Introduction

Acuity Knowledge Partners (UK) Limited (for itself and on behalf of its “affiliates” within the Acuity Knowledge Partners business unit) (“Acuity”, “us”, “we”, or “our”) is a leading provider of bespoke research, analytics and technology solutions to the financial services sector, including asset managers, corporate and investment banks, private equity and venture capital firms, hedge funds and consulting firms.

This Privacy Notice is applicable to the personal data Acuity collects and explains how we collect, use, disclose, and protect your Personal Data (defined below) on Acuity website or any other websites under our control including any online services and mobile applications (“Site”). Please read this Privacy Notice carefully together with any other privacy notice or fair processing notice 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 Personal Data. This Privacy Notice supplements the other privacy notices and is not intended to override them. Your use of our website or provision of Personal Data will constitute acknowledgment of the terms of this Privacy Notice. Acuity may from time to time update this Privacy Notice. Any changes to this Privacy Notice will become effective when we post or link to the revised Privacy Notice on the Site. Please review the “LAST UPDATED” legend at the top of this page to determine when this Privacy Notice was most recently revised.

Who is covered

This Privacy Notice applies when we receive any personal information from you, our clients or other third parties, including the following circumstances:

• when you request information from us or provide information to us;
• when you or the organization you work for uses our services;
• when you or the organization you work for provide services to us;
• when you apply for a role or job opportunity with us;
• when you visit or use our Site and online services including mobile applications;
• when you visit our office locations;
• when you are entered onto our mailing lists to receive publications and other marketing emails;
• when you complete any forms on our Site;
• when you visit our hosted events or seminars;

What information is collected

Personal data means any information about an individual that identifies the individual or can be used to identify or contact the individual.
We may collect, use, store, transfer different kinds of personal data about you as required, such as the following:

• Identifying information– such as name (given or preferred), email, phone number, company name, designation, city/ location, date of birth, age, address, employment history, billing and financial information
• Contact information- such as postal address or location, telephone number, email address, IP address.
• Financial information- such as billing and financial information
• Professional information– such as job titles, employment history, employer name and details
• Transaction information- such as details about payments to and from you and other details of products and services you have purchased from us.
• Marketing and Communications data includes your preferences in receiving marketing from us and your communication preferences.
• Information collected via automated methods such as log data such operating system information, browser type, website use details, CPU speed, connection speed, the identification details of the device you use to access our website, IP address received from your browser or device to determine approximate location to assist with localization or for security purposes, metadata of emails and calendars.
• Call data– such as metadata of emails and calendars, image or video, and voiceprint for identification purposes on the automatic transcript.

If you do not provide Personal Data:

You do not have to provide us with any Personal Data to visit the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site. Where we need to collect your 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 and we may have to terminate the provisions of services or decline the requested performance of a task.

How do we collect your information

We use different sources to collect information about you including:

• Direct Interactions- You may be requested from time to time to provide your Personal Data via contact forms, registration forms, application forms, entry logs when you reach out to us:
  • on our Site to contact us;
  • to register for our any online services or mobile applications;
  • to apply to any jobs;
  • visit our office’s physical locations;
  • on our social media pages
• Third parties or publicly available data- Your data may be received by us through publicly available data and various third parties where:
  • the data is shared for company’s corporate websites, microsites and social media pages
  • the data is publicly available from corporate annual reports, SEC filings and other publicly available filings
  • the third party sharing the information with us has lawfully collected and shared the information with us;
  • we use third party tools to collect information when you visit or use our Site such as Google Analytics or Hubspot;

we may collect information from public sources such Companies House, MCA portal, news, websites or social media pages.

How we use your information

We will only use your Personal Data when the law allows us to. 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. We will process your Personal Data only if:

• where we need to perform the contract we are about to enter into or have entered with you;
• where it is in 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 or regulatory obligation
• where we have your consent or where a third party has shared your information and they have your consent to use your information

We may use your Personal Data to:

