Privacy Policy

1. INTRODUCTION

At Acacia Avenue, we respect the privacy of visitors to our website (https://www.acacia-avenue.com/ ). This policy is concerned with how we collect information, what we do with it and what rights you have over how we use your personal information. It is our intention to only collect the personal information of individuals over 18 years of age. By using the website and providing your personal information you are confirming you are over 18 years of age. Occasionally we require young people to take part in our focus groups but this would only be undertaken with parental consent. Acacia Avenue International Limited is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

2. WHAT INFORMATION DO WE COLLECT ABOUT YOU

Personal information means any information capable of identifying an individual. It does not include any anonymised data. When you work with us as a participant we may need to process certain types of personal information about you including:
  • Information by which we can identify you – such as first name, last name, maiden name, data of birth, etc.
  • Contact information – including address, email address, phone numbers
  • Financial information – your bank account and payment card details where we need to pay you.
  • Transaction information – payments between us and other details of purchases or activities between us.
  • Marketing and Communications information – include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
Sensitive Data We do not collect any Sensitive Data about you through the website.  Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences. We may collect sensitive personal information as part of your participation in Market Research with us but this would be with your consent and knowledge and we would ensure that we have appropriate security controls in place to protect this information. Where we are required to collect personal information by law, or under the terms of the contract between us and you do not provide us with that information when requested, we may not be able to perform the contract (for example, to pay an incentive or deliver services to you). If you don’t provide us with the requested information, we may have to cancel the service you have ordered but if we do, we will notify you at the time.

3. HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect information about you using different formats including:
  • Direct interactions: You may provide information by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
  • Take part in market research with us;
  • subscribe to our newsletter or publications;
  • request resources or marketing be sent to you; or
  • give us feedback.
  • Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy at https://www.acacia-avenue.com/cookie-policy for further details.
  • Third parties or publicly available sources: We may receive personal information about you from various third parties and public sources as set out below:
  • analytics providers such as Google based outside the EU but behind the privacy shield;

4. HOW WE USE YOUR PERSONAL INFORMATION

We will always have a legal basis for processing your personal information. The most common reasons we will use your personal information are:
  • Where we need to perform the contract between us.
  • 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.
  • And consent where we are collecting your information as part of a market research project or have signed up to our mailing list. You have the right to withdraw consent at any time and can do so by contacting us as info@acacia-avenue.com.
Purposes for processing your personal information We want to be transparent about the way we handle your personal information so we outline below the various ways we intend to use it and the legal basis for processing that information. We may process your personal information using more than one legal basis depending on the purpose we have collected your information for.  Please email us at info@acacia-avenue.com if you want to clarify the legal basis that we are relying on to process your personal information.
Purpose/Activity/use of personal information Type of information Lawful basis for processing
To register you as a new participant (a) first name, last name (b) Contact information Consent
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey (a) Identity (b) Contact (c) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To enable you to partake in market research (a) Identity (b) Contact (c) Profile (d) information provided as part of a screener (e) Communicating with you (a) Performance of a contract or consent depending on the circumstances. (b) Necessary for our legitimate interests to study how customers use products/services on behalf of our clients
To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical   (a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise (b) Necessary to comply with a legal obligation
To deliver relevant content to you and measure and understand the effectiveness of our advertising (a) Identity (b) Contact (c) Usage (d) Marketing and Communications Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Usage Necessary for our legitimate interests to develop our products/services and grow our business
Marketing communications  You will receive marketing communications from us if you have:
  • requested information from us or purchased goods or services from us; or
  • if you provided us with your details and ticked the box at the point of entry of your details for us to send you marketing communications; and
  • in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at info@acacia-avenue.com at any time. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us because of your participation in a market research event or other transactions. 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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at info@acacia-avenue.com. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing. We may process your personal data without your knowledge or consent where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal information with the parties set out below for the purposes set out in the table in paragraph 4 above:
  • Service providers who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.
  • Hard copy of your profile sheet given to researcher to facilitate your participation.
  • Contact information to a viewing facility to support your participation.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:
  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. Please email us at info@acacia-avenue.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to only those employees, agents, contractors and other third parties who have a business need to know such information. They will only use your personal information on our instructions and are subject to a duty of 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. DATA RETENTION

We will only retain your personal information for as long as necessary to fulfil the purposes we obtained it for. Where there is a legal, statutory or accounting purpose for the information we will retain it for the relevant period to meet this requirement. 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 unauthorised 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. By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise 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

Under certain circumstances, you have various rights under data protection laws in relation to your personal information. These include the right to:
  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/ If you wish to exercise any of the rights set out above, please email us at info@acacia-avenue.com. 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. 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. 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 several requests. In this case, we will notify you and keep you updated.

10. 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 notice of every website you visit.

11. 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. For more information about the cookies we use, please see https://www.acacia-avenue.com/cookie-policy.

12. CONTACT DETAILS

Our full details are: Full name of legal entity: Acacia Avenue International Email address: info@acacia-avenue.com Postal address: 353 City Rd, London EC1V 1LR Telephone: +44(0)20 7014 9500 If you are not happy with any aspect of how we collect and use your information, please contact us so that we may try to resolve any concerns or complaints you have. You also have the right to contact the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We aim to ensure that the information we hold about you is accurate and up to date. To help us with this, please let us know if your personal information changes by emailing us at info@acacia-avenue.com.