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Privacy policy

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.   

By using Acumen services, you are consenting to the practices described in this privacy policy.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.  

1. INTRODUCTION  

1.1 Definitions  

“We” (as defined below) adopted this Privacy Policy and act as the data controller of our Website, offering you the “Database” (as defined below). A “Controller” is a person or organization who alone or jointly determines the purposes for which, and the manner in which, any personal data is, or is likely to be, processed.

We are Acumen International OU (registry code 14091259), a company organized under the laws of the Republic of Estonia, with the following registered address: Narva mnt 13, Tallinn, 10151, Estonia, and trading under the Acumen International and Express Global Employment™ trademark (“Acumen”, “Express Global Employment” we, We, our, us, as applicable).   

“You” – references in this Policy to “you” or “your” are references to individuals who use the Website, Database and Service. The Website, Database and Service are not intended for children, and we do not knowingly collect personal data related to children. 

“Database” – is an online database dedicated to employment process, with included next per-country information:

  • Country profile,
  • Options of doing business in country,
  • Taxation,
  • Employment regulation,
  • Emigration procedure for expatriate employees.

“Service” – is a service for providing “Database”. This Privacy policy governs your access to and use of products and services we provide through website at  https://globalcomplianceguide.com/.

Website – website available at URL: https://globalcomplianceguide.com/.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities due to which our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to do so by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or taking steps at your request before entering into such contract. For example, DaaS agreement is a contract.  

Complying with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.  

External Third Parties:  

  • service providers who provide IT and system administration services,
  • third-party service providers (including contractors and designated agents) and other entities in our group who will participate in performing the services to you as subcontractors or otherwise,
  • professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services,
  • Estonian Tax and Customs Board, regulators and other authorities who require reporting of processing activities in certain circumstances,
  • payment processors who provide services on processing payments.  

Internal Third Parties means other companies in Acumen Group acting as joint controllers or processors and providing IT and system administration services and undertaking leadership reporting.   

1.2 Controller  

Acumen International OU is the controller and is responsible for this Website. This privacy policy is issued on our behalf.  

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise, please contact the DPO using the details set out below.   

Controller’s contact details: 

Full designation of a legal entity: Acumen International OU.

Contact details:  

Acumen Group is made up of different legal entities which may have status of joint controllers of Acumen International OU. Third-party service providers (including contractors and designated agents) and other entities within the business procedure may act as processors in order to collect, store and process your personal data. Other persons or entities may be treated as third parties on case-by-case basis.  

1.3 Purpose of this privacy policy  

This privacy policy aims to give you information on how Acumen collects and processes your personal data through your use of this website, and any other website operated by us from which you are accessing this Policy (each a “Website”) and our Services will only be used in accordance with this privacy policy, including any data you may provide through the Website when you sign up to our newsletter, request a commercial proposal or purchase a product or service.  

This privacy policy applies to all Acumen services which do not have a separate privacy policy or are linked to this privacy policy, designated the “Services.”  

It is important that you read this privacy policy together with any other privacy notice or other notice we may provide on specific occasions when we collect or process your personal data so that you are fully aware of how and why we use your data.   

1.4 Policy update  

We may update this Privacy Policy on occasional basis if we change internal procedures or once we are required to do so by law. We may at our sole discretion use additional notification on policy update, for example, pop-up notification, email or Online Cabinet notice on such change which may have immediate effect. The Customer confirms its awareness and consent to changed Policy by continuing access to the user interface of the Database upon change. By using the Service, Customer accepts changed terms and conditions in full. If the Customer disagrees with these terms and conditions or any part thereof, the Customer must not use this service.  

2. WHICH DATA WE COLLECT ABOUT YOU?  

2.1 Personal data  

For individuals covered by the General Data Protection Regulation (“GDPR”), personal data is any information relating to an identified or identifiable natural person. For individuals not covered by GDPR, personal data is any information relating to an identified or identifiable natural person. For example, your name, address, telephone number, e-mail address, government issued identification information, education information, payroll information, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. It does not include data where the identity has been removed (anonymous data or statistics data).  

2.2 Categories of Personal data  

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:  

  • Identity Data includes first name, middle name, last name, username or similar identifier, marital status, title, date of birth and gender.  
  • Contact Data includes registered address, billing address, delivery address, email address and telephone numbers.  
  • Transaction Data includes details about payments to and from you and other details of products and services you purchas from us.  
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.   
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.   
  • Usage Data includes information about how you use our website, products and services.   
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.  

