ACEUM Partners LLC d/b/a ACEUM Advisors and Search (“ACEUM,” “we,” “our” or “us”) is committed to preserving your privacy and being transparent about how it uses information that it may collect from or about you through your use of, interactions with or access to www.aceum.com (the “Site”) and any other applications, functionality or services that we offer (collectively with the Site, the “Services”). This privacy policy (the “Privacy Policy”) describes our practices for collecting, using, maintaining, protecting, and disclosing your information as well as the choices available to you regarding our use of your information. 

This Privacy Policy does not apply to any information collected by any website operated by any third parties including through any application or content (such as advertising) that may link to or be accessible from or through the Services.  More information concerning links to third party sources is available in the “Third-Party Services” section of this Privacy Policy.

By using, interacting with or otherwise accessing our Services or by providing your information to us or to our affiliates, you hereby agree to our treatment of your information in accordance with the terms and conditions of this Privacy Policy, our Terms of Service (the “Terms”), and any other policies, notices or terms posted on the Site. Please read such terms and conditions prior to using, accessing or otherwise interacting with our Services. Your continued use of, access to or interaction with the Services after we make changes to such terms and conditions is deemed to be acceptance of those changes. As such, please check the Site frequently for updates.

PERSONAL INFORMATION

We and certain of our agents, vendors, consultants and other service providers (collectively “Service Providers”) may obtain Personal Information about you in various ways, including, but not limited to, information you submit directly or indirectly through your use of, interactions with or access to the Services or through other automated means.  For purposes of this Privacy Policy, Personal Information shall consist of information that can be used to identify you by itself or when it is combined with other information such as your name, postal address, zip code, phone number and email address.  We will never rent or sell your Personal Information to any third party, or retain it for longer than is necessary to fulfill the purposes for which it was collected, as required by applicable laws.

NON-PERSONAL INFORMATION

To better understand how visitors to the Site use our Services and to help us provide a better experience for our visitors, we may collect, store and use non-personal information pursuant to the terms and conditions of this Privacy Policy. Non-personal information is information that does not identify you personally or Personal Information that has been “de-identified” or “aggregated.”  Examples of non-personal information include, but are not limited to: 

• Your IP address;
• Types of devices connected to our Services, 
• Language preferences, 
• Clickstream data;
• Date and time of the inquiry;
• Time zone difference to Greenwich Mean Time (GMT);
• Content of a request;
• Access status/status code;
• Data volume transmitted to the Site;
• Website from which a request comes;
• Browser type;
• Internet Service Provider (ISP);
• Operating system and its interface; and
• Language and version of the browser software.

INFORMATION WE MAY COLLECT

1. Information You Provide to Us

We and certain of our Service Providers may obtain information about you, including Personal Information, when you use, interact with or otherwise access the Services. Such interactions may include, but are not limited to: 

• Information that you provide by filling in forms on the Site, including as listed under our Contact Us tab.
• Requesting additional services or report problems with the Site.
• Any search queries you conduct on the Site.

1. Information We Obtain by Automated Means

When you use, interact with or otherwise access the Services, we or our Service Providers may obtain certain information about you by automated means, such as cookies, web server logs, web beacons, and other technologies, which collect certain information about your equipment, browsing actions and patterns. Some of the technologies we may use for this automated data collection include: 

• “Cookies” which are text files that websites send to a visitor’s computer or other internet-connected devices to uniquely identify the visitor’s browser or to store information or settings in the browser. 
• “Web beacons,” also known as an internet tags, pixel tags or clear GIFs that link web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
• “Flash cookies” which pertain to the locally stored objects on websites that collect and store information about your preferences and navigation to, from, and on a website. Flash cookies are not generally managed by the same browser settings as are used for browser cookies.
• “Location-identifying technologies” that can locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting relevant content based on your location.

The information we and/or our Service Providers obtain using these technologies and other automated means may include your device IP address, identifiers associated with your devices, types of devices connected to our services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of website visits.

