Privacy and Cookies Policy

1. Introduction

1.1    We are committed to safeguarding the privacy of accelerationpartners.com visitors and service users.

1.2    This policy applies where we are acting as a data controller with respect to the personal data of accelerationpartners.com; in other words, where we determine the purposes and means of the processing of that personal data.

1.3    You will have the option to opt-out of cookies when you first visit our website, in accordance with the terms of this policy when you first visit our website.

1.4    Our website incorporates privacy controls which affect how we will process your personal data. You can limit the publication of your information by contacting us at support@accelerationpartners.com.

1.5    In this policy, “we”, “us” and “our” refer to Acceleration Partners, LLC, a Massachusetts limited liability company, including all its U.S. subsidiaries: (i) Grovia Inc. (a Washington corporation), and (ii) IR Volt, LLC (a Delaware limited liability company).

 

2. How we use your personal data

2.1    In this Section 2 we have set out:

(a)    the general categories of personal data that we may process;

(b)    in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    the purposes for which we may process personal data; and

(d)    the legal bases of the processing.

2.2    We may collect and process data about your use of our website and services (“usage data“). The categories of usage data may include your name, email, job title, IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system and user input. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

2.3    We may collect and process your account data (“account data“).The categories of account data may include your name, email address, and company information. The source of the account data is your IP information and/or the information you have submitted to our website. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

2.4    We may collect and process your personal information included in your personal profile on our website (“profile data“).The categories of profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent.

2.5    We may collect and process personal information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent.

2.6    We may collect and process personal information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is your consent.

2.7    We may collect and process personal information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

2.8    We may collect process personal information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping] The legal basis for this processing is our legitimate interests, namely the communications with users or interested parties.

2.9    We may collect and process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2.10  We may collect and process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

2.11  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.

2.13  Listed below are the categories of the personal data that we collect: First Name, Last Name, Job Title, IP Information (IP address, inferred location), content downloads and page views on accelerationpartners.com

2.14  Listed below is where we store data (3rd parties): Marketo, Salesforce, BrightInfo, Zoom Webinar, SpotDraft, Google Drive and ClientPULSE). All data will be stored in Salesforce and Marketo.

2.15  Listed below is where we collect data on our website (accelerationpartners.com)

• Contact forms
• Content forms (Registering for webinars and downloading content)
• Email opt-in (footer of website, side column on blog page, bright info widget pop-up)
• Blog opt-in form
• Cookies

 

3. Automated decision-making

3.1    We will use your personal data for the purposes of automated decision-making in relation to sending relevant emails and outreach based on actions and preferences.

3.2    This automated decision-making will involve outreach catered to the specific actions you took on our website or emails.

 

4. Providing your personal data to others

4.1    We may disclose your personal data to any member of our group of companies (this means our affiliates, subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

4.2    We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

4.3    In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.’

 

5. International transfers of your personal data

5.1    We are located in the United States.  Information that we collect will be stored and processed in the United States in accordance with this Privacy Policy. To facilitate our global operations, we may transfer and access personal information from around the world, including to the United States. This Privacy Policy shall apply even if we transfer personal information to other countries.  You understand that by accessing the accelerationpartners.com website or providing us with any personal information, your personal information will be processed by us in the United States, which is a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside.  Note that your personal information may be available to the United States government or its agencies under legal process in the United States.  Acceleration Partners complies with legal requirements for cross-border data protection, including through the use of European Commission-approved Standard Contractual Clauses.  In addition, Acceleration Partners is self-certified under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, as described below.  Personal information from UK, Swiss and EU residents will be treated in accordance with the Data Privacy Framework Principles.  To exercise any legal right to see copies of the data transfer mechanism documents that Acceleration Partners uses to transfer data to third parties, please contact us.

 

6. California Residents

6.1    Pursuant to California’s “Shine The Light” law (California Statute § 1798.983), California residents are entitled to request, once a year and free of charge, certain information regarding what types of their personal information may be shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. Under the law, a business is to either provide California customers certain information upon request or permit California customers to opt out of this type of sharing.  You may request this information by contacting us at dporequest@accelerationpartners.com and indicate in the email subject line, “California Shine The Light Request.”  Please include your mailing address, state of residence and email address with your request.

