Welcome to Acin’s privacy policy. Please read this policy carefully before using Acin’s Services.

Acin Limited (“Acin“, “our”, “us” or “we”), a company registered at Abbey House, 282 Farnborough Road, Farnborough, Hampshire, England, GU14 7NA under Company Number 08632362 and ICO registration number ZA193862, is the controller and responsible for your personal data (collectively referred to as “Acin”, “we”, “us” or “our” in this privacy policy.

Our SaaS platform called the Acin Terminal and offered through our website Acin.com enables financial institutions to fully digitise non-financial risk and manage it like a data science (the “Services”).

Protecting data, privacy and personal information is very important to us. This policy sets out the basis on which we process personal data (also referred to as “personal information” or “information“) in connection with our Services, and when you use or visit our website (regardless of where you visit it from), sign up to our newsletter, or contact us, for instance, to make an inquiry or to request a demo. The policy will also tell you about your privacy rights and how the law protects you. This website is not intended for children, and we do not knowingly collect data relating to children.

Please ensure you read this privacy policy carefully to understand the types of information we collect, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to personal data about you.

Please read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager at [email protected].

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 3 March 2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications, for example to Twitter, LinkedIn, YouTube and others. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Information we collect and how we collect it

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Information we need to deliver, manage and improve our Services – justified on the basis of our legitimate interests

You will be asked to provide us with some basic information so that we can set you up with an account and so that we can manage this account. We will also ask you to provide some contact information so that we can reach out to you if that is necessary in relation to our Services. We will use this information to respond to any queries you may have in relation to our Services. This information typically includes a username and a password, your name, corporate email address and phone number. We need this information in order to provide our Services to the organisation you represent (i.e., our Clients). Although much of this data is collected through direct interactions with you when you give us information by filling in forms or corresponding with us by phone, email, online or otherwise, please note that sometimes the same information may be passed onto us directly from the organisation you represent.

Information we need to promote and advertise our Services – justified on the basis our legitimate business interests

We may approach you offline or online (for example on social media) and inquire whether the organisation you represent is interested in our Services. We will use whatever information you have decided to publish on your, say, LinkedIn profile, to do that. We will also use whatever information you have decided to share with us offline by way of, say, exchanging business cards, to do that. 

We may also approach you via other online channels, such as email, if we believe our Services or any promotional materials about our Services may be of interest to the organisation you represent (i.e., our Clients). We will use your name and email address to do that.

We will contact you if you fill in any of the web forms on our website. When we do that we will use the contact details you have decided to provide in the relevant form.

We will send you our e-newsletter if you subscribe for it. We will use your name and email address to do that.

If your information has been given to us by another person, we will identify that person when first making contact with you.

Information we need to promote and advertise our Services – justified on the basis our legitimate business interests

Where you represent one of our former, current or future Suppliers, we will ask you to provide us with some basic information so that we can receive and pay for the services your organisation provides. Such information typically includes your name, corporate email address and phone number.

We may collect and use marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences.

Information generated when you browse our website – justified on the basis of your consent

When you visit our website certain technical information about the device you use to access our website that may identify you will be generated by cookies, web-beacons and other similar tracking technologies. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our Cookies Policy for the technical details about this type of data processing.

Please use the cookies banner on our website to exercise your choice regarding accepting or rejecting cookies.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data (for example, information about how you use our website, products and services) to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not generally collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. Should we do so (for example during the application or background check process for a role with Acin) we will let you know more about details about this via a separate privacy notice which will be supplied to you at the time.

We may also collect data from third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

(a) analytics providers such as Google based outside the UK

(b) advertising networks based inside OR outside the UK; and

(c) search information providers based inside OR outside the UK

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside OR outside the UK
• Identity and Contact Data from data brokers or aggregators based inside OR outside the UK.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation or in the establishment, defence or exercise of a legal claim.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications (a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosure of your information

We will treat your information as confidential information and treat it in accordance with the law, and so shall our Suppliers and all third parties do. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We use various technological solutions providers in order to deliver, manage, improve and promote our Services. Our Suppliers are prohibited from using personal data for any purpose other than the delivery of their services to us. Nevertheless, depending on their type, our Suppliers may have access to your information. These providers include our cloud storage providers, customer relationship management systems providers, email services providers, social media companies, analytics providers and others to assist us in promoting, delivering, managing and improving our Services and our website. 

