Privacy Policy

1. INTRODUCTION

This privacy policy (“Privacy Policy”) is effective as of 6 September 2021 and explains how Acora collects, stores, shares, protects and uses personal data of our website visitors, business contacts, job applicants, suppliers, consultants, professional advisors, investors, actual and potential customers of Acora.

Please note that this Privacy Policy will be regularly updated to reflect any changes in the way we handle your personal data or any changes in applicable law.

In this Privacy Policy ‘Acora’, ‘we’, ‘us’ and ‘our’ refer to Acora Limited, its holding companies and subsidiary companies (collectively, the “Acora Group”).

Personal data means any information that we hold about you from which you can be identified either directly or indirectly and it may include your name; contact details; job title, employer organisation, qualifications and professional activities, references provided by third parties, and results of other due diligence carried out.

2. HOW WE COLLECT PERSONAL DATA

We will collect and store your personal data when you interact with our website, when you have had contact with Acora through introductions, referrals or meeting an Acora representative, when corresponding with us in relation to a sale, order, product or service with Acora or when applying for any career opportunities with us.

We collect personal data in writing, by telephone, by e-mail and by online registrations.  We may receive information from third parties who collect personal data from you and pass it on to us.

3. WHAT PERSONAL DATA DO WE HOLD ABOUT YOU

If you are a business contact, a trade supplier, or professional adviser we will hold limited amounts of personal data about you such as your name, contact details, job title, and employer organisation.

If you are a contractor or consultant, we will hold personal data about you including the information set out below in this section, as well as your date of birth, bank account details and VAT number (to the extent applicable).

If you are a job applicant, we may hold information you have provided to us in your CV, application form and covering letter including the information set out below in this section as well as your date of birth, gender and any information you provide to us as during an interview.  We may also hold special categories of more sensitive personal data such as your race or ethnicity, information about your health including any medical condition and sickness records.

If you are an investor or potential investor, shareholder or potential shareholder, personal data we hold about you may include the same information as listed below in this section, as well as bank account details, share in investments, amounts invested, returns from such investments and tax number, and information relating to your financial status and dealings, nationality (including copies of identity documents, such as a passport), references provided by third parties and results of other due diligence carried out. For more information, relating to the information we hold about you if you are an investor or shareholder, please refer to the relevant investment documentation.

We will take reasonable steps to keep the personal data that we store accurate and where necessary up to date. If you consider that any of the personal data that Acora holds about you is incorrect please notify Acora, see Contact Information in section 15 below.

4. HOW WE USE YOUR INFORMATION

We will use your personal data, and may share your personal data with other parties acting on our behalf, for one or more of the following purposes:

• managing and maintaining records of services or advice we have received, and commissioning further services;
• seeking and obtaining advice from our professional advisors, including lawyers, accountants and other consultants;
• inviting you to presentations and events and organising meetings between you and Acora representatives;
• assessing potential transactions;
• maintaining records of investments;
• complying with our regulatory and legal obligations;
• for our own administrative purposes or conducting internal audits;
• protecting our legal rights and interests;
• if you are a supplier, consultant, professional advisor, shareholder or investor, to carry out our contract with you; and
• to conduct research about the use of our website.

We will not sell your personal data to others.

If we wish to use your personal data for a purpose beyond that for which it was originally provided, we will ask for your consent or seek to rely on another valid legal ground to process your personal data in accordance with the applicable law.

5. INFORMATION FOR MARKETING PURPOSES

We may use your information to send you updates and news concerning Acora and its business and activities and events which we feel may be of interest to you.

If at any time you wish us to stop using your information for these purposes, please notify Acora, see Contact Information in section 15 below.

6. GROUNDS FOR PROCESSING

In order to store, hold and process your data lawfully we rely on one or more of the following legal grounds:

• your consent to particular processing activities. For example, where you have consented to us using your information for marketing purposes; or
• our legitimate interests in running our business. For example, if we enter into a transaction involving you, whether it completes or not, it may be necessary for us to process your personal information for the purpose of performing that contract and/or for complying with our legal and regulatory obligations;
• our compliance with a legal obligation to which Acora is subject. For example, we have a duty to investigate and respond to complaints made against us and may need to process your personal information as part of such investigation; or
• if you are a party to a contract, because processing your personal data is necessary for the performance of that contract.

7. DISCLOSURE OF YOUR PERSONAL DATA

There are circumstances where we may wish to disclose or are compelled to disclose your personal data to third parties. This will only take place in accordance with the applicable law and for the purposes listed above. These scenarios include disclosure:

• to other companies in the Acora group or our representatives;
• to our outsourced third party service providers who process personal information on our behalf such as providers of cloud hosting solutions or providers of data storage or security;
• to professional advisors such as lawyers and accountants, fund administrators or other consultants;
• to persons who have an interest or involvement in or who are considering an interest or involvement in a transaction with Acora (or funds managed or advised by Acora) including financial intermediaries, providers of finance, co-investors and investors in funds managed or advised by Acora;
• to legal and regulatory authorities where we are required by law or regulation to do so; and
• to any other third party where you have provided your consent.

