PRIVACY & DATA GOVERNANCE POLICY

ACORN Group of Companies (including ACORN TRADING LLC, ACORN CONTROL SYSTEMS, and global technology divisions)

Last updated: October 2026

1. Preamble & Global Context

The ACORN Group of Companies (hereinafter referred to as “Acorn”, “we”, “our”) is an international engineering and technology leader in industrial automation, commercial energy metering (CMSP), green engineering, and cloud-based resource management platforms (High-Tech Utility & Scientific Minimalism).

This Policy governs the collection, processing, cross-border transfer, and protection of personal and technical data belonging to clients, partners, and users of our digital assets (including official corporate websites such as acorn-trading.com.ua and associated domain assets of the group) as well as users of the ACORN ENERGY DATA PLATFORM.

2. Intellectual Property Protection & Platform Data Regime

  • ACORN ENERGY DATA PLATFORM: All telemetry algorithms, analytical modules, databases, interface structures (SCADA/EMS dashboards), data collection architecture, and software code of the ACORN ENERGY DATA PLATFORM are the exclusive intellectual property of the ACORN Group of Companies.
  • Domain Assets & Branding: All rights to trademarks, domain names (acorn-trading.com.ua, corporate platform domains, and related web resources), and brand artifacts are fully protected by national and international intellectual property laws.
  • Anti-Scraping & Reverse Engineering Prohibition: Any unauthorized copying, reverse engineering, automated data extraction (scraping), or commercial exploitation of the ACORN ENERGY DATA PLATFORM architecture is strictly prohibited and subject to legal prosecution.

3. Data Categories & Scope of Processing

As part of delivering global engineering services and energy supply operations, we process the following data categories:

  1. B2B Client Representative Data: Full names, corporate email addresses, phone numbers, job titles, and contractual signing authorizations.
  2. Industrial & Technical Data (Telemetry & IoT): Energy consumption metrics, load profiles, telemetry streams from metering infrastructure (AMR/AMI), safety sensor outputs, and refrigerant leak detection logs (Freon Leak Block) transmitted via secure channels to the ACORN ENERGY DATA PLATFORM.
  3. Digital & Network Logins: IP addresses, cookies, user session logs on corporate portals, and personal account dashboards.

4. Legal Bases & Processing Purposes

We process data strictly on legitimate legal grounds (in compliance with the EU GDPR and Ukrainian data protection legislation):

  • Contractual Execution: Delivering turnkey EPC engineering projects, fulfilling Commercial Metering Service Provider (CMSP) functions, and executing energy supply contracts.
  • Platform Operations: Ensuring continuous uptime, advanced analytics, and infrastructure optimization within the ACORN ENERGY DATA PLATFORM.
  • Regulatory Compliance & Security: Meeting energy market regulatory mandates, tax requirements, and industrial ESG compliance standards.

5. Cross-Border Transfers & Global Cybersecurity (Zero-Trust)

To support the ACORN Group’s expanding footprint across global energy markets:

  • Channel Encryption: All data transmitted through the ACORN ENERGY DATA PLATFORM is protected using enterprise-grade encryption (TLS 1.3 & AES-256).
  • Data Localization & Cross-Border Transfers: International data flows are executed under strict data transfer agreements and compliance frameworks (including Standard Contractual Clauses under the GDPR for European operations).
  • Security Architecture: We apply a Zero Trust Architecture policy across all internal, external, and industrial telemetry network access points.

6. Data Subject Rights

Every client, partner, and digital platform user maintains the right to:

  • Request confirmation regarding the processing of their personal and technical data.
  • Request rectification of inaccurate information or complete data erasure (“Right to be Forgotten”), except where retention is legally mandated for licensed Commercial Metering Service Provider (CMSP) compliance under active energy contracts.
  • Withdraw consent for promotional or non-essential communications at any time.

7. Contact Details & Official Inquiries

For questions concerning data privacy, intellectual property rights, or the exercise of data subject rights, please contact our Compliance Office:

  • Legal Address (Ukraine HQ): 28 Yaroslavska St, Kyiv, 04071, Ukraine
  • Contact Phone Numbers: +380 (44) 334-4817, +380 (50) 403-7161
  • Official Emails: info@acorn-trading.com.ua, acorn.csystem@gmail.com