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ACQUIS BI PRIVACY AND COOKIES POLICY
INTRODUCTION
This Privacy and Cookies Policy (the “Policy”) sets out the basis on which Acquis Business Intelligence (“Acquis BI”, “we”, “us” “our”), a limited liability corporation based at 900 E Hamilton Ave, Campbell CA 95008 USA uses, processes and protects any information that you give while using www.acquisbi.com (the “Website”) which is obtained while requesting information via the Website, attending events which we organize or sponsor, or information which you give to us when we act as data controller in connection with or in the course of services provided (the “Services”).
In this Policy, the term “Personal Data” means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes personal data as described Section 3 (as defined below).
Please read the following carefully. Submitting Personal Data to the Website and/or availing of our Services and/or accepting the terms of this Policy indicates that you have reviewed this Policy and have agreed to be bound by it. You will be required to accept this Policy before submitting Personal Data to the Website. If you do not agree to these terms you must leave our Website immediately and no longer avail of the Services. If you choose to accept this Policy, we will keep a record of your acceptance in this regard.
We will handle your Personal Data in accordance with Data Protection Legislation. “Data Protection Legislation” means the Data Protection Acts 1988 to 2018, the General Data Protection Regulation (EU) 2016/679 (“GDPR”), and any other applicable law or regulation relating to the processing of Personal Data and to privacy (including the E-Privacy Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (“E-Privacy Regulations”), as such legislation shall be supplemented, amended, revised or replaced from time to time.
We are the data controller in respect of the information that we collect through the Website. Our position regarding whether we act as a data processor or data controller in respect of the provision of the Services is set out in our Terms of Business with clients.
2. INFORMATION WE GATHER FROM YOU
We fully respect your right to privacy in relation to your interactions with the Website and our Services and we endeavor to be transparent in our dealings with you as to what information we will collect and how we will use your information. Also, we only collect and use an individual’s information where we are legally entitled to do so.
We may collect Personal Data from you in the course of our business, including through your use of our Website, when you contact or request information from us, when you engage our Services or as a result of your relationship with one or more of our staff and clients. The information that we process includes:
i. Basic information, such as your name (including name prefix or title), the company you work for, your title or position, and your relationship to a person,
ii. Contact information, such as your mail address, email address and phone number(s),
iii. Financial information, such as payment-related information,
iv. Technical information, such as information from your visits to our Website or applications or in relation to materials and communications we send to you electronically,
v. Information you provide to us for the purposes of attending meetings and events, including access and dietary requirements,
vi. Identification and background information provided by you or collected as part of our business acceptance processes,
vii. Personal information provided to us by or on behalf of our clients or generated by us in the course or providing services to them, which may include special categories of data,
viii. Images obtained through film/photographs at events that we organize or sponsor or provide with third parties, or
ix. Any other information relating to you that you may provide to us.
x. Comments, feedback, product reviews, recommendations, and personal profile.
We receive, collect and store any information you enter on our website or provide us in any other way. In addition, we collect the Internet protocol (IP) address used to connect your computer to the Internet; login; e-mail address; password; computer and connection information and purchase history. We may use software tools to measure and collect session information, including page response times, length of visits to certain pages, page interaction information, and methods used to browse away from the page.
If you are aged under 18, please get your parent/guardian’s permission before you provide your Personal Data to us/use the Service.
3. HOW WE OBTAIN AND USE YOUR INFORMATION
We collect information from you as part of our business acceptance processes, and about you and others as necessary in the course of providing our Services. We collect your personal information while monitoring our technology tools and services, including our Website which is hosted in the USA and email communications sent to and from Acquis BI. We gather information about you when you provide it to us, or interact with us directly. We may collect or receive information about you from other sources, such as keeping the contact details we already hold for you accurate and up to date using publicly available sources.
