Privacy policies

Privacy Policy

Armed Conflict Location & Event Data (“ACLED,” “us,” “we,” or “our”) has created this Privacy Policy (“Policy”) in compliance with applicable laws and in order to demonstrate our firm commitment to the privacy of your information. This Policy describes how ACLED collects, uses, discloses, transfers, stores, retains, or otherwise processes your information when you (whether in your individual or business capacity) access or use, in any manner, any of our content, products, services, or related activities (collectively “Services”), including through our Internet domains owned or operated by ACLED, which include, but are not limited to https://acleddata.com, https://developer.acleddata.com/, and https://www.caboligado.com (collectively, our “Website” or “Site”).

When we refer to “you” or “your,” we mean the person about whom we collect personal information or data. If the person accessing the Website or engaging with our Services does so on behalf of, or for the purposes of, another person, including a business or other organization, “you” or “your” also means that other person, including a business organization, if applicable.

You can find the previous version of this Policy here. This updated Policy does not communicate any substantive changes in our collection or processing of your personal data. Rather, we have performed an update in order to:

• Address recent changes to global privacy regulations that require ACLED to provide additional disclosures regarding our data collection and processing practices.

• Provide more clarity regarding the deployment and collection of online browsing information, including through cookie data and related technologies deployed on our Website.

• Provide more clarity on how we collect, process, and disclose personal information in the course of providing our Access Portal and soliciting donations.

Please read this Policy carefully. Our Policy includes:

1. General disclosures.

2. What information we collect and disclose and for what purposes.

3. How long we retain your information.

4. Marketing and promotional communications.

5. Integrations and links to other sites.

6. Security.

7. Changes to this privacy policy.

8. Contact us.

This Policy is supplemented by our:

• International Privacy Policy.

• Cookies Policy.

1. General disclosures

While we are registered in the United States, we operate globally, and our data centers and Website are hosted not only in the United States but also in the United Kingdom. If you are visiting this Website from outside of the United States or the United Kingdom, please note that by providing us with your information, it is being stored or processed in the United States or the United Kingdom, where our data center and servers are located and operated. The United States or the United Kingdom may not have privacy laws that are as strong or comprehensive as the privacy laws in your own country. If you are outside the United States or the United Kingdom and do not wish to allow the collection and storage of your personal information within the United States or the United Kingdom, you should not use this Website and you should opt-out of the collection of cookies by following the guidelines in our section titled “Enabling/disabling and deleting cookies” in our Cookies Policy.

This Policy sets forth our data policies and practices for the United States. If you are outside of the United States, please also review the provisions of our International Privacy Policy. Depending on your country of residence, applicable privacy laws may provide you with a right to additional disclosures as well as special data subject rights with regard to your personal information.

This Policy applies only to ACLED’s Website and Services, and not to other companies’ or organizations’ websites, mobile applications, and services to which we link. We are not responsible for the privacy practices of other businesses or the content of other websites, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “in cooperation with” relationships). To ensure protection of your privacy, always review the privacy policy of the companies with whom you engage.

2. What information we collect and disclose and for what purposes

In the course of performing our Services, we collect a variety of different kinds of personal information from a variety of different individuals. What information we collect and the purposes for which it is collected will depend on the context of our activities or the Service that is being performed. Therefore, just because this Policy lists a particular data collection practice does not mean that we have necessarily collected that data from you. Instead, please review the applicable disclosures below to learn about how we may have collected personal information from you depending on how you have interacted with us.

When possible, we collect personal information directly from you. However, in the course of providing our Services or administering our Website, we may collect personal information about you from another source. For example, if you access our Website through an external platform or click on external links, we may receive some information about you from that referring website. We may also collect information from social media platforms that may share information about how you interact with our social media content. The collection, use, and disclosure of your information and your use of those sites will also be subject to the privacy policies and other terms of such external parties and platforms. We have no control over the information collection and processing practices of such external parties, and you should review such privacy policies or terms of the websites or parties to which you give your information.

Website visitors

If you visit our Website, we may collect the following information about you for the described purposes and disclose it to the described recipients:

Further, we may collect personal information from you in the form of cookies. For information regarding how we collect, process, and disclose personal information in the context of cookies, view our Cookies Policy.

