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PRIVACY POLICY
INTRODUCTION
Acquia Inc., including its wholly owned affiliates, (“Acquia”, "us," "we," or
"our,") is committed to protecting the privacy of your information. This Privacy
Policy (“Policy”) governs Acquia’s use of personally identifiable information,
also "personal data," about users of our products, services and/or software that
are available for purchase and use through our sales teams, accessible by
download on our websites (our "Services"), and also users of our website
http://acquia.com as well as the other websites that Acquia operates and that
link to this Policy (collectively referred to as “Site(s)”). It also describes
the choices available to you regarding our use of your personally identifiable
information and how you can access and update this information.
Acquia complies with the relevant regulation applying to personal data,
including but not limited the General Data Protection Regulation issued by the
European Union.
Our Sites may contain links to other websites, applications, and services
maintained by third parties. The information practices of other services are
governed by their privacy statements, which you should review to better
understand their privacy practices.
EU-U.S. AND SWISS-U.S. PRIVACY SHIELD FRAMEWORKS
Acquia complies with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks as set
forth by the United States Department of Commerce regarding the collection, use,
and retention of personally identifiable information transferred from the
European Union, and the United Kingdom and/or Switzerland to the United States.
Consistent with our commitment to protect personally identifiable information
about individuals in the European Union, Acquia has certified to the Department
of Commerce that it adheres to the Privacy Shield Principles of Notice, Choice,
and Accountability for Onward Transfer, Security, Data Integrity and Purpose
Limitation, Access, and Recourse, Enforcement and Liability (the “Privacy Shield
Principles” or the “Principles”). Acquia’s EU-U.S. and Swiss-U.S. Privacy Shield
Certification also extends to personally identifiable information that we
receive directly through the Sites. More information on the EU-U.S. and
Swiss-U.S. Privacy Shield and Acquia’s scope of participation in the EU-U.S. and
Swiss-U.S. Privacy Shield Frameworks are available at
http://www.privacyshield.gov/welcome.
If there is any conflict between the terms in this Privacy Policy and the
Privacy Shield Principles, the Privacy Shield Principles shall govern.
CALIFORNIA RESIDENTS
If you are a California consumer, for more information about your privacy
rights, please see our California Consumer Privacy Statement.
BRAZIL RESIDENTS
If you are a Brazil consumer, for more information about your privacy rights
under Lei Geral de Proteção de Dados Pessoais (“LGPD”), please contact us at
Legal@acquia.com.
PRIVACY POLICY UPDATES
Due to the Internet’s rapidly evolving nature, Acquia may need to update this
Privacy Policy from time to time. If so, Acquia will post our updated Privacy
Policy on our Site located at http://acquia.com/about-us/legal/privacy-policy
and post notice of the change so it is visible when users log-on for the first
time after the change is posted so that you are always aware of what personally
identifiable information we may collect and how we may use this information. If
we make material changes to this policy, we will notify you here, by email, or
by means of a notice on our home page. Acquia encourages you to review this
Privacy Policy regularly for any changes. Your continued use of this Site and/or
continued provision of personally identifiable information to us will be subject
to the terms of the then-current Privacy Policy.
DATA INTEGRITY AND PURPOSE LIMITATION
Acquia is a provider of cloud platform related services, including Platform as a
Service (“PaaS”) and Software as a Service (“SaaS”) products, technical support
services and professional consulting services for Drupal websites which
processes personally identifiable information upon the instruction of its
customers in accordance with the terms of the applicable agreement between
Acquia and customer.
INFORMATION COLLECTION AND USE
You can generally visit our Site without revealing any personally identifiable
information about yourself. However, in certain sections of thes Site or
interactions with us, we may invite you to participate in one or some of the
following. We collect such information in the following situations:
* Surveys (If you voluntarily submit certain information to our services, such
as filling out a survey about your user experience, we collect the
information you have provided as part of that request)
* Contact Us features with questions or comments or request information,
participate in chat or message boards (If you express an interest in
obtaining additional information about our services, request customer
support, use our “Contact Us” or similar features, register to use our
services, sign up for an event, questionnaires, webinar, contests, or
download certain content, we may require that you provide to us your contact
information)
* If you interact with our websites or emails, we may automatically collect
information about your device and your usage of our websites or emails, (such
as Internet Protocol (IP) addresses or other identifiers, which may qualify
as Personal Data) (see “Device and Usage Data Processing section, below)
using cookies, Web Beacons, or similar technologies.
