Privacy Policy

ACSD
Effective Date: 03/03/2026
Website: https://acsdbf.com

1. Introduction

ACSD (“ACSD,” “we,” “us,” or “our”) is committed to protecting personal data and maintaining the highest standards of data governance across international jurisdictions.

This Privacy Policy explains how we collect, use, process, store, and protect personal data when you visit https://acsdbf.com (the “Website”) or engage with us professionally.

ACSD serves clients and partners globally, including the United States, Europe, and Africa.

2. Controller Information

For purposes of the EU General Data Protection Regulation (GDPR) and UK GDPR, ACSD acts as a Data Controller for personal data collected through the Website.

Contact:
ACSD
Website: https://acsdbf.com
Email: [Insert Email]

3. Categories of Personal Data Collected

We may collect:

A. Identity Data

  • Full name

  • Title

  • Organization

  • Professional role

B. Contact Data

  • Email address

  • Phone number

  • Business address

C. Technical Data

  • IP address

  • Browser type

  • Device type

  • Referring URLs

  • Time zone

  • Usage analytics

D. Professional & Due Diligence Data

  • Business inquiries

  • Project scope discussions

  • Compliance screening data

  • Publicly available institutional data

We do not knowingly collect sensitive personal data unless voluntarily provided.

4. Legal Bases for Processing (GDPR)

Where GDPR applies, we process personal data under one or more of the following bases:

  • Legitimate Interest – Responding to inquiries, evaluating business engagements, maintaining security.

  • Consent – Where required for analytics cookies or marketing communications.

  • Contractual Necessity – Where processing is required to enter into or perform a contract.

  • Legal Obligation – Sanctions compliance, anti-corruption laws, AML requirements.

5. How We Use Personal Data

We use personal data to:

  • Respond to inquiries

  • Evaluate potential consulting engagements

  • Conduct compliance and sanctions screening

  • Maintain cybersecurity and fraud prevention systems

  • Improve Website performance

  • Communicate regarding professional opportunities

  • Fulfill contractual obligations

We do not sell personal data.

6. Sanctions & Compliance Screening

Due to the international and fragile contexts in which ACSD operates, we may conduct screening against:

  • U.S. sanctions lists (OFAC)

  • EU consolidated sanctions lists

  • UK sanctions lists

  • UN sanctions lists

Such screening is conducted under legitimate interest and legal obligation grounds.

7. International Data Transfers

Because ACSD operates globally, personal data may be processed outside the country of origin.

Where required, we implement safeguards including:

  • Standard Contractual Clauses (SCCs)

  • Contractual data protection provisions

  • Secure technical safeguards

  • Data minimization practices

8. Data Retention

We retain personal data only as long as necessary for:

  • Business engagement evaluation

  • Contract performance

  • Compliance requirements

  • Legal obligations

Retention periods vary depending on legal and operational requirements.

9. Your Rights (EU, UK, and Similar Jurisdictions)

Individuals located in the EU, UK, or similar jurisdictions may have the right to:

  • Access personal data

  • Correct inaccurate data

  • Request deletion (“Right to be Forgotten”)

  • Restrict processing

  • Object to processing

  • Data portability

  • Withdraw consent at any time

Requests may be submitted via the contact information provided below.

10. U.S. Privacy Rights (Including California)

Residents of certain U.S. states may have rights to:

  • Know what personal data is collected

  • Request deletion of personal data

  • Opt-out of sale (ACSD does not sell personal data)

  • Correct inaccurate information

To exercise rights, contact us at: [Insert Email]

11. Data Security

We implement appropriate technical and organizational measures, including:

  • Secure hosting environments

  • Access controls

  • Encryption where appropriate

  • Firewall and intrusion detection measures

  • Limited personnel access

However, no system is completely secure.

12. Automated Decision-Making

ACSD does not use automated decision-making that produces legal or similarly significant effects on individuals.

13. Cookies & Tracking

We use cookies as described in our Cookie Policy.

Users may manage cookie preferences via our cookie banner or browser settings.

14. Third-Party Processors

We may use trusted third-party service providers for:

  • Website hosting

  • Analytics

  • Security monitoring

  • Email communication

These providers are contractually required to safeguard personal data.

15. Children

Our Website is not directed toward individuals under 18 years of age.

16. Changes to This Policy

We may update this Privacy Policy periodically. Updates will be posted with a revised effective date.

17. Contact & Supervisory Authority

If you are located in the European Union and believe your data protection rights have been violated, you may lodge a complaint with your local supervisory authority.

Contact ACSD at:
Contact Page
Website: https://acsdbf.com