Current or prospective donors or business partners

If you are an employee of one of our partners, vendors, or other entities who is involved in our relationship with your employer, or if you engage with us as a donor or potential donor, we may collect the following information about you for the described purposes and disclose it to the described recipients:

De-identified and aggregated information

We may process your personal information into aggregated, anonymized, or de-identified form for any purpose. Aggregated, anonymized, or de-identified information is information that can no longer reasonably identify a specific individual and is no longer “personal information.”

3. How long we retain your information

We may retain your personal information for a period of time that is consistent for us to perform our Services, as well as to comply with applicable law, applicable statute of limitations, and our data retention practices. We may also retain your personal information as we believe is reasonably necessary to comply with legal process or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems, to assist with investigations, to enforce other applicable agreements or policies, or to take any other actions consistent with applicable law. Cookies are stored on your own device. You can find out more information about the retention of cookies in our Cookies Policy.

4. Marketing and promotional communications

You may opt out of receiving marketing and promotional messages from us, if those messages are powered by us, by following the instructions in those messages. If you decide to opt out, you will still receive non-promotional communications that are necessary for the performance of our Services.

5. Integrations and links to other sites

This Policy applies only to our Website, and not to other companies’ or organizations’ websites to which we link from our Website. ACLED is not responsible for the privacy practices or the content of such websites or organizations, including any websites that may indicate a special relationship or partnership with us (such as co-branded pages or “powered by” or “in cooperation with” relationships). Other linked websites may collect personal information from you that is not subject to our control. To ensure protection of your privacy, always review the privacy policy of the websites you may visit.

6. Security

We take reasonable measures, including administrative, technical, and physical safeguards, to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. We hold information about you at our own premises and with the assistance of service providers. Further public disclosure here of our security measures could aid those who might attempt to circumvent those security measures. If you have additional questions regarding security, please contact us directly using the information provided under Contact us.

7. Changes to this privacy policy

We may amend this Policy at any time by posting revisions on our Website. If we make any material changes in the way we collect or process your personal information, we will notify you by prominently posting notice of the changes on our Website.

8. Contact us

To submit questions, you can email us directly at [email protected].

International Privacy Policy

The above general Policy still applies to those individuals who reside outside of the United States or who have had personal information collected by ACLED or its agents in a country other than the United States. However, due to various international regulations, those individuals may be entitled to additional disclosures and rights. This International Privacy Policy (the “International Policy”) supplements the above general Policy, but where the provisions of the general Policy and this International Policy cannot be construed consistently, this International Policy will govern.

While we are registered in the United States, we operate globally, and our data centers and Website are hosted not only in the United States but also in the United Kingdom. If you are visiting this Website from outside of the United States or the United Kingdom, please note that by providing us with your information, it is being stored or processed in the United States or the United Kingdom, where our data center and servers are located and operated. The United States or the United Kingdom may not have privacy laws that are as strong or comprehensive as the privacy laws in your own country. If you are outside the United States or the United Kingdom and do not wish to allow the collection and storage of your personal information within the United States or the United Kingdom, you should not use this Website and you should opt-out of the collection of cookies by following the guidelines in our section titled “Enabling/disabling and deleting cookies” in our Cookies Policy.

THIS INTERNATIONAL POLICY APPLIES TO ALL PERSONAL INFORMATION ABOUT YOU THAT WE COLLECT, HOLD, USE, AND DISCLOSE, REGARDLESS OF THE WAY IN WHICH WE COLLECT IT (I.E., WHETHER THROUGH THE WEBSITE, THE SERVICES, OR OTHERWISE).

Our International Policy includes:

1. Collection of personal information
2. How we use personal information
3. The basis on which we process your personal information
4. Obtaining consent
5. Third-parties
6. Limitations
7. Retention of personal information
8. Access and rights to your personal information
9. Response time
10. Costs
11. Identifying you in connection with requests
12. Opt-out and unsubscribe
13. Accuracy
14. Safeguards
15. Contact us

1.  Collection of personal information

You can find specific details about the personal information that we collect about you in the section titled What information we collect and disclose and for what purposes of the general Policy.

Where we are the data controller with regards to the personal information that we process, you may exercise your rights as a data subject, including the right to object to the processing of your personal information when it is processed based on legitimate interests, as described in this International Policy. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller to the extent we are required to do so by law.

2. How we use personal information

As a general matter, we collect your personal information to perform our Services and administer our Website. You can find specific details about the purposes for which we collect personal information about you in the section titled What information we collect and disclose and for what purposes.

