Acorn Performance Group, Inc., dba Acorn Systems Inc. and its subsidiaries (collectively we, our, us or “Company”) respects the individual privacy and protects the personal data provided to Company by its clients, employees and others. The Company develops, markets, licenses, implements, and supports decision-support software that utilizes activity-based costing information to provide its customers with profit-enhancement opportunities.
The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the “Safe Harbor Principles”) and frequently asked questions to enable U.S. companies to satisfy the requirement under EU law that adequate protection be given to Personal Information transferred from the European Economic Area to the United States (collectively, the “Safe Harbor”). The European Economic Area (“EEA”) has recognized the Safe Harbor as providing adequate data protection. Consistent with its commitment to protect personal privacy, Company adheres to the principles set forth in the Safe Harbor. If there is any conflict between this Policy and the Safe Harbor Principles, the Safe Harbor Principles will govern.
For purposes of this Policy, the following definitions apply:
“Agent” means any third party that collects or uses Personal Information under the instructions of, and solely for, Company or to which Company discloses Personal Information for use on Company’s behalf.
“Personal Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to, a specific individual; and (4) can be linked to that individual. Personal Information does not include information that pertains to a specific individual, but from which that individual could not reasonably be identified.
“Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, medical or health conditions, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns sex life of the individual. In addition, Company will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.
Scope of the Policy
Types of Data Collected and Where
The information we collect may include your personal information, such as your name, contact information, IP addresses, work process and time you spent to perform certain tasks for your employer, financial accounts numbers, telephone conversations, product and service selections and orders or other information that indentify you individually.
We may collection information about you in the following manners:
• You may provide your personal information to us via interview, email or other written correspondence, telephone calls, web based forms, or other means;
• We use automated technical means to collect information about all website visitors;
• Via third party providers; or
• Via your employers for projects that they have engaged us to do on their behalf.
Much of the data processed and hosted by Company or its hosting service provider does not constitute personal data as that term is defined above. However, personal data will, on occasion, enter into the possession of Company and/or stored at the Company’s servers located at its hosting service provider location.
You may visit our Websites in any of the following ways:
• By using your browser to navigate to our Websites including (but not limited to) www.acornsys.com; blog.acornsys.com
• By viewing an advertisement displayed on a third party website that is served content by our web server;
• By viewing an email that is served content by our or a third party web server
When you visit our Website and register to download any of our controlled access Resources (e.g. white papers), our server logs your IP address (unique network addresses), the time and duration of your visit, and the time and duration of the pages on our website you view. If you arrive at our website by clicking a paid advertisement (including a paid search engine result) or a link in an email, then we will capture information that tracks your visit from that link. If you arrive at our Website by clicking a non-paid source, such as link in a non-paid search engine result or an unsponsored link on another website, we may capture information that tracks your visit from that source, to the extent we are able to be do so. We may also capture information about your computer system, such as your browser type and operating system.
We will likely place a cookie on your hard drive during the web visit. A cookie is a unique alphanumeric identifier that we use to help us identify the number of unique visitors to our Website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus. Other servers cannot read them and personal information cannot be gathered from them. They are simply an identifier shared between you and us to allow us to improve the services we offer to you through our Website. If you do not wish cookies to be place on your computer, then they can be disabled in your web browser, The option to do so is normally found in your browser’s “security setting” section. However, please note, permanently disabling cookies in your browser may hinder your use of our Website as well as other websites and interactive services.
A web beacon, also known as a web bug, is a small graphic (usually 1 pixel x 1 pixel), that is embedded in a web advertisement, email, or page on our web site, but is invisible to you. When you view a page on our web site, an email or an advertisement, your web browser will request the web beacon from a web server, which in turn will set a cookie in your web browser containing a unique identifier. This unique identifier will be linked to log information that is used to track your movements on our web site in order to determine the effectiveness of content and advertising campaigns.
We do not collect personal information about you as part of a web visit, but web visit information may be tied to other information (including personal information) we collect from you via web forms, and the other means we describe in this Privacy Statement. Our advertising agencies may also use web beacons and cookies to track your activity on our website originating from the advertisement or from downloading any of our controlled access Resources. However, we will not provide your personal information to our advertising agencies. Our advertising agencies maintain their own privacy policies, and you also review those.
Links to non-Acorn Websites
We may provide links to third-party websites for your convenience and information. The privacy practices of those sites may differ from Acorn practices and are not controlled by Acorn and covered by this Privacy Statement. We do not make any representations about third-party websites. We encourage you to review their privacy policies before submitting your personal data.
Personal Information received from the EU
• When Acorn is a data controller – Safe Harbor compliance
Acorn adheres to the Safe Harbor Principles as described in this Privacy Statement, with respect to the personal data we collect from EU data subjects or received from our customers or third party service providers located in the EU, such as information regarding service requests, service orders, handling orders, and delivering services; and have certified our compliance with the Safe Harbor Framework to the United States Department of Commerce. Acorn Safe Harbor certification can be found at www.acornsys.com/privacypolicy.aspx
• When Acorn is a data processor
Acorn’s obligations with respect to personal data which Acorn is solely a data processor, such as personal data that Acorn’s customers store or transfer using Acorn’s hosting services provided directly by Acorn or by a third party service provider contracted by Acorn to provide such services, are defined in its agreements with its customers and are not included in this Privacy Statement. In those circumstances, Acorn receives personal data from the EU as an agent of the customer merely for processing and is not required to apply Safe Harbor principles to that information. The customer will remain responsible for the personal data that it collects and processes and for the compliance with applicable protection laws.