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Privacy Policy

Welcome to Acumen Intelligence and our website at www.acumenintelligence.com (our “website”). At Acumen Intelligence, we are committed to protecting and respecting your privacy.

This privacy policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website. This policy further sets out how we protect your privacy and your rights in respect of your Personal Data.

What is Personal Data?

Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, e-mail address, and also your IP address. Anonymous data exists where no personal reference to the user can be made.

What is Processing?

"Processing" means and covers virtually any handling of data.

What Law Applies?

We will only use your Personal Data in accordance with the applicable data protection laws, in particular Singapore's Personal Data Protection Act 2012 (PDPA) and the EU's General Data Protection Regulation (GDPR), and only as described in this Privacy Policy.

Who is Responsible for Data Processing?

The responsible party is Acumen Intelligence Solutions Pte. Ltd of Midview City, 22 Sin Ming Lane, #06-79, 573969, Singapore (“Acumen Intelligence”, “we”, “us”, “our”). If you want to contact us or if you have any questions, you can reach us using our Contact Form.

What are the Legal Bases for Processing Personal Data

In accordance with the PDPA and the GDPR, at least one of the following legal bases applies: (a) consent; (b) contract or pre-contractual measures; (c) legal obligation; or (d) legitimate interests, provided your interests are not overridden.

What Personal Data Do We Collect From You?

a) Personal Data that you give us: This includes information you provide by filling in forms on our website or corresponding with us by telephone, post, email, or otherwise (e.g., your name, address, email address, telephone number), information about your business relationship with us, and information about your requirements and interests.

We also process Personal Data involved in your use of our services, such as your contact information, full name, email, postal address, and phone number, and the data related to your use of our services and the contract between us, in order to provide our contractual services. This includes, in particular, our support, correspondence with you, invoicing, and fulfilment of our contractual, accounting, and tax obligations. In general, contract-related data is saved and stored using the services of Amazon (AWS).

b) Personal Data that our website and other systems collect about you: If you visit our website, it will automatically collect some information about you and your visit, including the IP address used to connect your device to the Internet and information such as the pages on our site that you visit. This is used to monitor website performance and improve visitor experience.

We use cookies on our website. As set out in the PDPA and the EU’s Privacy and Electronic Communications Directive (PECD), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our Cookie Policy.

Data Processing Through Third-Party Services

We use the content or service offers of third-party providers, based on our legitimate interests, to integrate their content and services on our website. This requires these providers to be aware of users’ IP addresses, since without the IP address they could not send content to the browser.

Overview of providers: (a) Hosting: HostGator.com (Newfold Digital Inc.); (b) Fonts: Google Fonts; (c) Tag Management: Google Tag Manager.

How Will We Use Your Personal Data?

We will only process Personal Data as necessary for the above purposes and where we have a legal basis. Where our lawful basis is legitimate interests, we will ensure that our processing does not prejudice you or your privacy in a way that overrides our interests. In exceptional circumstances, we may be required by law to disclose Personal Data.

  • Operate, manage, develop, and promote our business and our relationship with you.
  • Marketing purposes (with prior opt-in and/or legitimate interests).
  • Accounting and billing/payment purposes.
  • Operate, administer, and improve our website and operations.
  • Offer and provide our services or information you requested.
  • Keep you informed and updated on relevant topics or services.
  • Protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials, and other crimes.
  • Comply with legal and regulatory obligations, bring and defend legal claims, and assert legal rights.
  • If the purpose is directly connected with a previously notified purpose.

Data Sharing

a) Internal: We may transfer Personal Data within Acumen Intelligence. Access is granted only to authorised employees who need it for their job.

b) External bodies: Personal Data is transferred to service providers in the following instances: to fulfil our contract with you, to use marketing services and advertise our services online, to communicate with you, to provide our website, and to state authorities and institutions as far as required or necessary.

c) International transfers: We may transfer Personal Data to other companies as necessary. We use contractual arrangements including Processing Agreements with Standard Contractual Clauses and Non-Disclosure Agreements. We take reasonable technical and organisational measures to protect the Personal Data we transfer.

How Long Do We Keep Your Personal Data?

We will delete your Personal Data when we no longer need it, for instance where it is no longer necessary for the purposes for which we collected it, where we believe it is inaccurate, or in certain cases where you withdraw consent. Sometimes, however, legal or regulatory requirements require us to retain your Personal Data for a specified period, and we may need to retain it longer in relation to legal disputes.

Data Security

Our website uses SSL/TLS encryption to ensure secure transmission of confidential content. We have implemented numerous technical and organisational measures—such as encryption and need-to-know access—to protect Personal Data processed through our website.

Marketing

Where you have given us separate consent to process your data for marketing and advertising, we may contact you via the channels you consented to. Every directly addressed marketing communication will include a means to unsubscribe or opt out.

Your Rights and Privileges

You can exercise the following rights:

Under the PDPA:

  • Right to access
  • Right to correction
  • Right to erasure
  • Right to opt-out
  • Right to data portability

Under the GDPR:

  • Right to information
  • Right to rectification
  • Right to object to processing
  • Right to deletion
  • Right to data portability
  • Right to withdraw consent
  • Right to complain to a supervisory authority
  • Right not to be subject to a decision based solely on automated processing

Singapore Spam Control Act 2007 (SCA)

If at any time you would like to unsubscribe from receiving future emails, you can email us and we will promptly remove you from all correspondence.

Updating Your Information and Withdrawing Your Consent

If you believe that information we hold about you is inaccurate, or you request rectification or deletion, or object to processing based on legitimate interests, please contact us.

Access Request

To make a Data Subject Access Request, please contact us. We will respond as soon as reasonably possible. If we cannot respond within thirty (30) days, we will tell you why and when we will respond. If we are unable to provide Personal Data or to make a correction requested by you, we will tell you why.

Complaint to a Supervisory Authority

You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. In Singapore, this is the Personal Data Protection Commission (www.pdpc.gov.sg). We would appreciate the opportunity to address your concerns first.

What We Do Not Do

  • We do not request Personal Data from minors and children.
  • We do not process special category data without prior specific consent.
  • We do not use automated decision-making, including profiling.
  • We do not sell your Personal Data.

USA Specific Provisions

We aim to follow and apply the relevant privacy rules and regulations of your state. Where appropriate, we grant all users in the USA the same rights and privileges as set out above. Where ambiguity occurs, the most stringent provision is chosen.

“Shine the Light”: We respond to requests about disclosures of Personal Data to third parties for their direct marketing. COPPA: We do not specifically market to children under 13. CAN-SPAM: You may unsubscribe and we will promptly remove you. TCPA: For SMS marketing, reply “STOP” to opt out. Do-Not-Track: No uniform standard is currently finalised; our website does not respond to DNT signals. If a standard is adopted in the future, we will update this policy. Right to complain: users may lodge a complaint with relevant district attorney or attorney general offices; we appreciate the opportunity to address concerns first.

GCC Specific Provisions

The GCC has introduced data protection laws similar to the GDPR. In particular, Saudi Arabia’s PDPL, the UAE’s Federal Decree-Law No.45 of 2021, Bahrain’s PDPL, and Oman’s PDPL are relevant. We aim to grant a uniform level of protection; where ambiguity occurs, the most stringent provision is chosen.

Help and Complaints

If you have any questions about this policy or the information we hold about you, you can reach us using our Contact Form.

Changes

The first version of this policy was issued on Wednesday, 10th of October, 2024, and is the current version. Any prior versions are invalid, and if we make changes to this policy, we will revise the effective date.