Privacy Policy

Effective Date: April 5, 2025

Welcome to Acclimetry! We at Acclimetry (“Acclimetry,” “we,” “us,” or “our“) are committed to protecting your privacy and safeguarding your personal data. This Privacy Policy explains how we collect, use, share, and protect information when you use acclimetry.com and any related services, as well as your rights and choices regarding your information. We have crafted this Policy to be clear and user-friendly while maintaining legal integrity, in line with our obligations under applicable privacy laws in the UK, EU, and US. By creating an account or otherwise using Acclimetry’s platform, you acknowledge that you have read and understood this Privacy Policy. If you have any questions, please contact us using the details in the Contact Us section below.

1. Scope of This Privacy Policy

This Privacy Policy applies to all users of the Acclimetry platform, including our website and any applications or services we offer (collectively, the “Services”). It covers personal information you provide when registering an account, information generated through your use of the Services (including any content you create or share), and information we obtain from third parties. It also describes how we use cookies and analytics tools, how we protect your data, and your rights concerning your personal data.

Please note: Acclimetry’s Services are intended for business and investment purposes and are not directed to children under the age of 18. We do not knowingly collect personal information from anyone under 18. If you are under 18, please do not use the Services or provide any personal data to us.

2. Information We Collect

We collect personal information that you provide to us directly, information that is collected automatically when you use our Services, and in some cases information from third parties. We only collect what is necessary for the purposes described in this Policy.

2.1 Information You Provide to Us

When you create an account or use Acclimetry, you may provide information including:

Account Registration Data: When you sign up, we ask for information such as your name, email address, phone number, company or organization name, job title/role, and a password. This is required to create and secure your account, and to distinguish you from other users.
Profile and Company Information: You may provide additional profile details such as a profile photo, biography, or professional information. If you use the platform to create investment policies or asset allocation plans for a company, you might input company data (e.g. company financial details, investment objectives, policy documents). Any personal data about you or others that you include in such content will also be collected by us as part of providing the service.
Content and User-Generated Data: The platform enables you to input and generate content, such as investment policy statements, asset allocation models, reports, notes, or other materials (“User Content”). This content may include personal information (for example, names of team members, financial information, or other details you decide to input). Please only include personal or sensitive information in your User Content if you have the proper authority to do so.
Communication Data: If you communicate with us, for example by emailing support or using a contact form, we will collect the information you provide in those communications. This includes feedback, questions, or requests you send us, as well as any contact information (like email or phone number) you provide so we can respond.
Invitations and Referrals: The platform may allow you to invite others to join Acclimetry or to share content with other users. If you choose to refer a colleague or share content with another person, you might provide their name, email, or other contact information. We use this information to send an invitation or share the content as requested. Please ensure you have permission to provide another person’s information to us.

2.2 Information We Collect Automatically

When you use Acclimetry’s Services, we automatically collect certain information about your device and usage of the platform:

Usage Data: We record information about your activity on the platform. This includes the pages or screens you view, the features you use (such as creating a policy or generating a report), the time and date of each request or interaction, and what links you click on. We also log performance data (e.g., errors or load times) to help us improve the service.
Device and Technical Data: We collect technical information about the device and browser you use to access our Services. This may include your IP address, browser type and version, device type (e.g., laptop or smartphone), operating system, unique device identifiers, and approximate location (e.g., city or country) based on your IP. We also gather data through cookies and similar technologies (see Cookies and Tracking Technologies below) such as your preferences and session information.
Cookies and Tracking Information: When you visit acclimetry.com or use our app, we and our analytics partners use cookies, pixels, and similar tracking technologies to collect information about your browsing activities. This can include your interactions with our site (e.g., clicking buttons, logging in), which content you viewed, and how you navigated through our Services. For details on how we use cookies and your choices, please see Section 5: Cookies and Tracking Technologies.
Analytics Data: We use third-party analytics tools (like Google Analytics or similar services) that use cookies and device identifiers to help us understand how users engage with Acclimetry. These tools provide us with aggregated information such as which pages are most visited, how long users stay on pages, and general usage patterns. This information is generally collected on an anonymized or aggregated basis, but if it ever includes personal data, we treat it in accordance with this Policy.

