Our Privacy Commitment 

At Collective Acumen we recognize the importance of and are fully committed to protecting the privacy of personal information related to all individuals with whom we interact – including members of the public, employees, regulatory authorities’ representatives, health care organizations’ representatives, and business partners. 

About this Privacy Statement 

This Privacy Statement (the ‘Statement’) is an overview of how Collective Acumen processes personal information about individuals, and illustrates Collective Acumen’s commitment to ensuring that individuals can exercise choice and control over their personal information in accordance with local laws. 

Scope of this Privacy Statement 

This Statement is specifically intended to provide information for our website users, members of the public who interact with Collective Acumen, and individuals with whom we do business (including, but not limited to, staff at regulatory authorities, personnel of suppliers and partners, and visitors to Collective Acumen offices). This Statement also provides information about specific privacy practices towards specific categories of data subjects such as to individuals who may be considered for employment (“Job Applicants” or “Candidates”). 

References to “Collective Acumen”, “group”, “affiliates”, “we”, “us” and “our” are references to Collective Acumen Corporation and its worldwide affiliates. 

Please read this Statement before using Collective Acumen’s website (https://collectiveacumen.com)  or otherwise providing your personal information to us. By visiting our Website or by providing us your personal information, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Statement. 

Personal Information Collective Acumen May Process About You 

Collective Acumen may process personal information about you including, but not limited to: 

• General information such as name, postal and/or email address, phone number, date of birth, and other information such as photographs and digital imagery, payment- related information, government issued identification in accordance with applicable laws (e.g. driving license, passport, professional license number), agreements, your communications preferences; queries you make to Collective Acumen; 
• Professional information, such as your job title, educational information, professional qualifications, work experience, programs and activities in which you participated; 
• Digital information generated from your use of Collective Acumen’s websites and mobile applications, such as IP address, geo-localization, device ID and data transmitted via Cookies. For further details on the use of Cookies by Collective Acumen please read our Cookies Statement available at: Cookie Statement. 

Sources of Information 

In most cases, Collective Acumen will collect information directly from you, although sometimes we will obtain information about you from public or third–party information sources including (but not limited to): 

• Collective Acumen may collect information about you from public or third–party sources for marketing purposes (e.g. when you choose to download material made available by Collective Acumen over third-party websites) and to verify professional information (including but not limited to access to publicly accessible information, national registries or third party databases); 
• Collective Acumen may collect information from your computer or other device you use when visiting Collective Acumen ’s website such as Internet Protocol (IP), domain name, Internet Service Provider (ISP), information about date and time of your request and other information provided by tracking technologies. Please see our Cookie Statement here. 
• Information may be shared within the Collective Acumen Group of Companies, which includes our worldwide Affiliates. 

Why Collective Acumen Processes Your Personal Information 

Collective Acumen will only process your personal information for purposes permitted by applicable laws, which may vary depending on where you live, and where Collective Acumen operates. The purposes of the data processing activities may include: 

• Managing Collective Acumen’s relationship with individuals for example, responding to questions and comments, inviting individuals to Collective Acumen’s events; 
• For collaboration purposes, for example to enable Collective Acumen to make more informed and objective decisions when identifying, engaging with professionals and key opinion leaders, and managing the collaboration relationship with such professionals; 
• Recruitment, processing professional information to assess individual’s suitability for job openings at Collective Acumen; 
• Market Research, processing information about individuals for lawful market research purposes. We collect information through surveys and interviews to help us improve our 

• Direct Marketing and Business Development Purposes, we process personal information to provide promotional material and engage in marketing and promotional activities with individuals in accordance with applicable local laws (You have choices about this – see “Individual Choices: Rights and Access to Information” section of this Statement). 
• Website functionalities, to ensure that content from our Website is presented in the most effective manner for you and for your device. 
• Any other purpose that is relevant to the relationship between Collective Acumen and you. 

Collective Acumen will process personal information for further purposes, where lawful to do so (such as for archiving, scientific or market research purposes) or when legally obliged to do so. 

