UK Privacy

ACA COMPLIANCE GROUP
UK PRIVACY POLICY

 

Effective August 30, 2016

Updated August 14, 2018

Introduction

ACA Compliance (Europe) Limited and ACA Performance (Europe) Limited (collectively, “ACA UK”) are committed to respecting your privacy. 

For the purposes of the Data Protection Act 1998 (the “Act”), the data controller is ACA Compliance (Europe) Limited, of 4th Floor, Panton House, 25/26 Haymarket, London, SW1Y 4EN.

ACA UK has developed this UK Privacy Policy (this “Policy”) to advise you of the ways in which ACA UK collects, uses, shares and protects your information. Any person accessing, browsing or otherwise using a website where this Policy is posted (each, a “Site”) is a “User” for purposes of this Policy.

ACA UK, together with SIH ACA Topco, L.P. and its U.S. subsidiaries, ACA Intermediate Co 1, LLC, ACA Intermediate Co 2, LLC, ACA Intermediate Co 3, LLC, NM GRC Holdco, LLC, ACA Compliance Group Holdings, LLC, Adviser Compliance Associates, LLC, Broker-Dealer Compliance Associates, LLC, ACA Performance Services, LLC, ACA Technology, LLC, ACA Risk Strategies, LLC, ACA Corporate Holdings, Inc., ACA Technology Surveillance, Inc., and ACA AML Strategies, Inc. are hereinafter referred to as the “ACA Group”. For a copy of the ACA Compliance Group U.S. Privacy Policy, please visit http://www.acacompliancegroup.com/privacy.

User Consent to Policy

By accessing, browsing, or using a Site, each User acknowledges that he or she has read, understands, agrees and consents to the terms and conditions of this Policy and the practices described in this Policy. If you do not consent to the practices described in these terms and conditions, you should not access, browse, or use any Site or provide any information to ACA UK via any Site.

 

Information Collected by ACA UK

ACA UK may collect and process the following personal information, non-personal information and anonymous information (“Information”) about Users:

  • Information Users provide to ACA UK: Users may provide the following information by filling in forms on a Site, contacting the ACA Group or its representatives for information, or by registering to access services via a Site. Users may also provide information by submitting a request for information, proposals, or to receive periodic updates from the ACA Group, by subscribing to ACA Insight, attending a webcast, live conference or other ACA Group-sponsored or hosted event, participating in a discussion forum available through a Site, or engaging in any other activity through a Site in which personal information is provided by the User to ACA UK. The information Users may give ACA UK includes the name, title, company name, address, phone and/or fax number, job title, email address and credit card details.

 

  • Information the ACA Group collects about Users: With regard to a User’s visit to a Site, the ACA Group may automatically collect certain non-individually identifying (i.e., anonymous) browsing information, such as the Internet Protocol (IP) address used to connect your computer to the Internet, your computer’s operating system, the name of the domain you used to access the Internet, the website you came from, and the website you visit next. This information is collected automatically through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs, or other technologies, examples of which are explained further in the section titled “Cookies” below. Anonymous browsing information is not used, nor is it intended to be used, by ACA UK to personally identify an individual.

Cookies

ACA UK may automatically collect certain types of information whenever you use a Site or certain Site services or click on advertisements on a Site or in ACA Group’s periodicals, such as ACA Insight. ACA UK does this in a way which keeps your information anonymous. If ACA UK collects this anonymous information, it will be done automatically through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs, and similar technologies as explained below.

HTML Cookies: When you use a Site, the pages you see, along with something called a “cookie,” may be downloaded to the hard drive of your computer, mobile device, or tablet (individually or collectively, “Equipment”). Cookies are small files of letters and numbers that may be stored by your browser on your Equipment. ACA UK may use “cookies” to distinguish you from other Users of a Site. These cookies help ACA UK provide you with a good experience when you browse a Site, and also help ACA UK improve a Site. These cookies do not contain or collect any personal information. ACA UK may use:

  • Strictly necessary cookies, which are required for the operation of a Site. They include, for example, cookies which enable Users to log on to secure areas of a Site, use a shopping cart, or access and participate in discussion forums on a Site.
  • Analytical or performance cookies, which allow providers to recognise and count the number of Users and to see how Users move around a Site when they are using it. This helps ACA UK to improve the way the Sites work, for example, by ensuring that Users can more easily find what they are looking for.
  • Functionality cookies, which are used to recognise Users when they return to a Site, They enable Users to store preferences for certain types of information so that they do not have to input those preferences every time they use a Site.
  • Targeting cookies, which record a User’s visit to a website, the individual pages visited and the links followed. If the cookie is set by a third party (for example, a third-party advertising partner) which also monitors traffic on other websites, this type of cookie may also be used to track a User’s movements across different websites and to create profiles of their general online behavior. ACA UK does not currently use cookies to deliver targeted advertisements to you when you are on a Site or third-party websites.