We do not use automated decision-making or profiling in any way that produces legal or similarly significant effects on you, without human involvement. If this changes, we will update this Policy and comply with applicable legal requirements.

2.3 Information from Third Parties

On occasion, we may receive information about you from third-party sources, but only where we have lawful basis to do so. For example:

Service Providers and Integrations: If Acclimetry integrates with third-party services (for instance, if you link your Acclimetry account with a third-party financial account or import data from another service at your request), we will receive whatever information you authorize that third party to share with us. We will treat that information according to this Privacy Policy.
Other Users: If another user invites you to Acclimetry or shares content with you through the platform, they may provide some of your personal information (like your email address or name) to us as part of that process. We use that information only for the specific purpose of facilitating the invite or content sharing.
Public Sources: We generally do not collect personal data from public databases or social media, but if we ever do (for example, to verify professional credentials or prevent fraud), we will ensure we have a legal basis and will notify you as required by law.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

To Provide and Improve the Service: We process your information to create and manage your account, authenticate you when you log in, and operate the core functionalities of Acclimetry. This includes enabling you to create and manage investment policies, perform asset allocation analysis, store and share documents, and collaborate with others as you choose. We also use the information to monitor the performance of our Services, fix bugs, and improve and personalize your experience. For example, we might remember your preferences or settings to save you time, or use usage data to develop new features that matter to our users.
To Facilitate Sharing at Your Direction: If you choose to share content or collaborate with other authorized users on the platform, we use your personal information to make that possible. For example, if you direct us to share a policy document with a colleague, we will use the colleague’s contact information that you provided to grant them access. Similarly, we may show your name, profile, or contact info to other users with whom you are collaborating or who you invite, so they know who the content is from.
To Communicate with You: We use contact information (like your email and/or phone number) to send you important notices and updates about your account or our Services. This includes confirmations of account actions, transaction alerts (if any), changes to our terms or policies, security or fraud alerts, and other administrative or relationship messages. We may also send you newsletters or marketing communications about new features, content, or promotions if you have opted-in or if it’s otherwise permitted. You can always opt out of marketing emails (see Your Rights and Choices below), but we will still send essential account and service-related communications.
For Analytics and Service Enhancement: We analyze usage information and feedback to understand trends in how our Services are used and to make them better. This helps us troubleshoot issues, test out new features, and make informed decisions about business development. We might use aggregated usage data to, for instance, identify that a certain feature is popular and should be improved, or that users struggle with a certain workflow that we need to simplify.
To Enforce Policies and Prevent Misuse: We are dedicated to keeping Acclimetry a secure platform. We use personal data (including automated tools) to monitor for and prevent fraudulent, illegal, or abusive activities. For example, we may track login locations or unusual usage patterns to detect possible unauthorized access. We also enforce our Terms of Service and other usage policies; for instance, we may review content or accounts that are flagged for violating guidelines. If necessary, we’ll use information about such misuse to restrict or ban accounts in accordance with our terms.
To Comply with Legal Obligations: We process personal information as required by applicable laws and regulations. This may include retaining records for financial reporting, satisfying know-your-customer (KYC) or anti-money laundering regulations if applicable, responding to lawful requests by government or regulatory authorities (such as tax reporting or law enforcement requests), or fulfilling obligations relating to user privacy rights. If we are under a legal duty to disclose your data (for example, by court order or subpoena), we will only do so after verifying the validity of the request and, when permitted, informing you of the request.
With Your Consent (for specific purposes): In some cases, we may ask for your consent to use your information for a purpose that is not covered by one of the above bases. For example, if we ever want to use your testimonial or profile in our marketing materials, we would ask for your explicit consent. You have the right to withdraw your consent at any time, and we will stop the use of your information for that purpose. Withdrawing consent will not affect any processing already done while the consent was valid.

Legal Bases for Processing (EU/UK users): If you are in the UK or European Economic Area (EEA), we must inform you of the legal grounds we rely on under GDPR/UK GDPR. Most of our processing is based on “performance of a contract” (Article 6(1)(b) GDPR) – we need your data to provide the Services you signed up for. Some processing is based on “legitimate interests” (Article 6(1)(f)), such as improving our services, securing our platform, and sending you relevant communications about the service (we consider and balance any potential impact on your rights). We rely on “legal obligation” (Article 6(1)(c)) when processing is necessary to comply with law (e.g., financial record-keeping or responding to legal process). If we ever rely on “consent” (Article 6(1)(a)), we will explicitly ask you, and you can withdraw it as noted above.