Methods in Which Collective Acumen Collects and Uses Personal Information for Marketing and Business Development Purposes 

Collective Acumen may collect personal information in a variety of ways for purposes related to its own marketing and business development efforts.  These methods are outlined below: 

1. Downloads on the Collective Acumen Corporate Website – Collective Acumen makes some materials (white papers, reports, etc.) available for download on its own corporate website. This material is freely available for downloading. Collective Acumen may, at its discretion and subject to visitors’ consent, request that visitors also provide their basic identification and contact information (such as name, title, company, e-mail address, and similar data) to enable Collective Acumen to provide such visitors with additional promotional material related to the content of the material downloaded, as well as to contact them for marketing and introductory/business development purposes. Providing your consent to Collective Acumen to process your data for the above marketing and business development purposes is optional and is not a condition for downloading the material. If you choose to provide your consent you may later change your mind and withdraw it at any time as provided below. All information provided will be stored securely by Collective Acumen in its customer relationship management (CRM) system and made accessible only to authorized Collective Acumen personnel for the agreed purposes. Collective Acumen relies on its legitimate business interests for processing anonymized and statistical information relating to the downloads, such as number of downloads, location (country), industry, etc) for internal statistical analysis purposes. 
2. Downloads on Third-Party Websites – Collective Acumen periodically makes its materials (white papers, reports, etc.) also available for download on certain third-party websites. These third-party web sites are typically well-recognized industry news sources.  This material is freely available for downloading. Collective Acumen may, at its discretion and subject to visitors’ consent, request that visitors also provide their basic identification and contact information (such as name, title, company, e-mail address, and similar data) to enable Collective Acumen to provide such visitors with additional promotional material related to the content of the material downloaded, as well as to contact them for marketing and introductory/business development purposes. Providing your consent to Collective Acumen for processing your data for the above marketing and business development purposes is optional and is not a condition for downloading the material. If you choose to provide your consent you may later change your mind and withdraw it at any time as provided below.  Your information will be collected by these third-parties, in accordance with their own privacy policies and subject to specific contractual arrangements with Collective Acumen, for and on behalf of Collective Acumen and will be subsequently provided to Collective Acumen for further processing for the agreed above purposes. All information provided will be stored securely by Collective Acumen in its customer relationship management (CRM) system and made accessible only to authorized Collective Acumen personnel for the agreed purposes. Collective Acumen relies on its legitimate business interests for processing anonymized and statistical information relating to the downloads, such as number of downloads, location (country), industry, etc. for internal statistical analysis purposes. Information aimed at Collective Acumen will not be processed by such third-party websites for their own purposes. 
3. Newsletter / Blog Subscriptions – Collective Acumen may enable visitors to its corporate website / blog to subscribe to a corporate newsletter or to receiving updates/news from the blog. To subscribe, visitors would be required to enter basic contact information (including name and e-mail address).  This information would be stored in Collective Acumen’s CRM system which is accessible only to authorized personnel.  This information shall be used to deliver the blog or newsletter content, unless visitors specifically opt-in to also receive other forms of communication, such as information about Collective Acumen’s services, invitations to Collective Acumen events, and similar. Subscription to Collective Acumen’s blog and/or corporate newsletter is optional; if you choose to subscribe, please note that you can change your mind and withdraw your consent at any time by following the unsubscribe link at the end of each email communication. 
4. Off-Line Personal Data Collection – Collective Acumen may collect personal information directly from individuals in off-line settings. These settings may include face-to-face meetings, telephone conversations, conversations at conferences, and the like.  Collective Acumen may collect this information and store it in its CRM system which is accessible only to authorized personnel.  Collective Acumen may use this information to reach out to selected individuals for introductory or business development purposes. 

Legal Basis of Processing 

Collective Acumen processes personal information under one or more of the following conditions: 

• Where you have provided your consent (in which cases, such consent can be withdrawn at any time and without giving any reason); 
• Where it is necessary to comply with contractual obligations with you; 
• Where the processing is necessary for our compliance with a legal obligation; or 

• Where the processing is in Collective Acumen’s legitimate interest, for example, Collective Acumen processes information for statistical purposes, for purposes related to its marketing and business development efforts, information about Collective Acumen’s visitors and supplier personnel, for the improvement of our services, to provide security measures to protect Collective Acumen’s employees, contractors, information and other assets and to prevent crime (such as fraud, financial crime and theft of intellectual and industry property and to ensure the integrity of its manufacturing and other operations). 

