Last updated: October 2018
Our Mission and Services
The ACSS strives to be the most relevant force and voice shaping sanctions compliance around the world; an essential community for sanctions officers.
Our Products and Services help you find and connect with people, groups, businesses, organizations, and others that are important to you. We design our systems so that your experience is consistent and seamless across the different Products or Services that you use.
Ownership, License, Use
Unless otherwise stated, the Site and its contents are owned and operated by the ACSS. This Site, and all materials appearing on it, are protected by copyright and may not be used without our prior written permission. Other trademarks or copyrighted materials appearing on the Site are the property of their respective owners and may not be used without permission.
You may access and use the materials and information on our Site as they appear there for your own personal use, educational advancement, or professional development. Any materials that you download for your own use must maintain all copyright or other notices. Except as ACSS expressly permits, any redistribution, retransmission, commercial exploitation, linking, or other uses are strictly prohibited. For permission to reuse articles from ACSS publications in other published works, please contact us.
You shall not copy or edit the materials, or integrate them into any other media. You shall not claim ownership or authorship, or otherwise use the materials except as we expressly permit. You shall not hack into our Site or text messages, or otherwise gain unauthorized access to or make improper use of our content or Site.
Privacy and Copyright Protection
PURPOSE FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
ACSS collects, uses, and discloses your Personal Information in its normal course of business. The information may be used to plan new products or services, gauge customer satisfaction, measure awareness of products or services, or to test reaction to products, services or communications. ACSS is committed to respecting and protecting your privacy as a research respondent who is participating in a study. This policy explains how ACSS collects and uses data that ACSS obtains via surveys and other primary research methods that ACSS uses. If you are participating in one of ACSS research studies from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States. Below are the primary uses of this information supplied to us:
- Establishing and maintaining communications with you;
- Providing requested content or services from ACSS;
- Responding to your inquiries about content and other services;
- Making proposals for future service needs;
- Allowing our partners, affiliates, and local chapters to notify you of certain products, services, or events offered by them;
- Making your resume available to prospective employers;
- Processing transactions through service providers;
- Registration for conferences, training, and other events;
- Meeting legal, security, processing, and regulatory requirements;
- Protecting against fraudulent, suspicious, or other illegal activities; and
- Compiling statistics for analysis of our sites and our business.
WHAT INFORMATION WE COLLECT
The information gathered by ACSS from this Site falls into two categories: (1) information voluntarily supplied by visitors to our Site and other Products, and (2) tracking information gathered as visitors navigate through our Site.
Information Voluntarily Provided by You
When using this Site, you may choose to provide us with information to help us serve your needs. “Personal Information” or “PI” is information recorded in any form that identifies an individual or can be used to identify an individual. It includes an individual’s name, identification numbers, date of birth, gender, mailing address, phone numbers, email address and other similar information. It may include information about an individual’s personal opinions and preferences.
You provide “PI” to the ACSS in the course of participating in research directly to the ACSS and utilizing ACSS products and services. In such cases, ACSS will comply with the contact limitations and data protections to which you agreed when you provided that permission. The ACSS may collect and use PI obtained from publicly available sources, where this is permitted by law. Most research surveys include demographic questions such as racial or ethnic origin, age, gender or income. ACSS uses these questions to help confirm that the research reflects a representative sample of the population the ACSS is studying. The ACSS also automatically collects information that is made available by the device you use to access ACSS website for system administration, surveys, service improvement, data analysis, and data integrity purposes to ensure that survey respondents do not impermissibly duplicate participation in the same survey. The information automatically collected for this purpose, as well as other “PI”, may be shared with third parties for the purposes of detecting and preventing impermissible duplicate participation in the same survey.
Your participation is voluntary. You are entitled at any stage of the interview or survey, research, or afterward, to ask that part or all of your personal data be destroyed. Wherever reasonable and practical, we will carry out such a request.
Below are some additional ways we collect data:
- When you request content
- If you request content (e.g., best practices, research) or further information from us, we require you to submit your name, email address, the name of your organization, and the country in which you are based so we may send you the material you have requested and to enable us to identify if you are an existing client of ACSS.
- Following an inquiry into receiving content or services from us, if you decide to proceed, we will collect Personal Information necessary to proceed with the transaction, such as your name, address, post code, contact telephone number, email address, billing address, or payment details, as relevant to the product. We will use your Personal Information to administer your account, fulfill registrations, and generally manage your relationship with us.
