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1. Introduction

1.1    We are committed to safeguarding the privacy of accelerationpartners.com visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of accelerationpartners.com; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    You will have the option to opt-out of cookies when you first visit our website, in accordance with the terms of this policy when you first visit our website.

1.4    Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can opt out of email communications and via: http://pages.accelerationpartners.com/UnsubscribePage.html. You can also limit the publication of your information by contacting marketing@accelerationpartners.com.

1.5    In this policy, “we”, “us” and “our” refer to Acceleration Partners.

2.   How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may process data about your use of our website and services (“usage data“). The usage data may include your name, email, job title, IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system and user input. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is legitimate interests, namely monitoring and improving our website and services.

2.3    We may process your account data (“account data“).The account data may include your name, email address, and company information. The source of the account data is your IP information and/or the information you have submitted to our website. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4    We may process your information included in your personal profile on our website (“profile data“).The profile data may include [your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is consent.

2.5    We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.

2.6    We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

2.7    We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.8    We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping] The legal basis for this processing is our legitimate interests, namely the communications with users or interested parties.

2.9    We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10  We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely [he proper protection of our business against risks.

2.11  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.

2.12  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

2.13  Listed below is the personal data that we collect: First Name, Last Name, Job Title, IP Information (IP address, inferred location), content downloads and page views on accelerationpartners.com

2.14  Listed below is where we collect and store data (3rd parties): Marketo, Salesforce, BrightInfo, Zoom Webinar, MediaRails, APView (Trackonomics), Google Drive and ClientPULSE). All data will be stored in Salesforce and Marketo.

2.15  Listed below is where we collect data on our website (accelerationpartners.com)

  • Contact forms
  • Content forms (Registering for webinars and downloading content)
  • Email opt-in (footer of website, side column on blog page, bright info widget pop-up)
  • Blog opt-in form
  • Cookies

3.   Automated decision-making

3.1    We will use your personal data for the purposes of automated decision-making in relation to sending relevant emails and outreach based on actions and preferences.

3.2    This automated decision-making will involve outreach catered to the specific actions you took on our website or emails.

4.   Providing your personal data to others

4.1    We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

5.   International transfers of your personal data

5.1    In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

5.2    We have operations in the United States, UK and APAC region. The European Commission has made an “adequacy decision” with respect to [the data protection laws of each of these countries. Transfers to each of these regions will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.

5.3    The hosting facilities for our website are situated in North America. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely [the use of standard data protection clauses adopted or approved by the European Commission.

6.   Retaining and deleting personal data

6.1    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

7.   Amendments

7.1    We may update this policy from time to time by publishing a new version on our website.

7.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

7.3    We may notify you of changes to this policy by email or through the private messaging system on our website.

8.   Your rights

8.1    You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:

(a)    the payment of a fee (currently fixed at GBP 10); and

(b)    the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

8.2    We may withhold personal information that you request to the extent permitted by law.

8.3    You may instruct us at any time not to process your personal information for marketing purposes.

8.4    In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

9.   Third party websites

9.1    Our website includes hyperlinks to, and details of, third party websites.

9.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

10.   Personal data of children

10.1  Our website and services are targeted at persons over the age of 18.

10.2  If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.

11.   Updating information

11.1  Please let us know if the personal information that we hold about you needs to be corrected or updated.

12.   Acting as a data processor

12.1  In respect of data controlled and collected by the clients we represent, we do not act as a data controller; instead, we act as a data processor.

12.2  Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

13.   About cookies

13.1  A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. More about cookies here.

13.2  Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

13.3  Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

14.   Cookies that we use

14.1  We use cookies for the following purposes:

(a)    authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are stored in Marketo). Marketo is a marketing automation tool focused on email, mobile, social, digital ads, web management and analytics.

(b)    status – we use cookies [to help us to determine if you are logged into our website]

(c)    personalisation – we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: BrightInfo and Marketo.

 (d)   advertising – we use cookies to help us to display advertisements that will be relevant to you, cookies used for this purpose are for Google, Facebook, LinkedIn, Twitter and other paid marketing initiatives.

(e)    analysis – we use cookies to help us to analyse the use and performance of our website and services, cookies used for this purpose include Google Analytics.

(f)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally

15.   Cookies used by our service providers

15.1  Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

15.2  We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.

15.3  We use Marketo as our Marketing Automation Platform. This service uses cookies to track web visitor behavior and assist with our sales and marketing activities. You can view the privacy policy of this service provider at https://documents.marketo.com/legal/privacy/.

16.   Managing Cookies

16.1  Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

16.2  Blocking all cookies will have a negative impact upon the usability of many websites.

16.3  If you block cookies, you will not be able to use all the features on our website.

17.   Our details

17.1  This website is owned and operated by Acceleration Partners, LLC.

17.2  We are registered in the United States under registration number 42-1751446 and our registered office is at 16 Rae Ave, Needham, MA 02492

17.3  Our principal place of business is at 16 Rae Ave, Needham, MA 02492

17.4  You can contact us:

(a)    the postal address given above

(b)    using our website contact form

(c)    the contact number published on our website from time to time

(d)    by email, using info@accelerationpartners.com

18.   Data protection officer

18.1  Our data protection officer’s contact details are: Jesse Mastro; jesse@accelerationpartners.com

19.   Processing Data between the EU and US

19.1  Acceleration Partners complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Acceleration Partners has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/

19.2  In compliance with the Privacy Shield Principles, Acceleration Partners 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 Acceleration Partners DPO as named in section 18.

19.3  Acceleration Partners has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.

19.4  Acceleration Partners is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC)

19.5  It is possible, under certain conditions, for an individual to invoke binding arbitration

19.6  Acceleration Partners is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

19.7  Acceleration Partners accepts liability for onward transfers of data to third parties