Acorn Adaptive Privacy Policy
1. Introduction
Acorn Adaptive ("we," "us," or "our") is committed to protecting your personal information and your right to privacy. This Privacy Policy explains what information we collect, how we use it, and what rights you have in relation to it. This policy applies to all information collected through our website (acornadaptive.com), and/or any of our related services, sales, marketing, or events (we refer to them collectively in this Privacy Policy as the "Services"). This Privacy Policy DOES NOT apply to any third-party websites, platforms, or activities.
Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.
2. What Information Do We Collect?
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Website Visitors
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Personal Identifiers: We may ask for and collect personal information such as your name, address, phone number, and email (where you provide your opt-in consent) when you submit forms on our website or through third-party forms linked to from our website. We may ask you to submit such personal information if you choose to:
- Agree to receive email communications from us
- Access features or information available on the website
- Participate in surveys or provide feedback
- Otherwise communicate with us
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Internet or Other Electronic Network Activity Information: Third party services providers process information about traffic to and from our website. The information processed may include but is not limited to IP addresses, traffic routing data, system configuration information, and other information about traffic to and from our website.
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Attendees
- Personal Identifiers: We may ask for and collect personal information such as your name, address, phone number, and email when you choose to attend or participate in our virtual or in-person events.
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Clients
- Customer Records: We may ask for and collect personal information such as name, signature, address, telephone number, or employment from current or prospective clients or vendors relating to the administration of our business and provision of our goods and services.
- Commercial Information: We may record information regarding goods and services purchased, obtained, or considered relating to the administration of our business and provision of our goods and services.
We do not knowingly collect Sensitive Personal Information (SPI). If we become aware that we have collected SPI, we take steps to delete that information promptly.
3. How Do We Collect Information?
A. Directly from you: Including but not limited to name, email address, phone number, mailing address, and any other information you choose to provide in contact forms, event registrations, feedback, or other interactions with our staff or the Services.
B. From Third Parties: Including business partners, our affiliates, data analytics providers, third parties that we have partnered with for marketing or other purposes, or other publicly available sources.
C. Cookies and Other Automatic Collection Technologies: We do not, directly, automatically collect personal information from our website (acornadaptive.com) via cookies or other automatic collection technologies. However, we do use key third-party services alongside our Services that may utilize cookies or other automatic collection technologies. No non-essential automatic collection technologies, such as cookies, are knowingly administered directly by our website.
This section describes our approach to cookies and other automatic collection technologies you may encounter in connection with our Services, including those deployed by essential third-party service providers. Throughout our website we may link to other websites owned and operated by certain trusted third parties to service marketing or provide analytical services. These other third party websites may use cookies or similar automatic information collection technologies in accordance with their own separate policies. For privacy information relating to these other third party websites, please consult their policies as appropriate.
Key third party services:
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Cloudflare: Our website is hosted and delivered via Cloudflare, Inc. Cloudflare provides content delivery network (CDN) services, security services (like DDoS mitigation and Web Application Firewall), and DNS services. Cloudflare may use cookies and other automatic tracking to process information about visitors to our website, including IP addresses, system configuration information, and other information about traffic to and from the website, in order to operate, optimize, and secure its network and our Services. Any cookies Cloudflare uses when you connect to our website are understood to be strictly necessary, and no non-essential cookies are understood to be utilized by Cloudflare when you connect to our website. You can find more information in Cloudflare's Privacy Policy.
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Brevo (formerly Sendinblue): We use Brevo for email marketing and communication services (e.g., contact list storage, lead generation, and email marketing). A Brevo form collecting your contact information may be provided to you or linked from our website. Notably the 'Plan a Workshop' button, wherever it appears on the website, redirects the user to a form hosted by Brevo. If you choose to opt-in and subscribe to our contact lists via a Brevo form (typically 'brevo.com' or their 'sibforms.com' domain used for forms), your email address and any other information you provide (like your name) will be shared with Brevo for the purpose of sending you emails and managing our contact lists. Brevo uses tracking technologies (like pixels) in the emails it sends to help us measure engagement (e.g., open rates, click rates). These emails are likely to appear to be sent from an acornadaptive.com domain. You can withdraw your 'opt-in' consent to receive these emails at any time by unsubscribing from our contact list (usually via a link in the emails you receive). The forms Brevo uses may also utilize cookies. You can find more information in Brevo's Privacy Policy.
4. How Do We Use Your Information?
We use personal information collected via our Services and recieved from third parties for a variety of business purposes described below:
- To provide, operate, and maintain our Services.
- To improve, personalize, and expand our Services.
- To understand and analyze how you use our Services.
- To develop new products, services, features, and functionality.
- To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication, regarding updates or informative communications related to functionalities, products, or contracted services, when necessary or reasonable for their implementation.
- To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information. For compliance purposes, as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
- For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Service users is among the assets transferred. For other purposes: We may use your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
5. How Do We Share Your Information?
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With service providers: We may share your personal information with service providers to monitor and analyze the use of our Service, for payment processing, to contact you, provide the Services, and for other related operational purposes.
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With affiliates: We may share your information with future affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include parent companies and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
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With your consent: We may disclose your personal information for any other purpose with your consent.
We do not "sell" your personal information as that term is defined under the California Consumer Privacy Act (CCPA). Furthermore, we do not "share" your personal information for cross-context behavioral advertising purposes.
We may also disclose your information:
- As required by law, such as to comply with a subpoena, or similar legal process.
- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- If we are involved in a merger, acquisition, or sale of all or a portion of our assets. In this case you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
- With your prior consent to do so.
6. Data Security
The security of your personal information is important to us. While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.
7. Data Retention
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
8. Your Privacy Rights
Depending on your location (e.g., EEA, UK, California), you may have certain rights regarding your personal information under applicable data protection laws. These may include the right to:
- Request access and obtain a copy of your personal information.
- Request rectification or erasure.
- Restrict the processing of your personal information.
- If applicable, data portability.
- Object to processing.
- Withdraw consent at any time (where we rely on consent to process your information).
- The right to complain to a data protection authority about our collection and use of your personal information.
- The right to correct inaccurate information.
- The right to non-discrimination for users exercising their CCPA rights.
To exercise these rights, please contact us using the contact details provided below. We will respond to your request in accordance with applicable data protection laws.
9. International Data Transfers
Your information, including personal data, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Our use of third parties means that data may be processed globally. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable law.
For visitors from the EEA/UK, we rely on appropriate safeguards for information transferred outside of the EEA/UK such as Standard Contractual Clauses or adequacy decisions.
10. Legal Basis For Processing
If you are from the EEA/UK, our legal basis for collecting and using the personal information described depends on the personal information concerned and the specific context in which we collect it.
We will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms.
11. Children's Privacy
Our Services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children under this age. If we become aware that we have collected personal information from a child under the relevant age without verification of parental consent, we take steps to delete that information promptly.
12. Links to Other Websites
Our Service may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
13. Do Not Track
When you use the website, you may have set your browser or other means used to access the website to send “do not track” requests to us. The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized and the website knowingly tracks only strictly necessary cookies, the website is not compatible with DNT and so does not recognize DNT settings.
14. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The updated version will be indicated by the date at the beginning of this Privacy Policy and the updated version will be effective as soon as it is accessible. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.
15. Contact Us
If you have questions or comments about this policy, you may contact us at:
Acorn Adaptive LLC: [email protected]