- When you register with us and/or join the ACSS as a member
- If you register with the Site, request a service available on the Site (such as registration for a conference), or become a member of the ACSS, we may ask you for your name, email address, country, telephone number, and the reason for your communication, as well as information about your position and organization and such other information as is reasonably necessary so that we can provide you with the service or identify what would be of most interest to you. On the data submission form, we shall indicate by way of an asterisk which information is optional and which information is mandatory.
- When you submit content
- If you submit content through our Site, we will ask for your name and email address, so that, if you choose, we can update you by email when others also comment on the content and also so that we can manage the content in line with our Statement of Ethics. You should be aware that the information you provide there will be made publicly available to ACSS employees, ACSS members, and other users of the Site.
- When you submit a resume
- We operate a Career Center that enables you to store your resume in our database. When you create a resume, you have the option of making the resume searchable or nonsearchable and confidential or nonconfidential. Not allowing your resume to be searchable means that you can use it to apply for a job online, but employers and recruiters will not have access to search it through our resume database product. If you choose to make your resume searchable, then all employers and recruiters who pay for access to our resume database product will have access to your resume. In addition to making your resume searchable or nonsearchable, you may designate specific information contained within your resume as confidential. Such confidential information will not be shared with employers and recruiters who search the resume database or to whom you deliver your resume.
- We use our best efforts to grant access to the resume database only to paying employers, recruiters, hiring managers, and human resource professionals, but we cannot guarantee that other parties will not, without our consent, gain access to this database. You may remove your resume from our searchable database at any time. However, employers and recruiters who have paid for access to the database, and other parties who have otherwise gained access to the database may have retained a copy of your resume in their own files or databases. We are not responsible for the retention, use, or privacy of resumes in these instances, or for the use or privacy of resumes by any of such parties while resumes are in the database.
Website Navigational Information
As you navigate the Site, we may also collect information through commonly used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (e.g., browser type, browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the web pages viewed and the links clicked).
There are different kinds of cookies with different functions:
- Session cookies: a session cookie is only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.
- Persistent cookies: a persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
- First-party cookies: the function of a first-party cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between ACSS’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.
- Third-party cookies: the function of a third-party cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the third party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.
- Where strictly necessary: These cookies are essential to enable you to move around the Site and use its features, such as accessing secure areas of the Site. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
- Performance: These cookies collect information about how visitors use a Site (e.g., which pages visitors go to most often, if they get error messages from web pages). They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that our Site works. These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous.
- Functionality: These cookies allow our Site to remember choices you make (e.g., your user name, your language, region you are in) and provide enhanced features. For instance, a Site may be able to remember your login details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Site. These cookies can also be used to remember changes you have made to text size, font, and other parts of web pages that you can customize. They may also be used to provide services you have requested, such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.
Use of Web Beacons
- The Site may also use web beacons (including web beacons supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with emails from ACSS. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Site tied to the web beacon, and a description of a Site tied to the web beacon. We use web beacons to operate and improve our Sites and email communications. We may use information from web beacons in combination with other data we have about our clients to provide you with information about ACSS and our services. We will conduct this review on an anonymous basis.
Use of IP Addresses
- When you visit our Sites, ACSS collects your IP addresses to track and aggregate non-Personal Information. For example, ACSS uses IP addresses to monitor the regions from which users navigate the Sites. IP addresses will be stored in such a way so that you cannot be identified from the IP address
DISCLOSURE OF INFORMATION TO OTHERS
Third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation, which purposes are as follows:
- To provide the products and services you have requested from us;
- To notify you or allow our affiliated companies to notify you of certain products or services offered by our affiliated companies;
- To process transactions through data processing service providers;
- If the information is a credit card number, to process credit card payments—through third-party payment processing, clearing, and settlement systems in association with various banks; and
- To fulfill joint marketing agreements with affiliates and partners.
If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent. Contact us on for more information on these third parties.
In the normal course of performing services for our clients, Personal Information may be shared within ACSS and its affiliates for research and statistical purposes, system administration, and crime prevention or detection. When you supply us with information containing third-party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform general insurance and other services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information and the fact that it may be disclosed to third parties such as ACSS, and that they have consented to such disclosure and use.
