Aprexo Limited is the data controller in respect to all personal data collected through its website, www.aprexo.com and during the course of its business.

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We are committed to ensuring the privacy of our clients and other website visitors. In this policy we explain how we hold, process and retain your personal data.

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This Privacy Policy aims to give you information on how Aprexo Limited collects and processes your personal data, including any data you may provide through our website. It is important that you read this Privacy Policy together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data so that you are fully aware of how and why we are using personal data.

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1.        How we use your personal data

1.1        This section provides you with information about:

            (a)       What personal data we hold and process;

            (b)       In respect of personal data that we did not collect from you directly, where we obtained that data from,                            and what types of data we have collected;

            (c)       The purposes for which we may process your personal data; and

            (d)       The legal grounds on which we process your data.

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We will not pass on your information to any third party without your explicit consent. 

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1.2       Contact Data / Enquiry Data. We may process contact details that you provide to us (‘Contact Data’). This                   Contact Data may include your name, address, telephone number, and email address. We may use this Contact             Data to communicate with you as required to enable us to perform any contract we have with you.

1.3       For Enquiry data (including any data you supply when completing an enquiry form on our website (‘Enquiry                     Data’) the legal basis for this processing is our legitimate interest in responding to your enquiries and ensuring                 the efficient administration and continued function of our website.

1.4       We may use your Contact Data or Enquiry Data to form a view on which of our products and services 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). 

1.5       If at any time you wish to unsubscribe from receiving future marketing emails, we include detailed unsubscribe                instructions in all marketing communications.

1.6       Correspondence data. We may process information contained in or relating to any communication that you                 send to us (‘Correspondence Data’). The Correspondence Data may include the communication content and                   metadata associated with the communication. The Correspondence Data may be processed for the purposes of             communicating with you and record-keeping. 

1.7       The legal basis for this processing is our legitimate interests, namely the proper administration of our website                   and business and communications with users.

1.8       We do not collect any Special Categories of Personal Data about you (this include details about your race or               ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union                                   membership, information about your health and genetic and biometric data). Nor do we collect any information             about criminal convictions and offences.

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2.        Providing your personal data to others

2.1       Our professional advisers. We may disclose your personal data to our professional advisers insofar as                                reasonably necessary for the purposes of managing risks, obtaining professional advice and managing legal                    disputes.

2.2      Where we provide your personal data to any third party. Where we share your personal data with any third               party, we will ensure this processing is protected by appropriate safeguards including a suitable data                               processing agreement with that third party. 

2.3      To comply with legal obligations. In addition to the specific disclosures of personal data detailed above, we                   may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation               we have to comply with, or in order to protect your vital interests or the vital interests of another individual.

 

3.         Transfers of your personal data outside of the United Kingdom and the European Economic Area 

3.1        We do not transfer your personal data outside the United Kingdom and the European Economic Area (‘EEA’).

 

4.         Retaining and deleting personal data

4.1        Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for                   that purpose or those purposes. 

4.2       Unless we contact you and obtain your consent for us to retain your personal data for a longer period, we will                 retain and delete your personal data as follows:

            (a)       Contact data and Enquiry Data will be retained for 4 years following the date of our last contact or                                   dealing with you, at the end of which period it will be deleted from our systems;

            (b)       Correspondence data will be retained for 4 years following the date of our last contact or dealing with                             you, at the end of which period it will be deleted from our systems.

4.3      We may retain your personal data where such retention is necessary for compliance with a legal obligation to                   we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

5.        Amendments

5.1       We may update this policy from time to time by publishing a new version on our website.

5.2      You should check this page occasionally to ensure you are happy with any changes to this policy.

5.3      We may notify you of changes to this policy by email.

 

6.        Your rights

6.1       You may instruct us to provide you with any personal information we hold about you; provision of such                              information will be subject to: 

            (a)       Your request not being found to be unfounded or excessive, in which case a charge may apply; and

            (b)       The supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy                          of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current                         address).

6.2      We may withhold personal information that you request to the extent permitted by law.

6.3      The rights you have under data protection law are:

            (a)       The right to access;

            (b)       The right to rectification;

            (c)       The right to erasure;

            (d)       The right to restrict processing;

            (e)       The right to object to processing;

            (f)        The right to data portability;

            (g)       The right to complain to a supervisory authority; and

            (h)       The right to withdraw consent.

6.4       Your right to access your data. You have the right to ask us to confirm whether or not we process your                           personal data and to have access to the personal data, and to any additional information. That additional                       information includes the purposes for which we process your data, the categories of personal data we hold and               the recipients of that personal data. You may request a copy of your personal data. The first copy will be                           provided free of charge, but we may charge a reasonable fee for additional copies.

6.5       Your right to rectification. If we hold any inaccurate personal data about you, you have the right to have                      these inaccuracies rectified. Where necessary for the purposes of the processing, you also have the right to                     have any incomplete personal data about you completed.