* If you make purchases via our Sites or register for an event or webinar, we
may require that you provide your financial and billing information, such as
billing name and address, credit card number or bank account information.
* If you communicate with us via a phone call from us, we may record that call.
* We require you to complete a registration form and/or create a profile to
access certain restricted areas of the Site, to use certain services and when
you download any software.
* If you visit our offices, you may be required to register as a visitor and to
provide your name, email address, phone number, company name, and time and
date of arrival. Additionally, due to the COVID-19 pandemic, you may be
required to provide information regarding your health status, including your
temperature, COVID-19 related symptoms, exposure to COVID-19, positive
individuals, and recent travel history.
Due to the nature of some of these activities, we may collect personally
identifiable information such as your name, e-mail address, address, phone
number, password, screen name, credit card information and other contact
information that you voluntarily transmit with your on-line and in-person
communications to us and personally identifiable information that you elect to
include in your chart and message board postings.
If you use a forum on this Site, you should be aware that any personally
identifiable information you submit there can be read, collected, or used by
other users of these forums, and could be used to send you unsolicited messages.
We are not responsible for the personally identifiable information you choose to
submit in these forums. We receive permission to post testimonials that include
personally identifiable information prior to posting.
If you provide us or our service providers with any Personal Data relating to
other individuals, you represent that you have the authority to do so, and where
required, have obtained the necessary consent, and acknowledge that it may be
used in accordance with this Privacy Policy. If you believe that your Personal
Data has been provided to us improperly, or want to exercise your rights
relating to your Personal Data, please contact us by emailing
privacy@acquia.com.
ORDERS
If you purchase a product or service from us, we request certain personally
identifiable information from you on our order form. You must provide contact
information (such as name, email, and shipping address) and financial
information (such as credit card number, expiration date).
We use this information for billing purposes and to fill your orders. If we have
trouble processing an order, we will use this information to contact you.
In addition, we may collect information about the performance, security,
software configuration and availability of customer web sites in an automated
fashion as part of the Acquia subscription services.
We use your personally identifiable information to register you to use our
services or download or access software or other content, contact you to deliver
certain goods, services or information that you have requested, provide you with
notices regarding goods or services you have purchased, provide you with notices
regarding goods or services that you may want to purchase in the future
(including communications from third party service providers and/or Acquia
technology partners concerning additional products/applications which compliment
Acquia's services, or else are customizable with Acquia's services in order to
maximize your digital experience while leveraging Acquia services), verify your
authority to enter our Site and improve the content and general administration
of the Site and our services.
Certain modules within the Drupal software connect your installation of Drupal
to our subscription services, these modules will report to us, and we will
collect, your IP address, operating system type and version, web server type and
version, php version, database type and version, version of the services,
modifications to your Drupal code, information regarding the availability of
your website (e.g. if your website is live or down), website user statistics
such as the number of nodes, number of users and number of comments. The
foregoing information will be linked to your personally identifiable information
and user accounts and we may use the foregoing information to better provide
technical support to you and our customers and to improve our services.
If you install and use the Acquia Search module and connect your Drupal site to
the subscription services, in addition to the information we may collect,
analyze and store when you use our services as stated above, the Acquia Search
module may collect, analyze and store the content of your site in an index. This
index will be stored and updated on our servers to enable Acquia Search to work
with your site. A copy of this index may be retained for up to 14 days as a
backup in the event there is a problem with the index. Additionally, information
about the size of your index, the search queries performed on your index,
performance of Acquia Search for your queries, and other operational information
is stored indefinitely in order to enable Acquia to monitor performance over
time, manage the Search Service, and to provide you with information about the
Search activity on your site.
If you choose to contact us by e-mail, we will not disclose your contact
information contained in the e-mail, but we may use your contact information to
send you a response to your message. Notwithstanding the foregoing, we may
publicly disclose the content and/or subject matter of your message, therefore,
you should not send us any ideas, suggestions or content that you consider
proprietary or confidential. All e-mail content (except your contact
information) will be treated on a non-proprietary and non-confidential basis and
may be used by us for any purpose.
DETAILS OF DATA PROCESSING
Acquia processes your personal data as a customer and other customer’s personal
data (in the following just “customer”) in order to provide the contractually
agreed Services.
Subject matter: The subject matter of the data processing is the performance of
the Services agreed between Acquia and customer by Acquia involving personal
data provided by customer.
