Accumulus Synergy Privacy Policy

Effective Date: December 18, 2020

Accumulus Synergy, Inc. and its affiliates (collectively, “Accumulus Synergy,” “we,” or “us”) are committed to protecting the privacy and security of the information we collect and to being transparent about the ways in which we collect and process your information. This statement (the “Privacy Policy”) sets forth our policies and practices for how Accumulus Synergy collects, uses, shares and otherwise processes your personal data collected on our website (the “Services”).

I. COLLECTION OF INFORMATION
We collect the following categories of information when you use our Services:

    • Information you provide to us directly or through your engagement.
      • Contact Information, including name, email address, phone number and address;
      • Device data, consistent with your device permissions to provide you with certain features or functionality.
      • Correspondence you send to us or through the Services and other information you provide.
    • Information we collect automatically. We collect internet, electronic activity, and other information automatically from the devices and browsers that you use, including your device type; Internet protocol (IP) address; device identifiers; browser type and version; operating system and platform; Internet service provider; the date and time of your visit; information about the links you click, pages you view, and other information about how you use the Services; the technology on the devices you use to access these Services; and standard server log information.

Without this information, we may not able to provide you with all the requested services.

We may aggregate or de-identify the information described above. Aggregated or de-identified data is not subject to this Privacy Policy.

II. USE OF INFORMATION AND PURPOSE OF DATA PROCESSING
We use and otherwise process each of the categories of information identified above for the following business purposes:

Purpose/Activity EEA/UK lawful basis for processing, including basis of legitimate interest

To provide you with the information, products and services that you request from us; to allow you to participate in features of our Services; and to notify you about changes to our terms or privacy policy.

To communicate with you, including to make suggestions and recommendations to you, or to send promotional materials from us or by our affiliates and trusted business partners.

To improve our Services and to ensure that content is presented in the most relevant and effective manner for you and for your device; to administer our Services, including troubleshooting, data analytics, testing, research, statistical and survey purposes; to keep our Services, business and users safe and secure; to comply with applicable laws and regulations; and to protect or exercise our legal rights or defend against legal claims.

(a) Performance of a contract with you
(b) Necessity to comply with a legal obligation
(c) Necessity for our legitimate interests (for instance, to keep our records updated)

Necessity for our legitimate interests (to grow our business)

(a) Necessity for our legitimate interests (for running and protecting our business; for provision of administration and IT services; for network security and to prevent cybercrime and fraud; in the context of a business reorganisation; to study how people use our Services, to develop the Services, to keep our Services updated and relevant, to grow our business and to inform our communications strategy)
(b) Necessity to comply with a legal obligation
(c) Performance of a contract with you

Where legally required and we have no other valid legal basis to process your information, we will obtain consent, which may subsequently be withdrawn at any time by contacting us using the form on our website. Withdrawing consent does not affect the lawfulness of processing based on consent before it is withdrawn.

III. DISCLOSURE OF INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

  • Authorized third-party vendors and service providers. We share your information with our third-party vendors and service providers that provide services to us for a variety of business purposes.
  • Members. We may share your information with our member organizations.
  • Business transfers. We may share your information in connection with a substantial corporate transaction, such as a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
  • Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, safety, and security of Accumulus Synergy and its employees, our affiliates, users, or the public.

With your consent or direction. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

If you choose to engage in public activities on the Services, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.

IV. COOKIES AND SIMILAR TECHNOLOGIES
When you use our Services, we and our third party partners (including data analytics providers) use cookies, pixel tags, local storage, and other similar technologies (collectively, “cookies”) to collect information from your browser or device, including but not limited to provide analytics on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices. By using the Services, you consent to our use of cookies and similar technologies.

The following types of cookies are used on our Services:

  • Essential cookies – These cookies enable you to use our Services. These cookies are essential to enable you to browse our Services and use certain features. Disabling them may prevent you from using certain parts of the Services. Without these cookies, certain services cannot be provided. These cookies also help keep our Services safe and secure.
  • Preference cookies – These cookies store information such as your preferred country and language selection, login data and website preferences. Without these cookies, our Services may not be able to remember certain choices you’ve previously made (such as a saved country / language preference) or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
  • Performance cookies – These cookies collect information about how you use our Services such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages.
  • Content cookies – These cookies gather information about your use of our Services so we may improve your experience and provide you with more relevant content on our Services and elsewhere online and across your devices. They remember that you’ve visited our Services and help us understand usage of our Services.

Do-Not-Track Signals and Similar Mechanisms. Some mobile and web browsers transmit “do-not-track” signals. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

V. YOUR RIGHTS AND CHOICES
You may be entitled, in accordance with applicable law, to object to or request restriction of processing of your information, and to request access to, rectification, erasure, and portability of your information or more information about our information practices. Requests should be submitted in writing as set out below. If you become aware of changes or inaccuracies in your information, you should inform us of such changes so that the information may be updated or corrected. We may verify your request, such as by requesting additional information from you. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent.

We do not treat the sharing of your personal information as described in this Privacy Policy as a “sale” of your information, but you nonetheless have choices about collection of information about your use of our Services through cookies and other tracking technologies, including by third parties whose privacy practices we cannot control. For example, you may be able to refuse or disable cookies by adjusting your web browser settings. Some browsers have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable Local Shared Objects and similar technologies. For example, Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you and any differences in service are related to the data. Deleting cookies may in some cases cancel the opt out selection in your browser.

Some of the content, functionality, and services on the Services may be provided by third parties that are not affiliated with Accumulus Synergy. These third parties may collect or receive certain information about your use of the Services, including through the use of cookies, web beacons, and similar technologies. These entities may collect this information over time and combined with information collected from different websites and online services. We are not responsible for the privacy practices of these entities.

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on the Service may change or no longer be available to you.

You may lodge a complaint with a relevant data privacy authority if you believe our processing of your information is unlawful.

VI. INTERNATIONAL TRANSFERS
By using the Services and providing us with information, you understand that your information is being collected and stored on, and may be transferred to, servers located outside your resident jurisdiction. We and many of our third-party vendors are based in the United States, and your information is being processed by us in the United States and other jurisdictions where laws may not be equivalent to those where you reside. To the extent we disclose your information to third-party vendors, we use contractual safeguards to help ensure that such third-party vendors are bound to duties of confidentiality. Where local law permits, you are deemed to have consented to these data transfer practices through your use of the Services. If you do not consent to these data transfer practices, please do not use the Services.

VII. CHILDREN
We do not knowingly collect or sell any information from children, as defined by applicable law, without parental consent or as otherwise permitted by applicable law. If we learn that we have collected personally identifiable information from a child under age 16, we will delete that information from our database.

VIII. DATA RETENTION, SECURITY, AND INTEGRITY
Information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws.
We maintain security measures to safeguard information from loss, theft interference, misuse, unauthorized access, disclosure, alteration, or destruction. However, you should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure, accurate, complete, or current. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

IX. CHANGES TO THE PRIVACY POLICY
We may modify this Privacy Policy from time to time. When we update the Privacy Policy, we will revise the “Effective Date” date above and post the new Privacy Policy. We recommend that you review the Privacy Policy each time you visit the Services to stay informed of our privacy practices.

X. CONTACT INFORMATION
If you have any questions about this Privacy Policy or our practices, please contact us via the form on our website.