Data Sharing and Cross-Border Data Transfers 

Personal information about you may be accessible to Collective Acumen’s Affiliates outside the EU/ European Economic Area (“EEA”), and selected vendors and partners, established in the EU or globally. Your personal information may be accessed by staff or suppliers in, transferred to and stored at, a location outside the EU or the EEA in which data protection laws may not afford the same level of data protection as the one in the EU/EEA. Where Collective Acumen processes personal information in countries that may not provide the same level of data protection as in the EU or in your own country where you are resident, Collective Acumen will implement reasonable and appropriate legal as well as technical and organizational security measures to ensure the security of the processing and in particular to protect your personal information from unauthorized access, use or disclosure including, but not limited to, maintaining binding contractual arrangements with all third parties processing personal information of individuals, for and on behalf of Collective Acumen, as well as executing, where necessary, adequate data transfer mechanisms, in the form of standard contractual clauses, for any cross-border data transfers from the EU to controller or processors established in third countries, as adopted and approved by the European Commission, or by the competent supervisory authorities, with the aim to achieve an adequate level of data protection of the personal information of those individuals. 

For residents of EEA – whenever we transfer your information outside of the EEA, we will either ask for your explicit consent or take any and all necessary steps to ensure that adequate safeguards are put in place to protect your information (unless we are permitted under applicable data protection law to make such transfers without additional formalities e.g. where the recipient country is considered an adequate destination). Such safeguards include the use of European Commission approved standard contractual clauses as mentioned above. 

The confidentiality of Personal Information transmitted over the Internet cannot be guaranteed. Collective Acumen urges you to exercise increased caution when transmitting Personal Information over the Internet, as we cannot absolutely guarantee that unauthorized third parties will not gain access to your Personal Information. 

Our Website may contain links to other third-party websites which may have their own privacy policies and terms of uses. Collective Acumen has no control over such third-party websites or their content, and this Privacy Statement does not apply to such websites. We do not accept responsibility or liability for the policies or processing of your personal information by websites linked to or from our Website as we do not control the privacy practices of these third parties and we strongly recommend you review the privacy settings they have set up directly with them by visiting their respective privacy related websites and policies. 

Disclosure of Your Personal Information to Third Parties 

Collective Acumen does not sell personal data to third parties. 

Collective Acumen may disclose personal information to third party recipients where this is reasonably permitted to pursue its legitimate business aims and as required by applicable law. Your personal information will be disclosed only in accordance with local applicable laws, and appropriate safeguards will be established, where possible, to protect your personal information. Collective Acumen may disclose personal information to any member of our group of companies. 

In order to conduct Collective Acumen’s business, Collective Acumen may also disclose information to third parties such as public/regulatory authorities/governmental bodies (government, including social and benefits departments), third parties that provide services to Collective Acumen  (such as but not limited to service providers conducting audits, providing IT services, etc.). Collective Acumen may also disclose information if Collective Acumen or substantially all of our assets are acquired by a third party, in which case personal information held by us about individuals will be included as transferred assets, or if Collective Acumen is under a duty to disclose or share individuals’ information in order to comply with any legal or regulatory obligation or request. 

Collective Acumen may also disclose information to enforce any agreements it has with individuals; or to protect the rights, property or safety of Collective Acumen’s employees or others (e.g. visitors to Collective Acumen premises). 

Automated Decision Making and Individuals’ Rights 

Collective Acumen does not undertake decisions based solely on automated processing, including profiling, of individual unless we inform you otherwise. 

Individual Choices: Rights and Access to Information 

Access, Revision, Deletion 

Under applicable privacy laws (e.g. European data protection and privacy laws), you may have a right to request a copy of personal information of you held by Collective Acumen. You may also have the right to revise, correct, or delete such information. Your rights to such information may be subject to limited legal and regulatory restrictions. 

Choices about Marketing 

Whenever we collect and use your information for marketing and business development purposes we will inform you and ask for your consent;  Please note that your consent is voluntary and you will have the right to object to your personal information being further processed for the purposes of direct marketing at any time. You can exercise this right and prevent such processing by using the “opt-out” or “unsubscribe” functionality in electronic communications to update your preferences. You can also exercise the right at any time by contacting us as set out below. 

Cookies 

Information about use of cookies and similar technology implemented by Collective Acumen on digital services and Collective Acumen’s website can be found at Collective Acumen’s Cookie Statement available at: Cookie Statement

Objection to Processing and Additional Rights 

Under applicable privacy laws (e.g. European data privacy law), where Collective Acumen relies on legitimate interests or public interest to process information, and where Collective Acumen conducts direct marketing, individuals can formally object to processing of their information for these purposes (in addition to the “Choices about Marketing” set out above). Individuals should clearly state “objection to processing” when contacting Collective Acumen to exercise this right to objection. 

