NOTICE OF PRIVACY PRACTICES FOR ACUMEN
WE CARE ABOUT YOUR PRIVACY
As of September 2019
At Acumen Fund, Inc. (“Acumen,” “we,” “our,” “us”), we understand and appreciate that your decision to choose us for your philanthropic investment is an expression of confidence. You trust us with your investment and you trust us to keep secure any information we obtain from you or about you. We understand that privacy is important, and we are strongly committed to protecting the privacy of both our current and prospective investors as well as visitors to our Website.
We have structured our Website so that you can visit it without identifying yourself or revealing any Personal Data. If you choose to provide us with information by which you can be identified, you can be assured that it will only be used in accordance with this Privacy Statement.
WEBSITE PRIVACY STATEMENT
By accessing and using the Website, you agree that you have read and understand this Privacy Statement and that you accept and consent to the privacy practices and uses or disclosures of information about you that are described herein.
I. INFORMATION WE COLLECT
Our primary goals in collecting Personal Data are to share information about our work, to invite you to events designed to update you on Acumen’s activities, to allow you to request information, and to thank you for your support. However, in order to deliver personalized and relevant information to you through our Website, we collect certain information from users. Please do not provide any sensitive information or health information. If you should do so inadvertently, we will use and disclose that information in the same manner as any other information you provide to us as more fully described below.
In operating our website, we may collect and process the following data or information about you:
A. INFORMATION YOU PROVIDE
- If you make a donation to Acumen, we will request Personal Data, such as your name, address, phone number, and email address. We seek such information to facilitate your donation and communicate with you about it. In addition, we may use this information to update you on Acumen’s work and to request your attendance at events, such as our Investor Gathering, to increase your knowledge of Acumen’s investments, to improve our marketing and promotional efforts, and to answer any questions that you may have.
- Unless you specify that a gift be “anonymous” or otherwise request that your name not be listed, we list the names of our Partners in our Website, brochures, and other materials to recognize the generosity of those who support Acumen. We do not sell or rent our donor lists to anyone. We also do not share your personal data with any third parties other than service providers we employ to perform functions on our behalf, such as sending postal mail and email, processing credit card payments, and organizing events specifically designed to keep you abreast of Acumen’s activities. These companies and individuals have access to Personal Data needed to perform their functions, but are not authorized to use it for any other purpose.
- If you post a comment on Acumen’s Website, Acumen will collect your name, email address, and your Website (if you choose to share your Website). Acumen may publicly display your name and Website with your comment, but your email address will not be published.
B. INFORMATION COLLECTED AUTOMATICALLY
We may collect information used primarily to provide an enhanced online experience, including, but not limited to, traffic data, location data, weblogs, and other communication data, including your IP address, the date and time you accessed or left the Website and which pages you viewed, the type of operating system in use [e.g. Macintosh, Windows], the domain name, and the type of browser being used [e.g. Firefox, Chrome, Internet Explorer, etc.].
We do not track or collect personally identifiable information about our Website users unless you choose to subscribe for Acumen updates via e-mail and/or make a donation through our Website. Our Website does not have the ability to respond to a ‘do not track’ signal on a user’s browser.
II. USE OF YOUR INFORMATION
Acumen will not sell your Personal Data to third parties. However, Acumen will use the information we collect for the following purposes:
- To share or disclose information with your consent.
- To comply with applicable law, regulation, or governmental request; to protect the safety of Acumen, Website users, or others; to protect the rights or property of Acumen; to comply with contractual obligations of Acumen; and other instances when Acumen is legally required to disclose your information.
- To share information that is public or does not include Personal Data, such as aggregated data or a publicly posted comment.
- To provide you with information relating to our services.
- To provide third parties with statistical information about the users of our website.
- To any affiliated business entities or third parties necessary to provide services to you, including, but not limited to, our subsidiaries, our holding company and its other subsidiaries (if any), as well as third parties involved in the administration and operation of our services.
- To a third party if we sell any or all of our business and/or assets to them.
III. SECURITY AND RETENTION OF PERSONAL DATA
We maintain a risk-based approach to physical, administrative, and technical security measures to protect the confidentiality, availability, and integrity of your Personal Data, including encrypting financial donations using SSL. You should be aware, however, that no transmission of data over the Internet is 100% secure, and that unauthorized third parties may unlawfully intercept or access private data. You provide us with this information at your own risk.
We retain your Personal Data:
- For as long as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
- For as long as necessary for the purpose for which we collect it.
IV. THIRD-PARTY WEBSITE INTERACTION
By accessing other third-party websites through our Website, you are consenting to the terms and privacy policies of those third-party websites. We do not accept any responsibility or liability for their policies whatsoever, as we have no control over them. We do not have control over whether third parties track a user’s online activities over time and across different websites. We do not have the ability to respond to ‘do not track’ signals in this regard.
