Privacy Policy

ACC Group Privacy Policy

Last revised: 10 October 2024

Introduction

ACC Group ("ACC Group", "we", "us", or "our") is committed to safeguarding and processing personal information ("PI"), including sensitive personal information ("SPI")1, in line with all applicable privacy and data protection laws. Many of our offices are located in countries with laws governing the processing of PI. "ACC Group" includes ACC Group, Inc., its direct or indirect subsidiaries, and ACC managed products. The entity you contract with will be the controller of your PI.

References to "you" or "your" refer to individuals whose PI is processed by ACC Group, including individual investors, client employees, officers or agents (together "Representatives"), and beneficial owners of an organization or entity in connection with:

The provision of services to potential and actual clients;
Transactions in which we are a party (including those we conduct on behalf of clients);
Services provided to us by third-party vendors.

This Privacy Notice sets out the purposes for which we collect, use, and disclose (collectively "Processing") PI and how it is protected. It also sets out individuals' rights regarding the processing of their PI.

There may be additional terms, conditions, and commitments that also govern how we collect, use, and disclose your PI, which should be read in conjunction with this Privacy Notice.

PI We Collect About You

PI is information relating to an individual that can be used alone or with other information to identify that individual. PI does not include information where the identity of the individual or specific details have been removed, making it non-attributable. SPI is a sub-category of PI that includes information relating to race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health information, genetic, and biometric data.

The nature of the information that we collect will depend on the services provided, applicable laws, and our relationship with you. We categorize the PI we may process as follows (non-exhaustive examples):

Identification Data: Full name, title, gender, marital status, date of birth, passport number, driving license number, national identification number, signature.
Contact Data: Personal address, telephone number, email address.
Electronic Monitoring Data: To the extent permitted by law, we may record and monitor your electronic communications with us, including telephone conversations, email, instant messaging, and any other electronic communications.
Financial Data: Account number, client reference number, account statements, investment history.
Marketing, Behavioral, and Communications Data: Marketing and communication preferences, information about your use of our websites, portals, and platforms as explained in our Cookie Notice.
Professional Information Data: Position/job title, business address, business telephone number, business email address.
Profile Data: Username and password for our online services, investments made by you, services requested, marketing communications responded to, survey responses.
Services Data: Payment details to and from you, details of services you have provided to us, or we have provided to you.
Building and Asset Security Data: Records of visits to our premises, CCTV recordings.
Technical Data: Your use of and interaction with our online services, your IP address, browser type and version, browser plug-in types and versions, operating system.
SPI: In limited circumstances, we may collect information about criminal convictions and offenses, dietary requirements, disabilities, and political affiliations where legally required.

We collect PI in several ways, including:

Directly from you when provided in connection with an ACC product or service;
From Representatives of an organization or entity that is a client or vendor of ACC;
Throughout the course of our relationship with you, including updates or changes;
From public sources, including social media interactions;
From third parties such as credit reference agencies;
From visits to our websites or through logging into any of our online services.

Unless otherwise indicated, providing specific PI is necessary for us to provide our products and services. Failure to provide this information may limit our ability to provide those products and services.

Purpose and Legal Basis for Processing PI

The below table sets out the purposes and basis for which we process PI:

Processing Purpose

To consider opening an account or entering into a relationship at your request, including anti-money laundering and fraud checks

To deliver the services requested, including liaising with third parties

To manage payments, fees, and collect money owed

To manage our relationship, including notifying about changes

To interact with regulatory bodies or authorities

To detect or prevent fraud and protect employees and assets

To manage and protect our business, including data security

To invite you to participate in events and manage participation

To send marketing communications and improve user experience

Category of PI

Identification data, Contact data, Electronic Monitoring data, Financial data, Professional Information data, Services data, SPI

Identification data, Contact data, Electronic Monitoring data, Financial data, Profile data, Services data, Technical data, Marketing and Communications data, Professional Information data

Identification data, Contact data, Financial data, Professional Information data, Services data

Identification data, Contact data, Electronic Monitoring data, Profile data, Marketing and Communications data, Professional Information data

Identification data, Contact data, Electronic Monitoring data, Financial data, Services data, Professional Information data

Identification data, Building and Assets Security data, Contact data, Electronic Monitoring data, Financial data, Professional Information data, Profile data, Services data, Technical data

Identification data, Contact data, Electronic Monitoring data, Profile data, Technical data, Marketing and Communications data, Professional Information data

Identification data, Contact data, Profile data, Technical data, Marketing and Communications data, Professional Information data

Basis of Processing

Performance of a contract, Legal or regulatory obligation, Legitimate interests

Performance of a contract, Legitimate interests

Performance of a contract, Legal or regulatory obligation, Legitimate interests

Legal or regulatory obligation, Public interest

Legal or regulatory obligation, Public interest, Legitimate interests

Legal or regulatory obligation, Legitimate interests

Consent, Legitimate interests

To Whom We Disclose Your PI

We may disclose PI in any jurisdiction to:

Other members of ACC Group;
Professional advisors, third parties, agents, or independent contractors providing services to any member of ACC Group;
Goods and services providers, intermediaries, brokers, and others who partner with us;
Competent authorities, as required by law;
Any potential buyer, transferee, or merger partner in connection with a transaction;
Credit reference agencies or other organizations for anti-money laundering checks;
Any person as allowed or required by local or foreign law or regulation.

International Transfers

To provide global services, we may transfer PI to a location outside of your country of residence, including processing centers in the USA, EU, and Asia. Although these countries may not have the same privacy and data protection laws, we apply the same level of security and organizational controls to the processing of PI. We ensure appropriate safeguards are in place for transfers outside the EEA.

Marketing and Opt-Out Rights

You may need to expressly consent to receive marketing emails in certain jurisdictions. You can opt-out of receiving communications at any time by clicking on opt-out links in marketing materials, or by contacting us directly.

Third-Party Marketing

We do not share or sell your PI to third parties for their own marketing purposes.

PI Retention

We retain PI for as long as is necessary to fulfill the purpose for which it was collected or to comply with legal and regulatory obligations.

PI Security

We use a range of physical, electronic, and managerial measures to ensure a level of security appropriate to the risk of processing PI. These measures include:

Education and training for relevant staff;
Administrative and technical controls to restrict access to PI;
Technological security measures, including encryption;
Physical security measures, including access controls;
External security audits and assessments.

We endeavor to protect PI but cannot guarantee the security of data transmitted to or by us over the internet.

Your Rights

In certain circumstances, you may have the following rights regarding your PI:

Access: Request a copy of your PI and information on its use.
Object: Object to the processing of your PI.
Correction: Update or correct your PI.
Erasure: Request deletion of your PI.
Restriction: Request restricted processing of your PI.
Portability: Request a copy of your PI in a commonly used format.
Automated Decision Making: Request manual intervention where automated decisions affect you.

To exercise your rights, please contact us at privacy@accgroup.com. We may need specific information to verify your identity.

Contacting Us

If you have questions or wish to exercise your rights, please contact:

Privacy Officer
ACC Group
Magirus-Deutz-Straße 13

89077 Ulm, Germany
Email: privacy@accgroup.com

Complaints

If you have concerns or complaints, you have the right to contact the Privacy Officer at privacy@accgroup.com or the appropriate data protection authority in your country.

Cookie Notice

Please see our separate Cookie Notice.

Linked Websites

This Privacy Notice is not applicable to third-party websites that we do not own or control.

Changes to This Privacy Notice

We may modify this Privacy Notice from time to time. Please visit our website regularly to check for updates. Any material changes will be communicated to you.