PRIVACY POLICY

Privacy Notice

Effective Date: January 1, 2025
Last Updated: January 1, 2025

Aclero ("we," "our," "us") is committed to protecting your personal information and ensuring that it is handled securely and in compliance with the Personal Information Protection Act 2016 (PIPA) of Bermuda.

This Privacy Notice explains:

  • What personal information we collect

  • How we use and protect it

  • Your rights and how you can contact us about your data

1. Who We Are

Aclero provides talent management consulting and coaching services to individuals and organizations.

For any privacy-related questions, you can contact:

📍 Address: 11 Bermudiana Rd, Ste 1057, Pembroke HM08, Bermuda
📞 Phone: +1 (441) 300-0229
📧 Email: info@aclero.com
👤 Privacy Officer: Belinda Tribley

2. What Personal Information We Collect

We only collect the personal information necessary for our services. This may include:

  • Identity Information: Name, place of work, job title

  • Contact Information: Physical address, email address, phone number

  • Technical Information: IP address, browser type, and device identifiers (collected through cookies)

  • Other Information: Any information you provide voluntarily (e.g., through forms, surveys, or correspondence)

3. How We Collect Personal Information

We collect personal information in the following ways:

  • Directly from you when you contact us, sign up for our services, or complete a form

  • Via our website when you submit inquiries or interact with tracking technologies (see Section 9: Cookies)

  • From third-party tools such as PipeDrive (CRM system), SurveyMonkey (assessments and surveys), and Microsoft (email and document storage)

We do not collect sensitive personal data unless required for a specific service and with your explicit consent.

4. Why We Collect Personal Information

We process your personal information for the following purposes:

✅ To provide and manage our coaching and consulting services
✅ To communicate with you about services, updates, or inquiries
✅ To comply with legal and regulatory requirements
✅ To enhance our services and improve user experience
✅ To ensure data security and prevent fraud

We do not sell or share your personal data for marketing purposes without your explicit consent.

5. How We Share Personal Information

We may share your personal data with:

  • Service Providers & Contractors who assist with business operations (e.g., VA, CRM management, IT support)

  • Third-Party Platforms (e.g., Microsoft, PipeDrive, SurveyMonkey) used for secure data processing

  • Regulatory Authorities if required by law

We ensure that all third parties follow strict data protection measures and use your information only for necessary business purposes.

6. International Data Transfers

Some data may be stored or processed outside Bermuda, including in:
🌍 The UK, USA, Canada, and the European Economic Area (EEA)

We take appropriate safeguards (such as standard contractual clauses) to protect your data when transferred internationally.

7. Data Retention

We retain personal data for up to 7 years, unless:

  • We need to comply with a legal requirement

  • We have a legitimate reason to retain it for a longer period

After this time, data is securely deleted or anonymized.

8. Your Privacy Rights

Under PIPA, you have the right to:

🔹 Access your personal data
🔹 Request corrections to inaccurate or incomplete data
🔹 Request deletion of your personal data (subject to legal retention requirements)
🔹 Restrict processing of your data in certain circumstances
🔹 Withdraw consent if processing is based on your prior agreement
🔹 Lodge a complaint if you believe your privacy rights are being violated

To exercise these rights, contact our Privacy Officer at 📧 info@aclero.com.

9. Cookies and Website Tracking

We use cookies and similar tracking technologies on our website to:

  • Improve website performance and user experience

  • Track non-personal data such as browsing behavior and device type

We do not use cookies to collect personal data beyond what is necessary for website functionality and analytics.

💡 Managing Cookies:
You can disable cookies in your browser settings. However, some website features may not function properly without them.

10. Security of Your Personal Information

We use secure platforms and technical safeguards to protect your data, including:

✔️ Encryption for sensitive data
✔️ Access controls to limit who can view and process personal data
✔️ Secure storage using reputable cloud providers

While we take reasonable steps to protect your data, no system is completely foolproof. If we detect a security breach, we will notify affected users as required by law.

11. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. Any changes will be posted on our website with the updated effective date.

📌 Last Updated: January 1, 2025

Contact Us

For any questions or concerns about your personal data, please reach out to:

📧 Email: info@aclero.com
📞 Phone: +1 (441) 300-0229
📍 Address: 11 Bermudiana Rd, Ste 1057, Pembroke HM08, Bermuda