Acquire (“us”, “we” or “our”) is committed to ensure that your privacy is protected. This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“Personal Data”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.
Acquire on behalf of itself and its wholly owned U.S. domiciled entities, has made a decision to voluntarily adhere to the EU-U.S. Privacy Shield Principles recognized by the EEA as providing adequate data protection. Acquire complies with the EU-U.S. Privacy Shield Framework as agreed upon between the U.S. Department of Commerce and the European Commission regarding the collection, use, and retention of personal information from European Union member countries and the United Kingdom. Acquire has certified that it adheres to the EU-U.S. Privacy Shield Privacy Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability of the framework.
Should there be any conflict between the Privacy Shield Principles and this Policy, this Policy shall be interpreted to be consistent with the Privacy Shield Principles.
To learn more about the EU-U.S. Privacy Shield program, please visit https://www.privacyshield.gov/.
1. Personal Data:
Any data relating to an identified or identifiable natural person (‘Data Subject’) such as name, address, email address, phone number, educational background, financial details, educational details, nationality etc.
2. Data Controller:
Controls purpose and means of processing. Direct responsibility to data subject and data protection authority.
3. Data Processor:
Acts on instructions of Data Controller. Direct responsibility to data subject and data protection authority.
4. Data Subject:
Data subject is any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
The processing of personal data in such a way that the data can no longer be attributed to a specific data subject without the use of additional information.
Privacy Shield Principles
Acquire commits to subject to the Privacy Shields’ Principles. All Personal Data received by Acquire in the U.S. from European Union member countries and the United Kingdom in reliance on the respective Privacy Shield framework. A detailed description of the EU-U.S. Privacy Shield Principles can be found on the website of the U.S. Department of Commerce.
Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal Information to Acquire, or as soon as practicable thereafter, and in any event before Acquire uses the information for a purpose other than that for which it was originally collected or discloses it for the first time to a third party.
Data: Collection and Use
We may collect Personal Data that can be used to contact or identify you. This may include:
- Contact information including email address
- Demographic information, such as preferences and interests
- Website usage data
- Other information relevant to client enquiries
- Other information pertaining to special offers and surveys
Data Automatically Collected
1. Log Data:
The Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, and the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
2. Location Information:
To improve and customize our services we may use and store information about your location depending on the permissions you have set on your device.
3. Do Not Track Signals:
At present, we do not respond to Do Not Track (DNT) signals as there are currently no fixed standards for do not track signals. It is facility provided in your web browser to intimate websites that you do not want to be tracked.
Collecting this data helps us understand what you are looking from the company, enabling us to deliver improved products and services. Specifically, we may use data:
- For our own internal records
- To improve products and services we provide
- To contact you in response to specific enquiry
- To customize the website for you
- To send you promotional emails about products, services, offers and other things we think might be relevant to you
- For billing, identification and authentications, and fraud prevention
- To contact you via email, telephone, or mail for market research reasons.
Acquire will offer individuals the opportunity to choose (by either opt-out or opt-in) if their Personal Data is (a) to be disclosed to a third party that is not an Agent, or (b) to be used for a purpose materially different from the purpose for which it was originally collected or subsequently authorized by the individual.
Personal Data: Handling and Retention
At any time, you may review or update Personal Data that we hold about you, by signing in to your account on our website. When we receive any request to access, edit or delete personal data we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Any and every Personal Data we hold about you is stored and processed under General Data Protection Principles and Privacy Shield Principles.
If any information we are holding on you is incorrect or incomplete, please write us to email@example.com as soon as possible.
We preserve and retain your information according to the respective statutory retention period to comply with law and to support a claim or defense in court. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
|Classification||Description||Examples||General Retention Period|
| Personal Data|
|Individuals can be identified from their data or via the data being linked with other information owned by a Data Controller|
|Event Based Data||Visitor Queue, Visitor pending list, Agent Login attempts from IPs, Visitor browser information, browser type, screen size and device details||Upto 30 days in Acquire’s cache|
Personal data about and individual Customer used to enable and enhance their overall experience.
|6 Years or as per customer own Privacy and Data Protection Policy|
You may choose to restrict the collection or use of Personal Data by opting-out of receiving marketing communications from us and our third-party partners by email, telephone, text message or post. Users (Data Subjects) may opt-out any time if they have previously agreed to us of receiving any or all communications from Acquire by contacting us.
Accountability for Onward Transfer
Personal Data: Disclosure, Share and Transfer
We will never sell, distribute or lease your Personal Data to third parties unless you have permitted or as per law requirement.
Acquire may transfer information to others as described in this policy or to satisfy its legal, regulatory, compliance, or auditing requirements, including to disclose information to law enforcement authorities upon validly served legal process or a valid judicial instruction (for example, pursuant to a court order).
Acquire recognizes its responsibility and potential liability for onward transfers to Agents. Where Acquire has knowledge that an Agent is using or disclosing Personal Information in a manner contrary to this Policy and/or the level of protection as required by the EU-U.S. Privacy Shield Principles, Acquire will take reasonable and appropriate steps to prevent, remediate or stop the use or disclosure.
Consent & The Right to be Informed
Acquire ensures the Data Subjects by providing transparent, specified and informed consent in a clear affirmative action (positive opt-in) which signifies agreement to the processing of personal data. We never used pre-ticked or opt-in boxes. Consent is always provided separately for each matters and not be a precondition for any other services. We have ensured that withdrawing consent is as easy, clear and straightforward.