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data by law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.  

Special Categories of Data  

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, or genetic and biometric data). We do not collect any information about criminal convictions and offences.  

If you fail to provide personal data  

Where we are required to collect personal data by law, or under the terms of a contract we have with you and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.   

Your duty to inform us of changes  

By using our Service, you confirm that your personal cabinet contains up-to-date and accurate information about your identity, including your legal address and place of residence, which may be used for taxation purposes. You are responsible for ensuring the accuracy and timely update of this information.

Third-party links  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.  

3. HOW WE COLLECT YOUR PERSONAL DATA?  

We use different methods to collect data from and about you including through:  

  • Direct interactions. You may give us your Identity data, Contact data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    1. apply for our products or Services;
    2. create an account at our Website;
    3. subscribe to our Service or publications; 
    4. request marketing to be sent to you;
    5. enter a competition, promotion or survey; or
    6. give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our information about how we use cookies for further details in our Cookie Policy.  
  • Third parties’ or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
    1. Technical Data from the following parties:
      • analytics providers such as Google based inside or outside the EU; 
      • advertising networks based inside or outside the EU; and
      • search information providers based inside or outside the EU.
    2. Contact, HR Data and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
    3. Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
    4. Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA?  

4.1 Legal basis   

We will only use your personal data when the law allows us to do so. Most commonly, we will use your personal data in the following circumstances:  

  • where we need to perform the contract, we are about to enter into or have entered into with you;  
  • where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;  
  • where we need to comply with a legal or regulatory obligation.  

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

4.2 Purposes for which we will use your personal data

The EU GDPR mandates that we have a legal basis for processing personal information. The specific legal basis we rely on varies according to the purpose of the data processing. We use:

fulfillment of a contract when we provide you with products or services, or engage in related communication. This includes using your personal information to manage orders, deliver services, and process payments;

  • fulfillment of a contract when we provide you with products or services, or engage in related communication. This includes using your personal information to manage orders, deliver services, and process payments;
  • protection of your interests or interests of another person, that is prevention, mitigation, and investigation of unlawful activities that could potentially lead to the impairment of your interests or interests of another person, except where there is a statutory obligation to this effect,
  • compliance with our legal obligations under the GDPR, which includes participating in investigations and legal proceedings by public authorities, preventing, detecting, and mitigating illegal activities such as fraud, money laundering, and terrorist financing, responding to information requests from third parties based on statutory rights, handling reports and complaints of illegal content, including assessing repeated unfounded claims, complying with legal requirements related to consumer protection, online platforms, and taxes, ensuring the security of our services, retaining and storing data to meet specific legal retention requirements;
  • our legitimate business interests and those of our customers, particularly when enhancing Acumen services, detecting and preventing fraud and abuse to safeguard our customers, ourselves, or others, and offering interest-based advertising;
  • your consent when we request it for processing personal information for a particular purpose, which will be clearly communicated to you. You may withdraw your consent at any time, and we will stop processing your data for that specific purpose;
  • legal compliance when we are required to use your personal information to meet regulatory requirements. For example, we may collect seller establishment details and bank account information for identity verification.

4.3 Marketing   

We strive to provide you with choices regarding certain personal data uses, particularly in respect of marketing and advertising. Our email messages have unsubscribe feature.   

  • Promotional offers from us. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you use our services or create a new account, if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.  
  • Third-party marketing. Acumen reserves the right to use your name and/or company name as a reference for marketing or promotional purposes on Acumen’s website and in other communication with existing or potential Acumen customers. To decline this right you need to email us stating that you do not wish to be used as a reference. 

4.4 Opting out  

You can ask us or third parties to stop sending you marketing messages at any time by contacting us  at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.  

4.5 Cookies  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

4.6 Change of purpose   

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please  contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so or ask for your consent to further processing for the new purpose.  

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.  

5. DISCLOSURE OF YOUR PERSONAL DATA  

5.1  To Subcontractors (Service Providers)  

We reserve our right to engage (subcontract) other third-party service providers to provide services on our behalf to visitors of our websites, customers of the Service and may need to share your information with them to provide information, products or services to you. Examples may include analyzing data or performing statistical analysis or calculations, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we transfer your personal data to such recipients, we explicitly require the receiving party to acknowledge and adhere to our privacy rules.  

5.2 Corporate-related cases  

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company will receive all information gathered by Acumen on the websites and the Subscription Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data (e.g., request for data deletion, which may in some cases mean that you cannot use the Service any longer).  

