If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Acumen Solutions, Inc. and its subsidiary, Acumen Solutions UK Ltd. participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at [https://www.privacyshield.gov/list].
Acumen Solutions is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Acumen Solutions complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Acumen Solutions is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
All individuals who provide personal information, such as customers, subcontractors, partners, job applicants, employees, retirees and others;
All locations where we operate, even where local regulations do not exist; and
All methods of contact, including in person, written, via the Internet, direct mail, telephone, or facsimile.
In compliance with the Privacy Shield Principles, Acumen Solutions, Inc. commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield Ppolicy should first contact Acumen Solutions at:
The Office of the General Counsel at firstname.lastname@example.org or The Human Resources Department email@example.com.
Acumen Solutions, Inc. has further committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you do not receive timely acknowledgement of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs for more information or to file a complaint. The services of EU DPAs are provided at no cost to you.
"Controller," means Acumen Solutions and its authorized representatives, which determine the purposes and means of processing of Personal Data.
"Data Subject" refers to any employee or third person who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social identity.
"General Business Purpose" means the Processing of Personal Data for any activity related to the commercial operations of Acumen Solutions. This could include, but is not limited to Acumen Solutions' employees; sales; marketing; protecting intellectual property; the provision of services; support related to the services provided; internal operations; and general employment matters, including recruitment both internally and externally. Data Processing for General Business Purposes includes, but is not limited to, implementing or developing software, providing consulting or technology services, maintaining files, payroll processing, managing benefit and medical plans, conducting performance reviews, and intra-company communications.
"Personal Data" means any information related to an identified or an identifiable person. For example, a Data Subject's home address, e-mail address and/or phone number, personnel file, or benefits information constitutes Personal Data.
"Processor" means a natural or legal person, or any other entity that processes Personal Data on behalf of the Controller and under its control. For example, a Processor may be a payroll preparation firm that works on behalf of Acumen Solutions and under its control. Acumen Solutions requires Processors to protect the privacy, confidentiality and security of Personal Data obtained from Acumen Solutions.
"Processing" of Personal Data means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction. "Acumen Solutions" means Acumen Solutions, Inc. and Acumen Solutions UK, Ltd.
"Sensitive Data" is a subset of Personal Data, and refers to any Personal Data pertaining to racial or ethnic origins, trade union membership, medical or health conditions, political or religious beliefs, sex life, or criminal history.
"Third Party" means any natural or legal person, public authority, agency or any other entity other than the data subject, the Controller, the Processor and the persons who, under the direct authority of the Controller or the Processor, are authorized to process the Personal Data.
How We Use and Safeguard Personal Data
Although a Data Subject's Personal Data is protected in all cases, how it is maintained varies based on the circumstances. In the case of Acumen Solutions' employees, Personal Data is maintained in the personnel file and/or entered into ADP and/or Salesforce.com databases, which are managed by Acumen Solutions' Human Resources department and to which only authorized individuals with a "need to know" have access.
In the case of our clients, Acumen Solutions may gain access to Personal Data only during the course of providing services or support related to the services or as required by law. In most cases, if Personal Data is involved, Acumen Solutions will use only client-provided equipment to access and/or process the Personal Data. At the end of a project, all equipment is returned to the client. In addition, in the majority of cases, Acumen Solutions maintains the data on the client's systems, and only those individuals who are working on a project and who need to have access to the Personal Data are given such access. Any individual who is given such access has signed a confidentiality agreement specifically protecting all confidential information, including Personal Data.
In a circumstance where Personal Data is involved during the performance of a client project and the client requests that Acumen Solutions use its equipment for accessing, staging and/or processing the Personal Data, Acumen Solutions has put in place security measures to protect such Personal Data. Acumen Solutions' laptops are issued with multiple layers of security. In the event that a client requests that Acumen Solutions provide servers for staging client Personal Data, the client will determine the type of staging area to be used and the level of security, so long as the Personal Data is protected.
