“Personal information” is generally considered to be any information about an identified individual or that can be used (directly or indirectly) to identify an individual, for example, an individual’s name, e-mail address, phone number, online identifier, IP address or photo. Information that has been anonymized, and from which no individual can be identified either directly or in combination with other data, is not personal information.
- Websites, applications, products or services that are operated by companies other than ACL and may be accessed from our websites (such as YouTube, Twitter, Facebook, Instagram or Jobvite), or to business activities or practices of third parties, including our channel partners and resellers. Please consult the Privacy Policies of those third parties for information about their privacy practices; or
- Personal information collected and used in the operation of ACL products and services, unless we use your personal information for our own business purposes, such as direct marketing of our products or for product improvement. Your organization administers and controls your use of ACL products and services, including your personal information and the personal information of others that may be used in connection with the ACL products. Use of such personal information is governed by the applicable agreement(s) for the ACL products and services and is the responsibility of your organization. Please contact your administrator for any privacy questions about your use of ACL products and services.
Personal Information We Collect
ACL collects personal information that you provide to us directly, that we collect automatically when you access and use ACL websites and products, and that is provided to us by third parties or through publicly available sources.
Personal information you provide to us directly includes:
Personal information collected when you access and use ACL websites or products includes:
Personal information provided by third parties or publicly available sources includes:
- ACL Channel Partners and Resellers. We collect information you or your organization provide to an ACL channel partner or reseller in order to fulfill your organization’s order for ACL products and services.
- Data Providers. From time to time, we may collect business contact information and contact lists from third party data providers, provided they have demonstrated compliance with applicable privacy and data protection laws.
- Social Media. We may collect contact information you provide to third party social media services and make publicly available (such as LinkedIn).
How We Use Personal Information
ACL uses the personal information we collect for the following purposes:
We will also use personal information for other purposes of which we have notified you, or as legally required.
Legal Basis (For EU Individuals)
If you are an individual in the European Union (EU) or the European Economic Area (EEA), the lawful basis for collecting and using your personal information is consent, where you have given consent, or our legitimate interests (which are not overridden by your data protection interests), such as operating our business, understanding and improving our products, direct marketing related to our products and services, hosting events, communicating with our customers and their users about our products, services, events or related resources, improving our websites and protecting our legal rights and interests.
Where consent is the legal basis, you may withdraw that consent at any time. Where we are using your personal information for our legitimate interests, you have the right to object to that use. See below under Your Rights for how to withdraw consent or object. If you have any questions about the lawful basis upon which we collect and use your personal data, please Contact us.
Sharing Your Personal Information
ACL may share your information as set forth below.
- Vendors and Service Providers. ACL may share your personal information with third party vendors and service providers who provide products and services that we use to operate our business and carry out the purposes listed above. These include customer relationship management systems, contract signing applications, in-app notifications, website hosting, website analysis, marketing campaigns, email services, event registration, billing and payment processing, cloud-hosted document storage, job applications and alerts, surveys and contests, and other contractors or consultants that work on our behalf. Before sharing your personal information, we ensure that the third parties receiving the personal information have provided appropriate safeguards, and that your privacy rights are protected and preserved.
- Corporate Transactions. ACL may share your personal information in connection with, or during negotiations of, any merger, amalgamation, sale of company assets, financing, purchase or acquisition, subject to a commercially reasonable confidentiality or non-disclosure agreement.
- Compliance with Laws. ACL may disclose your personal information to a third party if we are required to do so in order to comply with applicable laws, government request, a court order or other quasi-government request to assist with an investigation. We may also be required to disclose your personal information to enforce our legal rights, to enforce security requirements, or to respond to an emergency which we believe, in good faith, requires us to disclose your personal information. In such instances, if permissible, we will make every reasonable effort to give you as much notice as possible regarding the disclosure of your personal information, what information was disclosed and why.
Storage and Retention
We retain personal information only for as long as necessary to achieve our stated purposes, or as required by applicable law. After such time, we will delete, archive or anonymize your personal information. We will securely store your personal information until it is deleted.
You may delete your personal information, or request that we do so, at any time. See below under Your Rights for further information on how to do this.
Many of the third parties we use to store and process your personal information are located in the United States. If you are located in the European Union, the European Economic Area, Switzerland or the United Kingdom, your personal information will be transferred outside your home country to the United States or to another country where our third party service providers operate.
Before making such transfers, we ensure that the third parties receiving the personal information have provided appropriate safeguards, and that your privacy rights are protected and preserved. Such safeguards may include certification and adherence to EU-US Privacy Shield and Swiss-US Privacy Shield Frameworks, the Standard Contractual Clauses approved by the European Commission, binding corporate rules, or other legal mechanisms to safeguard the personal information being transferred.
Information about the Privacy Shield Frameworks can be found at www.privacyshield.gov.
Correction and Deletion
ACL will make reasonable efforts to ensure that the personal information we collect from you is accurate and complete. You may update, correct or delete your personal information at any time by logging into your user account and modifying your personal information, including your preferences to receive messages from us. You may also update, correct or delete information by contacting us as noted below or by contacting the ACL Support Center (email@example.com). If you wish to deactivate your product user account, please contact your organization’s administrator.
Where we have relied on your consent to use your personal information, you have the right to withdraw that consent at any time by contacting us as noted below. In addition, all our marketing email messages contain the ability to automatically “opt-out” or unsubscribe from our mailing lists and marketing messages. You may also elect not to receive communication from us by updating your preferences in your account settings or sending an email to firstname.lastname@example.org to request that we remove your email, address and name from our mailing lists. We will continue to send you messages of a non-promotional nature related to your organization’s product subscription or your user account, such as security alerts, maintenance notices, updates, renewal or suspension notices, or notifications to comply with legal requirements or applicable law.
Access and Portability
You have the right to request a record of the personal information that we have collected about you. In addition, you have the right to request that we provide that information in a structured, commonly used electronic format for transmission to another company (where applicable and technically feasible). There may be some cases where we cannot provide you with certain information about you if it would mean disclosure of personal information of another person or other confidential information, or if it would compromise our security systems. If you require access to your personal information, please Contact Us. We will respond to you within thirty (30) days of receiving your request. We may charge a fee where permitted by applicable law.
Restriction and Objection
In certain limited circumstances, individuals in the EU may request that we restrict our use of their personal information and, where we rely on legitimate interests as the legal basis for using your personal information, you have the right to object to such use. In these cases, we can be required to no longer use your personal information; however, this may mean that certain products, services or information cannot be made available to you. If you wish to exercise your right to restrict or object, please Contact Us.
Individuals in the EU have the right to lodge a complaint with a supervisory authority (ie, the independent public authority responsible for monitoring data protection laws in their country). You may also contact the Privacy Commissioner of Canada (for international matters and inter-provincial matters) (http://www.priv.gc.ca/) or the Information and Privacy Commissioner of British Columbia (for British Columbian matters) (http://www.oipc.bc.ca/).
ACL Services Ltd.
1500, 980 Howe Street
Canada, V6Z 0C8
Attention: Privacy Officer