Who we are

We are Acora Limited (“Acora”, “us”, “we”, “our”). We are a limited company registered in England and Wales under registration number 02348923, and we have our registered office at Acora House, Albert Drive, Burgess Hill, West Sussex, RH15 9TN. We are registered with the UK supervisory authority, Information Commission (“IC”), in relation to our processing of Personal Data under registration reference Z5901752.

What we do

We are in the business of delivering integrated technology services — including Managed IT, Cyber Security, Data and AI, Cloud, and Application services — to help organisations accelerate performance in the AI era. We and our affiliates, subsidiaries and related entities are committed to protecting the privacy and security of the Personal Data we process about you.

Controller

Unless we notify you otherwise, we are the controller of the Personal Data we process about you. This means that we decide what Personal Data to collect and how to process it.

Purpose of this privacy notice

The purpose of this privacy notice is to explain what Personal Data we collect about you and how we process it. This privacy notice also explains your rights, so please read it carefully. If you have any questions or you wish to make a complaint, you can contact us using the information provided below under the ‘How to contact us’ section.

Who this privacy notice applies to

This privacy notice applies to you if:

• You visit our website
• You purchase goods or services from us
• You enquire about our products and/or services
• You opted (including through soft opt-in) to receive promotional communications from us

What Personal Data is

‘Personal Data’ means any information from which someone can be identified either directly or indirectly. For example, you can be identified by your name or an online identifier.

Personal Data we collect

The type of Personal Data we collect about you will depend on our relationship with you. For the type of Personal Data we collect see the table below in the section entitled ‘Purposes, lawful bases and retention periods’.

How we collect your Personal Data

We collect most of the Personal Data directly from you in writing, by telephone, by e-mail and by online registrations.

We may also collect your Personal Data from third parties who collect your Personal Data and pass it on to use.

Purposes, lawful bases and retention periods

We will only use your Personal Data when the law allows. Most commonly, we will use your Personal Data in the following circumstances:

Categories of individuals	Categories of Personal Data	Purpose of Processing	Lawful Basis	Retention Period
Customers (incl. prospective customers)	First name and last name. Contact details. Job title. Employer organisation.	to deliver a contractual service or product to you and your customers; or because you have asked us to do something before entering into a contract (e.g., provide a quote)	Contract	7 years from purchase order date or end of contract or if no contract is entered into, 1 year from last interaction
Customers	First name and last name. Contact details. Job title. Employer organisation.	To obtain your views or comments on the services/products we provide or to offer a service or product that we think may be of interest to you You can opt out at any time	Legitimate interests: to improve and promote our services and products	7 years from the purchase order date or end of contract
Trade Suppliers (incl. prospective suppliers)	First name and last name. Contact details. Job title. Employer organisation.	to deliver a contractual service or product to us; or because we have asked you to do something before entering into a contract (e.g., provide a quote)	Contract	7 years from purchase order date or end of contract or if no contract was entered into, 1 year from last interaction
Professional Advisers (incl. prospective advisers)	First name and last name. Contact details. Job title. Employer organisation.	To deliver a contractual service or product to us; or because we have asked you to do something before entering into a contract (e.g., provide a quote)	Contract	7 years from purchase order date or end of contracf no contract or if as entered into, 1 year from last interaction
Contractors (incl. prospective contractors)	First name and last name. Contact details. Job title. Employer organisation. Date of birth. Bank account details. VAT number.	To deliver a contractual service or product to us; or because we have asked you to do something before entering into a contract (e.g., provide a quote)	Contract	7 years from purchase order date or end of contract or if no contract was entered into, 1 year from last interaction
Consultants (incl. prospective consultants)	First name and last name. Contact details. Job title. Employer organisation. Date of birth. Bank account details. VAT number.	To deliver a contractual service or product to us; or because we have asked you to do something before entering into a contract (e.g., provide a quote)	Contract	7 years from purchase order date or end of contract if no contract was entered into, 1 year from last interaction
Investors/ Shareholders (inc. potential investors and shareholders)	First name and last name. Contact details. Job title. Employer organisation. Bank account details. Share in investments. Amounts invested. Returns for investments. Tax number. Information relating to financial status. Nationality (including copies of identity documents, such as a passport). Third-party references.	To fulfil the terms under the agreement, because we have asked you to do something before entering into an agreement	Contract	12 years from expiry of agreement or if no agreement was entered into, 1 year from last interaction

 

Where Personal Data is processed because it is necessary for the performance of a contract to which you are a party, we will be unable to provide our services without the required information.