6.2    California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)

• The CCPA and CPRA provides California residents with five major privacy rights:

1. 1. Right to delete personal information collected from you;
   2. Right to correct inaccurate information they have about you;
   3. Right to request a business to disclose to you: (a) categories and/or specific pieces of personal information they have collected about you; (b) categories of sources for that personal information; (c) purposes for which the business uses that information; (d) categories of third parties with whom the business discloses the information; and (e) categories of information the business sells or discloses to third parties;
   4. Right to opt-out of sale or sharing;
   5. Right to limit use and disclosure of sensitive personal information.

In addition, California residents can be notified of the types of personal information a business is collecting and what they may do with the information. For more information about your rights, please visit https://cppa.ca.gov/faq.html.

• We are a covered business under the CCPA and CPRA as it collects and process the personal information of California residents. This Privacy Policy provides the required notices to California residents.
• We do not presently sell personal information to third parties for any purpose.
• To make a “request to know” or request to delete your personal information, send us an e-mail at dporemoval@accelerationpartners.com. (Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.) You may also submit these requests via an online form or by mailing your request to address in the United States:

 

Data Protection Officer
Acceleration Partners
6 Liberty Square
PMB 96813
Boston, MA 02109

 

• We will honor these requests for US individuals whether or not you would qualify as a California consumer under the CCPA and CPRA.
• We will confirm receipt of your request within 10 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your personal information within 45 days of receipt of your request but can use an additional 45 days, but we must let you know the additional time is needed.
• When contacting us, we may ask you to provide certain, limited personal information, such as your name, email address and/or username to verify your request and to match with our records and systems. This is to protect against fraud.  We will not retain this personal information or use it for any other purpose.  And we need to search our records and systems only for the preceding 12 months.

6.3  Residents of other states may also have similar rights to request information about or delete their personal information.  To inquire about exercising these rights, please contact us at dporemoval@accelerationpartners.com.

 

7. Retaining and deleting personal data

7.1    When you apply to a job on this site, the personal data contained in your application will be collected by us (“Controller”). Your personal data will be processed for the purposes of managing the Controller’s recruitment related activities, which include setting up and conducting interviews and tests for applicants, evaluating and assessing the results thereto, and as is otherwise needed in the recruitment and hiring processes. Your personal data will be retained by Controller, in accordance with data compliance standards (GDPR, CCPA, PCI, etc.), as long as Controller determines it is necessary to evaluate your application for employment.

The Controller’s Data Protection Officer (DPO) oversees compliance with recruiting candidate personal data collection (GDPR, CCPA, PCI, etc.). If you have any questions about this privacy notice or how we handle your personal data, please contact the DPO at dporequest@accelerationpartners.com.

If you would like your application/data REMOVED from all Controller related recruiting systems, please contact the Data Protection Officer at dporemoval@accelerationpartners.com.

7.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

 

8. Amendments

8.1    We may update this policy from time to time by publishing a new version on our website.

8.2    You should check this page occasionally to ensure you agree with any changes to this policy.

8.3    We may notify you of changes to this policy by email or through the private messaging system on our website.

 

9. Your rights

9.1    You may instruct us to:

• delete personal information we hold about you;
• correct inaccurate information we have about you;
• disclose:

• categories and/or specific pieces of personal information they have collected about you;
• categories of sources for that personal information;
• purposes for which the business uses that information;
• categories of third parties with whom the business discloses the information; or
• categories of information the business sells or discloses to third parties;

9.2    We may withhold personal data that you request to the extent permitted by law.

9.3    You may instruct us at any time not to process your personal data for marketing purposes.

9.4    In practice, you will usually either expressly agree in advance to our use of your personal data for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal data for marketing purposes.

 

10. Third party websites

10.1    Our website includes hyperlinks to, and details of, third party websites.

10.2    We have no control over, and are not responsible for, the privacy policies and practices of third parties.

 

11. Personal data of children

11.1    Our website and services are targeted at persons over the age of 18.

11.2.   If we have reason to believe that we hold personal data of a person under that age in our databases, please inform us and we will delete that personal data.

 

12. Updating information

12.1    Please let us know if the personal data that we hold about you needs to be corrected or updated.

 

13. Acting as a data processor

13.1    In respect of data controlled and collected by the clients we represent, we do not act as a data controller; instead, we act as a data processor.

13.2    Insofar as we act as a data processor rather than a data controller, this policy shall not apply. Our legal obligations as a data processor are instead set out in the contract between us and the relevant data controller.

 

14. About cookies

14.1    A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. More about cookies here.

14.2    Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

14.3    Cookies do not typically contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies.

 

15. Cookies that we use

15.1    We use cookies for the following purposes:

(a)    authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are stored in Marketo). Marketo is a marketing automation tool focused on email, mobile, social, digital ads, web management and analytics.

