Privacy Statement - Effective as of May 17, 2018

Committed to Protecting Your Information

Aptean is committed to protecting personal information that we collect from you or that you provide to us and to using such personal information in compliance with applicable laws and regulations. This privacy statement aims to tell you how we process your personal information as a data controller whether received from our websites or collected by other means and will also tell you about your privacy rights. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy statement together with any other privacy notice or fair processing notice we may provide on specific occasions when we’re collecting or processing personal data about you so that you are fully aware of how and why we’re using your data. This privacy statement supplements other notices we may provide and is not intended to override them.

This privacy statement is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this Privacy Statement.


1. Who we are

Aptean is made up of different legal entities, including without limitation those stated below under ‘Aptean Group of Companies.’ This Privacy Statement is issued on behalf of the Aptean Group of Companies and references to “Aptean” “we” and “our” means any one or all of the Aptean group of companies.

This Privacy Statement covers the information practices of websites that link to this Privacy Statement, including without limitation: Aptean.com, Aptean.co.uk, Aptean.fr, Aptean.de, Aptean.es, Aptean.cn, and Aptean.jp (collectively referred to as “Aptean’s websites”, “our websites” or “the Company’s websites”).

We have appointed a data protection officer who is responsible for overseeing questions in relation to this Privacy Statement. If you have any questions about this Privacy Statement, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Email address: dpo@aptean.com

Postal address: the Data Protection Officer, 7 Rushmills, Northampton, NN4 7YB, UK

Changes to this privacy statement

This Privacy Statement may change from time to time so please re-visit this page as often as you wish. Changes to this Privacy Statement are effective at the time they are posted to our websites.

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

Aptean's websites may contain links to third party websites. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites. When you leave our website we encourage you to read the privacy notice of every website you visit.

2. The data we may collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). In general, the list below refers to data we collect from our customers, prospective customers, prospective employees, partners, vendors and other individuals we interact with.

Depending on whether you are a customer, prospective customer, prospective employee, partner, vendor or other individual we interact with, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:


We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.


Cookies

For each visitor to our websites, our web server may automatically recognize and store information, such as the visitor's IP address/domain name combination; the full Uniform Resource Locators (URL) clickstream to, through and from our websites (including date and time); products you viewed or searched for; page response times; download errors; length of visits to certain pages and page interaction information (such as scrolling, clicks, and mouse-overs).

When you visit our websites, or advertisements appearing on it, or use one or more of our website services, we may use "cookies". A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Our websites use cookies to distinguish you from other users of our websites and contain information to customize your experience, better match your interests and preferences, or to simply facilitate signing in to use our services. We use the following cookies:


Except for essential cookies, all cookies will expire after 10 years.

Most browsers will allow you to erase cookies from your computer hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies, we may be unable to restore previously specified preferences or customization settings and our ability to personalize your online experience may be limited. Please refer to your browser instructions or "help" screen to learn more about these functions.

In addition, you may provide us with information about yourself by filling in forms on our websites or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you use our websites, subscribe to our communications, search for a product, participate in discussion boards or other social media functions on our websites, enter a competition, promotion or survey, report problems on our websites or participate in other authorized activities on the websites. Please do not provide us with personal information that we do not request as we will have no responsibility or liability to you for the consequences of your doing so.

If you fail to provide personal data

The information that is associated with your individual profile enables you to participate in activities, apply for a job or complete a registration using our websites. If you fail to provide that data when requested, we may be unable to complete your registration or application and we may not be able to permit you to participate in the activity that you are interested in.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if we have to take this course of action.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

(i) Direct interactions. You may give us your personal data in person at trade shows or meetings, when you register for user events or in other circumstances, or by filling in forms including job applications or by corresponding with us by post, phone, email or other direct communications. This includes personal data you provide when you:


(ii) Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie section above for further details.

(iii) Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including without limitation those as set out below:


4. How do we use your personal data?

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Domain name information that we collect is not used to personally identify you and instead is aggregated to measure the number of visits, average time spent on the websites, pages viewed and to improve the content of our websites.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

Prospective customers may receive marketing and other communications from us if you have:

Existing customers may receive marketing and other communications from us provided you have not opted out of receiving those communications.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by Contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie section above.

Legal bases for processing

We have set out below a description of some of the legal bases we rely on to process your personal data. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please email: dpo@aptean.com or write to the Data Protection Officer, 7 Rushmills, Northampton, NN4 7YB, UK if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to prospective customers.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please email: dpo@aptean.com or write to the Data Protection Officer, 7 Rushmills, Northampton, NN4 7YB, UK.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Who we disclose your personal data to

We may have to share your personal data with the parties set out below where they are involved in providing services to us. We will only share personal information about you that is reasonably necessary for the other companies to have in order to provide their services to Aptean. These companies are contractually bound to use personal information we share with them only to perform the services we have engaged them to provide:

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International data transfers

Aptean primarily stores the personal data we collect in the United States. To facilitate Aptean’s global operations, staff who work for Aptean and/or our service providers may transfer and access such personal data from locations around the world. This will involve transferring your personal data outside the European Economic Area (EEA).

We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Statement.

Whenever we transfer your personal data out of the EEA, we will ensure one of the following safeguards is implemented:

7. Data Security

We maintain appropriate physical, electronic, and administrative safeguards that are designed to protect your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Employees who misuse personal information are subject to disciplinary action.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our websites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting our DPO at dpo@aptean.com or by writing to The Data Protection Officer, Aptean Limited, 7 Rushmills, Northampton, NN4 7YB, UK.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data: see Request erasure. below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.