Information provided to us as data processors via our SaaS product Services are covered by a separate privacy policy specific to our role as data processors and not as data controllers. Data delivered by clients and their users in those products are hosted within the legally required geographic jurisdiction. Data delivered to us via our USA website and other sources as hosted with the service providers of those services.
We use that information:
i. To provide and improve this Website, including auditing and monitoring its use,
ii. To provide and improve our Services to you and to our clients, including handling the personal information of others on behalf of our clients,
iii. To provide information requested by you,
iv. To promote our Services, including print and online publications, and sending business updates and details of events,
v. To manage and administer our relationship with you and our clients,
vi. To fulfil our legal, regulatory and risk management obligations, including establishing, exercising or defending legal claims, or
vii. For the purposes of recruitment.
4. ON WHAT BASIS WE USE YOUR INFORMATION
We may use your Personal Data on the following bases: (i) to perform a contract, such as engaging with an individual to provide services; (ii) for the establishment, exercise and provision of requested information or communications including newsletters; (iii) to comply with legal and regulatory obligations; or (iv) for legitimate business purposes. Please see ‘How We Obtain And Use Your Information’ above for more detail.
5. HOW LONG WE KEEP YOUR INFORMATION
Your Personal Data will be retained in accordance with our data retention policy which categorises all of the information held by us and specifies the appropriate retention period for each category of data. Those periods are based on the requirements of Data Protection Legislation and the purpose for which the information is collected and used, taking into account legal and regulatory requirements to retain the information for a minimum period, limitation periods for taking legal action, good practice and Acquis BI’s business purposes.
6. COOKIES
A cookie is a small text file that is placed on your device or your computer to distinguish you from other users of our website. Cookies may remember your actions or preferences over a length of time or provide you with a better experience as you browse our Website which also allows us to improve the Website. They also help us to improve our Service and to deliver many of the functions that make your browser experience more user-friendly.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following, to the extent permitted by law: Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
We collect such Non-personal and Personal Information for the following purposes:
1. To provide and operate the Services;
2. To provide our Users with ongoing customer assistance and technical support;
3. To be able to contact Visitors and Users with general or personalized service-related notices and promotional messages;
4. To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
5. To comply with any applicable laws and regulations.
We use the following types of cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical or performance cookies. These allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily and to see how effective and relevant advertising on our Website is.
E-marketing Cookies
Where you receive a marketing email, event invitation or other direct mailing from us, we may collect information about you in the following ways:
• View as web page: If you click on the “view it as a web page” link, a session cookie is recorded by us so that the web page is personalized in the same way as the email.
• Links to web pages: If you click on any web link, we will record a session cookie and will automatically log such activity on our database.
• Unsubscribe: If you click unsubscribe, we will automatically log this information on our database. If you unsubscribe from any email invitation or alert, we will continue to store your personal data on a ‘marketing suppression list’ so as to record your preference.
• Event RSVP buttons: In our event invitations and confirmations, we provide buttons to allow you to accept, decline, cancel and register (if you are not the original recipient of the email) for that event. Clicking on these buttons will generate session cookies and your choice will be recorded in our database to help us manage the event.
Third-party cookies
Please note that a number of third parties may also use cookies, over which we have no control. We may use third parties such as Google Analytics to collect user information, including through the use of cookies and web beacons. They help us to improve our Website and to deliver many of the functions that make your browser experience more user-friendly.
You should also be aware that there are cookies which are found in other companies' internet tools which we may use to enhance the Website. You may see ‘social buttons’ during your use of the Service, including but not limited to Twitter, Facebook and LinkedIn, which enable you to share or bookmark certain web pages. These websites have their own cookies, which are controlled by them.
To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
You can find a list of third party cookies we use and the purposes for which we use them in the table below.
