Acupay System, LLC - Privacy and Data Protection Policy
- Acupay System LLC ("We") are committed to protecting and respecting your privacy in accordance with best industry practices and relevant privacy legislation. We follow a comprehensive information and data security program which include appropriate administrative, technical, physical and disaster recovery safeguards. All information you provide to us is stored on our secure servers.
- For the purpose of the Data Protection Act 1998 (“the Act”), the Data Controller is Acupay System LLC of Unit 2, 242 Kingsland Road, London E8 4DG, registered in England under number FCO26354. Our headquarters are in New York (30 Broad Street, 46th Floor, NY 10004). We are accordingly registered with the Information Commissioner’s Office (ICO). For more information on the Data Protection Act 1998 or to view our entry on the ICO’s public register of Data Controllers, please visit http://www.ico.org.uk/.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
Information you give us. You may give us information about you by filling in forms on our Site or by corresponding with us by phone, e-mail or otherwise.
Information we collect about you. With regard to each of your visits to our Site we may automatically collect the following information:
- Technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); subjects you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- To ensure that content from our Site is presented in the most effective manner for you and for your computer and improve our Site;
- To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- As part of our efforts to keep our Site safe and secure.
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.
- Analytics and search engine providers that assist us in the improvement and optimisation of our Site.
Where required by the Privacy Shield, we enter into written agreements with the third parties referred to above requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third party agents and service providers process Personal Data in accordance with our Privacy Shield obligations and to stop and remedy any unauthorised processing. Under certain circumstances we may remain liable for the acts of third parties who perform services on our behalf for their handling of personal data that we transfer to them.
WHERE WE STORE YOUR PERSONAL DATA
- You may have the right to access the personal data that we hold about you. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to your personal data, you can submit a written request. Please mention “ACCESS MY DATA PRIVACY PROTECTION POLICY” in the subject of your general inquiry for the attention of Stef Lambersy. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee to access your information.
- Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.
In compliance with the Privacy Shield Principles, Acupay commits to resolve complaints about the collection or use of your personal information. Acupay has a privacy officer who is responsible for Acupay’s compliance with and enforcement of this policy who may be contacted via the general enquiries form on our contact page. Please mention “Privacy/Data Protection Policy” in the subject of your enquiry for the attention of “Stef Lambersy”.
Acupay is registered with the Information Commissioner’s Office in the UK (ICO), acting as the British Data Protection Agency. For more information on the Data Protection Act 1998 or to view our entry on the ICO’s public register, please visit http://www.ico.org.uk/. Acupay has committed to cooperate with EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints. If you do not receive timely acknowledgment of your complaint from Acupay, or if Acupay has not addressed your complaint to your satisfaction, please contact ICO, http://www.ico.org.uk/ for more information or to file a complaint. The services of ICO are provided at no cost to you.
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps:
- raised your complaint directly with Acupay and provided us with the opportunity to resolve the issue;
- made use of the independent dispute resolution mechanism operated by the ICO; and
- raised the issue submitted to ICO with the US Department of Commerce and allowed the US Department of Commerce an opportunity to resolve the complaint.
For more information on binding arbitration, see the US Department of Commerce’s Privacy Shield Framework: Annex 1 (Binding Arbitration).