HOW WE USE THE INFORMATION WE COLLECT

1. Use of Non-Personal Information

We may use and disclose, in our sole discretion, any non-personal information that does not alone or together with any other information identify you, including without limitation, all de-identified and aggregated information, without restriction. Such use may include, but is not limited to, analyzing requests and tracking usage patterns so that we may improve our products and Services, enhance our user experience, and gather broad demographic information for aggregate use.

1. Use of Personal Information

We take your privacy very seriously, and we do not sell, rent or disclose Personal Information we obtain about you in connection with your use of, interaction with, or other access to the Services, except as described in this Privacy Policy. We may use the information we obtain about you, including Personal Information, to:

• Provide the Services to you;
• Communicate with you and provide customer or technical support;
• Send you administrative information (such as information regarding the Services, and changes to our terms, conditions and policies);
• Personalize your experience with our Services;
• Perform analytics (such as market and consumer research and trend analysis);
• Operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving the Services; developing new products and services; managing and evaluating the effectiveness of our communications; and performing accounting, auditing, and other internal functions);
• Communicate with our affiliates for internal business purposes;
• Facilitate negotiations of any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another company;
• To provide you with notices on changes and upgrades to the Services and our other products;
• Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; 
• Comply with and enforce any of our terms, conditions and policies, including, but not limited to, the Terms; and
• Fulfill any other purpose for which you grant your consent or complete any other transaction which we may describe to you when you provide us with your information.

In addition to the above, we may disclose Personal Information about you: (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government or regulatory agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity by any government or regulatory agency or law enforcement body; or (6) otherwise with your consent.

If you provide us with your email address, then we may from time to time, email you useful information about the Services. Additional information concerning opting-out of receiving such messages is contained in the “Your Options Concerning Our Collection of Personal Information” Section of this Privacy Policy.

If you require technical or service level help with regards to your use, access or other interaction with our Services, our support team may ask you to confirm some of your Personal Information, such as your name, address, or other relevant identifying information. ACEUM will never email you directly and ask for these details unless you have requested help or support.

THIRD PARTY SERVICES AND SERVICE PROVIDERS

1. Your Use of Third Party Services

Our Services may also provide hyperlinks to websites, locations, platforms, and services operated and owned by third parties (the “Third Party Services”) for your convenience and information, and may include third party features such as apps, tools, payment services, widgets and plug-ins (e.g., Facebook, Twitter and LinkedIn). In addition, our Services may contain features that allow you to interact with, connect to, or facilitate access through certain Third Party Services. For example, you may access such Third Party Services when you, “like” and/or “share” content over social media through our Services or through the use of your own social media accounts These online services and third party features operate independently from us and may use various other tracking technologies to independently collect information about you and may solicit Personal Information from you via your use of their services. Such Third Party Services each contain their own privacy practices, information security policies, terms of use or service and other rules or regulations.  As such, your use of any Third Party Services is subject to those privacy practices, information security policies, terms of use or service and other rules or regulations. More information on your use of Third Party Services is available in our Terms. 

We strongly suggest you read and all review all privacy practices, information security policies, terms of use or service and all other rules or regulations of Third Party Services prior to using such services. 

1. Third Party Services and Third Party Features Disclaimer

WE ARE NOT RESPONSIBLE FOR, MAKE NO REPRESENTATIONS CONCERNING, AND HEREBY SPECIFICALLY DISCLAIM ANY AND ALL LIABILITY ARISING FROM OR RELATED TO, YOUR USE OF ANY THIRD PARTY SERVICES, THIRD PARTY FEATURES AND THE PRIVACY PRACTICES, INFORMATION SECURITY POLICIES, TERMS OF USE OR SERVICE AND ANY OTHER RULES OR REGULATIONS CONNECTED THEREWITH.

