise your other rights, we may require specific information from you. This is a crucial security measure to prevent unauthorised disclosure of personal data.

Time Limit to Respond

Our goal is to address all legitimate requests within one month. If your request is particularly complex or you’ve made multiple requests, it may take us longer. If so, we will inform you and keep you updated on the progress.

Questions or Complaints

Your satisfaction is our priority. If you have any concerns about how we handle personal data, please reach out to us first. We aim to resolve any issues directly, but you have the right to lodge a complaint with your Data Protection Authority at any time.

Data Protection Authority Contacts

•           For the UK: Information Commissioner’s Office (ICO) – Contact ICO

•           For the EEA: European Data Protection Board (EDPB) – Contact EDPB members

•           For Switzerland: Federal Data Protection and Information Commissioner – Contact FDPIC

Contacting Us

For questions about this privacy policy or our practices, contact:

Acume International Ltd.

Email: admin@acume.org

Updates to the Privacy Policy

We regularly review and update our Privacy Policy to reflect changes in our practices and services, as well as compliance with applicable laws. The current version was last updated on 14 December 2023. The revision date at the bottom of the policy document will be will be updated with any future amendment to this policy, and significant changes will be communicated on our website or as a direct notification to you.

This policy was last updated on 14 December 2023.