Duration: As between customer and Acquia, the duration of the data processing is
determined by customer and its contractual commitments with regard to the use of
Acquia’s Services.
Purpose: The purpose of the data processing by Acquia is the provision of the
Services initiated by the customer from time to time.
Nature of the processing: Cloud computing as platform and software as a service
and such other Services as described in the Documentation and initiated by the
customer from time to time.
Type of personal data:
The type and extent of personal data that is subjected to Acquia’s data
processing is determined and controlled by our customer as data controller in
its sole discretion - this may include, but is not limited to the following:
* First and last name
* Title, work department, and manager/supervisor name
* Position and employment history
* Employer
* Contact information (company, personal and work email, phone, home address,
physical business address, emergency contact details)
* Photographs
* Biographical and directory information, including linked social media profile
or posts
* Company user names or IDs and login credentials
* Identifiers related to work or personal devices used to access data
exporter’s IT systems
* Log information generated through the use of data exporter’s IT systems
* Actions performed by the employee while accessing or using the Services
* Full time or part time status
* Business travel arrangements
* Training undertaken and training needs
* Localization data
Categories of data subjects: Customer’s representatives and end-users including
employees, contractors, collaborators and advisors of our customer (who are
natural persons).
COMMUNICATIONS FROM THE SITE
SPECIAL OFFERS AND UPDATES
We will occasionally send you information on products, services, special deals,
promotions. Out of respect for your privacy, we present the option not to
receive these types of communications. Please see “Choice and Opt-out.”
NEWSLETTERS
If you wish to subscribe to our newsletter(s), we will use your name and email
address to send the newsletter to you. Out of respect for your privacy, we
provide you a way to unsubscribe. Please see the “Choice and Opt-out” section.
SERVICE-RELATED ANNOUNCEMENTS
We will send you strictly service-related announcements on rare occasions when
it is necessary to do so. For instance, if our service is temporarily suspended
for maintenance, we might send you an email.
Generally, you may not opt-out of these communications, which are not
promotional in nature. If you do not wish to receive them, you have the option
to deactivate your account.
--------------------------------------------------------------------------------
CUSTOMER SERVICE
Based upon the personally identifiable information you provide us, we will send
you a welcoming email to verify your username and password. We will also
communicate with you in response to your inquiries, to provide the services you
request, and to manage your account. We will communicate with you by email or
telephone, in accordance with your wishes.
CHOICE/OPT-OUT
We or one of our authorized partners may place or read cookies on your device
when you visit our websites for the purpose of serving you targeted advertising
(also referred to as “online behavioral advertising” or “interest-based
advertising”). To learn more about targeted advertising and advertising networks
please visit the opt-out pages of the Network Advertising Initiative, here, and
the Digital Advertising Alliance, here. We provide you the opportunity to
‘opt-out’ of having your personally identifiable information used for certain
purposes, when we ask for your information.
To request updates or changes to your information or your preferences regarding
receiving future promotional messages from us, you may contact our Privacy
Officer using the information in the Contact Us section of this Privacy Policy
or follow the opt-out instructions that are contained in the bottom of the email
communication you received.
You will be notified prior to when your personally identifiable information is
collected by any third party that is not our agent/service provider, so you can
make an informed choice as to whether or not to share your information with that
party.
Please note that if you opt out of receiving our promotional or marketing
emails, you may still receive certain service-related communications from us,
such as administrative and services announcements and messages about your
account. Occasionally these materials are sent from a different email domain:
marketing@theacquiateam.com.
EMPLOYMENT OPPORTUNITIES
We provide you with a means for submitting your resume or other personally
identifiable information through the Site for consideration for employment
opportunities at Acquia. Personally identifiable information received through
resume submissions will be kept confidential. We may contact you for additional
information to supplement your resume, and we may use your personally
identifiable information within Acquia, or keep it on file for future use, as we
make our hiring decisions.
CHILDREN'S PRIVACY
Acquia recognizes the privacy interests of children and we encourage parents and
guardians to take an active role in their children’s online activities and
interests. This Site is not intended for children under the age of 13. Acquia
does not target its services or this Site to children under 13. Acquia does not
knowingly collect personally identifiable information from children under the
age of 13. If you are a parent or guardian and believe your child has provided
us with personal information without your consent, please contact us by emailing
privacy@acquia.com.