(b)    status – we use cookies to help us to determine if you are logged into our website.

(c)    personalisation – we use cookies to store information about your preferences and to personalise the website for you (cookies used for this purpose are: BrightInfo and Marketo.

(d)   advertising – we use cookies to help us to display advertisements that will be relevant to you, cookies used for this purpose are for Google, Facebook, LinkedIn, Twitter and other paid marketing initiatives.

(e)    analysis – we use cookies to help us to analyse the use and performance of our website and services, cookies used for this purpose include Google Analytics.

(f)    cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally

 

16. Cookies used by our service providers

16.1    Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

16.2    We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google provides further information about its own privacy practices and offers a browser add-on (https://tools.google.com/dlpage/gaoptout)  to opt out of Google Analytics tracking.

16.3    We use Marketo as our Marketing Automation Platform. This service uses cookies to track web visitor behavior and assist with our sales and marketing activities. You can view the privacy policy of this service provider at https://documents.marketo.com/legal/privacy/.

 

17. Managing Cookies

17.1    Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

(a)    https://support.google.com/chrome/answer/95647?hl=en (Chrome);

(b)    https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);

(c)    http://www.opera.com/help/tutorials/security/cookies/ (Opera);

(d)    https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);

(e)    https://support.apple.com/kb/PH21411 (Safari); and

(f)    https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).

17.2    Blocking all cookies will have a negative impact upon the usability of many websites.

17.3    If you block cookies, you will not be able to use all the features on our website.

 

18. Our details

18.1    This website is owned and operated by Acceleration Partners, LLC.

18.2    We are registered in the United States under registration number 42-1751446 and our registered office is at 6 Liberty Square, PMB 96813, Boston, MA 02109, US

18.3    Our principal place of business is at 6 Liberty Square, PMB 96813, Boston, MA 02109, US

18.4    You can contact us:

(a)    the postal address given above

(b)    using our website contact form

(c)    the contact number published on our website from time to time

(d)    by email, using info@accelerationpartners.com

 

19. Data protection officers

19.1  Our data protection officers’ contact details are:

• Shane Gibbons – sgibbons@accelerationpartners.com; and
• Krislyn Huan – khuan@accelerationpartners.com

 

20. Processing Data between the EU and US

20.1    Acceleration Partners, LLC (a Massachusetts limited liability company), including all its U.S. subsidiaries: (i) Grovia Inc. (a Washington corporation), (ii) IR Volt, LLC (a Delaware limited liability company), hereinafter collectively referred to as “Acceleration Partners”, complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce.  Acceleration Partners has certified to the U.S. Department of Commerce that it adheres to:

• the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF; and
• the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.

If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

20.2    In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Acceleration Partners commits to resolve DPF Principles-related complaints about our collection and use of your personal information.  EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF should first contact Acceleration Partners’ data protection officers as provided in section 19.

20.3    If Acceleration Partners’ internal complaints mechanism is unable to resolve such complaints, in compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Acceleration Partners commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

20.4  Acceleration Partners is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

20.5    If Acceleration Partners fails to resolve your complaint, you may have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding DPF compliance not resolved by any other internal or independent recourse mechanisms. To learn more, please visit Annex I of the DPF for additional information here.

20.6    Acceleration Partners is required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements

20.7    You have the opportunity to choose (i.e., opt out) whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you, as provided under Section 9. To make a “request to know” or request to delete your personal information, send us an e-mail at dporemoval@accelerationpartners.com. (Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.) You may also submit these requests via an online form or by mailing your request to address in the United States:

 

Data Protection Officer
Acceleration Partners
6 Liberty Square
PMB 96813
Boston, MA 02109

 

20.8       You have the opportunity to choose (i.e., opt out) whether your personal information is (i) to be disclosed to a third party or (ii) to be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you, as provided under Section 9

20.9       Acceleration Partners accepts liability for onward transfers of personal data to third parties for processing.

20.10    You have the right to access your personal data as provided under Section 9. You shall have access to personal information about you that we hold and you have the right to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question, or where the rights of persons other than the individual would be violated. To exercise your rights, please make a “request to amend ” or request to delete your personal information, send us an e-mail at dporemoval@accelerationpartners.com. (Please put either “Request to Amend” or “Request to Delete” in the subject heading of your email.) You may also submit these requests via an online form or by mailing your request to address in the United States:

 

Data Protection Officer
Acceleration Partners
6 Liberty Square
PMB 96813
Boston, MA 02109