The Right of Access
We have ensured that appropriate measures have been taken to provide information referred to in Articles 13 and 14 of GDPR and any communication under Articles 15 to 22 and 34 (collectively, The Rights of Data Subjects), relating to processing to the data subject in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
The Right To Erasure
Also, known as ‘The Right to be Forgotten’, Acquire complies fully with Article 5(e) of GDPR and ensures that personal data which identifies a data subject, is not kept longer than is necessary for the purposes for which the personal data is processed. All personal data obtained and processed by Acquire is categorized when assessed by the information audit and is either given an erasure date or is monitored so that it can be destroyed when no longer necessary. These measures enable us to comply with a Data Subjects right to erasure, whereby an individual can request the deletion or removal of personal data where there is no compelling reason for its continued processing. Whilst our standard procedures already remove data that is no longer necessary, we still follow a dedicated process for erasure requests.
Right to Automatic Decision Making and Profiling
As a responsible company, we do not use automatic decision-making or profiling.
Cookies and its use
1. Analyze our web traffic using analytics package to improve website structure, design, content and functions.
2. Identify whether you are signed in to our website.
3. Test content on our website.
4. Store information about your preferences.
5. To recognize when you return to our website.
A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can configure your web browser’s cookie settings to enable or disable cookies as per your need. Mostly, the default browser settings automatically allow cookies but, it can be easily modified as per your preferences at your end. However, some pages and services may become unavailable and prevent you to take full advantage of the website.
Links from our sites
Please note that we may have links on our website that redirects you to other websites or locations, however we have no control of websites outside Acquire Domain. If you provide information to a website to which we link, we are not responsible for its protection and privacy. Always be aware when submitting data to websites. We firmly advised you to read the site’s data protection and privacy policies of websites you visit.
Data Protection Provisions for Personal Data
We at Acquire are committed to ensuring that all personal data obtained and processed by Acquire is done so in accordance with the GDPR and its principles, along with any associated regulations and/or codes of conduct lay out by the Supervisory Authority and local law. We are dedicated to ensure safe, secure, ethical and transparent use of personal data and uphold the highest standards of data processing. We have adopted Pseudonymization and Anonymization of data as suggested under the Regulation.
CCPA Privacy Statement for California Residents
We have adopted this CCPA Privacy Statement to comply with California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA shall have the same meaning when used in this CCPA Privacy Statement. This CCPA Privacy Statement applies solely to visitors and users of our website who reside in the State of California.
Information We Collect, Use and Disclose
Identifiers, such as your real name, alias, postal address, email address, account name which is generally collected at the time of registration.
Commercial information, including records of products or services purchased.
Internet or other electronic activity information such as Location, IP address, cookie identifiers, browsing history and consumer’s interaction with a website or application.
Geolocation data such as demographic location associated with IP address, postcode when you choose to share it.
Professional or employment-related information including employees’ current or past job history or performance evaluations.
Inferences drawn from other personal information given by you at the time of creating your profile with given preferences, characteristics, and behavior.
Your Rights and Choices
From January 1, 2020, California residents have the following rights:
Right to Know- You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you the categories and specific pieces of personal information we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, the categories of third parties with whom we share such information.
Right to Delete- You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Right to Non-Discrimination- You have the right to not be discriminated against for exercising any of these rights.
Exercising Your Rights
To exercise your California privacy rights mentioned above, please contact us by email using the contact information given below. We may need you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We endeavor to respond to a verifiable consumer request within 45 days of its receipt.
We are always committed to hold your information securely. We have implemented suitable physical and electronic security procedures to safeguard your sensitive information from unauthorized access or disclosure. We follow stringent procedures to ensure we work with all personal data in line with General Data Protection Regulations (GDPR). For more information kindly refer to our Data Protection Policy.
Use of Site by Children
We do not sell products or provide services for purchasing by children, nor do we market to children. If you are under 13, you may use our website only with consent from parent or guardian. If found that we have unknowingly collected Personally Identifiable Information from children under 13, we take immediate measures to delete the information from our servers.
We may update this privacy notice regularly as per the company’s requirement and customer’s feedback. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records or future requirement.
Recourse, Enforcement and Liability
In compliance with the Privacy Shield Principles, Acquire commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Acquire at:
Name and Address of Data Protection Officer
133 Kearny street. suite 401, San Francisco, CA 94108
Email : firstname.lastname@example.org
Acquire has further committed to refer unresolved Privacy Shield complaints to JAMS an alternative dispute resolution provider located in the [United States]. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS alternative dispute resolution are provided at no cost to you.
Acquire is also subject to the investigatory and enforcement powers of the Federal Trade Commission, which is the competent supervisory body under the Privacy Shield.
Where a complaint cannot be resolved by any of the before mentioned recourse mechanisms, individuals have a right to invoke binding arbitration (ICDR-AAA) under the Privacy Shield Panel as recourse mechanism of ’last resort’.
We welcome your questions or comments regarding this Statement of Privacy. If you believe that Acquire has not adhered to this Statement, please contact
Name and Address of the Data Controller
133 Kearny street. suite 401, San Francisco, CA 94108
Email : email@example.com
Phone : +1 (415) 212-5151
Website : https://acquire.io