4. How We Share Your Information

We understand that your personal information is important, and we are careful about how we share it. We do not sell your personal data to third parties. We only share information in the following circumstances:

With Service Providers (Processors): We share information with trusted third-party companies that provide services to us or perform functions on our behalf, to support the uses described in this Policy. For example, these partners include cloud hosting providers (to store our data securely), email and SMS providers (to send verification codes or communications), analytics services (to help us understand usage of our platform), and customer support tools. These service providers are contractually bound to only use your data for our purposes and to protect it under standards at least as strict as those in this Policy.
With Other Users (at Your Direction): Personal information or content may be shared with other authenticated users of Acclimetry when you choose to do so. For instance, if you collaborate on an investment policy with a colleague, that colleague will see the content you input and may see your profile information (like your name and the fact that you are the creator of that content). Similarly, if you post content in a shared workspace or team environment on the platform, any member of that workspace will have access to it as per the platform’s functionality. We will only share your information with other users when you intentionally do so through the sharing features of our Services.
Within Our Corporate Group & Affiliates: If Acclimetry is part of a group of related companies, we may share your information with our parent company, subsidiaries, or affiliates as necessary to operate the Service (for example, if we have affiliate companies providing elements of the service or providing support). Any such entity will honor the commitments in this Privacy Policy.
For Legal Reasons: We may disclose your information if required to do so by law or in a good-faith belief that such action is necessary to (i) comply with a legal obligation, such as a subpoena, court order, or regulatory request; (ii) protect and defend the rights, property, or safety of Acclimetry, our users, or the public; (iii) investigate and defend against third-party claims or allegations; or (iv) detect, prevent, or otherwise address criminal activity, fraud, security, or technical issues. We will attempt to notify you of legal demands for your data when appropriate, unless prohibited by law or court order.
In a Business Transfer: If Acclimetry is involved in a merger, acquisition, sale of assets, bankruptcy, or other transaction where personal data would be transferred to a third party as part of the business asset, we will ensure your data remains protected. You would be notified via a prominent notice on our site or via email of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information in such an event.
With Your Consent: Apart from the cases listed above, if we need to share your information for any other purpose, we will ask for your consent. For example, if we ever want to publish user success stories or testimonials containing personal info, we would only do so with your explicit permission.

Aggregated or De-Identified Data: We may also share information that has been aggregated or anonymized, so it no longer can be used to identify you. For instance, we might publish trend reports or performance statistics that do not contain any personal identifiers. This kind of data is not considered personal information and may be shared freely.

5. Cookies and Tracking Technologies

What Are Cookies? Cookies are small text files that websites place on your device’s browser to store information. Like most online services, Acclimetry uses cookies and similar tracking technologies (such as web beacons, pixels, and device identifiers) to provide, customize, and improve your experience on our platform.

How We Use Cookies: We use cookies and tracking technologies for several reasons:

Essential Cookies: These are necessary for our website to function properly. For example, they help authenticate your login, keep your session active as you navigate through secure areas of the site, and remember your preferences (such as your chosen language or region). Without these cookies, certain features of the Services may not work.
Analytics Cookies: We use analytics and performance cookies to collect information about how users interact with our site, which pages are visited, and any errors encountered. This data helps us improve the design and functionality of Acclimetry. For instance, we use Google Analytics (or similar analytics providers) to understand overall user behavior on our platform. These analytics cookies may collect your IP address and generate aggregate statistics, but they do not identify you personally. Google Analytics may set its own cookies; however, we have configured these services to respect privacy norms (for example, by anonymizing IP addresses where applicable).
Functionality Cookies: These cookies remember choices you make to give you better personalization. For example, if you adjust settings on your account or dismiss a one-time notification, a cookie might remember those actions so we don’t show you the same prompts repeatedly.
Advertising Cookies: (As of the Effective Date, Acclimetry does not host third-party ads on its platform, and we do not use advertising cookies. If this changes in the future, we will update this Policy and, if required by law, obtain your consent before using any non-essential cookies.)