5.3 Mandatory Disclosure  

We reserve the right to use or disclose your Personal Data if required by law or by court order. Also, we reserve our right to use or disclose your Personal Data if such use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with law.  

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.  

6. INTERNATIONAL TRANSFERS  

6.1 International Transfers within Acumen’s Entities  

To facilitate our global operations, we may transfer information to other countries and allow access to that information from countries in which the Acumen Affiliates operate for the purposes described in this policy. This Privacy Policy shall apply even if we transfer Personal Data to other countries. We have taken appropriate safety measures to ensure that your Personal Data will remain protected. When we share information about you within and among Acumen’s Affiliates, we make use of standard contractual data protection clauses, which have been approved by the European Commission.   

6.2 International Transfers to Third Parties  

Certain third parties, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws (inadequate level of data protection). When we share information of customers in the European Economic Area or Switzerland, we make use a variety of legal mechanisms to safeguard the transfer, including the European Commission-approved standard contractual data protection clauses or other appropriate legal mechanisms. For transfers to or from the United Kingdom, we make use of the standard contractual clauses. Please contact us if you need more information about the legal mechanisms, we rely on to transfer Personal Information outside the EEA, Switzerland and the United Kingdom.  

Currently we do not transfer data to the US. Any future data transfers to the US will be conducted under the procedure compliant with Article 49 of GDPR.  

7. DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a commercial interest. They will only process your personal data based on our instructions and they are subject to  confidentiality.   

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.   

8. HOW LONG WE WILL USE YOUR DATA?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.   

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.  

  • Customer Data collected during your use of the Service is retained for as long as you have a paid Subscription and/or remain an active customer in your portal. Your data is deleted upon your written request or after an established period following the termination of all customer agreements. In general, Customer Data is deleted after your paid Subscription ends  after one year, when your account becomes inactive. Some personal data is stored longer if we have legal basis for doing so or if we are required to extended data storing under the law (for example, if data is necessary for taxation and accounting needs).  
  • By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.  

In some circumstances you can ask us to delete your data: see Request erasure below for further information.  

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.  

9. YOUR LEGAL RIGHTS  

9.1 Brief list of your rights  

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data;  
  • Request correction of your personal data;  
  • Request erasure of your personal data (right to be forgotten);  
  • Object to processing of your personal data;  
  • Request restriction of processing your personal data;  
  • Request to data portability;  
  • Right to withdraw consent;  
  • Right to lodge complaint with supervisory authority.  

Please get acquainted with the information below to find out more about the aforementioned rights.

9.2 You have the right to:  

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.  

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.  

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.   

Objection  to process of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel its impact on your fundamental rights and freedoms. You also have the right to object to  processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process information which override your rights and freedoms.  

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data accuracy; (b) where our use of data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.   

Data portability of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.   

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.  

Lodge complaint with supervisory authority  

You have the right to lodge a complaint  to Estonian Data Protection Inspectorate available at https://www.aki.ee/en. If you wish to exercise any of the rights set out above, please  contact us.

9.3 No fee usually required  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.  

9.4 What we may need from you  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.  

9.5 Time limit to respond  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.   

9.6 Complaints  

If you have any questions, concerns or complaints regarding our compliance with this policy or data protection law, or if you wish to exercise your rights, we encourage you to first contact us at  the email address set out in paragraph 1.2. We will investigate and attempt to resolve complaints and disputes and will make every reasonable effort to honor your wish to exercise your rights as quickly as possible and in any event, within the timescales provided by data protection laws.  

If you are dissatisfied with Acumen ’s handling of any privacy complaints, or if you do not receive timely acknowledgement of your complaint, or your complaint is not satisfactorily addressed please contact the The Data Protection Inspectorate of Estonian Republic at https://www.aki.ee/en. 

10. INFORMATION ABOUT OUR USE OF COOKIES  

When you use our Services, we, along with selected third parties, may utilize cookies and similar technologies to enhance your user experience by making it faster, safer, and more personalized, including showing you tailored advertising. Cookies are small text files automatically generated by your browser and stored on your device when you access the Service.

Our cookies and similar technologies serve various purposes:

  • they may be essential for the operation of our Service;
  • they assist in the technical optimization of our Service, such as monitoring errors and improving load times.
  • they enhance your user experience by, for example, saving font preferences and pre-entered form data.
  • they enable us to deliver more relevant advertisements.

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided in the cookie banner. You can also set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our Website though your access to some functionality and areas of our Website may be restricted.