Last modified on January 4th, 2019

INTRODUCTION

Acru Consulting Inc. (“Acru”, “us”, “we” or “our”) respects the privacy of our users (each, “you”, “your” or “user”) and is committed to protect the privacy of users who access, visit, use or engage with our website or any other services we provide (collectively, the “Services”). We have prepared this Privacy Policy to outline our practices with respect to collecting, using and disclosing your information when you use the Services. We encourage you to read the Privacy Policy carefully and use it to make informed decisions. By using the Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy. Any use of the above terminology or other words in the singular, plural, capitalization are taken as interchangeable and therefore as referring to the same.

ACCEPTANCE OF PRIVACY POLICY

It is important for you to review this Privacy Policy as it applies to all Services.

By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.

By accepting the Privacy Policy on use of our Services, you expressly consent to our collection, use and disclosure of your personal information and direct us to do so in the manner described in this Privacy Policy.

If you disagree with the terms of this Privacy Policy, please do not register for or use the Services.​

OVERVIEW

We take the protection of privacy of your personal information very seriously and will collect, use and disclose your information only in accordance with the terms of this Privacy Policy or otherwise with your consent or in compliance with the law. In order to operate and provide the “Services” and to reduce the risk of fraud, we must ask you to provide us with information about yourself. This Privacy Policy describes the information we collect and how we use and disclose that information.

We will not sell or rent your personal information to third parties for their marketing purposes without your explicit consent. However, in order for us to offer our services to our users; enhance the quality of our service from time to time; and protect the interests of our users, we will in limited circumstances share some of your personal information with third parties under strict restrictions, as described in more detail in this Policy.

INFORMATION WE COLLECT

Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you.

You may be asked to provide personal information anytime you are in contact with us. We may share your personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, and content. We may collect two types of data and information from you.

The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is information of an anonymous nature, such as an Internet Protocol Address (IP Address) provided it has been stripped of personal information, the domain used to access the Services, and the type and version of browser or operating system being used by visitors to the website. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, and average time spent on the Services is not considered Personal Information.

Non-personal Information which is information of an anonymous nature, such as an Internet Protocol Address (IP Address) provided it has been stripped of personal information, the domain used to access the Services, and the type and version of browser or operating system being used by visitors to the website. Aggregate information, such as demographic statistics of our users (e.g. average age or geographical allocation of our users), number of visitors, what pages users access or visit, and average time spent on the Services is not considered Personal Information.

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). Personal identifiable information, such as your name, e-mail address, phone number, address. At the time of collection, we will clearly identify the information being collected. It is always your choice whether or not to provide Personal Information but if you choose not to provide certain requested Personal Information, in some instances you may not be able to register to use the Services or be able to access and use the Services at all. In other instances, your choice not to provide certain other Personal Information may mean that you will not be able to use certain features of the Services. We may collect Personal Information in respect of the Services through service purchases; communications with you, transaction and user authentication procedures, user support; and surveys.

Such information may include:

  • Basic Service: When you use our Services, we ask you to provide Personal Information such as full name, date of birth, age, nationality, gender, signature, utility bills, photographs, employment, phone number, home address, and/or email. In general, none of your information will be shared with any other users of our Services. Using certain profile information, we may utilize third parties to extract additional information to help verify the authenticity, and any background checks required on your profile. 
  • Transaction Information: When you use our Services, we may ask you to provide information related to that transaction, including such information as the amount of the transaction, the type of transaction and payment information. We retain this information for each of your transactions through the Services and may add this information to your profile to be used for future transactions that you may make with us. We also collect the Internet address (IP address) and other identifying information about the computer or device you use to create or access our Services, in order to help detect possible instances of unauthorised or fraudulent transactions. Despite your indicated preferences, we provide notifications for certain activities relating to your use of our Services such as sending unique identification numbers to your mobile phone in order to verify purchases and confirmations to your email address when a transaction has been completed. We may also send you notices of any updates to our Privacy Policy.
  • Communication Information: We may collect information from your communications with us. For example, when you communicate with us, or respond to communications from us, via email, chat, audio or video calls (“Communications”). We may record and keep all the Communications.
  • Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers, as well as other information which relates to your activity through the Services.
  • Website Traffic Information: Because of the way Internet communication standards work, when you arrive at or leave our Services, we automatically receive the web address of the site that you came from or are going to. We also collect information on which pages of our website you visit, IP addresses, the type of browser and operating system you use and the times you access our website. We use this information to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve the Services. Cookies are used by us to track content usage and traffic on the website. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. The Services uses cookies to help it compile aggregate statistics about usage of our Services, such as how many users visit the website, how long users spend viewing the site, and what pages are viewed most often. This information is used to improve the content of the Services. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the website. We do not link any of the information we use in cookies to any personally identifiable information submitted by you when you are using our Services.

For avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.

HOW DO WE USE THE INFORMATION

We aim to collect, use and disclose only such information as is required to enable us to provide the Services, including verifying identification and authenticating transactions, to maintain transaction histories and customer lists, to respond to your inquiries or provide feedback, for identification and authentication purposes, and for service improvement. We will maintain the confidentiality of any Personal Information you provide to us on signing up for our Services or contacting us with questions or for further information and we will use it only for the purposes for which we have collected it (subject to the exclusions and disclosures we have listed below), unless you agree that we may disclose it to other third parties.

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

  • To set up an account in order to provide specific Services;
  • To identify and authenticate your access to certain features of the Services;
  • Resolve disputes, collect fees, and troubleshoot problems;
  • Inform you about service updates and faults;
  • Investigate and prevent potentially prohibited or illegal activities;
  • Customize, measure, and improve our services and the content and layout of our website;
  • Deliver targeted marketing and advertising, service updates, and promotional offers;
  • Compare information for accuracy, and verify it with third parties;
  • For our internal purposes, to associate relationships amongst our users and transactions through such attributes as name, mobile number or device information to comply with anti-money laundering and anti-terrorist financing laws and regulations.
  • Protect your and our interests, including in particular to investigate, prevent and fight against fraud; and
  • Comply with legal and regulatory requirements.

HOW WE SHARE THE INFORMATION AND FOR WHAT PURPOSE

Disclosure to Third Parties Other Than Our Users

We will not sell or rent any of your personal information to third parties for their marketing purposes without your explicit consent, and will only disclose this information in the limited circumstances and for the purposes described in this Policy. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including meeting national security or law enforcement requirements.

Specifically, you consent to and direct us (and third party service providers acting strictly on our behalf) to do any and all of the following:

  • Disclose information including, without limitation, transaction information, account information, personal information and the contents of communications to: the police; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies (other than tax related authorities), departments, regulatory authorities, self-regulatory authorities or organizations; and other third parties that we in good faith believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activity or potential illegal activity, or to conduct investigations. If you provide false or inaccurate information and fraud is identified, we may pass details to fraud prevention agencies and law enforcement agencies may access and use that information. We and other organizations may also access and use this information (including information from other countries) to prevent fraud and money laundering.
  • Disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian legally appointed for you).
  • Disclose aggregated statistical data with our business partners. For example, we may disclose that a specific percentage of our users live in particular geographies. However, this aggregated information is not tied to Personal Information.
  • As with any other business, it is possible that in the future we could merge with, or be acquired by, another company. If such an acquisition occurs, you consent to the successor company having access to the information maintained by us, including customer account information, and such successor company would continue to be bound by this Privacy Policy unless and until it is amended. 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.

HOW WE USE COOKIES

Cookies are used by us to track content usage and traffic on the Services. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. The Services uses cookies to help it compile aggregate statistics about usage of this Services, such as how many users visit the website, how long users spend viewing the Services, and what pages are viewed most often. This information is used to improve the content of the Services. You can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Services. We do not link any of the information we use in cookies to any personally identifiable information submitted by you when you are on the Services.

We use analytics software to allow us to better understand the functionality of our software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. We do not link the information we store within the analytics software to any personal information you submit within the mobile app.

HOW LONG WE RETAIN THE INFORMATION

We retain the information we collect for as long as needed to provide the Services (including aspects of risk management) and to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements (unless we are instructed otherwise). We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion.

HOW WE PROTECT YOUR INFORMATION

We take great care implementing and maintaining the security of the Services and your information. We aspire to continuously employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information.

We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. We will take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation.

We encrypt all transmission of information using secure socket layer technology (SSL). Your personal and traffic data can only be accessed by authorized employees of ours or our affiliates, subsidiaries or service providers who need to have access to this data in order to be able to fulfill their given duties.

Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied, or otherwise, that we will manage to prevent such access. If you feel that your privacy was treated in discordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at info@acruconsulting.com.

MINORS​

Children are not eligible to use our Services and we ask that minors (under the age of 18) do not submit any personal information to us or use our Services. We do not knowingly solicit data from, or market to, persons under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without his or her consent, he or she should contact us at info@acruconsulting.com. We will delete such information from our files.

LINKS TO THIRD PARTY SITES

Our site includes links to other websites whose privacy practices may differ from those of ours. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

POLICY UPDATES AND NOTIFICATIONS

All future changes to this Privacy Policy as already published on our website at the time you register for the Services. We may amend this Privacy Policy at any time by posting a revised version on our website. The revised version will be effective at the time we post it. If you disagree with the terms of this Privacy Policy, you may close your account at any time.

Please check our website at any time for the most current version of our Privacy Policy.

If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at info@acruconsulting.com.