Third-Party Tracking: In addition to our own cookies, some third parties may set cookies or similar trackers when you visit our site. For example, if we embed a video from a third-party service or if you use a third-party single sign-on to register (like signing in via Google or LinkedIn), those providers may set their own cookies. We do not control the data collection of these third parties and their use is governed by the privacy policies of the third parties. We encourage you to review the privacy and cookie policies of any third-party services you interact with through our platform.

Your Cookie Choices: When you first visit acclimetry.com, you will be presented with a cookie notice or banner. Where required by law (such as in the EU/UK), we will ask for your consent before placing non-essential cookies on your device. You can choose to accept or reject certain cookies using this tool. Even after you’ve given consent, you typically have the option to change your cookie preferences by accessing our Cookie Settings (look for a “Cookie Preferences” link on our site) or by clearing cookies in your browser. In addition:

Browser Settings: Most web browsers let you control cookies through their settings preferences. You can set your browser to refuse all or some cookies, or to alert you when cookies are being set. Keep in mind that if you disable cookies entirely, our website may not function correctly (for example, you might not be able to log in or use certain features).
Do Not Track: Some browsers have a “Do Not Track” (DNT) feature that sends a signal to websites requesting not to track your activity. Currently, there is no industry standard for recognizing or honoring DNT signals. As such, we do not respond to DNT browser signals at this time. We will update this section if a standard emerges and we are able to implement it.
Analytics Opt-Out: For Google Analytics, Google provides an opt-out mechanism for the web (a browser add-on) if you want to prevent your data from being used by Google Analytics across all websites.

By continuing to use our site with cookies enabled, you are consenting to our use of cookies as described in this section. For more detailed information about the cookies we use or to change your preferences, please refer to our Cookie Notice (if available) or contact us with any questions.

6. Communications and Marketing Preferences

We may send you different types of communications, and you have choices in how you receive or opt out of certain messages:

Service and Account Communications: We will always send transactional or relationship messages that are necessary for our Services, such as confirmation of account creation, password reset emails, customer support responses, policy updates, or security alerts. Because these communications are essential, you cannot opt out of them without deleting your account. We will send these primarily via email, or via in-app notifications when appropriate. In some cases, if you’ve provided a phone number, we might send urgent account alerts via SMS or call (for example, to verify a new device or notify you of important account activity).
Marketing and Promotional Emails: With your permission or as otherwise permitted by law, we may periodically send newsletters, product updates, or special offers to the email address associated with your account. You have the right to opt out of these marketing communications at any time. If you prefer not to receive promotional emails, you can click the “unsubscribe” link in the footer of any marketing email we send, or adjust your preferences in your account settings (if that feature is available). You can also contact us at any time to request removal from our marketing list. Please note that even if you opt out of marketing messages, we may still send you necessary service-related communications as described above.
In-App and Push Notifications: If our platform or mobile app provides notifications (for example, a banner notice within the app or push notifications on your device), we will only send these with respect to your account activity or updates about our service. You can typically control push notification preferences via your device settings or the app’s settings.
SMS/Texts and Calls: If you opted in to receive text messages or phone calls for verification, support, or marketing, and you change your mind, you can opt out by following the specific instructions provided for that channel (e.g., replying “STOP” to a text message to unsubscribe from SMS alerts). Standard messaging/data rates may apply for any text communications, as per your carrier’s policies.

Your Responsibility for Communications: If you invite others to Acclimetry or share content that triggers a notification to them, ensure that your communications or invitations are sent in compliance with applicable laws (for example, only invite people who expect to receive an invite from you). We allow you to send such invitations, but the recipients should not be surprised or spammed by our platform on your behalf.

If you have any issues with unwanted communications from us, please contact our support or use the unsubscribe mechanisms provided. We will promptly address your concerns.

