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
Contact Here
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