Please read this policy carefully before using Acin’s Services.
Acin Limited (“Acin“, “our”, “us” or “we”) is a company registered at Abbey House, 282 Farnborough Road, Farnborough, Hampshire, England, GU14 7NA under Company Number 08632362 and ICO registration number ZA193862.
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“) and in connection with our Services.
This policy is addressed to our Clients’, Suppliers’ and prospective Clients’ and Suppliers’ employees, contractors, agents and any other authorised representatives (“you” or “your“). 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.
Information we collect
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 user name 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 (ie our Clients). 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 (ie 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.
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.
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.
Disclosure of your information
We will treat your information as confidential information and so shall our Suppliers do. 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 we are working towards certifying against it. Our security programme applies to all information we hold and not only to personal data. All of our key Supplier 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.
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. 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), 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’ 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.
Where we send your data
Questions, comments and requests regarding this privacy policy are welcome and should be addressed to [email protected]