• provide and improve our services and products to you or the organisation you work for (including auditing and monitoring use of those services and products);
• maintain and develop our relationship with you and our clients;
• monitor and analyse our business;
• facilitate our internal business operations;
• fulfil our legal, regulatory (including in relation to anti-money laundering or sanction requirements), accounting, reporting, risk management or professional obligations;
• identify services you may be interested in;
• send you updates, publications, marketing and details of events;
• protect, establish, exercise or defend legal rights; and
• process and respond to requests, enquiries or complaints received from you.
• enable registration/sign-up and the upkeep of your accounts.
• Deliver content tailored to your location.
• Analyze and comprehend Our audience, refine Our service (including user interface experiences), enhance recommendation algorithms and delivery mechanisms, which could necessitate sharing personal information with Our group entities, affiliates, or third-party service providers.
• Assist advertisers in comprehending Our audience and confirming the efficacy of advertising on Our Site (usually in the form of aggregated traffic statistics for various site pages), while also providing you with pertinent advertisements.
• Present you with interest-based content such as newsletters, blogs, articles, whitepapers, stories, and news on our site.
• Facilitate your involvement in our in-person events, webcasts and webinars hosted on the Site or any external location.
• Correspond with you regarding Our service (e.g., via email), to share updates on new features and content available, promotional announcements, surveys, and to assist you with operational needs like password resets.
• Enable participation in interactive features offered through Our Services.
• Offer trial /pilot access to Acuity BEAT suite of tools and technologies
• Share with Our customer support team to address your inquiries/concerns related to your rights or the services provided to you.
• To provide, update, maintain and protect our services. This includes the use of information to support delivery of the services under a customer agreement, prevent or address service errors, security, or technical issues, analyse and monitor usage, trends and other activities, or at an authorised user’s request.
• To develop and provide search, learning and productivity tools and additional features. It is in our interest and in the interest of customers to continuously improve and develop the customer support, features and user experience that we provide.
• Account information is used to communicate with enterprise customers to resolve their queries or requests. Account information is used to send service emails and other relevant operational communications to enterprise customers. Additionally, account information is used for billing and invoicing tracking purposes, account management and other administrative matters.
• To operate sweepstakes, contests, and similar promotions.

Your anonymized and/or pseudonymized information may be used:

• to enhance the design and content of our Site, ultimately providing you with an improved browsing experience
• to assess content performance and analyze marketing effectiveness, reach, comparison, our digital services use to improve our services.
• to enhance personalized communications and offers for you
• to monitor user behavior on our Site

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.

Who will have access to my information?

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. We may have to share your personal data with the parties set out below for the purposes set out in paragraph 5 above:

a) Intra-group transfers- We may share your information within affiliate companies from the Acuity Knowledge Partners business unit i.e. Acuity affiliates operating from different geographical jurisdictions other than the location where you submitted the information to perform its legal duties or offer the necessary services required by the technology.

Business Transfers: Your information may be shared or transferred during events like mergers, sales of company assets, financing arrangements, or acquisitions involving all or part of our business with another company.

b) Third-Party Service Providers- We may provide Personal Data to third-party service providers including but not limited to, data analytics, order fulfillment, payment processing, virtual computing, hosting, storage services, cloud service providers, promotions and surveys, background checks and other services. Additionally, certain selected third parties may use tracking technology on our website services to analyse your interactions with them over time, helping us improve our content and understand online activity.

Furthermore, we may disclose your information to specific third parties. We’ve categorized each party to provide clarity regarding the purpose of our data collection and processing practices. If your data was processed based on your consent and you wish to withdraw that consent, please do not hesitate to contact us at privacy@acuitykp.com or unsubscribe from our mailing list by contacting unsubscribe@acuitykp.com

Where we transfer your information internationally, we will take reasonable steps to ensure that your information is treated securely and the means of transfer provides adequate safeguard.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. 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 DO NOT share, sell, rent, or trade your information with third parties.

Data Retention

We’ll retain your personal information only for as long as it’s essential for the purposes outlined in this Privacy Notice, unless the law mandates or permits a lengthier retention period, such as for tax, accounting, or legal obligations. None of the purposes mentioned in this notice will require us to hold your personal information beyond the duration of your account with us.

Once there’s no longer a valid business need to handle your personal data, we’ll either delete it or anonymize it. If deletion or anonymization isn’t immediately feasible, like in cases where your information is stored in backup archives, we’ll securely store it and segregate it from further processing until we can carry out the deletion.

General data is retained by us for a maximum of 7 years, with regulatory and financial data retained for a maximum of 10 years.

We regularly review and delete any data that is no longer needed

Protection of Data

Acuity has established reasonable organizational and technical measures to protect Personal Data within our organization from loss, misuse, or unauthorized access, disclosure, alteration or destruction. These measures encompass internal assessments of our data collection, storage, processing practices, and security procedures, involving appropriate encryption and physical safeguards to prevent unauthorized entry into systems containing personal data. All data collected through Acuity Knowledge Partners websites is securely stored in an encrypted database. This database is housed on firewalled servers, with access restricted by passwords and tight limitations. While our security measures are robust, it’s important to acknowledge that no security system is entirely invulnerable. We cannot ensure absolute database security, nor can we guarantee that information transmitted to us over the internet will not be intercepted. Additionally, any details shared in discussion areas can be accessed by individuals with internet connectivity.

International Transfer

Transferring your personal data outside the United Kingdom (UK) and People’s Republic of China (PRC)

Information we hold about you may be transferred to other countries (which may include countries outside the UK, PRC or the European Economic Area (“EEA”)):

• where Acuity Knowledge Partners do business;
• which are linked to your engagement with Acuity Knowledge Partners;
• from which you regularly receive or transmit information; or
• where Acuity Knowledge Partners third parties conduct their activities.
• Locations that are contractually agreed with you as an enterprise customer.

These countries may have less strict privacy laws than the UK, PRC, or EEA, which could result in disclosure of your information to regulatory agencies, governmental bodies, or private individuals. When we or our permitted third parties transfer your data outside the UK, PRC, or EEA, we will impose contractual obligations on the recipients of the data to ensure that they protect your personal data to the same standard as required in the UK, PRC, and EEA.