7. Data Security

The security of your personal information is extremely important to us. We implement a variety of technical, administrative, and physical security measures to protect your data from unauthorized access, misuse, alteration, and loss. These measures include, for example:

Encryption: We use encryption protocols (such as HTTPS/TLS) to secure data in transit between your device and our servers. Sensitive data (like passwords) is stored in encrypted form (for instance, hashed and salted) in our databases.
Access Controls: We limit access to personal information to authorized employees and contractors who need it to operate or improve our Services. Those who have access are subject to strict confidentiality obligations. We employ role-based access and two-factor authentication internally to prevent unauthorized access to systems that contain user data.
Monitoring and Testing: Our systems are monitored for vulnerabilities and breaches. We regularly update our software and infrastructure and conduct security assessments. Where possible, we also obtain third-party security audits or certifications to validate our practices.
Payment and Financial Information: (If our service involves payments or financial account connections, we ensure that this information is handled securely. For example, credit card information would be processed and stored by a PCI-DSS compliant payment processor, not stored on our servers directly.)
Training and Policies: Our staff is trained on data protection best practices and we have internal policies in place to handle personal data safely and to respond quickly in the event of a security issue.

While we strive to protect your information, no method of transmission over the internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security of your data. You can play a part in keeping your data secure too: please use a strong, unique password for Acclimetry and do not share it with others. If you suspect any unauthorized access to your account or any security breaches, notify us immediately so we can help protect your account.

In the unfortunate event of a data breach that poses a risk to your rights and freedoms, we will notify you and the appropriate authorities as required by law.

8. Third-Party Services and Links

Acclimetry’s Services may contain links to third-party websites, integrations, or services that we do not own or control. This can include, for example, links to external resources, partner websites, or embedded third-party tools within our platform. If you choose to visit or use any third-party services via our platform, this Privacy Policy does not apply to those services.

Third-Party Websites: If you click a link to an external website (for example, a financial news article or a partner’s site), you will be directed to a site that is outside of our control. Those sites might collect your personal information independently and have their own privacy practices. We are not responsible for the content, privacy, or security practices of external websites. We encourage you to review the privacy policies of any website or service you visit.

Integrated Services: In some cases, Acclimetry may integrate with third-party services (for instance, allowing you to import data from a brokerage, or login through a third-party identity provider). If you use or interact with these integrated services, the third parties may receive certain data about you. For example, if you use Google OAuth to sign in, Google’s privacy policy will apply to the data Google collects. We attempt to only work with third parties that share our respect for your privacy, but we can’t control how they operate. We recommend checking the privacy settings and notices for any third-party services you use in connection with Acclimetry.

Social Media and Sharing Features: Our Services might include social media sharing buttons or widgets. If you use these, the social media company operating the widget may collect data about your browser activity, even if you don’t click the widget. This could include your IP address or which page you’re visiting on our site, and they may set a cookie. These interactions are governed by the privacy policy of the social media company (e.g., LinkedIn, Twitter).

Liability for Third Parties: Acclimetry is not responsible or liable for any issues arising from your use of third-party websites or services. This includes how those third parties collect, use, or share your data. If you have questions about how a third party handles your information, please read their privacy policy and contact them directly. We provide links and integrations for your convenience and functionality, but use of them is at your discretion and risk.

9. User-Generated Content and Your Responsibilities

User-Generated Content: Acclimetry allows you to create, input, and share content as part of our Services. This content – which might include investment strategies, policy documents, analysis, comments, or other materials you create – is considered “User-Generated Content.” You are solely responsible for the content you provide or make available on the platform. Acclimetry disclaims any liability for the content that users generate or any actions taken by users based on such content.

Sharing and Privacy of User Content: When you choose to share User-Generated Content with others on the platform (for example, by inviting other users to view or collaborate on a document or strategy), you acknowledge that any personal or sensitive information included in that content will be disclosed to those recipients. While we provide the tools to share content securely with authorized users, we cannot control (and take no responsibility for) what recipients do with the information you share. Please exercise caution when including personal data in content and when deciding who to share content with. If you do not want certain information seen by others, do not include it in any content you share on the platform.

No Monitoring or Endorsement: Acclimetry does not routinely monitor or pre-screen user content. We do not endorse or verify the accuracy, completeness, or usefulness of any User-Generated Content. Any opinions or recommendations expressed by users are their own and not necessarily those of Acclimetry. If you rely on any information provided by another user, you do so at your own risk. Acclimetry will not be liable for any losses or damages arising from your reliance on user content or interactions with other users.

