We are committed to protecting your privacy when you interact with us. The purpose of this Privacy Statement (“Statement”) is to set forth the Acumen Solutions, Inc. and its affiliated entities Acumen Solutions UK, Ltd. (“Acumen Solutions,” “us” or “we”) privacy practices with respect to Personal Data (which means any information relating to an identified or identifiable natural person), we collect from and about individuals with whom we interact (“you”).
If we make any changes to this Statement we will notify you by means of an updated Privacy Statement on our website prior to the change becoming effective, including the date last updated at the top of the page. The most current version of the Statement can always be reviewed by clicking on the “Privacy Statement” link located at the bottom of our website.
If you are visiting our website from the European Union (“EU”) or where applicable EU data protection laws so provide, please see the section below titled, "Your EU Privacy Rights" for additional information. This Privacy Statement describes Acumen Solutions' standard global procedure governing access to and use of Personal Data across borders. As part of this Privacy Statement, Acumen Solutions will comply in all material respects with the General Data Protection Regulation (GDPR) 2016/679 and implementing legislation enacted by the member states of the European Union with respect to its operations in those member states, as well as such legislation as the Health Insurance Portability and Accountability Act of 1996, as amended, and other privacy laws, rules, and regulations that may apply to Acumen Solutions.
What Information Do We Collect?
The types of Personal Data Acumen Solutions collects includes:
- Contact information (such as name, email address, mailing address and phone numbers),
- Account log-in credentials,
- Resume and applicant information for those applying for a job, and
- Data gathered by technology when you visit our website.
How Do We Use Personal Data?
We use your Personal Data for Acumen Solutions’ business purposes, including the provision of services; support related to the services provided; and, internal operations. This includes developing and implementing software, providing consulting and technology services, and intra-company communications.
Specifically, we process your Personal Data to:
- Provide our products or services or process orders – this is necessary for the performance of a contract,
- To send administrative notices about important changes in our contractual relationship – this is necessary for the performance of a contract with you or for our legitimate interest to do so,
- To provide a more efficient and customized educational and shopping experience; provide customized marketing and promotional services; provide information about our products, services, special offers and upcoming events; statistically analyze website use (for more information in this respect, see our separate Cookie Statement); improve our product and service offerings; and enhance our website content, layout, and services – this is necessary for our legitimate interests as set out herein or based on your consent (in which case we would ask you separately to provide your consent to a particular processing activity),
- To consider resumes and applications received by applicants for jobs with Acumen entities, including all elements of the procedure leading up to making a decision whether to offer, subject to any appropriate background checks, the applicant a position. Some job applicant data processing may also be necessary to comply with legal obligations.
With Whom Do We Share Personal Data?
Within the Acumen group of companies: Your Personal Data may be shared with other Acumen companies (i.e., intra-group) for all the purposes described above. We may also provide some of our services through contractual arrangements with other Acumen companies who process the Personal Data on our behalf, in particular for IT support, hosting and maintenance services and mailing or delivery/transport services.
With third-party service providers: We need to share your Personal Data with other third parties in order to deliver the requested products or services. We also share your Personal Data with accounting and consulting firms and external counsel. We may also use or share your information in an anonymized or aggregate manner.
Law enforcement or other legal reasons: Occasionally we may be required by law enforcement or other public authorities as well as judicial authorities, courts or tribunals to share Personal Data with them or other parties. We will disclose Personal Data upon receipt of a court order, subpoena, warrant, or other legal process to the extent necessary to meet legal, national security, public interest, or law enforcement obligations or defend our interests in legal, administrative or other proceedings, which may require us to share Personal Data with other parties to the proceedings and their external counsel. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
Business transactions or legal restructuring: If we or some or all of our assets are acquired by another company, including through a sale in connection with bankruptcy, we will share the information that we hold with that company. We may also buy or sell all or part of our business or the business of a third party. All or part of your Personal Data may be transferred to a new business or owner as a result of such transactions, in accordance with applicable laws, however, your Personal Data will continue to be protected by any pre-existing Privacy Statement of Acumen Solutions, unless you agree otherwise.
We do not sell your Personal Data to third parties.
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 Data.
Acumen Solutions takes steps to make sure that the Personal Data it uses is correct. Subject to certain legally permissible exceptions, 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.
Security of Personal Data
Acumen Solutions will take reasonable precautions to protect Personal Data and Sensitive Data (defined below) from loss, misuse, unauthorized access, disclosure, alteration, and destruction. We follow generally accepted standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure; therefore, we cannot guarantee its absolute security.
