Privacy Policy

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PRIVACY POLICY

This Privacy Policy explains how ACCLERRA, INC., together with entities in the Acclerra group (together, “Acclerra,” “we,” “our,” or “us”), collects, uses, stores, shares and protects personal information through https://acclerra.com, through direct business contacts, through vendor or client onboarding, and through related communications and relationship management activities.

Acclerra is a Delaware corporation. At the present stage of its operations, business operates through a cross-border model, and service delivery may involve group personnel, contractors and service providers operating in multiple jurisdictions. This Policy is intended to provide a proportionate but clear statement of Acclerra’s privacy approach.

1. Scope and Acclerra’s role

ACCLERRA, INC. is the controller, or under U.S. terminology the “business,” for personal information collected directly through the Acclerra website, inquiry channels, public forms, relationship management activities and related direct business interactions, unless a different role is expressly stated in a contract.

Where Acclerra processes personal information solely on behalf of an enterprise client under a written services agreement, a statement of work, or a signed data-processing addendum, Acclerra may act only as processor or service provider for that client-controlled data. In that case, the relevant client remains primarily responsible for the lawfulness of that processing and for handling requests relating to the client-controlled data set unless the contract provides otherwise.

This Policy applies to website users, business contacts, prospective clients, vendor contacts, and others who communicate with Acclerra directly. It is not intended to replace a client-specific privacy notice or a separate employment or contractor privacy notice.

2. Categories of information we may collect

Depending on the context, Acclerra may collect business identity and contact details such as names, job titles, company names, business email addresses, telephone numbers and mailing addresses.

We may also collect inquiry details, proposal requests, communication content, calendar details, onboarding data reasonably needed for client, vendor or contractor setup, and records of commercial interactions such as meeting notes, contracting status, billing contacts and relationship history.

When users interact with the website, Acclerra and its website tools may collect technical and usage information such as IP address, browser and device type, operating system, approximate region, referral information, page interactions, security or anti-bot signals, and similar metadata reasonably connected to operating and securing the website.

Acclerra asks users not to submit special-category, highly sensitive, or more-than-necessary personal information through ordinary public website forms unless specifically requested and supported by an appropriate legal and contractual basis.

3. Sources of personal information

Information may be collected directly from the individual, from the individual’s employer or organization, from website forms and communications, from public professional sources such as company websites or professional networking sources used for legitimate business purposes, and from service providers or referrals involved in a legitimate introduction or onboarding process.

Where Acclerra receives personal information from a client in connection with client-controlled services, the client remains responsible for the basis on which that information was collected and shared, subject to the parties’ written contract.

4. How we use information

Acclerra uses personal information to respond to inquiries; evaluate and pursue business opportunities; prepare proposals and statements of work; manage contracting, onboarding and commercial administration; maintain contact and relationship records; operate, secure and improve the website; manage vendor and contractor relationships; detect, prevent and investigate misuse, fraud, security incidents and compliance issues; and comply with law, regulation, professional obligations and recordkeeping requirements.

Acclerra may also use information to establish, exercise or defend legal claims; to carry out internal reporting, governance and risk-management activities; and to maintain evidence supporting due-diligence, audit, procurement or continuity requests from clients and counterparties.

5. Legal bases and U.S. state privacy framing

Where non-U.S. privacy frameworks apply, Acclerra generally relies on one or more of the following lawful bases as appropriate to the context: legitimate interests in operating and protecting the business and website, taking steps at the request of the data subject before entering into a contract, performing a contract, complying with legal obligations, and consent where consent is specifically required or used.

Where U.S. state privacy laws apply, Acclerra provides this Policy as part of its transparency obligations and will handle requests according to the role it plays in the relevant processing activity and the scope of the applicable law. Acclerra does not sell personal information in the ordinary sense and does not use cross-context behavioral advertising. 

6. Cookies, analytics and similar technologies

The Acclerra website may use essential cookies and similar technologies for core functionality, security, routing, form protection and basic site operation. The site may also use limited analytics or anti-bot tools where implemented.

7. Sharing and disclosure

Acclerra may share personal information on a need-to-know basis with hosting providers, domain and website providers, email and productivity providers, CRM or workflow providers, analytics or anti-bot providers, legal and accounting advisers, banking or payment service providers, insurers, corporate group entities, and service providers reasonably required to operate the business and website.

Information may also be shared where required by law, regulation, court order or lawful governmental request, or where reasonably necessary to protect the rights, property, systems, personnel, clients or users of Acclerra or others. If Acclerra is involved in a merger, financing, sale, restructuring, asset transfer or similar transaction, information may be disclosed to relevant advisers, counterparties and successors subject to reasonable confidentiality and transaction controls.

8. International access and transfers

Because Acclerra is managed and delivered through a cross-border operating model, personal information may be accessed from the United States and other jurisdictions where Acclerra personnel, contractors or approved service providers are located or operate.

Acclerra seeks to use contractual, organizational and role-based safeguards proportionate to the scale and sensitivity of the information involved. Where more formal transfer mechanisms are required by law or contract, these should be handled through the relevant customer or vendor documentation.

9. Retention

Acclerra retains personal information only for as long as reasonably necessary for the purpose collected, for lawful business administration, to comply with legal, regulatory, insurance, accounting or tax obligations, to preserve evidence, or to establish, exercise or defend legal claims.

Retention periods may vary according to the type of record, the relationship involved, the sensitivity of the information, and the contractual or legal context. Information no longer needed should be securely deleted, anonymized or archived according to the relevant process and legal constraints.

10. Security and confidentiality

Acclerra uses administrative, technical and physical safeguards. These may include role-based access, credential standards, approved-app controls, incident escalation procedures, device and physical-security controls, and restricted handling of commercial and client information.

No system is completely secure, and Acclerra cannot guarantee absolute security. Users should avoid sending more information than necessary through ordinary website forms or unencrypted channels.

11. Privacy rights and requests

Depending on applicable law and Acclerra’s role in the relevant processing, individuals may have rights to request access, correction, deletion, information about categories of data collected or disclosed, portability, objection, limitation, or similar rights subject to applicable exceptions and verification requirements.

Where Acclerra acts only as processor or service provider for a client-controlled dataset, Acclerra may direct the requester to the relevant client or coordinate the request with that client as required by contract.

12. Children’s information

The website and Acclerra’s business services are not directed to children, and Acclerra does not knowingly collect personal information from children through its ordinary business website or public forms.

13. Changes to this Policy

Acclerra may update this Policy from time to time to reflect operational, legal, website or service changes. The updated version will be posted with an updated effective or reviewed date where appropriate.

14. Contact details

Questions, concerns or requests relating to this Policy may be sent to team@acclerra.com or by writing to ACCLERRA, INC. (a Delaware corporation), at its registered office in the United States: 3524 Silverside Road, Suite 35B, Wilmington, DE 19810, USA.

If a request relates to client-controlled processing carried out by Acclerra on behalf of an enterprise client, the requester may also need to contact the relevant client directly.

Effective Date: October 27, 2026