Because many of the service providers we use are located in the United States, including certain ACSS affiliates, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under U.S. laws.
ACSS’s service suppliers adhere to the same protections regarding the collection, use, and retention of data as we do.
As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. In addition, if either ACSS itself or substantially all ACSS assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances.
Other Legally Required Disclosures
ACSS preserves the right to disclose without your prior permission any Personal Information about you or your use of this Site or other Products if ACSS has a good faith belief that such action is necessary to (1) protect and defend the rights, property, or safety of ACSS, employees, or other users of this Site or the public; (2) enforce the terms and conditions that apply to use of this Site; (3) comply with a legally valid request from a competent governmental authority; or (4) respond to claims that any content violates the rights of third parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process, or governmental request.
CALIFORNIA’S “SHINE THE LIGHT” LAW
California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what personal information the operator disclosed to third parties for direct marketing purposes for the preceding calendar year, as well as the addresses and names of such third parties. ACSS does not share any personal information collected from this site with third parties for their direct marketing purposes.
European Union’s “General Data Protection Regulation (GDPR)” Law
The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation in EU law on data protection and privacy for all individuals within the European Union. It also addresses the export of personal data outside the EU. The GDPR aims primarily to give control to citizens and residents over their personal data and to simplify the regulatory environment for international business by unifying the regulation within the EU. In compliance of this law, ACSS does not utilize data for any reasons other than to fulfill commitments to existing products and services. The ACSS has data retention and storage mechanisms in place to control who has access to the data and has placed limits on what purposes the data can be used for.
Your knowledge of and consent to ACSS collection, use, and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
- Your voluntary provision of Personal Information to us directly;
- Your express consent or acknowledgment contained within a written, verbal, or electronic application or claims process; and
- Your verbal consent solicited by ACSS (or our agent) for a specified purpose.
Where ACSS relies on consent for the fair and lawful processing of Personal Information, the opportunity to consent will be provided when the Personal Information in question is collected. Your consent may be given through your authorized representative such as a legal guardian, agent, or holder of a power of attorney.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. ACSS will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for ACSS to collect, use, or disclose your Personal Information could mean that we cannot obtain insurance coverage or other requested products, services, or information for you.
If you wish to withdraw your consent, please refer to the “Questions or to Withdraw Consent” section below.
However, there are several instances in which ACSS does not require your consent to engage in the processing or disclosure of Personal Information. ACSS may not solicit your consent for the processing or transfer of Personal information for those purposes that have a statutory basis, such as in the following instances:
- The transfer or processing is necessary for the performance of a contract between you and ACSS (or one of its affiliates);
- The transfer or processing is necessary for the performance of a contract, concluded in your interest, between ACSS (or one of its affiliates) and a third party;
- The transfer or processing is necessary, or legally required, on important public interest grounds; for the establishment, exercise, or defense of legal claims; or to protect your vital interests; or
- The transfer or processing is required by applicable law.
LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION
ACSS will collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose and, subject to your consent (where appropriate), that new purpose will become an Identified Purpose.
ACSS will collect Personal Information by fair and lawful means. We will normally retain Personal Information as long as necessary for the fulfillment of the Identified Purposes. However, some Personal Information may be retained for longer periods as required by law, contract, or auditing requirements.
We have in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information we maintain. Safeguards will vary depending on the sensitivity, format, location, amount, distribution, and storage of the Personal Information. They include physical, technical, and managerial measures to keep Personal Information protected from unauthorized access. Among such safeguards are the encryption of communications via SSL, encryption of information while it is in storage, firewalls, access controls, separation of duties, and similar security protocols. However, due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information, and ACSS expressly disclaims any such obligation.
ACCURACY, ACCOUNTABILITY, OPENNESS, AND CUSTOMER ACCESS
Our knowing about changes to some of your Personal Information (e.g., email address) may be key to effectively communicating with you at your request. If any of your details change, you can update us by emailing us. Please keep us informed of changes to your Personal Information.
You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete, or incorrect. However, to secure your Personal Information, ACSS does not provide online access to its customers to view or amend Personal Information in its database.
QUESTIONS OR TO WITHDRAW CONSENT
You may exercise your right to withdraw your consent to applicable uses or disclosures of your Personal Information (which may limit or terminate the products and services that ACSS provides to you) by either (1) making changes to your profile via our online portal or (2) writing or sending an email to us.