“Acora Group” means (i) Acora Limited; and (ii) any body corporate which is the subsidiary or subsidiary undertaking or holding company or parent undertaking of any of the parties referred to in (i) and (ii) above and each body corporate which is a subsidiary or subsidiary of the holding company or parent undertaking of any of the parties referred to in (i) and (ii) above.

8. TRANSFER OF PERSONAL DATA OUTSIDE OF THE UK

From time to time, we may transfer your personal data to a third party in countries outside the UK including outside of the EEA for further processing in accordance with the purposes set out in this Privacy Policy. In particular, your personal data may be transferred to our outsourced service providers located abroad, and this may include companies, offices or data centres. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisational, contractual or other lawful means.  Please contact us if you would like more information about how your personal data may be transferred by Acora and the safeguards that we have put in place; see Contact Information in section 15 below.

9. RETENTION OF PERSONAL DATA

We will take all reasonable steps to retain personal data only for the duration of the purpose for which it was obtained as set out in this Privacy Policy (unless longer retention is required by the applicable law or regulation). We may keep an anonymised form of your personal information, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.

10. CONFIDENTIALITY AND SECURITY

Acora will take all reasonable steps to:

• safeguard all personal information that you provide to us;
• ensure that it remains confidential and secure; and
• ensure that personal privacy is respected.

All our data is stored in written or electronic form on our servers and computers and in various physical locations.  We maintain physical, electronic and procedural safeguards to protect your personal information from misuse, unauthorised access or disclosure and loss or corruption by computer viruses and other sources of harm.

11. YOUR RIGHTS WITH REGARDS TO YOUR PERSONAL DATA

Data protection law provides individuals with certain rights, including the right to: access, rectify, withdraw consent, erase, restrict, transport, and object to the processing of, their personal information. Individuals also have the right to lodge a complaint with the relevant data protection authority if they believe that their personal information is not being processed in accordance with the law. Further information about your rights is set out below:

• Right to obtain a copy of your personal information. You may have the right to obtain a copy of the personal information we hold about you.
• Right to rectification. You may request that we rectify any inaccurate and/or incomplete personal information.  If we disagree and believe the information to be accurate and complete, we will advise you and include a notation on the record that you dispute the information’s accuracy.
• Right to withdraw consent. You may, as permitted by law, withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent.
• Right to object to processing. You may request that we stop processing your personal information.
• Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
• Right to lodge a complaint with the supervisory authority. You have the right to complain about the use of your personal information to the relevant supervisory authority, which in the UK is the Information Commissioner’s Office.

Any request under this section should be submitted in writing to the Data Protection Officer at DPO@acora.com. We would also suggest that you contact us if you have any questions or if you have a complaint in relation to how we process your personal information, see Contact Information in section 15 below. However, you do have the right to contact the relevant supervisory authority as noted above in this section.

12. LINKS

Our website may provide hyperlinks to websites owned and controlled by others. Acora is not responsible and accepts no liability in relation to such websites or their contents or for their privacy practices. You should read any applicable privacy policy on any such website.

13. THIRD PARTIES

Where you submit personal information on behalf of another person, you confirm that you have made that person aware of how we may collect, use and disclose their personal information, the reason you have provided it, how they can contact us and the terms of this Privacy Policy. You further confirm that they have consented to such collection, use and disclosure.

14. COMPLIANCE WITH PRIVACY LAWS

Acora complies with the data protection and privacy laws to which it is subject.  You should satisfy yourself that you are familiar with those laws, including any exceptions which may apply under them.  You should also be aware that privacy laws in various jurisdictions may change from time to time.

Except to the extent expressly stated otherwise in this Privacy Policy, Acora accepts no obligations with respect to the handling of personal information other than those mandated by law in any relevant country.

15. COOKIES

Our website uses cookies.  A cookie is a small file of letters and numbers that may be stored on your browser or the hard drive of your computer or device when you access our website.  It allows the website to recognise your device and store some information about your preferences or past actions.

Cookies help us to provide you with a good experience when you browse our website and also allows us to improve our site.

You can find more information about the types of cookies in our Cookie Policy.

16. CONTACT INFORMATION

If you have any questions about this Privacy Policy, please contact us by email at DPO@acora.com or by post to Acora House, Albert Drive, Burgess Hill, West Sussex RH15 9TN.