Acumen Academy

PRIVACY POLICY

Acumen Fund, Inc. (“Acumen,” “we,” “our,” or “us”) is a 501(c)(3) non-profit corporation. Acumen offers world-class learning experiences (the “Acumen Academy Courses”) at AcumenAcademy.org (“Acumen Academy”) that empower you to think differently, learn collaboratively and join a global community of learners and doers with a burning desire to change the world.

This privacy policy (“Privacy Policy”) is designed to help you better understand the information we gather, share, and store when you use the Acumen Academy website (the “Website”).

For purposes of this Privacy Policy, the Website and all content, information, and services accessed via our Website, including but not limited to the Acumen Academy Courses, program applications, and the discussion forums, are collectively called the “Services.” Please note that this Privacy Policy applies only to Acumen Academy and our Services and not necessarily to other companies with whom we work or to organizations’ websites to which we may link.

As described in our Terms of Use and Conditions, our Services may use platforms made available by third parties (each, a “Service Provider”). When you access any of our Services made available by one of our Service Providers, be sure to read their privacy policy and terms of use to learn how they collect and use your personal information.

This Privacy Policy is incorporated by reference into the Acumen Academy Terms of Use and Conditions (the “Terms”). By sharing information with Acumen, visiting this Website or by using the Services, you are acknowledging the terms of this Privacy Policy and confirming you have read and understood them.

For the purpose of the General Data Protection Regulation (the “GDPR”), Acumen is the controller of the personal information processed in accordance with this Privacy Policy.

Capitalized terms used but not defined herein shall have the respective meanings given to them in the Terms.

I. INFORMATION WE COLLECT AND HOW WE COLLECT IT

A. Personal Information We Collect

Depending on the Services you use and how you interact with Acumen, Acumen Academy, or our Website generally, the categories and specific types of personal information collected from you may include the following:

Categories of personal information collected	Examples
1. Identifiers	a. Title b. First name c. Last name d. E-mail address e. User name f. Answers to security questions g. Passwords h. Gender i. Country of residence j. State in country k. City/town l. Employer m. Reasons for engaging with the product n. Age o. Educational attainment p. Employment sector
2. Financial information	a. Credit card number [(only last 4 digits stored)] b. Other financial information related to payments for services or goods
3. Internet/electronic activity	a. Device identification number and type b. IP Address c. Statistics on you page views d. Access to reliable internet [Y/N/frequency] e. Access to reliable phone signals [Y/N] f. Sites you navigate from or to our websites g. Referral URL h. Ad data i. Browsing history j. Weblog information
4. Geolocation data	a. Location information
5. Information collected from Acumen Fellowship and accelerator applicants (including identifiers, historical and present professional or employment-related information, and other personal information	Identifiers a. Phone number and country code b. E-mail address last used to apply to an Acumen Fellowship, if any c. Birthdate d. Residential status [citizen, permanent resident, temporary work permit] Professional or employment-related data a. CV/resume, which includes information related to: - Professional experience; - Other relevant experience. b. Long-form questions asked in connection with an Acumen Fellowship application may include: - Prior application history to Acumen Fellowship, if any; - Information about current employer’s work, including name or organization/initiative; nature of work; size of team; website address; and employer’s performance against performance metrics, if any; - Name of Acumen Fellow/staff referred [if relevant to how applicant first learned about Acumen Fellowship]; - Job title and responsibilities; - Information regarding applicant’s other projects or work commitments; - Professional achievements. c. Range or multiple choice questions asked in connection with an Acumen Fellowship application may include: - Total years of full-time professional experience; - Total years of work in poverty/injustice issues; - Area of current employer’s work; - Length of employment; - Nature of employment (full-time/part-time). Other a. Long-form essay questions required as part of the Acumen Fellowship may require applicants disclose the following information in personal narrative form: - The impact applicant hopes to have on their country; - How the applicant’s current work contributes towards that vision; - Applicant’s current areas of growth as a leader and their goals for personal and professional growth.

B. How We Collect Personal Information

Acumen may collect the personal information described above in the following ways: Information you provide us: We collect personal information that you provide us when you use our Website or Services. For example, we collect personal information when you: sign up for and participate in our Acumen Academy Courses; submit a program application; when you contact us by email, over the telephone, or by other means to ask us questions; or respond to our surveys, promotions, or requests.