COOKIES AND GIFS
We use small text files called cookies to improve overall Site experience. A
cookie allows us to gather information about the use of our sites and how
people interact with our emails. Cookies generally do not permit us to
personally identify you (except as provided below). We may also use clear GIFs
(a.k.a. “Web beacons”) in HTML-based emails sent to our users to track which
emails are opened by recipients.
Additionally, when using the Site, we and any of our third party service
providers may use cookies and other tracking mechanisms to track your user
activity on the Site and identify the organization or entity from which you are
using the Site. If you register with the Site, we, and our third party service
providers, will be able to associate all of your user activity with your
personally identifiable registration information. We will use such user activity
information to improve the Site, to provide context for our sales and support
staff when interacting with you and customers, to initiate automated email
marketing campaigns triggered by your activity on the Site and for other
internal business analysis.
AGGREGATE INFORMATION
The Site may track information that will be maintained, used and disclosed in
aggregate form only and which will not contain your personally identifiable
information, for example, without limitation, the total number of visitors to
our Site, the number of visitors to each page of our Site, browser type,
External Web Sites (defined below) linked to and IP addresses. We may analyze
this data for trends and statistics in the aggregate, and we may use such
aggregate information to administer the Site, track users’ movement, and gather
broad demographic information for aggregate use.
DISCLOSURE
We will not sell your personally identifiable information to any company or
organization, except we may transfer your personally identifiable information to
a successor entity upon a merger, consolidation or other corporate
reorganization in which Acquia participates or to a purchaser or acquirer of all
or substantially all of Acquia’s assets to which this Site relates. We may
provide your personally identifiable information and the data generated by
cookies and the aggregate information to parent, subsidiary or affiliate
entities within Acquia’s corporate family, partner entities that are not within
Acquia’s corporate family and vendors and service agencies that we may engage to
assist us in providing our services to you. For example, we may provide your
personally identifiable information to a credit card processing company to
process your payment. Such third party service providers may be obligated to
protect your personally identifiable information consistent with the terms of
this Privacy Policy and not for their promotional purposes and/or required to
enter into written confidentiality and data processing agreements including the
commitment to be compliant with the Standard Contractual Clauses issued by the
European Commission. We will also disclose your personally identifiable
information (a) if we are required to do so by law, regulation or other
government authority, in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements, or
otherwise in cooperation with an ongoing investigation of a governmental
authority (b) to enforce the Acquia Terms of Use agreement or to protect our
rights or (c) to protect the safety of users of our Site and our services.
The Site may provide links to other Web sites or resources over which Acquia
does not have control (“External Web Sites”). Such links do not constitute an
endorsement by Acquia of those External Web Sites. You acknowledge that Acquia
is providing these links to you only as a convenience, and further agree that
Acquia is not responsible for the content of such External Web Sites. Your use
of External Web Sites is subject to the terms of use and privacy policies
located on the linked External Web Sites.
SECURITY
We employ procedural and technological measures that are reasonably designed to
help protect your personally identifiable information including sensitive data
from loss, unauthorized access, disclosure, alteration or destruction. Acquia
may use encryption, secure socket layer, firewall, password protection and other
physical security measures to help prevent unauthorized access to your
personally identifiable information including sensitive data. Acquia may also
place internal restrictions on who in the company may access data to help
prevent unauthorized access to your personally identifiable information. These
precautions take into account the risks involved in the processing, the nature
of personally identifiable information, and best practices in the industry for
security and data protection.
Please find additional information about Acquia’s security measures on our
website https://www.acquia.com/solutions/security and for our Services
specifically in our Acquia Security Annex available at
https://www.acquia.com/sites/default/files/legal/acquia-security-annex.pdf
ACCOUNTABILITY FOR ONWARD TRANSFER
Acquia is accountable for personally identifiable information that we receive
and subsequently transfer to third parties. If third parties that process
personally identifiable information on our behalf do so in a manner that does
not comply with the Privacy Shield Principles, we are accountable, unless we
prove that we are not responsible for the event giving rise to the damage.
Contact information and Customer personally identifiable information is
accessible only by those Acquia employees and consultants who have a reasonable
need to access such information in order for us to fulfill contractual, legal
and professional obligations. All of our employees and consultants have entered
into confidentiality agreements, and/or have been subjected to thorough criminal
background checks requiring that they maintain the confidentiality of Customer
personally identifiable information.