Quality of Personal Data
Acumen Solutions collects Personal Data from Data Subjects including but not limited to name, email address, and phone number. Acumen Solutions will take reasonable steps to ensure that Personal Data and Sensitive Data are:
Obtained, where possible, directly from the Data Subject to whom the Personal Data relates or from the client who is responsible for the Personal Data;
Obtained and processed fairly and lawfully by Acumen Solutions for General Business Purposes;
Relevant to and no more revealing than is necessary for General Business Purposes; and
Kept up to date to maintain data accuracy, while data are under the control of Acumen Solutions, and kept only for so long as is reasonably necessary except in cases where a client manages or is responsible for managing the accuracy of the data.
Disclosure of Personal Data
We may provide your personal information to companies that provide services to help us with our business activities such as shipping your order or offering customer service. These companies are authorized to use your personal information only as necessary to provide these services to us.
We may also disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
Notice and Use of Personal Data
In cases where the Personal Data is obtained from the Data Subjects, Acumen Solutions informs Data Subjects what information we collect, how it is used, whether it may be temporarily transferred to others to provide the products or services requested, and how to contact Acumen Solutions with privacy inquiries. Acumen Solutions' use of Personal Data and Sensitive Data will be limited to General Business Purposes, and will not be kept longer than is necessary.
When you provide us with personal information about your contacts, we will only use this information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us firstname.lastname@example.org.
Individual Rights of Access to Personal Data
Upon request, Acumen Solutions will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information.
Acumen Solutions takes steps to make sure that the personal information it uses is correct. We will allow Data Subjects reasonable access to Personal Data and Sensitive Data about themselves during normal working hours and upon reasonable request, and will be allowed to update, delete and/or correct any inaccurate information by emailing our Customer Support at email@example.com. We will respond to your request to access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you (or a third party you have authorized) with our services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
Security of Personal Data
Acumen Solutions will take reasonable precautions to protect Personal Data and Sensitive Data from loss, misuse, unauthorized access, disclosure, alteration and destruction. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.
Acumen Solutions expects its employees, independent contractors, subcontractors, and partners to maintain the trust placed in Acumen Solutions by those Data Subjects who provide Personal Data to Acumen Solutions. Those who manage Personal Data will complete periodic privacy self-assessments to make sure that the Personal Data is secure and protected. Acumen Solutions will periodically audit privacy compliance, and where necessary, will extend by contract its privacy policies and data protection practices to Acumen Solutions' supplier and partner relationships.
Procedure for Accessing Personal Data
Acumen Solutions must receive specific authorization from the Data Subject or our client in order to access Personal Data and Sensitive Data, except when required by law or when a Data Subject requests access to his or her own data. Questions about Personal Data and/or authorization to access such Personal Data are to be directed to the General Counsel's office at 703-600-4000. Unauthorized access may be grounds for disciplinary or contractual actions as applicable, including termination.
As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
We do not link this automatically-collected data to personally identifiable information. IP addresses are tied to personally identifiable information to distinguish new visitors from those who are returning to our site.
We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partners may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads.
Email or Newsletter
You may sign-up to receive marketing campaign emails, newsletters or other communications from us. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in the communications or by emailing back with the word “unsubscribe” in the subject line, or by contacting us at firstname.lastname@example.org.
Transfer of Data
Acumen Solutions' personnel, outside firms and consultants, and clients who receive Personal Data may be located in the Data Subject's home country, the United States or any other country in which Acumen Solutions or its affiliates do business. Therefore, Personal Data may be transferred to any country in the world, including but not limited to the United States of America, and other countries where Acumen Solutions does business, and where the privacy laws may be more or less protective than the privacy laws where the Data Subjects live or work.
Concerned individuals may withhold their consent to such international transfers, and are to be informed of the impact such opt-out will have on their employment within Acumen Solutions (e.g., inability to process benefits or payroll data in a timely or appropriate fashion).
Links to 3rd Party Sites
Social Media Widgets
For More Information
Questions or concerns about how Acumen Solutions handles Personal Data are to be directed to the General Counsel's Office at 703-600-4000. Email: email@example.com.
Acumen Solutions, Inc.
1660 International Dr., Suite 500
McLean, Va. 22102
Effective Date: February 8, 2017