ACEI Privacy Policy

Effective Date of Current Policy: March 1, 2019

Underdog Group LLC DBA ACEI (“ACEI,” “we”, “us”, “our”) operates and is committed to protecting and respecting your privacy. This Privacy Policy describes the information that we collect through our website and in interactions with our clients and their customers and what we do with that information. Please read the following carefully to understand our practices regarding your personal information and how we will handle it.

If you have any questions about our Privacy Policy, please contact You may also contact us at:

Contact Information:
ACEI Digital
2049 South Ocean Drive,
7th Floor – Office #709E,
Hallandale Beach, FL 33009

This Privacy Policy applies to all technology, products, and services offered by ACEI, as well as any other content we may offer.
1. Information ACEI May Collect
We collect two types of information from visitors of ACEI’s website: personally identifiable information and non-personally identifiable information. You doing business with ACEI or communicating with ACEI about doing business constitutes your acceptance that we will gather personally identifiable or non-personally identifiable information about you, as applicable and as explained below.

1.1 Personally Identifiable Information
If you purchase our products or services as a client of ACEI (“Client”) or visit our website to consider purchasing our products or services as a potential client (“Potential Client”), we may request or collect certain personally identifiable information from you, including when you use our website, or interact with us via email or form through our website. Personally identifiable information means details which identify you or could be used to identify you. This includes contact information such as your name, email address, street address, phone numbers, as well as financial information such as a credit card number and its expiration date. It may also include the IP address of the computer you are using to access the ACEI website.

We use the personally identifiable information that we collect to facilitate our business relationship with you, for billing purposes and to communicate with you, including to send you marketing materials for our services and products. In addition, if you contact us by email or form through our website, we may keep a record of your correspondence.

ACEI also collects personally identifiable information from its employees, including contact information, government-issued identification and benefits information.

1.2 Non-Personally Identifiable Information
With respect to our Clients who purchase our products or services, Potential Clients who visit our website to consider purchasing our products or services and our Clients’ customers (“Customers”), we may also collect information that is not related to an identified or identifiable person or that could be used to identify a person. Our website, our service or our products may incorporate tags, pixels, or other similar tracking technologies and cookies that allow us to track the actions of visitors of our website, identify the name of your internet service provider, the type of browser software and operating system that you use, the date and time you access our website or our Clients’ websites, generalized geographic information, the website address, if any, from which you linked directly to our website, the website address, if any, to which you travel from our website, and other similar traffic-related information. We may aggregate your information with similar data collected from other visitors to help us improve our website and the products, services, applications, content and features that we provide through our website. We do not use non-personally identifiable information in any way to create or maintain a personal profile of you or to collect personally identifiable information from you.

In providing services and products to our Clients, we also collect non-personally identifiable data relating to our Clients’ Customers. We assign a unique hashed identifier to each user of our Clients’ websites that permits ACEI to provide insights into the management and to optimize the success of a Client’s product marketing through various internet-based channels. This unique identifier is not related to a specific individual by ACEI and cannot be used by ACEI or others to identify a natural person. Further, it would be a violation of ACEI’s Terms of Service for a Client to provide the mapping of the Customer’s identity to the unique hashed identifier that would enable the identification of the natural person to whom the identifier is assigned.

2. What We Do With the Information We Gather
We use our Clients’ and Potential Clients’ personally identifiable information that we collect for the purpose of:

• Sending you marketing materials for our services and products;
• Contacting you related to the provision of our services;
• Informing you about changes to our services and products;
• Facilitating your access to and use of our services and products;
• Website-related services such as web hosting;
• Improving website-related services and features; and
• Performing maintenance and other services.
We also process personal data when we believe that we are required to do so for any or all of the following reasons: (i) to comply with the law; (ii) to comply with valid legal process or regulatory obligations; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our website or our network; and/or (iv) to protect the rights, property, safety and security of ACEI and its employees, our website visitors, and/or the public

If the lawful basis upon which we process your personal data changes, we will notify you about the change and any new lawful basis to be used if required. We shall stop processing your personal data if the lawful basis used is no longer relevant.

3. Sharing and Transferring of Data
We will not share your personally identifiable information with third parties who wish to market other services and products to you. In some cases, we use third parties to provide services and products to our Clients. To the extent that ACEI engages a third party for this purpose, we require confirmation that the third party affirm that it (1) maintains its own privacy policy that complies with the European Union’s General Data Protection Regulation (“GDPR”); (ii) will comply with ACEI’s Privacy Policy; or (3) is exempt from GDPR compliance.

We also will share your information with third-parties when we believe that we are required to do so: (i) to comply with the law; (ii) to comply with valid legal process or a regulatory obligation; (iii) to prevent, investigate, detect, or prosecute criminal offenses or attacks on the technical integrity of our website or our network; and/or (iv) to protect the rights, property, safety and security of ACEI and its employees, our website visitors, and/or the public.