Cookie Purpose
Google Analytics_ga Used to distinguish users
Google Analytics_gid Used to distinguish users
Google Analytics_gat Used to distinguish users
7. ARE THERE CASES WHERE WE MAY USE YOUR INFORMATION TO CONTACT YOU?
We may contact you:
• for the reasons outlined in Sections 2 and 3 above;
• for administration reasons related to the Website (e.g. to provide you with password reminders or to notify you that a particular service, activity/content has been suspended for maintenance, or in response to a question that you ask us);
• to provide you with information about our services, activities or online content, including sending e-newsletters or similar correspondence and updates corresponding to any contact you have made with us, e.g. on our Website, by email or via the ‘How To Contact Us’ facility referred to below. You will be given the opportunity to ‘unsubscribe’ from electronic communications on every electronic communication that we send to you;
• to invite you to participate in surveys about our services (participation is always voluntary).
• We may contact you to notify you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect fees or monies owed, to poll your opinions through surveys or questionnaires, to send updates about our company, or as otherwise necessary to contact you to enforce our User Agreement, applicable national laws, and any agreement we may have with you.
For these purposes we may contact you via email, telephone, text messages, and postal mail.
Where we wish to use your Personal Data in any other way, we will ensure that we notify you and get your consent first. You will be given the opportunity to withhold or withdraw your consent for the use of your Personal Data for purposes other than those listed in this Policy.
8. WHAT RIGHTS DO YOU HAVE?
As a data subject, derived from The Website, you have the following rights under Data Protection Legislation and we, when acting as data controller in respect of Your Personal Data, will comply with such rights:
• the right to receive a copy of your Personal Data relating to you;
• the right to correct any mistakes in your Personal Data;
• the right to ask us to stop contacting you with direct marketing;
• rights in relation to automated decision taking;
• the right to restrict or prevent your Personal Data being processed;
• the right to erasure; and
• the right to complain to the DPA if you believe we have not handled your Personal Data in accordance with Data Protection Legislation.
To the extent that you are the data controller in respect of Personal Data which you provide to us to process as data processor, you will be responsible for complying with the Terms and Conditions and privacy policies of our products as stated in each product.
Right of access to Personal Data relating to you
You may ask to see what Personal Data we hold about you and be provided with such of the following information as you may request:
• a summary of such Personal Data and the categories of Personal Data held (see ‘Information We Gather from You’ above);
• details of the purpose for which it is being or is to be processed (see ‘How We Obtain and Use Your Information’ above);
• details of the recipients or classes of recipients to whom it is or may be disclosed, including if they are overseas and what protections are used for those oversea transfers (see ‘Who We Share Your Information With’ below);
• details of the period for which it is held or the criteria we use to determine how long it is held (see ‘How Long We Keep Your Information’ above);
• details of your rights, including the rights to rectification, erasure, restriction or objection to the processing (set out in this Section 8);
• any information available about the source of that data (see ‘Information We Gather From You’ above);
• where your Personal Data are transferred out of the EEA, what safeguards are in place (see ‘Who We Share Your Information With’ below).
Requests for your Personal Data must be made to us (see ‘How To Contact Us’ below) specifying what Personal Data you need access to, and a copy of such request may be kept by us for our legitimate purposes in managing our services. To help us find the information easily, please give us as much information as possible about the type of information you would like to see. If, to comply with your request, we would have to disclose information relating to or identifying another person, we may need to obtain the consent of that person, if possible. If we cannot obtain consent, we may need to withhold that information or edit the data to remove the identity of that person, if possible.
There are certain types of data which we are not obliged to disclose to you, which include Personal Data which records our intentions in relation to any negotiations with you where disclosure would be likely to prejudice those negotiations. We are also entitled to refuse a data access request from you where (i) such request is manifestly unfounded or excessive, in particular because of its repetitive character (in this case, if we decide to provide you with the Personal Data requested, we may charge you a reasonable fee to account for administrative costs of doing so), or (ii) we are entitled to do so pursuant to Data Protection Legislation.