Information we automatically collect: Our Website utilizes web beacons, pixel tags, cookies, local storage, embedded links, and other commonly used information-gathering tools. When accessing or otherwise using a website, small pieces of data concerning your device and your visit are stored within your web browser, which can be retrieved upon future visits. These pieces of data make up a small file called a “cookie.” Both first and third parties can store their own cookies on your web browser.

Cookies allow websites to do things such as remembering information about a user, such as a user’s preferences when visiting the website. This information can be considered “personal information” under certain laws. As with most websites, Acumen, by itself and through third-party services such as Google Analytics, uses cookies to evaluate use of this Website and improve our Services. You can generally opt to disable cookies in your browser. However, if you disable cookies, you may not be able to access certain parts of this Website or certain aspects of this Website may not work correctly. For more information on how we use cookies, please see our Cookies Policy.

Information collected from third parties: We also collect information about you from third parties. For example, portions of the Website may include features or widgets from various social media platforms, such as Facebook, Google Plus, Twitter, Pinterest, Instagram, Tumblr, and YouTube (each, a “Social Media Platform”), and we may enable you to register or log in to our Website through a Social Media Platform. These features use cookies to collect information about your IP address and the pages on our Website that you have visited. Your interactions with those features are governed by the terms of use and privacy policies of the companies that provide them. Where applicable, we may also collect information about you from employers, government programs, educational institutions, or other third parties that sponsor your enrollment in our Services.

When you access any Services made available by one of our Service Providers, you allow us to collect certain information from the Service Provider in accordance with this Privacy Policy and our Terms. For example, a Service Provider may share with us your course activity, course results, and course survey responses; or a Service Provider may share with us your fellowship application materials (including any information contained therein).

A. How we use the personal information we collect:

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

• To respond to your questions and requests, as well as to keep track of support and customer service requests;

• To provide you the Services and Website features (including administering Acumen Academy Courses and program applications);

• To maintain and improve the Services and Website;

• To prevent fraud;

• To email or contact you regarding Acumen Academy feedback, solicitations related to our work, our newsletters, and promotions, marketing, or special offers from us or our partners;

• To manage your account and account access; or

• To provide you with purchase confirmations.

B. How we share the personal information we collect:

We may disclose personal information we collect to third parties for the following purposes:

• To comply with applicable law, regulation or governmental request; protect safety of Acumen, users of this Website, or others; protect the rights or property of Acumen; to comply with contractual obligations of Acumen; and other instances when Acumen is legally required to disclose your information;

• To share information and confirm your enrollment, participation, progress, and completion status with employers, government programs, educational institutions, or other third parties that sponsor your enrollment in our Services;

• To share information that is public or does not include personal information, for example, aggregated data or a publicly posted comment;

• To provide third parties with statistical information about the users of our Website;

• To third parties if you use certain third-party features to share information about user activity through our Website, for example, the “Share” button on blog posts allows users to share posts on social networks. If you use these features, Acumen will share this information with the third-party website or service, along with additional information you provide to use the feature (e.g., a Twitter username). As previously noted, you should read those third-party website privacy policies and terms of use. We do not accept any responsibility or liability for their policies, terms, or practices whatsoever as we have no control over them;

• To any affiliated business entities or third parties necessary to provide services to you, including, but not limited to, our subsidiaries, our holding company and its other subsidiaries (if any), as well as third parties involved in the administration and operation of our services;

• To third parties to process payments if you make a purchase through the Services or donate to Acumen;

• To third parties such as our Service Providers to provide the Services to you and to collaborate on Acumen Academy improvement;

• To issue certificates for Statements of Accomplishment following course completion;

• To a third party if we sell any or all of our business and/or assets to them; or

• In other ways when we have your consent or are otherwise permitted to do so.