In addition, we may also disclose your personal information to third parties in the following circumstances:

Purpose of disclosure	Justification
if we buy any business or assets, we may disclose your personal information to the prospective seller of such business or assets	legitimate interests (to enable the acquired business to offer services to our Clients)
if Acin or substantially all of its assets are acquired by a third party, personal information about our Clients’ and Suppliers’ representatives will be one of the transferred assets	legitimate interests (to allow the prospective buyers to provide you the Services)
if we need to protect the rights, property, or safety of Acin, our Clients, or others, we may disclose your personal information to third parties, such as professional advisors and official authorities	legitimate interests (to enforce our rights)
we may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.	legal obligation

Security over the internet

Acin operates an information security management programme that aligns with the ISO 27001 standard on information security management and have certified our compliance with this standard.  In addition, Acin has Cyber Essentials accreditation.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

Our security programme applies to all information we hold and not only to personal data. All of our key Suppliers employ industry-leading standards in information security and contractually guarantee to keep personal information secure.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Services, you are responsible for keeping this password confidential and for complying with any other security procedures that we notify you of. We ask you not to share your password with anyone.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Exports outside the EEA or the UK

Your personal information will be stored electronically on computer systems located in the United Kingdom and managed by our Suppliers. In certain limited circumstances your personal information may be accessed by staff, stored with or transferred by our Suppliers in, a destination outside the United Kingdom (“UK”) or the European Economic Area (“EEA”) in which data protection laws may be of a lower standard than in the UK or the EEA. 

Regardless of location, we will impose data protection safeguards similar to those that we deploy inside the UK and the EEA. Where required by applicable law, we will transfer your personal information subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient. Please contact us if you would like further details of the specific safeguards applied to the export of your personal data.

How long we retain your personal data

We will hold the above information for as long as is necessary in order to conduct the processing detailed above, deal with any specific issues that may raise, or otherwise as is required by law or any relevant regulatory body, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Once your Acin account is terminated or deactivated, or, in the case of Suppliers, once we end the commercial relationship with the organisation you represent, we shall delete the personal data relating to you within 12 months. However, some personal data may need to be retained for longer than this to ensure Acin can comply with applicable laws and internal compliance procedures. Such personal data may be retained for up to 6 years.

We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information may be retained) or securely destroyed. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the personal risk or harm from unauthorised use or disclosure, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your rights

Under the General Data Protection Regulation (EU) 2016/679 (and under the UK GDPR), under certain circumstances, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at the email address specified below. 

Your have the right to:

be informed (of the processing);	access (such information);	rectification (of inaccurate information);
Erasure (of such information);	restrict processing (in certain cases);	object to profiling;
data portability (in certain cases);	complain to the Information Commissioner’s Office;	withdraw consent (if we have collected your personal information on this basis).

Detailed information on the full content of your rights (and any conditions that may apply) is provided by the United Kingdom’s Information Commissioner’s Office and is available on their website: https://ico.org.uk/your-data-matters/.

Asking us to stop processing your personal data or deleting your personal data will likely mean that you the organisation you represent will no longer able to use Acin’s Services, or at least those aspects of the Services which require the processing of the types of personal data you have asked us to delete. If you represent a Supplier, asking us to stop processing your personal data or deleting your personal data will likely mean that we will no longer be able to use the third-party services that your organisation provides to us.

While we will not sell your personal data (or any other data you provide us with) to third parties, we reserve the right to share any data which has been anonymised.  You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.  

Changes to this policy

Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email. We therefore encourage you to review it from time to time to stay informed of how we are processing your information.