In certain circumstances, you have the additional rights to restrict aspects of the processing of your information or ask for a copy of your data to be provided to you, or a third party, in a digital format. 

Exercising Your Individual Rights 

Your exercise of the above-mentioned rights is subject to certain exemptions to safeguard the public interest and our own legitimate interests. If you decide to exercise any of these rights, we will check your entitlement, we may request to confirm your identity and in any case we shall respond within a calendar month from receipt of such a request, unless there are valid grounds for extending the response periods, essentially due to the need to confirm your identity, to request additional information or to ask you to specify or limit your request, in case your request is too general or too complex to be handled within the initial deadline. Collective Acumen may not be able to comply with a request where personal information has been destroyed, erased or made anonymous in accordance with applicable laws and regulations as well as with Collective Acumen’s record retention obligations and practices.  In the event that we cannot satisfy a request with regards to your personal data, we will endeavor to provide you with an explanation, subject to any legal or regulatory restrictions. 

If we do not handle your request timely or if you are not satisfied with our response to any exercise of these rights, you are entitled to lodge a complaint with the competent supervisory authority. Further information and contact details of the competent supervisory authorities can be found here: https://edpb.europa.eu/about-edpb/board/members_en 

To exercise your individual data protection rights please contact our Privacy Office by email at privacy@collectiveacumen.com. Alternatively, you may contact us by post at the address available at Contact Us section below. 

How Long Collective Acumen Retains Your Personal Information 

We will retain your personal information for no longer than is necessary for the processing purpose(s) for which your information was collected and any other permitted associated purpose. Information may be retained for a longer duration where applicable laws or regulations require or allow Collective Acumen to do so. Your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed. 

Security of Processing of Personal Information 

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Statement, applicable data protection laws and regulations and international industry security standards. All information you provide to us is stored on secure servers and accessed and used subject to our security policies and standards. Collective Acumen has implemented reasonable physical, technical and managerial controls and safeguards to keep your personal information protected from unauthorized access, disclosure, alteration, and destruction. Such measures may include but are not limited to: access controls, separation of duties, and similar security protocols. 

Access to your personal information is limited to a restricted number of Collective Acumen employees whose duties reasonably require such information and third parties with whom Collective Acumen contracts to carry out business activities on its behalf. Our employees have been trained on the importance of privacy and how to handle and manage personal information appropriately and securely. 

Applying to Work at Collective Acumen 

Collective Acumen processes information to identify job applicants, assess job applications, and for other human resources processes necessary for evaluating and considering job applications. The information processed may include information such as your job title, education information, professional qualifications, work experience, publications and scientific activities, professional networks, and programs and activities in which you participated. 

In the course of an application, Collective Acumen may process further information, such as government issued identification number, tax status, bank account details, details of any known disability/workplace accessibility needs, background information, travel and expenses, performance management, emergency contact details, compensation, hours of work, holidays and benefits related information. 

Children 

Collective Acumen’s website is not intended or designed to collect or use any personal information from children (“children” are individuals who have not reached the age of majority in their residential jurisdictions). We do not knowingly collect personally identifiable information from or provide online services to any individual we know to be under the age of 13. 

Should you suspect that a child of whom you are the parent or legal guardian has provided us with Personal Information, please contact Collective Acumen using one of the methods specified below and we will work with you to address this issue. 

Changes to This Privacy Statement 

Collective Acumen reserves the right to amend this Privacy Statement from time to time to reflect technological advancements, legal and regulatory changes, and Collective Acumen’s business practices and processing activities, subject to applicable laws. If Collective Acumen changes its privacy practices, an updated version of this Privacy Statement will reflect those changes by posting any revisions on Collective Acumen’s corporate website with the respective update date listed on the bottom of this Statement. All changes to this Statement shall become fully effective thirty days (30) after the update date posted below. We, therefore, encourage you to view any amendments when you visit our Website from time to time to stay informed of how we are using your personal information. 

Contact Us 

If you have questions about this Privacy Statement, or to obtain more information about Collective Acumen’s privacy practices, please contact us. 

You can contact our Privacy Office by email at info@collectiveacumen.com or by postal mail at: 

Chief Privacy Officer 
Collective Acumen LLC
850 Canal Street, 3rd Floor
Stamford, CT 06902

Last Updated:  02/04/2021