Prohibited Content: Although this Policy is about privacy, we want to remind users that our Terms of Service (available on our website) outline what content and behaviors are not allowed (for example, posting unlawful, infringing, or harmful content). If you upload personal data about others, you should have their permission. If you misuse personal data or violate privacy rights of others via the platform, your account may be subject to suspension or termination.

Reporting Issues: If you believe another user is misusing your personal information or you find content that is offensive, infringing, or in violation of your privacy, please contact us immediately. We will investigate and take appropriate action, in line with our Terms and this Policy. However, note that our intervention in disputes between users regarding content may be limited.

In summary, you control what content you share and with whom, and you assume responsibility for the consequences of sharing. Acclimetry provides the platform but is not responsible for user-generated content or the actions users take with that content.

10. International Data Transfers

Acclimetry is a global service. The personal information we collect may be processed on servers in countries different from your own. In particular, if you are located in the United Kingdom or European Economic Area, please be aware that your personal data may be transferred to and stored in countries outside of the UK/EEA (for example, the United States) that may have different data protection laws.

Adequacy and Safeguards: Whenever we transfer personal data out of the UK or EU, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards as required by law. These might include:

Relying on a determination of adequacy by the European Commission or UK authorities (i.e., the country is deemed to provide an adequate level of data protection); or
Using approved Standard Contractual Clauses (SCCs) or equivalent legal instruments which contractually oblige the recipient to protect your data according to EU/UK standards; or
In limited cases, based on your explicit consent or another legal derogation permitted under Article 49 of GDPR (if applicable).

We also may implement additional technical and organizational measures to protect data transferred internationally, such as encryption and access controls as described in the Data Security section.

Your Rights Regarding International Transfers: If you are an EU/UK user and would like to know more about these transfer safeguards or receive a copy of the relevant contractual commitments, you can contact us using the information in the Contact Us section. We will be happy to provide you with further details upon request.

By using Acclimetry’s Services, you understand that your information may be transferred to our facilities and third parties as described in this Policy, which could be located in other jurisdictions. We will always handle your personal information in accordance with this Privacy Policy, wherever it is processed.

11. Your Rights and Choices

You have rights regarding your personal information, and we are committed to honoring them. Depending on your jurisdiction (for example, whether you are in the UK, EU, or certain states in the US), your rights may include:

11.1 Rights for UK and EU Individuals

If you are located in the United Kingdom, European Union, or a similar jurisdiction that grants data subject rights under the General Data Protection Regulation (GDPR) or equivalent laws, you have the following rights with respect to your personal data:

Right to Access: You have the right to request confirmation that we are processing your personal data, and to request a copy of the personal data we hold about you. This helps you understand what information we have and how we use it.
Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to ask us to correct or update it. You can also correct some of this information directly by logging into your account settings.
Right to Erasure: Commonly known as the “right to be forgotten,” this allows you to request deletion of your personal data when it’s no longer necessary for the purposes we collected it, or when you withdraw consent (in cases where we rely on your consent) or when you object to processing and we have no overriding legitimate grounds to continue, or if we unlawfully processed your data, or to comply with a legal obligation. Please note this right is not absolute – sometimes we must retain certain information for legal reasons (see Data Retention below). If you request deletion, we will explain if any data cannot be deleted due to legal requirements.
Right to Restrict Processing: You can ask us to suspend or limit the processing of your personal data in certain circumstances – for example, if you contest the accuracy of the data, or if you want to restrict processing while you pursue an objection to processing (see below). During such restrictions, we can store the data but not use it.
Right to Data Portability: You have the right to request a copy of certain personal data in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another controller (for example, another service provider). This typically applies to data you provided to us and that we process by automated means based on your consent or contract with us. Where technically feasible, you may request that we transfer the data directly to another entity.
Right to Object: You have the right to object to our processing of your personal data when we base our processing on legitimate interests (including profiling based on those interests). If you lodge an objection, we will no longer process your personal information for those purposes unless we have compelling legitimate grounds that override your privacy rights or if we need to continue processing for the establishment, exercise, or defense of legal claims. Importantly, you always have the right to object to the processing of your personal data for direct marketing purposes – if you object, we will stop using your data for marketing immediately.
Right to Withdraw Consent: If we have asked for your consent to process certain data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing based on consent before its withdrawal, and it won’t affect processing that is not based on consent (for example, processing based on contract or legitimate interests).
Right to Lodge a Complaint: If you believe we have infringed your data protection rights, you have the right to file a complaint with a supervisory authority. For UK users, this would be the Information Commissioner’s Office (ICO). For EU users, this would typically be the data protection authority in your country of residence or work, or where the alleged infringement took place. We would, however, appreciate the chance to address your concerns directly before you do this, so please consider reaching out to us first.