Notice to Residents of the Peoples Republic of China

Your Rights Under the China Personal Information Protection Law (“PIPL”)
Pursuant to the China Personal Information Protection Law (“PIPL”), and subject to certain exceptions and limitations, residents of the Peoples Republic of China can contact us to exercise the rights described below with respect to certain personal information that we hold about them. Relatives of deceased persons about whom we hold personal information may, for their own lawful and legitimate interest, exercise these rights. To the extent those rights apply to you, they are described below.

Lawful basis for data collection and processing

We use Personal Data for legitimate business purposes, including the following:

Fulfillment of Requests. Acuity Knowledge Partners may use Personal Data about you to deliver products and services to you and provide you with information about products and services you’ve ordered. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.

Other Communications. From time to time, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If your employer is Acuity Knowledge Partners customer, we may also inform you of such products, programs, services and promotions using Personal Data about you that your employer provided to Acuity Knowledge Partners. If you would prefer that we not send electronic marketing messages to you, please see the “Your Choices” section below.

Furthermore, we may process your data or disclose it based on the following legal grounds:

• Consent: If you have provided us with specific consent to use your personal information for a particular purpose, we may process your data accordingly.
• Legitimate Interests: We may process your data when it is reasonably necessary to pursue our legitimate business interests.
• Performance of a Contract: In cases where we have a contractual agreement with you, we may process your personal information to fulfil the terms of that contract.
• Legal Obligations: We may disclose your information if legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes. This includes situations like responding to court orders or subpoenas, including those from public authorities for national security or law enforcement purposes.
• Vital Interests: Your information may be disclosed when we believe it is necessary to investigate, prevent, or take action regarding potential policy violations, suspected fraud, potential threats to safety, illegal activities, or as evidence in litigation in which we are involved.

Data Subject Rights

Where can I file a request to access, rectify or remove my data?

We acknowledge and uphold the rights granted to individuals under their respective local Data Protection legislation. If these rights apply to you, you can exercise them regarding the data we have by reaching out to us at the address provided below. These rights encompass:

• The right to receive information about the processing of your personal data and to understand what data we possess.
• The right to correct or rectify the information we hold.
• The right to access your data and exercise data portability rights.
• The right to have your data erased (the right to be forgotten).
• The right to withdraw any previously granted consents, such as those for direct marketing communications.
• The right to opt out of the sale of your data (in accordance with the California Consumer Protection Act of 2018 “CCPA” and Virginia Consumer Data Protection Act “VCDPA”).
• The right to non-discrimination for exercising your rights.
• The right to object to or request human intervention in fully automated decisions.
• The right to file a complaint with a local Privacy and Data Protection Regulatory body.
• There are additional rights pertaining to the China Personal Information Protection Law (“PIPL”), as described above in this document.

For any inquiries or comments regarding your privacy rights, please do not hesitate to contact us at privacy@acuitykp.com Contact us

You may also have the right to submit a complaint to the relevant supervisory authority in your jurisdiction.

If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

Cookies we use and its purpose of collection/use

A cookie is a small text file delivered to and stored on a visitor’s computer. We may use cookies on our website in order to help us improve your experience when you browse our Site.

We categorize cookies used on our Site into four types:

• Strictly necessary- Strictly necessary cookies are essential for the Website to function properly and cannot be disabled in our systems. They are typically activated in response to actions you take that require services, such as setting privacy preferences, logging in, or filling out forms.
• Analytics and Performance- Analytics and Performance cookies help us track website analytics by counting visits and traffic sources, allowing us to measure and improve the Website’s performance. These cookies may be set by us or by third-party providers, and they help us determine which pages and videos are the most and least popular and how visitors navigate the Website.
• Functional- Functional cookies provide enhanced functionality and personalization based on your interactions with the Website. Like Analytics and Performance cookies, these may be set by us or by third-party providers, whose services we have incorporated into our pages.
• Advertising and Targeting- Advertising cookies may be set by our advertising partners, such as Adobe, and they enable those companies to create a profile of your interests and display relevant ads on other websites.

Do Not Track

Do Not Track (“DNT”) is a preference in your browser that you can enable to warn websites you visit that you do not want them to collect certain information about you. Acuity does not respond to DNT signals. If you object to Acuity’s practice with respect to DNT signals, you may choose not to participate in or use Acuity’s services by following the procedure described below.

As part of Acuity’s Online Advertising Effectiveness Program, Acuity authorizes its contractors, partners or customers to discontinue, deploy or develop third-party technologies to facilitate audience measurement and advertising recall activities. Acuity assumes no responsibility for third parties’ compliance with or response to DNT signals.

Use of this Site by Minors

This Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through this Site. We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

Privacy Notice revisions

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

Applicable Privacy Laws

This notice is defined and adopted to the best of our efforts to comply with the privacy laws EU GDPR, UK GDPR, CCPA, PIPL, India’s DPDP wherever Acuity operates from.