ACA UK will obtain your consent to the use of cookies when you first visit a Site. In addition, you can choose to accept or decline cookies when you first visit a Site by changing the settings in your browser.

Most web browsers automatically accept cookies by default, but you should be able to change your browser settings to limit or prevent the download of cookies. Cookies in themselves do not personally identify the individual user of the Equipment, but rather the Equipment that is being used to access a Site. You may have the opportunity to set your Equipment to accept all cookies, to notify you when a cookie is issued, or to not receive cookies at any time. Different browsers may address cookies differently.

If you do not consent to the use of cookies or if you set your browser to decline cookies, it may result in certain personalised services not being provided to you when you use your Equipment.

Web beacons, Pixels and Clear GIFs: ACA UK may use web beacons, pixels, and clear GIFs. These electronic technologies are transparent image files that, if used, allow ACA UK and its advertising partners to track website usage information, such as the number of times a website has been viewed and whether and when you have opened a HTML email, how many times the email was forwarded and which links in the email were clicked. Unlike cookies, these technologies are not placed on your Equipment. If used, this information will help ACA UK to improve a Site and ACA UK’s advertising materials, and will help ACA UK’s advertising partners by measuring the effectiveness of such communications sent to you. These technologies may be used in association with cookies to understand how Users interact with a Site or advertisements.

Please note that third parties (including, for example, advertising partners and providers of external services like web traffic analysis services) may also use cookies on a Site. ACA UK may not have control over the use of these cookies. These cookies are likely to be analytical or performance cookies or targeting cookies.

How ACA UK Uses the Information

ACA UK uses the Information collected from Users for the following purposes:

  • to respond to Users’ questions and/or comments;
  • where ACA UK has obtained Users’ consent to such direct marketing, to market or provide products, services or information to Users,
  • to process Users’ purchases, or provide related account status to the applicable User.

Information may be used to gather broad demographic information used in marketing, promotion, analytics, or similar activities. This information may be aggregated to measure the number of visits, average time spent, page views and other statistics about Users of a Site. ACA UK also may use this Information to monitor Site performance and to make a Site easier and more convenient to use.

ACA UK also may use Information collected from its Users to enforce its agreements with Users, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that ACA Group complies with applicable laws.

ACA UK Sharing of Your Information with Third Parties

ACA Group may share Users’ Information with any members of the ACA Group.

ACA UK only will share Information that it collects or receives regarding its Users with select third parties under the following circumstances:

 

  • Consent: If ACA UK has a User’s consent to share any Information, it may do so.  
  • Agents and processors: ACA UK may use third parties to provide products and services which Users have requested on its behalf, such as marketing new or additional ACA Group products and services, sending postal and electronic mail to Users, processing credit card payments, fulfilling orders, delivering products and services, hosting discussion forums, and providing customer services to Users. These third parties have access to Information needed to perform the User’s requests, but may not use it for any other purposes.
  • Aggregate Anonymous Information: ACA UK may provide third parties with aggregate statistics about our Users’ Site activity for purposes of marketing, promotion, analytics, or similar activities. None of these statistics will identify Users personally.
  • Protection of ACA Group or Others: ACA UK may disclose Information about our Users to others if ACA UK has a good faith belief that it is required or permitted to do so by law or legal process to respond to claims, to protect the rights, property or safety of ACA Group or others, or take action regarding illegal activities or suspected fraud.
  • Business Transfers: In the event that ACA Group decides to sell all or part or its assets, ACA Group reserves the right to include Users’ Information among the assets transferred to the acquiring company.
  • Conference and Roundtable Attendees. Where Users have given their consent, ACA UK may provide the names, titles, company names, addresses, phone information, and email addresses of conference or roundtable attendees to current, past, or prospective conference or roundtable attendees, exhibitors, sponsors, or co-sponsors.

Where Your Personal Information is Stored

The Information that ACA UK collects from Users may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It also may be processed by persons operating outside the EEA who work for ACA Group or for one of ACA Group’s subcontractors or service providers. Such persons may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of Site services. By submitting your Information, you agree to this transfer, storing or processing. ACA UK will take all steps reasonably necessary to ensure that your Information is treated securely and in accordance with this Policy.

