Privacy policy

Welcome to Acumen Intelligence and our website at www.acumenintelligence.com (our “website”). At Acumen Intelligence, we are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.

WHAT IS PERSONAL DATA?

Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

WHAT IS PROCESSING?
“Processing” means and covers virtually any handling of data.

WHAT LAW APPLIES?
We will only use your Personal Data in accordance with the applicable data protection laws, in particular Singapore’s Personal Data Protection Act 2012 (“PDPA”) and the EU’s General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

WHO IS RESPONSIBLE FOR DATA PROCESSING?
The responsible party within the meaning of the above is Acumen Intelligence Solutions Pte. Ltd of Midview City, 22 Sin Ming Lane, #06-79, 573969, Singapore (“Acumen Intelligence”, “we”, “us”, “our”). If you want to contact us or if you have any questions, you can reach us using our Contact Form.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA
In accordance with the DPA and the GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent; b) the data is necessary for the fulfilment of a contract/pre-contractual measures; c) the data is necessary for the fulfilment of a legal obligation; or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
We may collect and process the following Personal Data about you:

a) Personal Data that you give us:

This is information about you that you give to us by filling in forms on our website or correspond with us by telephone, post, email, or otherwise. It may include, for example, your name, address, email address, and telephone number; information about your business relationship with us; and information about your requirements and interests.

We also process the Personal Data involved in your use of our services, such as your contact information, full name, email, postal address, and phone number, and the data related to your use of our services and the contract between us, in order to be able to provide our contractual services. This includes in particular, our support, correspondence with you, invoicing, and fulfilment of our contractual, accounting, and tax obligations. In general, the data related to your contract with us is saved and stored using the services of Amazon (AWS). Accordingly, the data is processed on the basis of your consent, fulfilling our contractual obligations and our legal obligations.

b) Personal Data that our website and other systems collect about you:

If you visit our website, it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information, such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website.

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the PDPA and the EU’s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our Cookie Policy.

DATA PROCESSING THROUGH THIRD-PARTY SERVICES
We use the content or service offers of third-party providers on the basis of our legitimate interests in order to integrate their content and services (“Content”) on our website. This always requires that the third-party providers of this Content are aware of the IP address of the user, as without the IP address they would not be able to send the content to their browser. The IP address is therefore necessary for the display of this content.

The following provides an overview of third-party providers and their content, together with links to their privacy policies, which contain further information on the processing of data and so-called opt-out measures, if any: a) Hosting: HostGator.com a service operated by Newfold Digital Inc.; b) Fonts: Google Fonts from Google; and c) Tag Management: Google Tag Manager from Google.

HOW WILL WE USE YOUR PERSONAL DATA?

We may collect, store, and use your Personal Data for the following purposes:

  • to operate, manage, develop, and promote our business and, in particular, our relationship with you and related transactions, including, for example:
  1. marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to send you communications which we believe to be relevant and of use to you);
  2. accounting and billing/payment purposes;
  3. to operate, administer, and improve our website and other aspects of the way in which we conduct our operations;
  4. to offer you our services;
  5. to provide you with services or information that you may have requested; and
  6. to keep you informed and updated on relevant topics or services you may be interested in.
  • to protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes;
  • to comply with our legal and regulatory obligations, bring and defend legal claims and assert legal rights; and
  • if the purpose is directly connected with an assigned purpose previously made known to you.

We will only process your Personal Data as necessary so that we can pursue the purposes described above and where we have a legal basis for such processing. Where our lawful basis for processing is that such processing is necessary to pursue our legitimate interests, we will only process your Personal Data where we have concluded that our processing does not prejudice you or your privacy in a way that would override our legitimate interest. In exceptional circumstances, we may also be required by law to disclose or otherwise process your Personal Data.

DATA SHARING
In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.

a) Internal

If necessary, we transfer your Personal Data within Acumen Intelligence. Access to your Personal Data is only granted to authorised employees who need access to the data due to their job, e.g., to provide our services or to contact you in case of queries.

b) External bodies

Personal Data is transferred to our service providers in the following instances:

  • in the context of fulfilling our contract with you,
  • to use marketing services and to advertise our services online,
  • to communicate with you,
  • to provide our website, and
  • to state authorities and institutions as far as this is required or necessary.

c) International transfers

We may transfer your Personal Data to other companies as necessary for the purposes described in this Privacy Policy. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements including Processing Agreements that include Standard Contractual Clauses and Non Disclosure Agreements covering such transfers. We take all reasonable technical and organisational measures to protect the Personal Data we transfer.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will delete your Personal Data when we no longer need such Personal Data, for instance where:

  • it is no longer necessary for us to retain your Personal Data to fulfil the purposes for which we had collected it;
  • we believe that your Personal Data that we hold is inaccurate; or
  • in certain cases where you have informed us that you no longer consent to our processing of your Personal Data.