In the event Acquia discloses personally identifiable information covered by
this Policy to a non-agent third party, it will do so consistent with any notice
provided to Data Subjects and any choice they have exercised regarding such
disclosure. Acquia will only disclose personally identifiable information to
third-party agents that have given us contractual assurances that they will
provide at least the same level of privacy protection as is required by this
Privacy Policy and the Principles and that they will process personally
identifiable information for limited and specific purposes consistent with any
consent provided by the individual. If Acquia has knowledge that a third party
to which it has disclosed personally identifiable information covered by this
Privacy Policy is processing such personally identifiable information in a way
that is contrary to this Privacy Policy and/or the Principles, Acquia will take
reasonable steps to prevent or stop such processing. In such case, the
third-party is liable for damages unless it is proven that Acquia is responsible
for the event giving rise to the violation.
Acquia may use from time to time a limited number of third-party service
providers, contractors, and other businesses to assist us in providing our
solutions to our customers or in meeting internal business operation needs.
These third-parties may access process or store personally identifiable
information in the course of performing their duties to Acquia. Acquia maintains
contracts with these providers restricting their access, use and disclosure of
personally identifiable information in compliance with our obligations under the
Principles.
YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
Depending on the applicable local data protection laws, you have certain rights
relating to your Personal Data including, but not limited to:
* Access to your data
* Rectification
* Erasure ("right to be forgotten")
* Restriction of Processing
* Object, opt-out, withdrawing your consent
* Transfer of your data
Acquia provides you with the ability to exert any such right by contacting us
through this web
form (https://acquia-privacy.my.onetrust.com/webform/29a25674-36fd-4a6f-8e09-7e5a4f94cf4a/8511aea7-dd1f-4353-9429-a0dbe52f01cc).
ENFORCEMENT AND LIABILITY
Acquia is subject to the jurisdiction and enforcement and investigatory
authority of the United States Federal Trade Commission.
Acquia also commits to periodically reviewing and verifying the accuracy of this
Policy and the company’s compliance with the Principles, and remedying issues
identified. All employees of Acquia that have access to personally identifiable
information covered by this Policy in the U.S. are responsible for conducting
themselves in accordance with this Policy. Failure of an Acquia employee to
comply with this Policy may result in disciplinary action up to and including
termination.
Acquia assures compliance with this EU-U.S. and Swiss-U.S. Privacy Shield Policy
and the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks by utilizing the
self-assessment approach as specified by the U.S. Department of Commerce. The
assessment is conducted on an annual basis to ensure that all of Acquia’s
relevant privacy practices are being followed in conformance with this EU-U.S.
and Swiss-U.S. Privacy Shield Policy and the EU-U.S. and Swiss-U.S. Privacy
Shield Frameworks. Any employee that Acquia determines is in violation of these
policies will be subject to discipline, up to and including termination of
employment and/or criminal prosecution.
DISPUTE RESOLUTION
Acquia assures compliance with this EU-U.S. and Swiss-U.S. Privacy Shield Policy
by fully investigating and attempting to resolve any complaint or dispute
regarding the use and disclosure of personally identifiable information in
violation of this Privacy Policy.
Any questions or concerns regarding the use or disclosure of personally
identifiable information should first be directed to the owner of the website in
question (our customer); or if the question or concern is from our customer,
then to Acquia at the address given below.
Acquia will respond to any inquiries or complaints within forty-five (45) days.
In the event that Acquia fails to respond or its response is insufficient or
does not address the concern, Acquia has registered with JAMS to provide
independent third party dispute resolution at no cost to the complaining party.
To contact JAMS and/or learn more about the company’s dispute resolution
services, including instructions for submitting a complaint, please visit:
https://www.jamsadr.com/eu-us-privacy-shield.
If your complaint is not resolved through these channels, under limited
circumstances, a binding arbitration option may be available before a Privacy
Shield Panel.
Acquia will cooperate with the United States Federal Trade Commissions and any
data protection authorities of the EU Member States and/or United Kingdom
(“DPAs”) in the investigation and resolution of complaints that cannot be
resolved between Acquia and the complainant that are brought to a relevant DPA.
CONTACT US
If you have any questions or complaints regarding this Privacy Policy please
contact us by mail: Acquia Inc. 53 State Street Boston, MA 02109 USA Attention:
General Counsel
Or e-mail to privacy@acquia.com
Updated February 11, 2022
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Boston MA, 02109
888-922-7842
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888-922-7842
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