C. Our lawful bases:

With respect to the GDPR, to carry out the processing of your personal information as described above, we rely on the following lawful bases:

• Your consent, for example if we would like to send you certain interesting information;

• The performance of a contract to which we are both parties or in order to take steps at your request prior to entering into a contract, for example delivering a Service for which you have registered or account administration;

• The legitimate interests of a third party such as organizations that sponsor your enrollment in our Services, so long as these interests are not outweighed by your own interests;

• Compliance with a legal obligation to which we are subject, for example in relation to fraud; and

• Our legitimate interests which include the use of our personal information in pursuit of our goals as an organization, for our desire to continually improve our Services and Website to help achieve our goals, to ensure the safety, security, and performance of our Services and Website, and to better understand similar organizations, industries, and markets.

III. SECURITY

We care about the security of your personal data and we employ commercially reasonable measures to protect your personal information from unauthorized or accidental access, use, loss, or destruction by users inside and outside the organization, including encrypting payments you make on our Website using SSL. You should be aware, however, that no transmission of data over the internet is ever 100% secure and that there is always a risk of unauthorized third parties unlawfully intercepting or accessing your information. As such, you provide us with your information at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

IV. CHILDREN

The Services offered by Acumen are only intended for use by those who are at least thirteen (13) years old. Acumen does not knowingly collect personal information from children under 13. If you believe that a child under the age of 13 has provided information to this Website or to Acumen Academy, please notify us at courses@acumenacademy.org. We are not liable for any damages that may result from a user’s misrepresentation of age.

V. INTERNATIONAL DATA TRANSFERS

Acumen offers its Services in a variety of countries. If you are in the European Economic Area (EEA) or other region with laws governing data collection and use which differ from those of the United States, please note that your information, including your personal information, may be transferred to countries located outside the EEA, in particular to the United States, and those countries may not have the same level of protection as the country in which you initially provided that information. We will, however, take all reasonable steps and establish effective measures as required by law to ensure your personal information is protected when transferred outside the EEA. When we transfer your personal information, we will protect it as described in this Privacy Policy.

VI. RETENTION OF PERSONAL INFORMATION

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal information for a longer period if we have a legal obligation to, or in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

VII. NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS

A. CA “Shine the Light” Disclosure:

For California residents, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information, as that term is defined in Section 1798.83, to third parties for the third parties’ direct marketing purposes. To make such a request, you may contact us by using the contact details provided below under “How to Contact Us.”

B. CA “Privacy Rights for California Minors”:

California minors under 18 years old may request the removal of any information that they have posted to the Website by contacting us at the contact details provided below under “How to Contact Us”. Upon such request, Acumen will anonymize, or remove from public view, any content posted by a minor to this Website, unless required by law to retain such content or information.

C. CA “Do Not Track” Disclosure:

We have disclosed our collection practices herein, but at this time, we do not honor do-not-track signals.

VIII. YOUR RIGHTS AND CHOICES

Subject to applicable law, you may have several rights in respect of how your personal information is processed by us. These may include:

• the right to request access to and receive information about the personal information we maintain about you,

• the right to update and correct inaccuracies in your personal information,

• the right to object to the way your personal information is being processed;

• the right to request a restriction on the processing of your personal information;

• the right to have the information blocked or deleted, as appropriate; and

• the right to withdraw your consent to the use of your personal information if the use of your personal information is reliant on consent.

If you receive promotional messages from us, you may unsubscribe at any time by following the opt-out instructions contained within such message. Even after you opt out of receiving promotional messages from us, you may continue to receive administrative or transaction-related messages from us regarding our Services. To exercise your rights and choices to your personal information, please contact us by using the contact details provided below under “How To Contact Us.” In addition to the rights you may have exercisable towards us as described above, you may also, depending on your jurisdiction, have a right to submit a compliant to a data protection authority. We would appreciate the chance to deal with your concerns before your approach a data protection authority, so we ask you please contact us in the first instance and we will aim to resolve your concern.

IX. PRIVACY POLICY CHANGES

We may, from time to time, make changes to this policy. The most current version of this policy will always be available at https://acumenacademy.org/privacy/, along with the date last revised. Any modifications will become effective immediately upon posting. By continuing to use this Website and the Services, you accept such modifications. If we make any substantial changes in the way we use your personal information, we will notify you via email, by posting a prominent announcement on our Website, or as otherwise required by applicable law. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting our Website and this Privacy Policy to check for any changes.

X. HOW TO CONTACT US

Please contact us at courses@acumenacademy.org if you have any questions about this Privacy Policy or our privacy practices generally.