VI. YOUR RIGHTS REGARDING PERSONAL DATA
Investors and those who visit our Website, including you, may have a variety of legal rights regarding the processing of Personal Data. These rights vary depending on applicable law, but may include, by way of example:
- the right to know what Personal Data we maintain about you;
- the right to know with whom we have shared your Personal Data;
- the right to receive a copy of your Personal Data; and
- the right to access, correct, or delete your Personal Data.
You may exercise any rights you have under your applicable law with respect to Personal Data by contacting us as described below. We may request additional information from you to authenticate any such requests. If you receive promotional messages from us, you may unsubscribe at any time by following the opt-out instructions contained within the message. Even after you opt-out of receiving promotional messages from us, you may continue to receive administrative messages from us.
VII. PRIVACY STATEMENT CHANGES
We may, from time to time, make changes to this Privacy Statement, based on your comments and our needs. The most current version of this Privacy Statement will always be available at http://acumen.org/privacy-policy. Any modifications will become effective immediately upon posting. By continuing to use the Website, you accept such modifications.
If we make any substantial changes in the way we use your Personal Data, we will contact all donors directly, whether in writing, telephonically or via email, and notify all others by posting a prominent announcement on our Website.
VIII. GOVERNING LAW
You agree that your use of this Website, this Privacy Statement, and any disputes relating thereto shall be governed in all respects by the laws of the State of New York.
IX. HOW TO CONTACT US
Your privacy is important to Acumen. If you have any questions or concerns regarding Acumen’s Privacy Statement, please direct them to:
Lynn Roland, General Counsel
Acumen Fund, Inc.
40 Worth Street, Suite 303
New York, NY 10013
You may also send an email to email@example.com
X. PRIVACY STATEMENT FOR DATA SUBJECTS WHOSE PERSONAL DATA MAY BE COLLECTED IN THE EUROPEAN UNION
EU GENERAL DATA PROTECTION REGULATION (“GDPR”). Acumen is a global brand, and thus our investors and website visitors may be from the European Economic Area (“EEA”). In order to serve our investors and website visitors, we may transfer Personal Data from individuals located within the EEA (“Data Subjects”). Personal Data that may be collected by us from a Data Subject in the EEA may include:
- Phone Number
- Email Address
- Contribution history
We may potentially deal with local supervisory authorities in all EU states where we have an existing relationship with a Data Subject. Additionally, information that we collect may be transferred outside of the EEA, including to countries, such as the United States, which have not been deemed as having “adequate” security measures by the European Commission.
LAWFUL GROUNDS TO PROCESS AND OBTAIN CONSENT
We process Personal Information of Data Subjects who are located in the EEA for one or more of several lawful purposes, including when you consent to providing us information; to comply with our own legal obligations; and for our legitimate business purposes.
Data Subjects whose Personal Data is collected in the EEA may withdraw consent at any time, where consent is the lawful basis for processing his/her information. Should a Data Subject withdraw consent for processing or otherwise object to processing that impedes Acumen’s ability to comply with applicable regulations, a Data Subject may be unable to avail himself/herself of the services that Acumen provides.
DATA SUBJECTS’ RIGHTS
All individuals whose Personal Data is held by Acumen have the right to:
- ask what information Acumen holds about them and why;
- ask for a copy of such information or access to such information;
- be informed how to correct or keep that information up to date; and
- be informed on how Acumen is meeting its data protection obligations.
Furthermore, for data collected in the EEA, Data Subjects have the right to:
- ask for a copy of such information to be sent to a third party;
- ask for data to be erased if possible and required under the GDPR;
- ask for processing of Personal Data to be restricted if possible and required under GDPR;
- object to processing of Personal Data if possible and required under GDPR;
- object to automated decision-making where applicable; and
- contact a supervisory authority in the EEA to lodge a complaint regarding Acumen’s processing of your Personal Data.
Acumen will not engage in automated decision-making activities.
NON-DISCLOSURE OF INFORMATION
Acumen does not share any Personal Data with any nonaffiliated third parties, except as detailed in this Privacy Statement:
CONTACT INFORMATION FOR PERSONS LOCATED WITHIN THE EEA. If you are located in the EEA or Switzerland and have questions or concerns regarding the processing of your Personal Data, you may contact our EU Representative at firstname.lastname@example.org or write to us at:
Lynn Roland, General Counsel
Acumen Fund, Inc.
40 Worth Street, Suite 303
New York, NY 10013
If, as an EEA Citizen, you believe that Acumen has not adequately resolved any such issues, you have the right contact the EU supervisory authority.
We would like to thank our donors for selecting Acumen to make philanthropic investments, our prospective partners for considering Acumen, and our visitors for taking the time to understand more about Acumen by browsing our Website.