Retention of Data
We will keep your Personal Data as reasonably necessary to fulfill the purposes for which Personal Data is collected as stated herein; for as long as is necessary for the performance of the contract between you and us, if any; and to comply with legal and statutory obligations, such as tax, trade and corporate laws. When we no longer need your Personal Data for our purposes, we will destroy, delete or erase that Personal Data or convert it into an anonymous form.
We do not use the Site to knowingly collect Personal Data from children under the age of thirteen (13), nor is this Site designed for or directed at children. By using the Site, you represent that you are age thirteen (13) or over. If you are a child under thirteen (13) years of age, you are not permitted to use the website and should not send any Personal Data about yourself to us through the website. If you believe that a child may have provided his or her Personal Data to us, please contact us using the contact information at the end of this Statement. In the event that we become aware that we have collected Personal Data from a child under the age of thirteen (13), we will dispose of that Personal Data immediately.
You may sign-up/opt-in 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 “unsubscribe” or by contacting us at firstname.lastname@example.org.
Links to Third-Party Websites
Our website includes links to other websites whose privacy practices may differ from those of Acumen Solutions. If you submit personal data to any of those websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.
Social Media Widgets
Our website includes Social Media Features, such as the Facebook Like button [and Widgets, such as the Share this button or interactive mini-programs that run on our website]. These Features may collect your IP address, which page you are visiting on our website, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our website. Your interactions with these Features are governed by the privacy statement of the company providing it.
Updates to Privacy Statement
This Privacy Statement is subject to change. If it does, we will update this Privacy Statement prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
International Transfers of Your Personal Data
“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' sales; marketing; protecting intellectual property; the provision of services; support related to the services provided; internal operations; employees 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 natural 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” or “Special categories of personal data” is a subset of Personal Data, and refers to any Personal Data pertaining to racial or ethnic origin, political opinion, religious or philosophical beliefs, or trade union membership, and the Processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
“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.
Subject to this Privacy Statement, Acumen Solutions may from time to time transfer Personal Data and Sensitive Data within and between its various worldwide locations for General Business Purposes, in compliance with country of origin regulations, EU law, the Privacy Shield Principles and this Privacy Statement.
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.
In compliance with the Privacy Shield Principles, Acumen Solutions commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Private Shield Statement should first contact Acumen Solutions at: The Office of the General Counsel at email@example.com or The Human Resources Department at firstname.lastname@example.org.
Acumen Solutions 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 acknowledgment 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.
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, 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.
If you are visiting the website from the EU or where applicable EU data protection laws so provide, you may, subject to certain limitations, exercise the following rights regarding your Personal Data:
You have the right to obtain from us confirmation if your Personal Data is being processed and certain information in this regard.
You have the right the request the rectification of inaccurate Personal Data and to have incomplete data completed.
You have the right, when we process Personal Data on the grounds of legitimate interests, to object to the processing of your Personal Data for compelling and legitimate reasons relating to your particular situation, except in cases where legal provisions expressly provide for that processing. In addition, you have the right to object at any time where your Personal Data is processed for direct marketing purposes.
You may receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit them to other data controllers without hindrance. This right only exists if the processing is based on your consent or a contract and the processing is carried out by automated means.
You may request to restrict processing of your Personal Data if (i) you contest the accuracy of it – for a period we need to verify your request; (ii) the processing is unlawful and you oppose the erasure of it and request restriction instead; (iii) we no longer need it, but you tell us you need it to establish, exercise or defend a legal claim; or (iv) you object to processing based on public or legitimate interest – for a period we need to verify your request.
You may request to erase your Personal Data if it is no longer necessary for the purposes for which we have collected it, you have withdrawn your consent and no other legal ground for the processing exists, you objected and no overriding legitimate grounds for the processing exist, the processing is unlawful, or erasure is required to comply with a legal obligation.
Right to lodge a complaint
You also have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your residence, or the location where the issue that is the subject of the complaint occurred.
Right to refuse or withdraw consent
Please note that in case we ask for your consent to certain processing, you are free to refuse to give consent and you can withdraw your consent at any time without any adverse negative consequences. The lawfulness of any processing of your Personal Data that occurred prior to the withdrawal of your consent will not be affected.
If you have questions about exercising any of those rights or their applicability to any of our particular processing activities or have questions about any data transfer mechanism or want a copy thereof, you may contact us at email@example.com or at the address provided below.
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: firstname.lastname@example.org.
Acumen Solutions, Inc.
8280 Greensboro Drive Suite 400
McLean, VA. 22102
Effective Date: May 14, 2018
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