Acupay System, LLC - Privacy and Data Protection Policy


  1. 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.
  2. This Policy (together with our Terms of Use) and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting our website (“our Site”) you are accepting and consenting to the practices described in this Policy.
  3. Any changes we may make to this Policy in the future will be posted on this page. Please check to see any updates or changes to our privacy Policy.
  4. 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 FC026354. 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


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.


  1. Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
  2. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use both session ID cookies and/or persistent cookies. We use session cookies to make it easier for you to download documents on the site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Our web analytics product may use cookies to track page views and users on the site. This information is only used to analyse the traffic on our websites by Acupay. This information is not tied to personally identifiable information. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such as document downloads will be limited.
  3. Our Site uses Google Analytics and this uses cookies which will be saved on your computer and which allow an analysis of your use of the Site. The information provided by the cookie concerning your use of the website (including your IP-address) will be transferred to a Google server in the United States and saved there. Google will use this information to analyse your use of the website, to compile reports about the website activities for the website operator and to provide additional services concerning the website and internet utilization. Google may transfer this information to third parties, if this is a legal requirement or if third parties are commissioned by Google to process the information. Google will in no event connect your IP-address with other Google data. You can prevent the installation of cookies with the relevant browser software setting; however, in this case you may not be able to use all the functions on this website to the full extent. Through use of the Sites, you agree to the processing of your data by Google in the way described above and for the purpose stated above.


We use information held about you in the following ways:

  1. To ensure that content from our Site is presented in the most effective manner for you and for your computer and improve our Site;
  2. To administer our Site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
  3. As part of our efforts to keep our Site safe and secure.


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.

Note that we may disclose personal information to third parties if we are under a duty to disclose or share that data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use.


  1. Acupay is a global company with operations in several countries. We have developed global data practices designed to ensure that personal information is appropriately protected. The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. By submitting your personal data, you agree to this transfer, storing or processing.
  2. Acupay complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Acupay has certified to the US Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall prevail. To learn more about the Privacy Shield program, and to view our certification, please visit For the purposes of enforcing compliance with the Privacy Shield program, Acupay is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
  3. 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.
  4. 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 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, 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).