Platform Privacy Notice

Introduction

This Privacy Notice details how AcumenLabs Ltd. ("us", "we" or "Company")process information of our customers' employees who are registered users of our services (each, "you" or "User") collected through our platform (the "Services").  

The details of the Company are as follows: Acumen Labs Ltd.[Acumen Address]

Our data protection officer may be contacted by email at: [Acumen privacy email address]

We may revise this notice from time to time, in our sole discretion, and the most current version will always be posted on our website(as reflected in the "Last Revised" heading). We encourage you to visit this page regularly for any changes.

What information we collect

We may collect personal information about you ("Personal Information") which we receive from our customers when signing-up or registering to our Services, which may include the following information your name and email address.

Legal basis

The Company processes Personal Information based on the following legal basis: Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

How we use the information

We use the information in the manners described in this PrivacyPolicy. In addition to the purposes listed herein, the information we collect, which may include your Personal Information, is used for the following purposes:

• To provide our customers with the Services;
• To investigate and resolve disputes in connection with your use of theServices;
• To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or     negatively affect the integrity of the Services; and
• To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

With whom we share the information and for what purpose

We do not rent or sell any Personal Information. We may sharePersonal Information with the following recipients:

• our third party vendors engaged in providing services in connection with the Services;
• our subsidiaries and affiliated companies;
• auditors or advisers of our business processes; and
• any potential purchasers or investors in the Company.

We may share Personal Information with our recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) assisting us with our business operations (e.g., issuing credit cards and processing transactions);and (iii) performing research, technical diagnostics, personalization and analytics that will enable us to improve the Services.

We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our agreements), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) establish or exercise our rights to defend against legal claims;(v) prevent harm to the rights, property or safety of us, our affiliates, our users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights. 

International transfer

Since we operate globally, it may be necessary to transfer data, including Personal Information, to other countries than the country in which the information was collected. In these instances, we will transfer your data only based on standard data protection clauses adopted by the European Commission. 

For how long we retain the information

We retain the information that we collect from our Users for as long as we are providing the Services to the applicable customer. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.Under applicable regulations, we may keep records containing Users' PersonalInformation, account opening documents, communications and anything else as required by applicable laws and regulations.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Your privacy rights

Certain jurisdictions provideUsers with certain statutory rights to their Personal Information. Subject to exemptions provided by law, and with proper identification, you may have the right to certain actions to your Personal Information such as:

• Right to verify your Personal Information (to access, delete, change or update any Personal Information relating to you. For example, if you believe that your Personal Information is incorrect, you may ask to have it corrected or deleted);
• Right to see what Personal Information about you we have;
• Right to request that we erase Personal Information about you(subject to any other legal obligation that may require us to keep that information);
• Right to restrict us from processing Personal Information pertaining to you (for example, you may request that we will stop using or sharing your Personal Information with third-parties); and
• Right to export Personal Information in a portable format.

If you wish to exercise any of these rights, contact us at: privacy@acumen.io. When handling your request, we will ask for additional information to confirm your identity (which may include Personal Information).However, please note that if you choose not to allow us to process yourPersonal Information, we may be prevented from providing our Services. 

Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. 

If you wish to raise a complaint on how we have handled your Personal Information, please contact us directly at: privacy@acumen.io  

If you are not satisfied with our response or believe we are collecting or processing your Personal Information not in accordance with the laws, you can file a complaint to the applicable data protection authority