Sharing 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 recorded in our table in the section entitled ‘Purposes, lawful bases and retention periods’.

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 people 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.

International Transfers

Your Personal Data may be processed outside of the UK and EEA. This is because the organisations we use to provide our service to you are based outside the UK.

We have taken appropriate steps to ensure that the Personal Data processed outside the UK or EEA has an essentially equivalent level of protection to that guaranteed in the UK and EEA. We do this by ensuring that:

• Your Personal Data is only processed in a country which the UK Secretary of State and the European Commission has confirmed has an adequate level of protection (an adequacy regulation); or
• We enter into Standard Contractual Clauses (“SCCs”) and UK Addendum with the receiving organisations and adopt supplementary measures, where necessary (A copy of the UK International Data Transfer Addendum can be found here); or
• When transferring your Personal Data to America, we may rely on the UK Extension to the EU-US Data Privacy Framework, where appropriate.

Marketing Communications

From time to time, we may use your information to contact you with details about our products and services which we feel may be of interest to you.  You have the right at any time to stop us from contacting you for marketing purposes. If you wish to exercise these rights, you can do so by following the ‘unsubscribe’ link on any emails received or contacting us at DPO@acora.com.

Your rights

You have certain rights in relation to the processing of your Personal Data, including to:

Right to be informed

You have the right to know what personal data we collect about you, how we use it, for what purpose and in accordance with which lawful basis, who we share it with and how long we keep it. We use our privacy notice to explain this.

Right of access (commonly known as a “Subject Access Request”)

You have the right to receive a copy of the Personal Data we hold about you.

Right to rectification

You have the right to have any incomplete or inaccurate information we hold about you corrected.

Right to erasure (commonly known as the right to be forgotten)

You have the right to ask us to delete your Personal Data.

Right to object to processing

You have the right to object to us processing your Personal Data. If you object to us using your Personal Data for marketing purposes, we will stop sending you marketing material.

Right to restrict processing

You have the right to restrict our use of your Personal Data.

Right to portability

You have the right to ask us to transfer your Personal Data to another party.

• Automated decision-making. You have the right not to be subject to a decision based solely on automated processing which will significantly affect you. We do not use automated decision-making.
• Right to withdraw consent

If you have provided your consent for us to process your Personal Data for a specific purpose, you have the right to withdraw your consent at any time. If you do withdraw your consent, we will no longer process your information for the purpose(s) you originally agreed to, unless we are permitted by law to do so.

How to exercise your rights

You will not usually need to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

If you wish to exercise your rights, you may contact us using the details set out below within the section called ‘How to contact us and our Data Protection Officer’. We may need to request specific information from you to confirm your identity before we can process your request. Once in receipt of this, we will process your request without undue delay and within one month. In some cases, such as with complex requests, it may take us longer than this and, if so, we will keep you updated.

Complaints

You have the right to complain if you consider that we have not complied with the data protection law when handling your Personal Data. We will acknowledge receipt of your complaint within 30 days, investigate the matter without undue delay, and keep you informed of the progress and outcome. If you wish to complain please use the contact details given below under “How to contact us and our Data Protection Officer”.  We will do our best to resolve the matter to your satisfaction.

If you are not satisfied with the outcome of your complaint, you can complain with the relevant supervisory authority. The supervisory authority in the UK is the Information Commission who can be contacted online at:

Contact us | ICO

Or by telephone on 0303 123 1113

How to contact our Data Protection Officer

If you wish to contact us in relation to this privacy notice or if you wish to exercise any of your rights outlined above, please contact us as follows:

Acora House, Albert Drive, Burgess Hill, West Sussex, RH15 9TN

DPO@acora.com

We have also appointed a Data Protection Officer (“DPO”). Our DPO can be contacted as follows:

West Lodge, Leylands Business Park, Colden Common, Hampshire, SO21 1TH

dpo@evalian.co.uk

Please mark your communications FAO the ‘Data Protection Officer’.

Changes to this privacy notice

We may update this notice (and any supplemental privacy notice), from time to time as shown below. We will notify of the changes where required by applicable law to do so.