Last updated February 29, 2020
Thank you for choosing to be part of our community at ACOLYST (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. We recognize the importance of protecting the personal information of any visitor to www.acolyst.com, sites that operate on a related sub-domain, or sites identified as being owned and operated by Acolyst (“Acolyst websites”). This Privacy Statement (or “Statement”) applies only to Acolyst’s online activities and is valid for visitors to Acolyst website with regards to the information that is shared and/or collected. This policy is not applicable to any information collected offline or via channels other than this website. We commit to processing your Personal Information responsibly and in compliance with applicable data protection/privacy laws in the countries where we operate and conduct business.
If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at firstname.lastname@example.org
TABLE OF CONTENTS
- WHAT INFORMATION DO WE COLLECT?
- HOW DO WE USE YOUR INFORMATION?
- WILL YOUR INFORMATION BE SHARED WITH ANYONE?
- HOW LONG DO WE KEEP YOUR INFORMATION?
- DO WE COLLECT INFORMATION FROM MINORS?
- WHAT ARE YOUR PRIVACY RIGHTS?
- CONTROLS FOR DO-NOT-TRACK FEATURES
- DO USA STATE RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
- DO WE MAKE UPDATES TO THIS POLICY?
- HOW CAN YOU CONTACT US ABOUT THIS POLICY?
- HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information (if applicable).
We collect personal information that you voluntarily provide to us when expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise contacting us.
The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Publicly Available Personal Information. We collect first name, maiden name, last name, and nickname; email addresses; phone numbers; and other similar data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Consent to Data Transfer: While Acolyst has active businesses in many countries around the globe, we are headquartered in the United States. Thus, if you proceed to use this site, your Personal Information may be transferred to or accessible by entities or individuals in the United States and processed according to the terms described in this Privacy Statement.
Personal Information collected by Acolyst may be stored and processed in the United States and/or in any other country where Acolyst or its affiliates, subsidiaries, or service providers operate facilities. Typically, the primary storage location is in the United States or a customer’s region (which may also be the United States), often with a backup to a data center in a different region. Storage location(s) are chosen in order to operate efficiently, improve performance, and create redundancies to protect the data in the event of an outage or other problem.
We (or our service providers) may transfer Personal Information from the EEA to other countries, some of which have not yet been determined by the European Commission to have an adequate level of data protection. For example, those countries’ laws may not guarantee you the same rights, or there may not be a government authority capable of addressing your concerns. When we engage in such transfers, we use a variety of legal mechanisms, including contracts and written assurances from service providers, to help ensure your rights and protections travel with your Personal Information. To learn more about the European Commission’s decisions on the adequacy of the personal data protection in the countries where Acolyst operates (such as the United States), please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
By continuing to use this site, you authorize Acolyst and its service providers to transfer your Personal Information to – or make it available in – destinations outside your home country and to process it according to this Privacy Statement.
What Types of Personal Information Are Collected via Acolyst Websites?
For the purposes of this Privacy Statement, “Personal Information” generally means data, or a combination of data from one or more sources, that identifies or could reasonably be used to identify an individual.
When you visit a Acolyst website, the Personal Information collected about you may include, but is not limited to:
- postal address;
- e-mail address;
- organization name and job title;
- telephone number;
- IP address;
- network and geo-location; and
- education and/or employment history.
If you cannot or choose not to provide us with this Personal Information, we may be unable to provide you with the information or services you have requested.
Why is this Personal Information Collected?
We generally collect the Personal Information described above on an entirely voluntary basis – in other words, we do not require you to give us your Personal Information. Certain areas of Acolyst websites, however, may request your Personal Information so that you can use specific features, learn more about Acolyst or access certain content. For example, you may be asked to submit Personal Information if you:
- request a product demo, download or access information about our products, services or programs;
- watch on-demand content;
- submit a contact form to request customer or technical support;
- access content information;
- apply for a job with Acolyst; or
- ask to have a Acolyst employee contact you.
Non-Personal Information, Analytics, and Advertising
We market our business in a number of ways, primarily through digital advertising, owned social media presences, email marketing campaigns and other offline mechanisms. To understand how our marketing or promotional campaigns are performing, one or more of our third-party service providers may collect certain information via our Acolyst websites. We and these service providers use several industry standard analytics and tracking tools to collect this information, such as web browsers and flash cookies, web beacons and other, similar technologies. The information we collect includes IP addresses, number of page visits, pages viewed, search engine referrals, browsing activities over time and across other websites following your visit to one or more of our Acolyst websites, and responses to offline marketing campaigns through dedicated tracking web addresses.
Note: Although network or device identifiers such as computer or device IP addresses, serial numbers or other identification numbers do not necessarily identify an individual who uses such computers or devices, some jurisdictions’ laws may define them as Personal Information.
We use Non-Personal Information to:
- identify new visitors to Acolyst websites;
- recognize returning visitors;
- analyze the effectiveness of our website content and marketing or sales-related activities;
- better understand our audience, customers, or other website visitors; and
- determine whether website visitors, potential customers and customers might be interested in additional content, new products or services.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.
We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.