If we sell all or any part of our business or sell or transfer all or a material part of our assets or are otherwise involved in a merger or other transfer or disposition of any part our business, we may access, transmit or disclose any and all information that we collect from our website’s visitors, or that we otherwise collect in connection with the website, to the party or parties involved in the transaction as part of that transaction.

We will only transmit your personally identifiable information to those third-parties and transfer it to those countries necessary to accomplish one of the purposes above. To the extent that your information is transmitted to a third-party to fulfill one of these purposes, it will be transmitted in a manner that is calculated to protect that information from unauthorized access and use (e.g., by password-protected files, provided to specified users, etc.).

4. Right to Opt Out of Marketing
If you decide you would no longer like to be sent marketing communications, you can change your mind at any time. You can request that ACEI no longer send you marketing communications by writing to us at:
145 Chestnut Avenue
Suite 3L
New Jersey NJ 07306
(646) 748-77910

In addition, each marketing communication we send by email will also have an unsubscribe option which will allow you to stop receiving further marketing emails. You may also stop any further text messages by replying with the word “STOP”. We aim to implement requests to stop being sent marketing communications within 10 working days of receiving those requests, but it is possible you will receive some marketing in the period prior to that change being made.

Please note that if you tell us that you do not wish to be sent further marketing communications, you will still receive service communications (as described above) which are necessary to perform a contract with you. If you ask us to stop sending marketing communications, please note we will retain your personal information for the purposes of indicating that you do not want to receive marketing communications.

5. Your Rights as to Personally Identifiable Information We Collect
5.1 Information
You have the right to be informed of your rights and how your personal data will be stored, treated, deleted and controlled, as all is set out in this policy.

5.2 Access to information
You have the right to access your personal data, so that you are aware of and can verify the lawfulness of the processing. Generally, any access request is free of charge, although please note we may need to charge a reasonable fee to cover the administrative costs of providing the information, particularly if any request is repetitive or excessive. Please send your request to:
145 Chestnut Avenue
Suite 3L
New Jersey NJ 07306
(646) 748-77910

We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request, including a request for information relating to others who have not consented to the disclosure of their information and information that is legally privileged.

5.3 Correction or Completion of Information
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

You have the right to correct any data that is incorrect and, taking into account the purposes of the processing, you have the right to request that any incomplete information is completed (together, right of rectification).

5.4 Right to Request Deletion of Information
You can request that any personally identifiable information is deleted (right to be forgotten) in the following circumstances:
i. Where the personally identifiable information is no longer necessary in relation to the purpose for which it was originally collected/processed;

ii. When you wish to withdraw consent and that information was collected based on consent;

iii. When you object to the processing and there is no overriding legitimate interest for continuing the processing; and

iv. When your personal data has to be erased in order to comply with a legal obligation.
5.5 Restrictions on Rights
Please note that there are considerations that may affect your rights:
i. You may request us to stop sending you marketing. If you do so we will no longer be able to send you marketing communications. However, if you subsequently use our services, we will need to send you communications about the services you have agreed to use. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using.

ii. You may request us to stop using your personal information where we are doing so under legitimate interests (see the section “What We Do With the Information We Gather”, Section 2 for examples of when that applies) unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights.

iii. You may ask for personal information which identifies you to be erased (or forgotten). To do this we will remove the information that identifies you from the data we hold in our active operating systems (“anonymise”).

iv. We cannot erase personally identifying information for active Clients with whom we have a contract or are doing business.

v. For former Clients, we may need to retain certain elements that relate to a contract between you and ACEI because we need it for our own legal and auditing purposes.

vi. A record of your request including the personal information you supplied will be retained in the request used to carry this out for five (5) years.

vii. We cannot erase your personal information if we have identified that you either have an open complaint with us or you have raised a complaint with us in the past ten (10) years.
5.6 Data Access Portability
You may also request free of charge to view, access and use your personal and transaction data in a way that is generally portable. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
6. Protecting Your Information
Unfortunately, no security system, or system of transmitting data over the Internet, can be guaranteed to be 100% secure. Consequently, while we use commercially reasonable efforts to protect your personally identifiable information, we cannot guarantee the security of our servers, the means by which information is transmitted between your computer and our servers, or any information provided to us or to any third party through or in connection with the website. Any information that you provide to us is done so entirely at your own risk.

7. We May Update and/or Revise this Privacy Policy at Any Time
We reserve the right to update and revise this Privacy Policy at any time. You will know if this Privacy Policy has been revised since your last visit to the ACEI website by referring to the “Effective Date of Current Policy” date at the top of this page.

8. Links to Other Websites
Please be aware that we are not and cannot be responsible for the privacy practices of any websites that you access through our website and that this Privacy Policy applies solely to the information which we collect through our website. We encourage you to ensure that you read the privacy statements of all the destination websites which you visit.

9. Filing of Complaints
We strive to handle your information responsibly. If you have any questions about this policy, please contact We hope that we will be able to resolve any concerns you may have. However, if we cannot resolve your concern, you have a right to complain to any relevant privacy authority that has jurisdiction over the matter, which may include a privacy authority where you live or where the act where you are complaining of occurred.