To exercise any of these rights, please contact us using the details in the Contact Us section below. We may need to verify your identity before fulfilling your request (to protect your privacy, we need to be sure it’s you). We will respond to your request within the timeframe required by law (generally within one month for UK/EU requests, with the possibility of extension by two further months in certain circumstances, in which case we will inform you of the delay and the reasons). Exercising these rights is generally free of charge; we will not charge you for requests unless they are manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse to act on the request (we would explain why).

11.2 Rights for California and Other U.S. Residents

If you are a resident of certain U.S. states, such as California, you may have specific privacy rights under state law. In particular, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants California residents certain rights regarding their personal information (as defined under California law). These rights include:

Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell (note: Acclimetry does not sell personal information). You can request both the categories of personal information and specific pieces of personal information that we have collected about you. You also have the right to know the categories of sources of that information, the business or commercial purpose for collecting it, and the categories of third parties with whom we share it.
Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. For example, we may retain information needed to complete a transaction you requested, to detect security incidents, to comply with a legal obligation, or other purposes permitted by law. If an exception applies, we will inform you in our response.
Right to Correct: Under CPRA, you have the right to request correction of inaccurate personal information that we maintain about you. We will take into account the nature of the information and the purposes of processing when determining how to correct it.
Right to Opt-Out of Sale/Sharing: You have the right to direct businesses that sell or “share” (for cross-context behavioral advertising) personal information to stop doing so. However, Acclimetry does not sell personal data or share it for targeted advertising. If that ever changes, we will update this Policy and provide a “Do Not Sell or Share My Personal Information” link or similar mechanism for you to exercise this right.
Right to Limit Use of Sensitive Info: If we collect categories of “sensitive personal information” (as defined by law, e.g., precise geolocation, social security numbers, etc.), California residents can direct us to limit the use of such information to certain allowable purposes (like providing the Services). Acclimetry’s collection of sensitive data is minimal and only used for necessary business purposes (for instance, login credentials or any financial info would be considered sensitive and we use it only for providing the service).
Right of Non-Discrimination: We will not discriminate against you for exercising any of these rights. That means we won’t deny you services, charge you a different price, or provide a different quality of service just because you exercised your privacy rights. However, please note that if the exercise of your rights limits our ability to process your personal information (for example, a deletion request), we may not be able to provide you with certain services that require the use of that information.

Exercising Your U.S. Privacy Rights: To make any request under California law (or similar laws of other states, like Virginia, Colorado, etc.), please contact us using the information in the Contact Us section below. Clearly describe your request – for example, whether you want to know about your data or delete your data. We will take steps to verify your identity (such as asking you to provide information that matches our records). For certain requests, we might require a signed declaration confirming your identity. You may also designate an authorized agent to make a request on your behalf. If you use an authorized agent, we will require proof of the agent’s identity and authority (for example, a written permission from you). We aim to respond to verified requests within 45 days as required by CCPA/CPRA. If we need more time (up to an additional 45 days), we will inform you of the reason and extension in writing.

Shine the Light (California): California’s “Shine the Light” law allows residents to request certain information about our disclosure of personal information to third parties for their own direct marketing purposes. As noted above, we do not share your personal information with unaffiliated third parties for their own marketing use without your permission. Therefore, we do not have such information to provide. If you have questions about this, you can contact us.