6.6       Your right to erasure. In certain circumstances you have the right to have personal data that we hold about                   you erased. This will be done without undue delay. These circumstances include the following: it is no longer                     necessary for us to hold the personal data in relation to the purposes for which they were originally collected or               otherwise processed; you withdraw your consent to any processing which requires consent; the processing is for             direct marketing purposes; and the personal data have been unlawfully processed. However, there are certain                 general exclusions to the right to erasure, including where processing is necessary for exercising the right of                     freedom of expression and information, for compliance with a legal obligation, or for establishing, exercising or               defending legal claims.

6.7       Your right to restrict processing. In certain circumstances you have the right for the processing of your                         personal data to be restricted. This is the case if you do not think that the personal data we hold about you is                   accurate, your data is being processed unlawfully but you do not want your data to be erased, it is no longer                   necessary for us to hold your personal data for the purposes of our processing but you still require that personal             data in relation to a legal claim, and if you have objected to processing and are waiting for that objection to be               verified. Where processing has been restricted for one of these reasons we may continue to store your personal               data. However, we will only process it for other reasons, namely with your consent, in relation to a legal claim,                 for the protection of the rights of another natural or legal person, or for reasons of important public interest.

6.8       Your right to object to processing. You can object to us processing your personal data on grounds relating to               your particular situation, but we may assert that the legal basis for the processing is that it is necessary for the               performance of a task carried out in the public interest or in the exercise of any official authority vested in us, or             that the purpose is in the legitimate interests of us or of a third party. If you make an objection, we will stop                       processing your personal information unless we are able to demonstrate compelling legitimate grounds for the                 processing and that these legitimate grounds override your interests, rights and freedoms, or if the processing is             in relation to a legal claim.

6.9       Your right to object to marketing. You may instruct us at any time not to process your personal information for             marketing purposes.

            You can object to us processing your personal data for marketing purposes. If you make an objection, we will                   stop processing your personal data for this purpose.

6.10     Your right to object for statistical purposes. You can object to us processing your personal data for statistical             purposes on grounds relating to your particular situation, unless the processing is necessary for performing a                 task carried out for reasons of public interest.

6.11      Automated data processing. To the extent that the legal basis we are relying on for processing your personal               data is consent, and where the processing is automated, you are entitled to receive your personal data from us               in a structured, commonly used and machine-readable format. However, you may not have this right if it would               adversely affect the rights and freedoms of others.

6.12     Complaining to a supervisory authority. If you think that our processing of your personal data infringes data             protection laws, you can lodge a complaint with a supervisory authority responsible for data protection. You                   may do this in the EU member state of your habitual residence, your place of work or the place of the alleged                   infringement.

6.13     Right to withdraw consent. To the extent that the legal basis we are relying on for processing your personal                   data is consent, you are entitled to withdraw that consent at any time. Withdrawal will not affect the lawfulness             of processing before the withdrawal.

6.14     Exercising your rights. You may exercise any of your rights in relation to your personal data by written notice                 to us in addition to the other methods specified above.

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7.        Cookie Policy

7.1       A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic                      device) when using a website in order to help recognise a user and its device and store some information about a            user’s preferences or past actions.

7.2      Cookies may be either ‘persistent’ cookies or ‘session’ cookies: a persistent cookie will be stored by a web                          browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session            cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

7.3      We use cookies our website to: 

           (a)      Recognise you whenever you visit this website (this speeds up your access to the website as you do not                             have to log in each time);

           (b)      Obtain information about your preferences and use of our website;

           (c)       Carry out research and statistical analysis to help improve our content, and to help us better understand                         our users’ requirements; and

           (d)      Target our marketing and advertising campaigns more effectively by providinginterest-based                                               advertisements that are personalised to your interests; and

           (e)       Make your online experience more efficient and enjoyable.

7.4      We use the following cookies: 

           (a)      Strictly necessary cookies. These are cookies that are required for the operation of our website. They                             include, for example, cookies that enable you to log into secure areas of our website or make use of e-                               billing services. 

           (b)      Analytical / performance cookies. These allow us to recognise and count the number of visitors and to                           see how visitors move around our website when they are using it. This helps us to improve the way our                               website works, for example, by ensuring that users are finding what they are looking for easily. 

           (c)      Functionality cookies. These are used to recognise you when you return to our website. This enables us                          to personalise our content for you, greet you by name and remember your preferences (for example, your                         choice of language or region). 

           (d)      Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links                       you have followed. We will use this information to make our website and the advertising displayed on it                             more relevant to your interests. We may also share this information with third parties for this purpose.

7.5      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. 

7.6      For further information on cookies generally, visit www.aboutcookies.org or www.allaboutcookies.org.

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8.        Registration

8.1       We are registered with the Information Commissioner's Office under registration number ZA453816.

 

9.        Our details

9.1       This website is owned and operated by Aprexo Limited.

9.2      We are registered in England and Wales under registration number 10548365, and our registered office is at Second Floor, 107 Cheapside, London, EC2V 6DN, United Kingdom.

9.3      You can contact us:

           (a)      By post, using the postal address given above;

           (b)      Using our website ‘Contact Us’ button;

           (c)      By telephone, on the contact number published on our website from time to time; or

           (d)      By email, using the email address published on our website from time to time.