Privacy Policy for The Humble Professionals
Last Updated: 20 July 2026
1. Who This Policy Applies To
This Privacy Policy applies to five different groups of people who interact with The Humble Professionals. Please read the section that applies to you.
| If You Are... | Read This Section |
|---|---|
| A Merchant subscribing to our Platform | Sections 1–17 (full policy) |
| A Content Contributor creating content on our Platform | Sections 1–17 (full policy) |
| A Supporter supporting merchants through our Platform | Sections 1–17 (full policy) |
| A Casual Visitor browsing our Platform without registering | Sections 1–17 (full policy) |
| A Consumer purchasing from a merchant through our Platform | Section 2 (Key Information for Consumers) |
2. Key Information for Consumers
If you are a consumer purchasing goods or services from one of our merchants (SMEs) through our Platform, please read this section carefully.
- We are the platform provider only. We provide the cloud infrastructure that allows merchants to sell their products to you.
- Your personal data is collected and controlled by the merchant you are buying from. The merchant decides what data to collect, why, and how long to keep it.
- The merchant is responsible for their own Privacy Policy. That policy explains how they handle your data, your rights, and how to contact them. You should read it carefully before making a purchase.
- We process your data only on behalf of the merchant. We do not use your data for our own purposes, sell it, or share it with third parties except as required to provide the Platform (e.g., hosting, payment processing) or by law.
- If you have questions about how your data is being used, contact the merchant directly. They are the data controller. We are the data processor.
Summary: The Humble Professionals is the infrastructure. Your merchant is the business you are dealing with. They control your data, not us.
3. What This Policy Covers
This Privacy Policy applies to:
- Our website at pro.acutice.com
- Our cloud-based ICT Platform provided to Small and Medium Enterprises (SMEs, "merchants") on a subscription basis
- Communications and interactions with our merchants, users, and their consumers
- Visitors to our marketing website
What's Not Covered
- Consumer Data: Merchants are responsible for the personal information they collect from their Consumers. They must have their own Privacy Policies covering that collection and use. We process Consumer data only on behalf of merchants.
- Third-Party Services: We are not responsible for third-party services, tools, or platforms that merchants, users, or consumers may access through our Platform.
4. How We Collect Information About You
The types of information we collect depend on your relationship with us.
A. Information We Collect from Merchants
When you subscribe to our Platform as a Merchant, we collect:
| Information | Purpose |
|---|---|
| Company name, registration number, tax ID | Account setup, verification, billing |
| Primary contact name, email, phone number | Account management, support, service communications |
| Billing address and payment details | Subscription processing |
| Subscription plan and usage metrics (pages, visitors) | Service delivery, billing |
| Communication history (support tickets, emails) | Customer support |
B. Information We Collect from Content Contributors
When you create or publish content on our Platform as a Content Contributor, we collect:
| Information | Purpose |
|---|---|
| Full name, email address | Account setup, content attribution, communication |
| Optional biography, profile picture, social media links | User profile, content authorship |
| Content you create, publish, or upload (articles, product descriptions, reviews, images, videos) | Platform functionality, content delivery |
| Activity history (content created, date of contributions) | Performance monitoring, content management |
C. Information We Collect from Supporters
When you support a merchant through our Platform as a Supporter, we collect:
| Information | Purpose |
|---|---|
| Full name, email address | Account setup, recognition, communication |
| Acknowledgment preferences (whether you want your name displayed publicly) | Privacy control |
| Donation or support history (amount, frequency, merchant supported) | Support tracking, reporting |
D. Information We Collect from Casual Visitors
When you browse our Platform without registering as a Casual Visitor, we collect:
| Information | Purpose |
|---|---|
| Email address (if you choose to register or create a limited account) | Access to Platform features |
| IP address, device type, browser, operating system | Security, fraud prevention, analytics |
| Browsing activity (pages visited, time spent, referral URLs) | Performance monitoring, Platform improvement |
E. Information We Collect from Consumers
We do not collect Consumer data directly. Consumers interact with our Platform through their merchant's account. The merchant is responsible for collecting and controlling that data.
However, we may automatically collect limited technical data when Consumers use the Platform (see Section 4F below) for security, fraud prevention, and operational purposes. This data is processed on behalf of the merchant.