Right to update your Personal Data or correct any mistakes in your Personal Data
You can require us to correct any mistakes in your Personal Data which we hold free of charge. If you would like to do this, please:
• email or write to us (see ‘How To Contact Us’ below);
• let us have enough information to identify you (e.g. name, registration details); and
• let us know the information that is incorrect and what it should be replaced with.
If we are required to update your Personal Data, we will inform recipients to whom that Personal Data have been disclosed (if any), unless this proves impossible or has a disproportionate effort. It is your responsibility that all of the Personal Data provided to us is accurate and complete. If any information you have given us changes, please let us know as soon as possible (see ‘How To Contact Us’ below).
Rights in relation to automated decision taking (if applicable) You may ask us to ensure that, if we are evaluating you, we don’t base any decisions solely on an automated process and have any decision reviewed by a member of staff. Profiling may occur in relation to your Personal Data for the purposes of targeted advertising and de-targeting you from specified advertising. This allows us to tailor our advertising to the appropriate customers and helps to minimise the risk of you receiving unwanted advertising. These rights will not apply in all circumstances, for example where the decision is (i) authorised or required by law, (ii) necessary for the performance of a contract between you and us, or (ii) is based on your explicit consent. In all cases, we will endeavour that steps have been taken to safeguard your interests.
Right to data portability In accordance with Data Protection Legislation, you may ask for an electronic copy of your Personal Data that you have provided to us and which we hold electronically, or for us to provide this directly to another party. This right only applies to Personal Data that you have provided to us – it does not extend to data generated by us. In addition, the right to data portability also only applies where:
• the processing is based on your consent or for the performance of a contract; and
• the processing is carried out by automated means.
Right to erasure
In accordance with Data Protection Legislation, you can ask us (please see ‘How To Contact Us’ below) to erase your Personal Data where:
• you do not believe that we need your Personal Data in order to process it for the purposes set out in this Policy;
• if you had given us consent to process your Personal Data, you withdraw that consent and we cannot otherwise legally process your Personal Data;
• you object to our processing, and we do not have any legal basis for continuing to process your Personal Data;
• your Personal Data has been processed unlawfully or have not been erased when it should have been; or
• the Personal Data must be erased to comply with law.
We may continue to process your Personal Data in certain circumstances in accordance with Data Protection Legislation (i.e. where we have a legal justification to continue to hold such Personal Data, such as it being within our legitimate business interest).Where you have requested the erasure of your Personal Data, we will inform recipients to whom that Personal Data have been disclosed, unless this proves impossible or involves disproportionate effort. We will also inform you about those recipients if you request it.
Right to complain to the DPC
If you do not think that we have processed your Personal Data in accordance with this Policy, please contact us in the first instance. If you are not satisfied, you can complain to the DPC or exercise any of your other rights pursuant to Data Protection Legislation. Information about how to do this is available on the DPC website at https://www.dataprotection.ie
9. WITHDRAWAL OF CONSENT
If you no longer consent to our processing of Your Personal Data (in respect of any matter referred to in this Policy as requiring your consent), you may request that we cease such processing by contacting us via the ‘How To Contact Us’ facility referred to below. Please note that if you withdraw your consent to such processing, it may not be possible for us to provide all/part of the Service to you.
10. WHO WE SHARE YOUR INFORMATION WITH
We will not share your Personal Data without your consent or unless required by law (except as set out in this Policy).We restrict access to personal information to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Services and the Website. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, civil litigation and/or criminal prosecution, if they fail to meet these obligations.
Your Personal Data may be transferred to, stored at, or accessed from a destination outside the European Economic Area (“EEA”) for the purposes of us providing the Services or operating the Website. It may also be processed by staff operating outside the EEA who work for us or any of our suppliers. By submitting your Personal Data to us, you explicitly consent to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Policy. The safeguards in place with regard to the transfer of your Personal Data outside of the EEA are the entry by us into appropriate contracts with all transferees of such data.
11. THIRD PARTY WEBSITES
This Policy applies to the Websites and related Services that are owned and provided by AcquisBI. We do not exercise control over the sites/applications that may be linked from our website.