We use the information we collect or receive:
To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
Use of Personal Information
Legal Basis for Collecting and Using Personal Information
We collect, use and share Personal Information when we have an appropriate legal basis to do this, such as the following:
- you have consented, for example by signing up to receive communications from us;
- our use of your Personal Information is necessary to meet our legitimate interests as a commercial organization (see examples below);
- our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you, for example if you apply for a job with us or if you work for one of our service providers, partners, prime contractors or subcontractors; and/or
- our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation, for example, in response to an audit, subpoena or court order.
Examples of Acolyst’s legitimate interests:
- operating, maintaining, and improving Acolyst websites, products, services and programs;
- responding to comments and questions, or provide customer service or technical support;
- sending information such as confirmations, invoices, technical notices, software updates, security alerts, and support and administrative messages;
- providing information which may be of interest to website visitors, potential customers and customers, including but not limited to, educational content, fact sheets, webinars, white papers, upcoming vents, and other news about products and services offered by us and our selected partners;
- protecting against, investigating, and deterring fraudulent, unauthorized, or illegal activity;
- to process employment applications (more detail below); and
- protecting Acolyst’s personnel or property.
We may also use what we know about you to highlight products and services that may be of interest to you, or we may combine your online Personal and Non-Personal Information with information collected from offline sources or information we already have.
More About Employment Applications
In general, if you apply for a Acolyst job through any Acolyst or third party website, we use the Personal Information you submitted via the application process to process and respond to your job application, including to assess your skills and interest in job opportunities, conduct reference checks and/or background checks, verify the information you provided, and for compliance with corporate governance and/or legal and regulatory requirements. Personal Information that you submit may also be added to our candidate database for purposes of considering whether you are suitable for other job vacancies. If you are hired, we may also use the information collected during the application process for other business purposes related to your employment.
Sharing Personal and Non-Personal Information
We process and share your Personal Information and Non-Personal Information only to the extent reasonably necessary to fulfill your requests and for our legitimate business purposes, as further described above and in the Authorized Service Providers section below. When we disclose Personal and Non-Personal Information to other entities or individuals to perform support services for us, they may access such information for the limited purposes of performing those support services.
We may disclose Personal and Non-Personal Information to others to:
- respond to questions about our product or services;
- send communications, including email newsletters, or other marketing materials;
- comply with applicable laws, obey judicial orders, respond to subpoenas; cooperate with law enforcement authorities, and respond to law enforcement requests;
- detect or prevent suspected or actual illegal activities or harm to our personnel or property;
- help us run our day-to-day business operations;
- protect the rights or property of others, including our customers; and
- respond to and/ or assist our auditors and legal advisors.
We may also disclose Personal and Non-Personal Information:
- when legally required (e.g., for government reports);
- for other legitimate business purposes, such as product or service development, marketing, sales and website administration; and
- as otherwise permitted or required by law.
Authorized Service Providers
We sometimes hire or contract with other companies and individuals to perform certain functions and services on our behalf. This is a common industry practice. We may need to disclose Personal and Non-Personal Information so that they can perform these functions and services which may include, for example, call center/customer service support, sending or processing postal mail or email, and analyzing or hosting data on cloud-based servers.
Acolyst does not share or sell Personal Information with unaffiliated third parties for their own direct marketing purposes.
Safeguarding your Information
The integrity, availability and confidentiality of your Personal Information matters to us. That is why we use industry-standard and government-approved technical, administrative and physical controls to protect Personal Information from unauthorized access, use and disclosure. We also review and evaluate our security procedures and controls on an ongoing basis to consider appropriate new technology and updated methods and to help minimize risks from new security threats as they become known.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data about how you interact with the Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Third-Party Advertisers. We may use third-party advertising companies to serve ads when you visit the Services. These companies may use information about your visits to our Website(s) and other websites that are contained in web cookies and other tracking technologies in order to provide advertisements about goods and services of interest to you.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/
5. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
6. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
Acolyst websites are not directed to nor intended for use by minors. We do not knowingly collect any Personal Information or knowingly track the use of Acolyst websites by children under the age of 18.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at email@example.com
7. WHAT ARE YOUR PRIVACY RIGHTS?
Application of Local Laws
This Privacy Statement is designed to comply with relevant applicable laws in the United States, United Kingdom, European Union, Canada and Australia. If an applicable local data protection or privacy law provides for a lesser level of protection than that established by this Statement, then this Statement shall prevail.
In Short: In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
For UK visitors to Acolyst websites:
If you have concerns about our information rights practices, you may lodge a complaint with the Information Commissioner’s Office (“ICO”). Details of how to contact the ICO are located at ico.org.uk.
For Australian visitors to Acolyst websites:
If we fail to respond to your complaint within a reasonable period of receiving it in writing, or if you are dissatisfied with the response that you receive from us, you may lodge a complaint with the Office of the Australian Information Commissioner (“OAIC”). Details of how to contact the OAIC are located at oaic.gov.au.
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. DO USA STATE RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, for example, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.
10. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.
11. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org or by post to:
12. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here. We will respond to your request within 30 days.