Sometimes, however, there are legal or regulatory requirements which may require us to retain your Personal Data for a specified period, and in such cases we will retain your Personal Data for such specified period; and we may need to retain your Personal Data for certain longer periods in relation to legal disputes, and in such cases we will retain it for such longer periods to the extent required.

DATA SECURITY
Our website uses SSL or TLS encryption to ensure the security of data processing and to protect the transmission of confidential content, such as orders, login data or contact requests that you send to us. We have also implemented numerous security measures (“technical and organisational measures”) for example encryption or need to know access, to ensure the most complete protection of Personal Data processed through our website.

MARKETING
Insofar as you have given us your separate consent to process your data for marketing and advertising purposes, we are entitled to contact you for these purposes via the communication channels you have given your consent to.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or contractual relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or contractual relationship with us.

Direct Marketing generally takes the form of email but may also include other less traditional or emerging channels. These forms of contact will be managed by us, or by our contracted service providers. Every directly addressed marketing sent or made by us or on our behalf will include a means by which you may unsubscribe or opt out.

YOUR RIGHTS AND PRIVILEGES

a) Privacy rights
You can exercise the following rights under the PDPA:

  • Right to access
  • Right to correction
  • Right to erasure
  • Right to opt-out
  • Right to data portability

You can exercise the following rights under the GDPR:

  • Right to information
  • Right to rectification
  • Right to object to processing
  • Right to deletion
  • Right to data portability
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing.

b) Singapore Spam Control Act 2007(SCA)
The SCA is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with SCA, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.

c) Updating your information and withdrawing your consent
If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to legitimate interest processing, please do so by contacting us.

d) Access Request
In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.

e) Complaint to a supervisory authority
You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority. The supervisory authority in Singapore is the Personal Data Protection Commission (www.pdpc.gov.sg).

f) What we do not do

  • We do not request Personal Data from minors and children.
  • We do not process special category data without obtaining prior specific consent.
  • We do not use automated decision-making, including profiling.
  • We do not sell your Personal Data.

USA SPECIFIC PROVISIONS
The following applies to users located in the United States. While we understand and appreciate that privacy and consumer data protection laws differ as they are subject to each state’s legislature and that no data protection framework similar to the PDPA or GDPR exists on a federal level, we are committed to follow and apply the for your state relevant privacy rules and regulations.

As of the day of drafting, the following states had enacted privacy and consumer data protection laws: California, Colorado, Connecticut, Delaware, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia. Under consideration of the similarities of the above provisions, no conflict should arise pursuing a uniform approach in granting all users in the USA the same rights and privileges as set out above. However, should ambiguity occur the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your Personal Data.

Further, the following also apply

  1. “Shine the Light”
    “Shine the Light” law (Civil Code Section 1798.83) requires us to respond to requests from California asking about the business’s practices related to disclosing Personal Data to third parties for the third parties’ direct marketing purposes. You may make a request about our collection and disclosure of your Personal Data using the contact details provided.
  2. COPPA (Children Online Privacy Protection Act)
    When it comes to the collection of Personal Data from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.
  3. CAN SPAM Act
    The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.
  4. Telephone Consumer Protection Act (TCPA)
    If we process your Personal Data for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalised direct advertising per SMS.
  5. Controls For Do-Not-Track Features
    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalised. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this policy.
  6. Right to complain
    Finally, and in regard to the right to complain to a supervisory authority. You have the right to lodge a complaint about our processing of Personal Data with a supervisory authority responsible for data protection. Users based in the above mentioned States may lodge a complaint with the relevant district attorney or attorney general office. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.

GCC SPECIFIC PROVISIONS
The Gulf Cooperation Council (GCC) has recently introduced data protection laws that are similar to the European Union’s General Data Protection Regulation (GDPR). In particular, Saudi Arabia’s Personal Data Protection Law (PDPL), the UAE’s Federal Decree-Law No. 45 of 2021, Bahrain’s
Personal Data Protection Law (PDPL) and Oman’s Personal Data Protection Law (PDPL) are the relevant provisions in the GCC region. Further and under consideration that the GDPR has played a pivotal role, no conflict should arise pursuing a uniform approach in granting all users in the GCC region the same rights and privileges as set out above. However, should ambiguity occur, the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your personal data.

HELP AND COMPLAINTS
If you have any questions about this policy or the information we hold about you, you can reach us using our Contact Form.

CHANGES
The first version of this policy was issued on Wednesday, 10th of October, 2024, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.