Privacy Policy 

Acume respects your privacy and is committed to protecting your personal data. This privacy policy will inform you on how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Important Information

Purpose of this Privacy Policy 

This Privacy Policy aims to give you information on how Acume International Ltd. (“Acume”, “we”, “our” or “us”) collects, uses, protects and discloses your personal data through your use of this website, online products and other services that link to us (collectively, “Services”), and all interaction including contact with our teams and engaging with us on social media.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

By accessing and using the Website and Services, you acknowledge that you agree to the terms of this agreement and agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorised to access or use the Website and Services.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 4/01/22. 

It is possible we may change this policy from time to time. But if we do make changes, then we will revise the date at the top of this policy, and, if significant changes are made, we may provide you with additional notice (such as adding a statement to our website or providing you with a notification).

It is your responsibility to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

The Data We Collect About You 

Personal Data, or Personal Information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer information you willingly provide to us. For example, you may share information directly with us when you create an account, fill out a form, give feedback, submit or post content through our Services, or communicate with us via third-party platforms, request customer support, or otherwise communicate with us. 

The types of personal information we may collect include:

  • Identity Data, which include first name, maiden name, last name, job title, organisation information, interests, nationality, country of residence, and any other information you choose to provide.
  • Contact Data, which include email address and telephone numbers.
  • Profile Data, which includes your username, password, your interests, your content including summaries, comments and responses, your preferences, feedback and survey responses.
  • Technical Data, which internet protocol (IP) address, your login data, browser type and version, time zone setting and location, language preference, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Usage Data, which includes information on how you use our website, products and services, such as access times, pages viewed, time spent viewing pages, links clicked, and information you search for while on the website, and some other statistics.
  • Activity Data, which includes your reading history and when you share links, and like posts.
  • Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  •  

We do not collect payment information or transaction data through our Services. In the future, we will rely on third parties to process payments in connection with our Services. Any information you provide to facilitate such a payment 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.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. 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 (this includes details details about trade union membership, information about your health, sex life, and 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.

If you fail to provide personal data 

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How Is Your Personal Data Collected

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

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you :

  • apply for our services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

  • (a) analytics providers, such as Google based outside the UK; and
  • (b) search information providers, inside or outside the UK, such as Identity and Contact Data from publicly available sources, such as Companies House based inside the UK; and 
  • (c) we may collect information about you from social media networks, university websites, public databases and  marketing partners.

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.

How We Use Your Personal Data 

We will only use and process your personal data when the law allows us to. 

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

Performance of Contract. Where we need to perform the contract we are about to enter into or have entered into with you, including:

  • Register you as a user, including creating your user account;
  • Providing support or assistance to you and responding to your queries;
  • Uploading and hosting your academic summary on our Website.

Legitimate Interest. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, including: 

  • To provide, maintain, and improve our Services, which includes publishing and distributing user-generated content, personalising the posts you see and operating our metered paywall;
  • To respond to your comments and questions and provide customer service;
  • To communicate with you about new content, products, services, and features offered by Acume and provide other news and information we think will interest you. See ‘Opting Out’ below for information about how to opt out of these communications at any time);
  • Monitor and analyse trends, usage, and activities in connection with our Services.

Legal Obligation. Where we need to comply with a legal obligation, including:

  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Acume and others;
  • Debug to identify and repair errors in our Services;
  • To maintain a record of your consents and track those who have opted out of non-administrative communications.

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

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

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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services may be relevant for you (we call this marketing).

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.

Opting Out 

You can ask us to stop sending you marketing messages at any time by contacting us. We do not share your details with third-party organisations for the purpose of marketing. 

You may opt out of receiving certain communications from us, such as emails and newsletters by following the instructions in those communications. An unsubscribe link will be in the footer of every marketing email. 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.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Disclosures of Your Personal Data 

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

Internally

  • Personal information is shared between and among Acume and our current and future parents, partners, affiliates, and subsidiaries and other companies under common control and ownership.

External Third Parties:

  • Other users of the Services. 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).
  • We share personal information with vendors, service providers, and consultants that 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.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.

In accordance with the law

  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. 
  • If we are going to disclose your personal information in response to a legal process, we will give you notice so you can challenge it (for example by seeking court intervention), unless we are prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our Services that we believe are improper.
  • 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.

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.

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

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.

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

International Transfers

Depending on your location,  we may transfer and store your personal information in a country other than your own. These jurisdictions may not provide levels of data protection that are equivalent to those of your home jurisdiction. By using the Services or providing personal information to us, you consent to the transfer of your personal information to other countries that may not provide equivalent levels of data protection as your home jurisdiction. However, we will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. 

You can find out more about the specific mechanism used by us when transferring your personal data by inquiring with us using the information provided in the contact section.

Data Security 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Website and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

In the event of any suspected personal data breach, we have put in place procedures to deal with this breach and will notify you and any applicable regulator of a breach where we are legally required to do so. When we notify you, we will post a notice on the Website and send you an email.

Data Retention 

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Legal Rights 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights include the right to:

  • Request access to your personal data and receive your data in a portable format (including a structured, machine-readable and commonly used format);
  • Request correction of your personal data;
  • Request erasure of your personal data;
  • Object to processing of your personal data;
  • Request restriction of processing your personal data;
  • Request transfer of your personal data;
  • Right to withdraw consent through contacting us.

If you wish to exercise any of the rights set out above, please contact us at admin@acume.org

Accessing personal Data

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond 

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Questions or Complaints 

You have the right to make a complaint at any time. We would, however, appreciate the chance to deal with your concerns before you approach the appropriate Data Protection Authority, so please contact us in the first instance.

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. 

Contact details for your Data Protection Authority can be found using the links below:

For individuals in the UK: Information Commissioner’s Office (ICO), the UK regulator for data protection issues

https://ico.org.uk/global/contact-us/

For individuals in the EEA: European Data Protection Board (EDPD), representatives of the EU national data protection authorities, and the European Data Protection Supervisor (EDPS) https://edpb.europa.eu/about-edpb/board/members_en

For individuals in Switzerland: Federal Data Protection and Information Commissioner https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

Contact Us 

If you have any questions about this privacy policy or our privacy practices, please contact us in the following way:

Full name of legal entity: Acume International Ltd.

Email address: admin@acume.org

This policy was last updated on  4th January 2022.