General Content
Welcome to ACM's privacy policy.
ACM respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy aims to give you information on how ACM collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy, or notice, we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other privacy policies and notices, and is not intended to override them.
ACM Global Laboratories is a recognized leader in medical diagnostic and global clinical trial testing services. Details of which can be found here: [https://www.acmgloballab.com/about-us]. This privacy policy is issued on behalf of the ACM for processing your data. ACM is also the data controller responsible for this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:
Full name of legal entity: ACM Medical Laboratory, Inc. / ACM Global Central Laboratory Ltd / ABS Laboratories Ltd
Email address: data.protection@acmlab.com
Postal address: 160 Elmgrove Park, Rochester, New York 14624
Telephone number: 1 (800) 525-5227
We keep our privacy policy under regular review. This version was last updated on 25 FEB 2020.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services).
We use different methods to collect data from and about you including through:
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
See the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
| Purpose/ActivityPurpose/ActivityPurpose/Activity
To register you as a new customer |
Type of dataType of dataType of data
(a) Identity (b) Contact |
Lawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interest
Performance of a contract with you |
| Purpose/ActivityPurpose/ActivityPurpose/Activity
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
Type of dataType of dataType of data
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
Lawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| Purpose/ActivityPurpose/ActivityPurpose/Activity
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
Type of dataType of dataType of data
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
Lawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| Purpose/ActivityPurpose/ActivityPurpose/Activity
To enable you to partake in a customer survey |
Type of dataType of dataType of data
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
Lawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interest
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business) |
| Purpose/ActivityPurpose/ActivityPurpose/Activity
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
Type of dataType of dataType of data
(a) Identity (b) Contact (c) Technical |
Lawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interest
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| Purpose/ActivityPurpose/ActivityPurpose/Activity
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
Type of dataType of dataType of data
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Lawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy) |
| Purpose/ActivityPurpose/ActivityPurpose/Activity
To use data analytics to improve our website, services, marketing, customer relationships and experiences |
Type of dataType of dataType of data
(a) Technical (b) Usage |
Lawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| Purpose/ActivityPurpose/ActivityPurpose/Activity
To make suggestions and recommendations to you about services that may be of interest to you |
Type of dataType of dataType of data
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Lawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interestLawful basis for processing including basis of legitimate interest
Necessary for our legitimate interests (to develop our services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a transaction we have made or are making with you.
Our website uses analytical cookies, which tell us about how you use our website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
See also our Privacy Shield Policy, at section 14 below, under 'Transfers of personal data.'
We share your personal data within the ACM. This will involve transferring your data outside the European Economic Area (EEA).
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers for several years after they cease being customers for tax purposes. Also by law we have to keep the results of certain clinical tests for a long period, and in some cases indefinitely.
In some circumstances you can ask us to delete your data. See the Glossary for further information.
In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary to find out more about these rights.
If you wish to exercise any of the rights, please contact us.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You can direct any questions or complaints about the use or disclosure of your personal information to us, using the details in the section headed ‘Contact details’ above. We will investigate and attempt to resolve any complaint within 45 days of receiving the complaint.
UK citizens can make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk), or the equivalent in their country. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
See also the Privacy Shield Policy below.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties
Other companies in the ACM acting as joint controllers or processors and who are based in the US and the UK and provide IT and system administration services and undertake leadership reporting.
External Third Parties
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
ACM complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. ACM has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ .
This Privacy Shield Policy ("Policy") describes how ACM Medical Laboratory, Inc., in the United States ("we" or "us") collects, uses, and discloses certain personally identifiable information that we receive in the US, which is transferred to the US from the European Economic Area ("EEA"), the United Kingdom, and Switzerland.
We recognize that the EEA, the UK, and Switzerland have established strict protections regarding the handling of personal data, including requirements to provide adequate protection for personal data transferred outside of the EEA, the UK, and Switzerland. To provide adequate protection for certain personal data about clients, suppliers, business partners, job applicants and employees received in the US from the EEA, the UK, and Switzerland, we have elected to self-certify to the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework administered by the US Department of Commerce ("Privacy Shield"). We adhere to the Privacy Shield Principles of Notice, Choice, and Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.
For purposes of enforcing compliance with the Privacy Shield, we are subject to the investigatory and enforcement authority of the US Federal Trade Commission.
Our Website Privacy Policy, above, describes the categories of personal data that we may receive in the US, as well as the purposes for which we use that personal data. We may receive the following categories of personal data in the US: HR data relating to our employees, and non-HR data such as the Identity Data, Contact Data etc. described in section 4 of the Website Privacy Policy.
Third-party agents or service providers. We may transfer personal data to our third-party agents or service providers who perform functions on our behalf as described in our Website Privacy Policy. Where required by the Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process personal data in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing.
We remain liable for any breaches of the Privacy Shield Principles committed by our third-party agents or service providers, who perform services on our behalf in respect of personal data that we transfer to them, unless we prove we are not responsible for the event giving rise to the damage.
Third-Party Data Controllers. In some cases, we may transfer personal data to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your personal data to third-party data controllers for the purposes described in our Website Privacy Policy. We will only provide your personal data to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive personal data, where you have opted-in if the Privacy Shield requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for personal data the Privacy Shield requires. We also limit their use of your personal data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your personal data to one of our affiliated entities within our corporate group, we will take steps to ensure that your personal data is protected with the same level of protection the Privacy Shield requires.
Disclosures for National Security or Law Enforcement. Under certain circumstances, we may be required to disclose your personal data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.
We maintain reasonable and appropriate security measures to protect personal data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.
You may have the right to access the personal data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the Privacy Shield. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your personal data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information.
In compliance with the Privacy Shield Principles, ACM commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact ACM at: data.protection@acmlab.com
ACM has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU and Switzerland in the context of the employment relationship.
Binding Arbitration You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances. For information about this, see: https://www.privacyshield.gov/article?id=ANNEX-I-introduction
Contact Us
If you have any questions about this policy or would like to request access to your personal data, please contact us at: data.protection@acmlab.com.