F. Information We Collect Automatically (All Users)
When you use our Platform or visit our website, we automatically collect:
| Information | Purpose |
|---|---|
| IP address, device type, browser, operating system | Security, fraud prevention, analytics |
| Log data (access times, pages visited, referral URLs) | Performance monitoring, troubleshooting |
| Usage metrics (pages viewed, visitor counts, session duration) | Service delivery (for merchants), platform improvement |
5. How We Use Your Information
| Purpose | Information Used | Legal Basis |
|---|---|---|
| Provide and manage merchant subscriptions | Business name, contact details, account credentials | Performance of contract |
| Process billing and payments | Billing address, payment information | Performance of contract / Legal obligation |
| Calculate usage (pages, visitors) for billing | Account ID, usage logs | Performance of contract |
| Provide customer support | Communication history, account details | Performance of contract / Legitimate interest |
| Enable Content Contributors to publish content | Account data, content, profile | Performance of contract / Consent |
| Acknowledge Supporters (if they opt in) | Name, merchant supported | Consent |
| Provide access to Casual Visitors | Account data (if registered), technical data | Legitimate interest |
| Send service announcements (maintenance, security) | Contact email | Legitimate interest |
| Send marketing communications (with opt-out) | Contact email, preferences | Consent |
| Ensure security and prevent fraud | IP address, device identifiers, log data | Legitimate interest / Legal obligation |
| Improve our Platform | Usage data, aggregated analytics | Legitimate interest |
| Respond to visitor inquiries | Contact details provided via forms | Legitimate interest |
We do not sell your personal information to third parties.
6. Data Ownership
6.1 Merchant Data is Merchant Property
Any business data, content, documents, or materials that a Merchant uploads, stores, or processes through our Platform remains the Merchant's property. We claim no ownership over it.
6.2 Consumer Data Belongs to the Merchant
Consumers' personal data is collected and controlled by the Merchant. We are a processor of that data and do not claim ownership or control over it.
6.3 Content Contributor Content
Content created and published by Content Contributors remains the property of the Content Contributor, subject to the terms of our Terms of Service. The Merchant may have rights to use that content as defined in their agreement with the Content Contributor.
6.4 Our Platform is Ours
The Platform infrastructure, software, tools, and proprietary systems are owned by The Humble Professionals.
6.5 Data Relationships
| Role | Relationship |
|---|---|
| Data Controller (for Consumer data) | The Merchant (SME) |
| Data Processor (for Consumer data) | The Humble Professionals |
| Data Controller (for Merchant business data) | The Humble Professionals |
| Data Controller (for Content Contributor data) | The Humble Professionals |
| Data Controller (for Supporter data) | The Humble Professionals |
| Data Controller (for Casual Visitor data) | The Humble Professionals |
We process Consumer data only on Merchants' instructions and for the purposes defined in our agreement with them.
7. When We Share Your Information
We share your information only in the following circumstances:
A. Service Providers (Subprocessors)
We use trusted third-party providers to deliver our services:
| Service Provider | Purpose | Data Shared |
|---|---|---|
| Hetzner | Cloud hosting and infrastructure | All data processed on the Platform |
| [To be confirmed] | Subscription billing and payment processing | Billing information |
| Apple | Email and communication services | Email address, contact details |
| Internal Analytics | Platform usage monitoring | Usage data |
| Internal Support | Customer support | Contact details, support history |
All service providers are bound by data processing agreements and comply with applicable data protection laws.
B. Merchants (for Consumer Data)
When a Consumer uses our Platform, their data is made available to the Merchant they are purchasing from. The Merchant is the controller of that data.
C. Content Contributors and Supporters
Content Contributors' content may be visible to Merchants, Consumers, and other users of the Platform. Supporters' names may be displayed publicly only if they have opted in to acknowledgment.
D. Legal and Regulatory Compliance
We may disclose your information if required by law, court order, or government regulation, or to protect our rights, property, safety, or the rights of our Merchants, users, or Consumers.
E. Business Transfers
In the event of a merger, acquisition, reorganization, or sale of assets, your data may be transferred. We will notify affected Merchants and users before this occurs.
F. Merchant Data Separation
We implement technical and organizational measures to ensure that each Merchant's data is isolated and accessible only to that Merchant. Consumer data for one Merchant is not accessible to other Merchants.
8. Where We Store Your Information
Your information is hosted on our Cloud Service Provider Hetzner, with data centers located in:
- Germany: Nuremberg (NBG1) and Falkenstein/Vogtland (FSN1)
- Finland: Helsinki (HEL1)
- USA: Ashburn, Virginia (us-east / ASH) and Hillsboro, Oregon (us-west / HIL)
- Singapore: (ap-southeast / SIN)
International Transfers
If we transfer data to countries outside the European Economic Area (EEA) or your country of residence, we will:
- Ensure adequate safeguards are in place (e.g., Standard Contractual Clauses)
- Comply with applicable data transfer laws
- Provide you with information about these safeguards upon request
9. How Long We Keep Your Information
| Data Type | Retention Period |
|---|---|
| Active Merchant subscription account data | Duration of subscription |
| Active Content Contributor account data | Duration of active account |
| Active Supporter account data | Duration of active account |
| Casual Visitor account data | Duration of active account (if registered) |
| Usage and transaction history | Duration of subscription/account + 12 months |
| Billing and accounting records | As required by tax law (typically 7 years) |
| Support tickets and communication | Up to 3 years after account closure |
| Content created by Content Contributors | Duration of account + 30 days after deletion |
| Deleted or terminated account data | Deleted or anonymized within 90 days after termination, except where legal retention applies |
| Consumer data | Retained only as long as required by the Merchant's instructions. Deleted when the Merchant requests deletion or terminates their account |
Account Inactivity
If you have no active subscription and your account is inactive for 12 months, we will notify you and delete your account data unless you respond.