These other sites/applications may place their own cookies or other files on your computer, collect data or solicit personal information from you. You acknowledge that the Services that we provide may enable or assist you to access the website content of, correspond with, and purchase products and services from, third parties via third-party websites and that you do so solely at your own risk. We make no representation or commitment and shall have no liability or obligation whatsoever in relation to the content or use of, or correspondence with, any such third-party website, or any transactions completed, and any contract entered into by you, with any such third party and the use by any such third-party of your Personal Data. We do not endorse or approve any third-party website nor the content of any of the third-party website made available via the Services. We encourage you to carefully familiarize yourself with the terms of use and privacy policies applicable to any websites and/or services operated by third parties. Please be aware that we are not responsible for the privacy practices of any third parties.
Our company is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to sell our products and services to you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.
All direct payment gateways offered by Wix.com and used by our company adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit card information by our store and its service providers.
12. HOW DO WE PROTECT YOUR PERSONAL INFORMATION?
We do our utmost to protect user privacy through the appropriate use of security technology. We restrict access to your Personal Data to employees, contractors and agents who need to know such Your Personal Data in order to operate, develop or improve the Services that we provide and the Website. We ensure that we have appropriate physical and technological security measures to protect your information; and we ensure that when we outsource any processes that the service provider has appropriate security measures in place. However, the Website may contain hyperlinks to websites owned and operated by third parties. These third-party websites have their own privacy policies, including cookies. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.
We will implement appropriate technical and organizational measures to ensure a level of security appropriate to the risks that are presented by the processing of your Personal Data. We will consider the risks presented by accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your Personal Data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of any data transmitted us and any such transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. To the extent permitted by law, we are not responsible for any delays, delivery failures, or any other loss or damage resulting from (i) the transfer of data over communications networks and facilities, including the internet, or (ii) any delay or delivery failure on the part of any other service provider not contracted by us, and you acknowledge that the Website may be subject to limitations, delays and other problems inherent in the use of such communications facilities.
You will appreciate that we cannot guarantee the absolute prevention of cyber-attacks such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your Personal Data arising from such risks.
13. BREACH REPORTING
To the extent that we are data controller in respect of your Personal Data, we will notify serious data breaches in respect of your Personal Data to the DPC without undue delay, and where feasible, not later than 72 hours after having become aware of same. If notification is not made after 72 hours, we will record a reasoned justification for the delay; however, it is not necessary to notify the DPC where the Personal Data breach is unlikely to result in a risk to the rights and freedoms of natural persons. A Personal Data breach in this context means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed.
We will keep a record of any data breaches, including their effects and the remedial action taken, and will notify you of any data breach affecting your Personal Data (which poses a high risk to you) when we are required to do so under Data Protection Legislation. We will not be required to notify you of a data breach where:
• we have implemented appropriate technical and organizational measures that render the Personal Data unintelligible to anyone not authorized to access it, such as encryption; or
• we have taken subsequent measures which ensure that the high risk to data subjects is not likely to materialise; or
• it would involve disproportionate effort, in which case we may make a public communication instead.
In the event of a Personal Data breach where we are the data processor, we will notify the relevant data controller of such breach as soon as reasonably practicable.
14. AMENDMENTS TO THIS POLICY
We may change this Policy from time to time and at our sole discretion. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use the Services to submit your Personal Data through the Website. If material changes are made to the Policy, we will notify you by placing a prominent notice on our Website or by sending you a notification in relation to this. We will not process your Personal Data in a manner not contemplated by this Policy without your consent.
15. HOW TO CONTACT US
If you need to contact us with regard to any of your rights as set out in this Policy, all such requests should be made in writing to the Data Protection Officer, Acquis BI 900 E Hamilton Ave. Suite 100, Campbell CA, 95008 USA, or by email to dpo@acquisbi.com