Unfortunately, the transmission of Information via the Internet is not completely secure. Although ACA UK will do its best to protect your personal data, it cannot guarantee the security of your Information transmitted to a Site; any transmission is at your own risk. Once ACA UK has received your Information, it will use strict procedures and security features to try to prevent unauthorised access to your Information.                                             

 

Accessing, Changing or Deleting Your Personal Information

ACA UK allows you to correct inaccuracies in or make other changes or delete your Information by contacting ACA Group at +1 (301) 495-7850 or sending an email to privacy@acacompliancegroup.com. In addition, you may correct inaccuracies in or make other changes or delete your Information collected through ACA Insight by updating your account in the My Profile section of www.acainsight.com or sending an email to privacy@acacompliancegroup.com.

Data Integrity

Users are responsible for the accuracy of the Information they provide to ACA UK. ACA UK will use reasonable efforts to maintain the accuracy and integrity of Information. 

Choices for Use or Sharing of Certain Information

ACA UK values your concerns about the privacy of your Information. Therefore, ACA UK offers you the opportunity to consent to how your Information is used by ACA UK, and to withdraw such consent if your preferences change.

You have the right to ask ACA UK to not process your Information for direct marketing purposes. ACA UK will inform you (before collecting your Information) if it intends to use your Information for such purposes or if it intends to disclose your Information to any third party for such purposes.

Certain emails (for example, emails containing marketing information) sent by ACA UK will include an option to unsubscribe from further correspondence. Please note that even if you opt-out from receiving direct marketing emails from ACA UK, you will continue to receive transactional and/or relationship messages, such as messages confirming a product purchase or your registration for an event.

As stated above, ACA UK may share names, titles, company names, addresses, phone information, and email addresses of conference and roundtable attendees with current, past, or prospective conference or roundtable attendees, exhibitors, sponsors, or co-sponsors. If you do not wish to receive further communications from these persons, you must contact them directly and make such a request. ACA UK is not responsible for how such third parties handle such Information.

Links to Third Party Websites

The Site may provide hyperlinks, which are highlighted words or pictures within a hypertext document that, when clicked, take you to another website not controlled by ACA UK. These hyperlinked websites may contain privacy provisions that are different from those provided in this Policy. ACA UK is not responsible for the collection, use, or disclosure of information collected through these websites, and ACA UK expressly disclaims any and all liability related to such collection, use, or disclosure. ACA UK encourages you to review the privacy policy of any third party website before submitting your Information on such websites.

Children’s Privacy Protection

No Site is directed towards children under 13 years of age, and ACA UK does not knowingly collect any information from children under 13 years of age through any Site. If you are under 13 years of age, you are not permitted to submit any information to ACA UK through any Site.

Security

Each Site has commercially reasonable security measures to protect against the loss, theft, misuse, and alteration of Information that is submitted to ACA UK and remains under ACA UK’s control. You should be aware, however, that ACA UK has no control over the security of other websites that you might visit or use, even when a link to those websites is available on or through the Site. If you share your Equipment or use Equipment that is accessed by the general public, remember to sign off and close your browser when you finish using the Site.

In the event of a breach of the confidentiality or security of your personal information, ACA UK will notify you if reasonably possible and as reasonably necessary under applicable law so that you can take appropriate protective steps. ACA UK may notify you under such circumstances using the email address or addresses that it has on record for you. You should also take care with how you handle and disclose your personal information. Please refer to the Information Commissioner’s Office website for information about how to protect yourself against identity theft.

Updates to this Privacy Policy

This Policy may change from time to time. Any changes that ACA UK makes to this Policy in the future will be posted on each Site. ACA UK will also keep prior versions of this Policy in an archive for your review.

 

Access to Information

The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to go towards ACA UK’s costs in providing you with details of the information it holds about you.

Questions and Complaints

If you have any questions, complaints, or disputes regarding the manner in which ACA UK handles or protects your Information, please bring it to ACA UK’s attention (see “How to Contact ACA UK” below).

No Rights of Third Parties

This Policy does not create rights enforceable by third parties.

How to Contact ACA UK

If you have any questions about this Policy, please

 

Call:    +1 (301) 495-7850

Email:   privacy@acacompliancegroup.com

Write:   Legal Department – Privacy 
            8401 Colesville Road, Suite 700
            Silver Spring, MD 20910  USA

 

© 2018 ACA Compliance (Europe) Limited and ACA Performance (Europe) Limited. All rights reserved.