Managing Your Personal Information
Certain data protection/privacy laws may provide you rights with respect to how we manage your Personal Information. These rights (and potential limitations on them) are described below.
Right to Change or Delete Your Personal Information
You have a right to request that we correct or delete inaccurate Personal Information about you. In such cases, we will first verify your identity and then check whether the Personal Information is in fact inaccurate. We will correct any Personal Information found to be incorrect.
You can also request that we delete your Personal Information if, for example,
- it is no longer needed for the purposes for which it was collected;
- you have withdrawn your consent (where the data processing was initially based on consent), and where there is no other legal basis for the processing;
- we are relying on our legitimate interests as the basis for processing your Personal Information, you object to such processing, and there is no overriding legitimate interest to continue processing it;
- we are processing it for direct marketing purposes and you object to that processing; or it has been processed unlawfully.
Please note that this right to deletion is not absolute and only applies in certain circumstances. For example, we are not required to comply with your request if it is necessary for us to maintain your Personal Information:
- for compliance with a legal obligation;
- for the establishment, exercise or defense of legal claims;
- for the performance of a contract;
- to detect, prevent, or otherwise mitigate illegal activities, including but not limited to fraud, computer crimes and identity theft;
- to avoid or mitigate harm to Acolyst personnel or property or to others,
- it is in our legitimate interests and there are compelling legitimate grounds for the processing that override your interests in having your Personal Information deleted; and
- to the extent necessary to comply with applicable laws and regulations, including employment laws and regulations.
Right to Restrict the Processing of Your Personal Information
You can ask us to limit processing of your Personal Information, but only when:
- you dispute its accuracy, to allow us to verify its accuracy;
- the processing is unlawful, but you do not want it erased;
- it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
- you have exercised the right to object, and verification of overriding grounds is pending.
After you submit a request to restrict the processing of your Personal Information, we can continue to process it:
- when we have your consent;
- to establish, exercise or defend legal claims; or
- to protect the rights of another natural or legal person.
Right to Transfer your Personal Information
You can ask us to provide your Personal Information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another entity or company, but only when:
- the processing of your Personal Information is based on your consent or the performance of a contract with you;
- the processing is carried out by automated means; and
- where such transfer or production is technically feasible.
Right to Object to the Processing of your Personal Information
You have the right to object to our processing of your Personal Information if our processing is for direct marketing purposes.
You can also object if the processing is for:
- a task carried out in the public interest;
- the exercise of official authority vested in us; or
- our legitimate interests (or those of a third party).
In these circumstances the right to object is not absolute. You must provide specific reasons why you are objecting to the processing of your Personal Information. These reasons should be based upon your particular situation. And please note that we may still continue processing if:
- we have compelling legitimate grounds for the processing which outweigh your interests, rights and freedoms; or
- the processing is for the establishment, exercise or defense of legal claims.
If we are processing your Personal Information for scientific or historical research, or for statistical purposes, your right to object might also be limited.
Right to Object to the Use of your Personal Information for Direct Marketing purposes
You can request that we change the manner in which we contact you for direct marketing purposes. We will respect your wishes not to receive marketing communications. You can change your marketing preferences by contacting us. You can also opt-out at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we may continue to send you service-related communications regardless of any opt-out request.
Acolyst does not share or sell Personal Information with unaffiliated third parties for their own direct marketing purposes.
Right to Not be Subject to Automated Decision-Making
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
We will retain your Personal Information for as long as required for the purposes for which it was collected. How long we retain it depends on a number of factors, including the legal basis for which it was obtained and/or additional legal or regulatory obligations. Thus, in some circumstances we may store your Personal Information for longer periods of time, for instance where we are required to do so to meet legal, regulatory, tax, or accounting requirements. We may also store it for longer periods of time to have an accurate record of your interactions with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation.
This Privacy Statement applies only to acolyst.com and Acolyst websites that are clearly identified as being owned and operated by us and which link to this Privacy Statement.
You should be aware that hyperlinks on this site may direct you to other websites that we do not control. Acolyst has no control over the privacy policies or practices of these other websites, and is not responsible for the privacy practices or the content of websites to which we link, list, rank or identify by means of a search. Acolyst takes no responsibility for the products, services, policies or actions of third parties or the content of third-party websites. We encourage you to be aware when you are leaving our site and to read the privacy policies of each website you visit.
Queries and Complaints
If you have any questions, have a complaint, or wish to send us comments about this Privacy Statement, please send an e-mail to email@example.com. We will investigate your complaint, and use reasonable efforts to respond as soon as possible.
Right to lodge a complaint with your local supervisory authority
You also have a right to file a complaint with your local supervisory authority if you have concerns about how we are processing your Personal Information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
For purposes of this Statement, “you” refers to any visitor to Acolyst website.
If there is a conflict between this Statement and the terms of any agreement between an Acolyst customer and Acolyst, the terms of such agreement will control.
Accepting this Statement
You acknowledge that you have read this Statement and that you understand and accept it.
Your use of our Acolyst websites and any dispute related to the collection of your Personal Information is subject to this Privacy Statement, any applicable Terms of Service (including any applicable limitations on damages and the resolution of disputes) and any applicable End User License Agreement.