YOUR OPTIONS CONCERNING OUR COLLECTION OF PERSONAL INFORMATION

We offer you certain choices in connection with the Personal Information we obtain about you. To update your preferences, stop receiving emails, or submit a request concerning those choices please contact us as specified in the “Contact ACEUM” Section of this Privacy Policy. 

You can opt-out of receiving certain promotional emails from us at any time by following the instructions provided in such emails or by contacting us pursuant to the “Contact ACEUM” Section of this Privacy Policy. Please note that your opt-out is limited to the email address associated with the request and will not affect subsequent subscriptions or non-promotional communications. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, enforce our agreements and comply with your requests.

We may ask for additional Personal Information or for you to verify certain Personal Information in conjunction with any of your requests pursuant to this Section of the Privacy Policy. We also reserve the right to deny any request made under this Section of the Privacy Policy if: (1) you are unable to provide any additional Personal Information that we may request; (2) we cannot verify your request; or (3) we believe the change would violate any applicable law or legal requirement, including, but not limited to, any lawful retention period or cause the information to become incorrect.

EUROPEAN USERS

The Services and all e-mail, text and other communications, including without limitation, the Newsletter, are based in the United States and operate under US law. If you are located outside the United States when you use, interact with or otherwise access the Services or engage in communications with us via mail, e-mail, telephone or any other means, please be aware that your Personal Information may be transferred to, stored and processed in the United States where our servers are located. Any information you provide to us, or that we collect through your use of the Services will be stored, processed, and transferred within, or to, the United States. Please be aware that the United States and jurisdictions other than the one in which you are located may not provide the same level of data protection as is considered adequate in your country. As such, visitors and users of the Services located outside the United States should not use, interact with, or otherwise access the Services or engage in communications with us via mail, e-mail, telephone or any other means if you do want your information to be treated in this manner. Note, that your Personal Information may be made available to the US Government or its agencies under legal process in the United States.

SECURITY AND DATA BREACH DISCLAIMER

In connection with our commitment to protect your information and abide by the terms and conditions of this Privacy Policy, we have taken reasonable efforts to put security measures in place, including physical, technological, and procedural safeguards, to protect your data and information, including without limitation, Personal Information, against data breaches, unauthorized disclosures and improper use. However, while we have implemented safeguards, you should be aware that no security measures are absolute. Internet security technologies rapidly change. As a result, we cannot guarantee that the safeguards we employ today can protect your Personal Information from the threats of tomorrow or that our security measures are fail-safe and not subject to circumvention or unauthorized intrusion. You should also be aware that, despite our efforts, factors beyond our control might result in the disclosure or misuse of your information, including, but not limited to, Personal Information.

CHILDREN’S PRIVACY

The Services are not intended for children under 16 years of age and no one under age 16 may provide any Personal Information to, or through, the Services. We do not knowingly collect Personal Information from children under 16. If you are under 16, you are expressly prohibited from using and/or providing any information on or through the Services, including without limitation, through any of its features. If we learn we have collected or received Personal Information from a child under 16, without verification of parental consent, we will delete that information. If you believe we might have any Personal Information from or about a child under 16, please contact us pursuant to the “Contact ACEUM” Section of this Privacy Policy.

CHANGES TO THIS POLICY

ACEUM retains the right to change, modify or revise this Privacy Policy at any time without prior notice to you to reflect changes in our practices for collecting, using, maintaining, protecting, and disclosing your information or to satisfy any legal requirements to which we may be subject. If a change is material, we will notify you of any such changes using the processes described in the Terms and those changes shall be effective immediately upon notice. We encourage you to regularly check this Privacy Policy so that you understand our current privacy policies. The date at the top and bottom of this Privacy Policy indicates the last update hereto.

CONTACT ACEUM

If you have any comments or queries about this Privacy Policy or the way we collect and use your information, or if you suspect a data breach, unauthorized use or improper disclosure you may email us at imachowsky@aceum.com  or write to us at. 

ACEUM Advisors and Search
510 fifth Avenue- 3rd Floor
New York, NY 10036

Last Updated: July 15, 2021