3. The basis on which we process your personal information

We will only collect and process your personal information as is reasonably necessary for, or directly related to, one or more of our functions or activities, including for administering our Website or providing our Services to you or our customers.

Where we are the data controller with regard to the personal information that we process, we process your personal information upon the legal bases described herein. This means that we collect, process, and disclose your personal information at the direction of our customers. Where we are collecting your personal information on behalf of another entity (i.e., we are not the data controller), we will provide you with the identity of the data controller upon request so that you can contact them to understand the legal basis upon which your data is processed, to the extent we are required to do so by law.

Where required by law, we rely on the following legal grounds to process your personal information:

• Performance of a contract: We may need to collect and use your personal information to enter into a contract with you or to perform a contract or provide services that you have requested from us.
• Consent: Where required by law, we will obtain your explicit consent for collecting and processing of your personal information.
• Legitimate interests: We may use your personal information for our legitimate interests of detecting and preventing fraud; investigating, asserting, and defending legal claims; our direct marketing; as well as maintaining the security of ACLED’s network and information systems.

4. Obtaining consent

Except when otherwise permitted by law or binding regulation, we will obtain the requisite consent from you prior to collecting and, in any case, prior to using or disclosing your personal information for any purpose other than as disclosed in this International Policy. You may provide your consent to us orally, in writing, by electronic communication, through your actions, or any other means reasonably capable of conveying your consent.

Generally, we will seek to obtain your explicit consent if we collect, use, or disclose sensitive personal information about you. However, your refusal to provide consent for collection (or your withdrawal of previously given consent) or to give your personal information when requested can have negative consequences. For example, if you do not give consent for ACLED’s collection of cookies, then the Website will not remember your prior log-in information or your preferences. In another example, if you do not provide your personal information when requested ,we may not be able to provide you with requested materials, disclosures, or Services.

5. Third parties

We remain responsible for all personal information communicated to other entities for processing on our behalf. As such, we ensure that other entities that are engaged to provide products or services on our behalf and are provided with personal information are required to observe the intent of this International Policy by having comparable levels of security protection or, when required, by assuring us (through a confidentiality agreement) that they will not use or disclose the personal information for any purpose other than the purpose for which the personal information was communicated. You can find specific details about to whom ACLED discloses your personal information in the section titled What information we collect and disclose and for what purposes.

6. Limitations

We only collect the personal information necessary to fulfill the purposes identified to you prior to or at the time of collection, or any other reasonable and legitimate purposes, or as required by law.

We do not use or disclose your personal information, except for the purposes for which it was collected, or new purposes to which you have consented, or as required or otherwise permitted by applicable law.

We do not, as a condition of providing the Website or performing the Services, or as an administrative or management requirement, require consent to the collection, use, or disclosure of personal information beyond what is reasonably required for such purposes, or to comply with our obligations under applicable law or regulation.

7. Retention of personal information

We may keep a record of your personal information, including correspondence or comments, in a file specific to you. We will utilize, disclose, or retain your personal information only for as long as necessary to fulfill the purposes for which it was collected and for legal or business requirements. We will establish minimum and maximum retention periods and procedures for maintaining and destroying your personal information. When personal information is retained to make a decision about you, we will retain such information for the period required in order to comply with our internal data retention policies.

8. Access and rights to your personal information

There are a number of data privacy laws that provide specific data subject rights to residents of certain jurisdictions. This section of this International Policy describes the rights available to those individuals who are entitled to them. Not all individuals about whom we possess information will have access to these rights, and we may not be able to provide these rights to everyone due to legal and jurisdictional limitations. We may not be able to comply with your request for a number of reasons, including:

• You do not live in a jurisdiction that grants you the specific right that you have requested.
• The information that you’ve requested is not subject to the regulation that grants you the right to make a request in relation to your personal information.
• We are prevented by law, regulation, or rule from complying with your request.
• We are not able to comply with your request without incurring a disproportionate burden or expense.
• If complying with your request conflicts with the integrity of our services or the ability to administer our business; to administer our business and related relationships; or to establish, defend, or administer legal claims.

If any of the above reasons apply, we will let you know in our response to your request. Note that we may be required to gather additional information from you in order to process your request. We will only use this information in the context of evaluating and responding to your request. If you fail or refuse to provide the necessary information, we may not be able to process your request.