11.3 General Choices for All Users

Regardless of where you live, Acclimetry provides the following controls over your information:

Account Profile: You can access and update certain profile and account information by logging into your Acclimetry account and editing your profile or settings. For example, you can change your contact details, password, and possibly certain preferences from the account settings section. Keeping your information up-to-date helps us serve you better (and you are required to maintain accurate information as per our Terms).
Content and Sharing Settings: Through our platform’s interface, you have control over what content you share and with whom. You can add or remove collaborators on documents, change sharing permissions, or make content private or public (if such features are available). We encourage you to review your sharing settings regularly to ensure they reflect your intentions.
Opting Out of Marketing: As described in Section 6, you can opt out of marketing emails at any time by unsubscribing or contacting us. You can also opt out of certain notifications or adjust communication preferences via your account if options are provided.
Account Deactivation: If at any time you wish to stop using Acclimetry, you may deactivate or delete your account. You can request account deletion by contacting us. Deleting your account typically means we will remove or anonymize personal information associated with your account (subject to the exceptions noted under Data Retention below). Be aware that content you shared with others may still be accessible to those individuals (for example, if you collaborated on a document, they might still have a copy), even after your account is deleted. It is your responsibility to remove any content you don’t want others to have before you delete your account, or to ask them to delete it.

If you have any questions about your rights or how to exercise them, or if you need assistance managing your choices, please reach out to us. We are here to help and will work to address any concerns you have about your personal data.

12. Data Retention

We will retain your personal information for as long as needed to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. How long we keep data can vary depending on the type of information and the context in which it was collected:

Account Information: We keep the personal information you provide for your account (such as contact info, profile details, content) for as long as you have an account with us. When you delete your account or request deletion, we will initiate the process to remove or anonymize that data. However, please note that we may retain certain information for a limited period afterward in back-ups or archives, or as required for legal compliance.
User Content: Content that you create on the platform is stored until you delete it or your account is deleted. If you remove specific content from the platform, we will delete it or anonymize it in the live database, but residual copies might remain temporarily in our backup systems. If you shared content with others, those individuals may still have access to or copies of your content even after you delete it – we do not control that, so keep it in mind when sharing.
Transactional and Usage Data: We may retain logs of usage (login records, system logs) and transactional data (for example, records of when you agreed to terms, or communications logs) for a certain period for security, auditing, and analytic purposes. Typically, this data is retained only as long as necessary for those purposes and often in aggregate form for analysis.
Legal Compliance: In some cases, we are required to keep certain data for a set period by law. For example, financial records or audit logs might need to be kept for a number of years to comply with tax or accounting regulations. If you engaged in a financial transaction on the platform or we issued invoices, we would retain that documentation as required by law. Also, if there is an ongoing legal issue (like a dispute or investigation), we would retain relevant information until it is resolved.
Backup and Archival: Even after deletion, your data might remain in backups or archival media for a short period until those backups cycle out or are deleted. We maintain backup systems to ensure reliability of our service and data recovery in case of emergencies. We secure any retained backup data and only use it if necessary for restoration or for legal compliance.

Once we have no ongoing legitimate business need or legal requirement to keep your personal information, we will ensure it is either securely deleted or anonymized (so that it can no longer be associated with you). If deletion is not immediately possible (for example, because your data is stored in backup archives), we will isolate it from further processing until deletion is possible.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will revise the Effective Date at the top of the Policy. If the changes are significant, we will provide a more prominent notice, such as by email notification to the address associated with your account or by placing a notice on our website’s homepage or dashboard.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of Acclimetry’s Services after any update to this Privacy Policy will constitute your acknowledgment of the changes and your agreement to be bound by the updated Policy. If you do not agree with the changes, you should discontinue use of the Services and may request deletion of your data as described above.

For previous versions of this Privacy Policy or any questions about the changes, you can contact us using the information below. We maintain an archive of past privacy notices which can be provided upon request, as required by law.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please do not hesitate to contact us. We are here to help.

By Email: You can reach our privacy team at [email protected]. This is the fastest way to get a response about privacy-related inquiries, including questions about your data or requests to exercise your rights.
By Contact Form: Alternatively, visit our website’s Contact or Support page at acclimetry.com/contact and submit a privacy inquiry through the provided form.

We will respond to your inquiries as soon as reasonably possible, and at most within any timeframe required by law. If you are contacting us to exercise a specific privacy right, please provide enough information for us to verify your identity (for example, the email associated with your account and a description of your request). For your security, we may need to ask for additional information to confirm your identity before we can disclose or update data.

Thank you for trusting Acclimetry with your investment policy and asset allocation needs. We value your privacy and are dedicated to protecting it.