Data Upon Termination
Upon termination of a Merchant's subscription, we will:
- Provide the Merchant with a copy of their data upon request (in a structured format)
- Delete or anonymize their data (including Consumer data) after the applicable retention period
- Notify the Merchant before deletion
10. How We Secure Your Information
We protect your information with:
Technical Measures
- Encryption: Data encrypted in transit (TLS/SSL) and at rest (AES-256)
- Access Controls: Role-based access, least privilege, multi-factor authentication
- Network Security: Firewalls, intrusion detection, regular vulnerability scanning
- Audit Logs: Comprehensive logging of system access
- Data Isolation: Merchant data is logically separated to prevent unauthorized access
Organizational Measures
- Employee security training and background checks
- Regular security assessments and penetration testing
- Data breach response plan
- Written agreements with all service providers
Limitations
No security system is 100% secure. We cannot guarantee absolute security. If you suspect any compromise of your account or data, contact us immediately.
Data Breach Notification
In the event of a data breach affecting your information, we will:
- Notify affected Merchants and users without undue delay (within 72 hours if required by law)
- Cooperate with regulatory authorities
- Take immediate steps to contain and remediate the breach
11. Cookies and Tracking Technologies
We use cookies and similar technologies to:
- Maintain your session and authentication
- Remember your preferences
- Analyze Platform usage and improve performance
- Enable security features
Types of Cookies We Use
| Type | Purpose |
|---|---|
| Strictly Necessary | Essential for Platform functionality (login, security, session management) |
| Functional | Remember settings and preferences |
| Analytics | Collect usage data for platform improvement |
Your Choices
- You can control cookies through your browser settings
- Blocking strictly necessary cookies may prevent Platform functionality
- For analytics, you may opt out through your browser settings
12. Your Rights
Depending on your location, you may have the following rights:
For EEA/UK Residents (GDPR / UK GDPR)
- Access: Request a copy of your data
- Rectification: Correct inaccurate data
- Erasure: Request deletion of your data
- Restriction: Limit how we use your data
- Portability: Receive your data in a structured format
- Objection: Object to certain processing (e.g., marketing)
- Withdraw Consent: Withdraw consent at any time
- Complaint: Lodge a complaint with your supervisory authority
For California Residents (CCPA / CPRA)
- Know: Request disclosure of data collected, used, and shared
- Delete: Request deletion of your data
- Opt-Out: Opt-out of sale or sharing (we do not sell data)
- Correct: Correct inaccurate data
- Non-Discrimination: Equal service regardless of exercising rights
For Consumers
If you are a Consumer purchasing from a Merchant, your data is controlled by that Merchant. To exercise your rights, you should contact the Merchant directly.
How to Exercise Your Rights (Merchants, Content Contributors, Supporters, Casual Visitors)
Contact us at: admin@acutice.com
We will respond within:
- 30 days (GDPR)
- 45 days (CCPA)
We may need to verify your identity before processing your request.
13. Your Obligations as a Merchant
This section applies only to Merchants who subscribe to our Platform. Content Contributors, Supporters, and Casual Visitors are not subject to these obligations.
If you are an SME subscribing to our Platform, you are responsible for:
- Obtaining consent from your Consumers to collect, store, and process their data
- Providing your own Privacy Policy to your Consumers
- Ensuring you have a lawful basis for any data you process through our Platform
- Notifying us immediately of any data breach related to your account
- Maintaining the security of your account credentials
- Complying with all applicable laws regarding data protection and consumer privacy
- Ensuring that any Content Contributors you engage have appropriate agreements in place
We are not responsible for your compliance obligations regarding your Consumers' data.
14. Children's Privacy
Our Platform is designed for business use and is not intended for individuals under the age of 13 (or 16 in certain jurisdictions).
- Merchants may sell products intended for children, but they are responsible for ensuring compliance with applicable children's privacy laws.
- Content Contributors, Supporters, and Casual Visitors must be at least 13 years old (or 16 in certain jurisdictions) to use our Platform.
We do not knowingly collect personal information from children. If you believe a child has provided us with personal data, please contact us at admin@acutice.com and we will delete it.
15. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will:
- Post changes on our website
- Notify Merchants and registered users by email of material changes
- Update the "Last Updated" date at the top
We encourage you to review this policy periodically.
16. Governing Law
This Privacy Policy is governed by the laws of Mauritius. For EEA/UK users, your rights under applicable local data protection laws remain unaffected.
17. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy, please contact us:
The Humble Professionals
- Email: admin@acutice.com
- Address: 37, Dr O. Beaugeard street, Port Louis, Mauritius
- Phone: +230 57731581
We aim to respond to all queries within 5 working days.