We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.
Normally, we will respond to access requests within 30 days.
No Representations or Warranties
ACSS strives to ensure that the information contained in our Site and Products are accurate and reliable. We provide you access to the information and materials on the Site and other Products on an “AS IS” basis without any representations or warranties. THE ACSS EXPRESSLY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF TITLE, MERCHANTABILITY, OR FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT. We reserve the right to amend or withdraw our information, materials, and services provided on or through the Site or Products at any time without notice. We will not be liable or responsible for any damages or injuries caused by use of the Site or other Products (such as viruses, omissions, or misstatements). No advice or information, whether oral or written, obtained by you from us or through or from the Site or Products shall create any warranty not expressly stated herein. We are not responsible or liable for any interruption or discontinuation of the Site, Products or our subscriptions. We also have the right to terminate your access to all or part of our Site, Products or our subscriptions without notice. While we offer a wide variety of useful information, materials, and services, we make no promises about the content, your ability to secure a position, or advance in your career. By using this Site, Products and other methods of communication, you confirm that you have not relied on any of their respective content.
Exclusion of Liability
By using the Site or other Products, you expressly understand and agree that the ACSS shall not be liable for any damages, including direct, indirect, special, incidental, or consequential damages or lost profits, including but not limited to damages for loss of profits, goodwill, use, data, or other intangible losses that are in any way related to the distribution, use, or inability to use the information or materials on this Site or the actions of third parties on or through the Site, even if we have been advised of the possibility of such damages. In all events, our total liability is limited to the amount, if any, that you actually paid us for accessing this Site.
ACSS, its affiliates, and their respective officers, directors, employees, shareholders, successors, or heirs (the “Protected Entities”) shall in no event be liable for any claims, damages, or related expenses or liabilities, including but not limited to indirect, incidental, consequential, special, general, exemplary, or punitive damages arising from, or directly or indirectly related to, (a) the use of, or the inability to use, the Site, materials, and functions related thereto, your provision of information via the Site, lost business, or lost sales, even if such protected entity has been advised of the possibility of such damages; (b) the purchase and/or use of any products, services, discounts, or deals obtained through the Site; (c) the activities of the issuer of any card by which you access the Site; or (d) any misprints or inaccuracies that may be found to exist on the Site.
You are responsible for complying with the laws of the jurisdiction wherever you are located, and you agree that you will not access or use this site, its information, or materials in violation of such laws. You are solely responsible for the confidentiality and protection of any access tools, user name, and password by which you utilize the Site. You must notify us immediately if you believe your user name and/or password has been compromised.
Linking to the Site
Other Internet websites may freely provide hypertext or “Hot Links” to the Site, including “deep” links (i.e., links other than to the home page of the Site), provided that they are not “framed,” surrounded, or obfuscated by other non-ACSS content, materials, or branding that is inconsistent with the mission of the ACSS (as judged by the ACSS in its sole discretion). We reserve the right to require that any link to the Site be discontinued and to revoke your right to link to the Site from any other website at any time upon written notice to you.
We may revise these terms at any time without notice. By continuing to access and use this site or our text messages, you consent to these policies. Your obligations may not be sublicensed or assigned without our prior permission. These policies constitute the entire agreement between us governing your access and use of our site and text messages and all such information and material. If any provision of these policies is unenforceable, it shall be modified to provide ACSS with the greatest protection possible. Your obligations to respect our intellectual property (trademarks, copyrights, Site, and text message content) continue even after you stop using the site or our materials. These policies are governed by the laws of Florida, and any dispute between us shall be brought in the state or federal courts located in Florida. You consent to the exclusive jurisdiction and venue of those courts. If you have violated or threatened to violate these policies, we may seek injunctive or other appropriate relief against you; this is in addition to any claims for damages that we may have. You agree to pay all our costs of enforcement, including reasonable attorney fees.
Terms Governing International Use
We control and operate the Site from our offices in the United States of America. We do not represent that materials on the Site are appropriate or available for use in other locations. Persons who choose to access the Site from other locations do so on their own initiative and are responsible for compliance with local laws, if and to the extent local laws are applicable. Any information collected through this Site will be transferred to and processed within the United States of America.
Governing Law, Miscellaneous