Subject to the exceptions provided by applicable law or regulation, and depending on your country of residence, you may have the following rights regarding your personal information:

• The right to request confirmation that ACLED maintains or processes personal information about you.
• The right to know what categories of personal information ACLED maintains or processes about you.
• The right to access the personal information that ACLED maintains or processes about you.
• The right to request that a copy of your personal information that ACLED maintains or processes about you be provided to you or another data controller in a portable format.
• The right to know the purpose for ACLED maintaining and processing your personal information.
• The right to withdraw your consent for ACLED’s processing of your personal information, if our processing is based upon your consent.
• The right to request the correction of inaccurate personal information that ACLED maintains about you.
• The right to request that ACLED delete the personal information that it maintains about you.
• The right to request that ACLED restrict the processing of your personal information.
• The right to object to ACLED’s processing of your personal information that is based upon ACLED’s legitimate interests, as described herein.

You can request to exercise these rights by using the information provided under Contact us. Please be as specific as possible in your request so that we can meet the applicable handling timelines.

Finally, you have the right to raise a complaint with ACLED or the appropriate data protection authority of your country of residence if you feel that ACLED’s processing of your personal information violates your individual rights; is not in line with this International Policy; or violates the privacy principles, laws, or regulations of your country of residence.

• You can contact ACLED by using the information provided under Contact us. We will promptly investigate any complaint and will respond within the timeframes described in this International Policy.
• If you are a resident of the European Union, you can find your appropriate data protection authority by following this link.
• If you are a resident of Switzerland, you can contact your data protection authority through the information provided in this link.
• If you are a resident of the United Kingdom, you can contact your data protection authority through the information provided in this link.
• If you are a resident of Australia, you can contact your data protection authority through the information provided in this link. You can view the Australian Privacy Principles through this link.
• If you are a resident of Canada, you can contact your data protection authority through the information provided in this link.

An interactive map showing the various Data Protection Authorities around the world and how to contact them can be found here.

9. Response time

We will make every reasonable effort to respond to your written request no later than 30 days after receipt of such request. We will advise you in writing if we cannot meet your request within this time limit. When applicable, you have the right to make a complaint to the appropriate supervisory authority, as detailed in this International Policy, with respect to this time limit.

10. Costs

We expect to be able to respond to your request without charge as a general matter. However, where allowed by law, we reserve the right to collect a reasonable charge when you request the transcription, reproduction, or transmission of such information. We will notify you, following your request, of the appropriate amount that will be charged. You will then have the opportunity to withdraw your request.

11. Identifying you in connection with your requests

We may require that you provide to us additional information to identify yourself before we provide information about the existence, use, or disclosure of your personal information in our possession. Any such information that you provide to us shall be used only for this purpose.

12. Opt-out and subscribe

You may opt out of receiving marketing and promotional messages from us, if those messages are powered by us, by following the instructions in those messages. If you decide to opt out, you will still receive non-promotional communications that are necessary to maintain the existing business relationship between you and ACLED, to the extent there is one.

13. Accuracy

We will use reasonable efforts to ensure that your personal information is kept as accurate, complete, and up-to-date as possible. We do not routinely update your personal information in our possession, unless such a process is necessary. In order to help us maintain and ensure that your personal information is accurate and up-to-date, you must inform us, without delay, of any change in the data that you have provided to us.

You can, at any time, challenge the accuracy or completeness of the personal information we have about you, subject to the exceptions provided by applicable law. If you demonstrate that the personal information we have on you is inaccurate or incomplete, we will amend the personal information as required. Where appropriate, we will transmit the amended data to third parties to whom we have communicated your personal information.

14. Safeguards

We use security safeguards appropriate to the sensitivity of personal data to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. These safeguards include physical measures, such as restricted access to offices and equipment; organizational measures, such as security clearances (limiting access on a “need to know” basis) and publishing this policy to appropriate personnel with instructions to act in accordance with its principles; and technological measures, such as the use of passwords and/or encryption.

To provide, administer our business, and provide our services, we may share your personal information with our affiliates or with third parties in locations around the world. If we transfer or store personal information outside of countries that require legal protection for international data transfer, we will ensure that an adequate level of protection is provided by the destination country, enter into written intra-group data processing agreements with recipients that require them to provide an adequate level of protection, or rely on other legally-approved transfer mechanisms.

15. Contact us

To submit questions, you can e-mail us directly at [email protected].