Introduction

Welcome to the Aptitude Advisors Limited’s privacy policy.

Aptitude Advisors Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website(regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WEARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATACOLLECTED?

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONALDATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

11. COOKIES POLICY

1 .Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Aptitude Advisors Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you apply for a job application or sign up to our newsletter.

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 policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to over rid them.

Controller

Aptitude Advisors Limited is made up of different legal entities, details of which can be found here. This privacy policy is issued on behalf of the Aptitude Advisors Limited Group so when we mention Aptitude Advisors Limited , "we", "us" or" our" in this privacy policy, we are referring to the relevant company in the Aptitude Advisors Limited Group responsible for processing your data. Aptitude Advisors Limited is the controller and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our privacy manager at privacy@aptitudeglobal.com

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on [19 Mar 2021]. Historic versions can be obtained by contacting us.

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

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. Itdoes not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address,delivery address, email address and telephone numbers.
• Technical Data includes     internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your nterests, preferences, feedback and survey responses.  
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data succahs statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

We do not collect any Special Categories of Personal Data about you (this includes 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.

If you fail to provide personal data

Where we need to collect personal data by law, or under thet arms 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 tenter 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 wewill notify you if this is the case at the time.

3. How is your personal data collected?

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

• Direct interactions. You may give us your Identity or Contact Data by filling in forms or by corresponding with us on this website. This includes personal data you provide when you:

• apply for a role with Aptitude Advisors Limited;
• subscribe to our service, events or publications;
• request marketing to be sent to you;
• contact us in relation to a business, media, supplier or career enquiry;
• send us information about a request for a proposal;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will 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  for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties (such asanalytics providers, advertising networks, and search information providers).  

4. How we use your personal data

We will only use your personal data when the law allows usto. Most commonly, we will use your personal data in the followingcircumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.
• To match your details with job vacancies at Aptitude Advisors Limited, and to engage with you in relation to the recruitment process.

In the table below, we have described the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis forprocessing your personal data although we will get your consent before sendingthird party direct marketing communications to you via email or text message.You have the right to withdraw consent to marketing at any time by contactingus.

Purposes for which we will use yourpersonal data

We have set out below, in a table format, a description ofall the ways we plan to use your personal data, and which of the legal bases werely on to do so. We have also identified what our legitimate interests arewhere appropriate.

Note that we may process your personal data for more than one lawful grounded pending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relyingon to process your personal data where more than one ground has been set out inthe table below.

Marketing

We strive to provide you with choices regarding certainpersonal data uses, particularly around marketing and advertising. If you nolonger want to receive marketing communications from us, you can click theunsubscribe link in any email you receive from us or you can contact us at privacy@aptitudeglobal.com.

Promotional offers from us

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

You will receive marketing communications from us if you:

• have requested information from us
• purchased services from us
• provided us with your contact details when we met at an event, conference or meeting

and, in each case. you have not opted out of receivingmarketing communications from us.

Third-party marketing

We will get your express opt-in consent before we shareyour personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending youmarketing messages at any time following the opt-out links on any marketingmessage sent to you OR byus at any time.

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 orrefuse cookies, please note that some parts of this website may becomeinaccessible or not function properly. For more information about the cookieswe use, please see here.

Change of purpose

We will only use your personal data for the purposes forwhich we collected it, unless we reasonably consider that we need to use it foranother reason and that reason is compatible with the original purpose. If youwish to get an explanation as to how the processing for the new purpose iscompatible with the original purpose, please contact us.

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

Please note that we may process your personal data withoutyour knowledge or consent, in compliance with the above rules, where this isrequired or permitted by law.

5. Disclosures of your personal data

We may share your personal data with the parties set outbelow for the purposes set out in the table Purposes for which we will useyour personal data above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties listed in the table Purposes for which we will use your personal data above.
• Third     parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security ofyour personal data and to treat it in accordance with the law. We do not allowour third-party service providers to use your personal data for their ownpurposes and only permit them to process your personal data for specifiedpurposes and in accordance with our instructions.

6. International transfers

We share your personal data within the Aptitude AdvisorsLimited Group. This will involve transferring your data outside the UK.

We ensure your personal data is protected by requiring allour group companies to follow the same rules when processing your personaldata. These rules are called "binding corporate rules". For furtherdetails, see the EuropeanCommission on BCR.  

Many of our external third parties are based outside the UKso their processing of your personal data will involve a transfer of dataoutside the UK.

Whenever we transfer your personal data out of the UK, we ensurea similar degree of protection is afforded to it by ensuring at least one ofthe following safeguards is implemented:

• We will only     transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data. For further details, see the European Commission Standard Conditional Clauses (SCC).
• Where we use     certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. For further details, see the European Commission Standard Conditional Clauses (SCC).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security

We have put in place appropriate security measures to preventyour personal data from being accidentally lost, used or accessed in anunauthorised way, altered or disclosed. In addition, we limit access to yourpersonal data to those employees, agents, contractors and other third partieswho have a business need to know. They will only process your personal data onour instructions and they are subject to a duty of confidentiality.

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

8. Data retention

How long will you use my personal datafor?

We will only retain your personal data for as long asreasonably necessary to fulfil the purposes we collected it for, including forthe purposes of satisfying any legal, regulatory, tax, accounting or reportingrequirements. We may retain your personal data for a longer period in the eventof a complaint or if we reasonably believe there is a prospect of litigation inrespect to our relationship with you.

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

Details of retention periods for different aspects of yourpersonal data are [available in our retention policy which you can request fromus by contacting us

OR

By law we have to keep basic information about ourcustomers (including Contact, Identity, Financial and Transaction Data) for sixyears after they cease being customers for tax purposes.

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

In some circumstances we will anonymise your personal data(so that it can no longer be associated with you) for research or statisticalpurposes, in which case we may use this information indefinitely withoutfurther notice to you.

9. Your legal rights

Under certain circumstances, you have rights under dataprotection laws in relation to your personal data.

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data(or to exercise any of the other rights). However, we may charge a reasonablefee if your request is clearly unfounded, repetitive or excessive.Alternatively, we could refuse to comply with your request in thesecircumstances.

What we may need from you

We may need to request specific information from you tohelp us confirm your identity and ensure your right to access your personaldata (or to exercise any of your other rights). This is a security measure toensure that personal data is not disclosed to any person who has no right toreceive it. We may also contact you to ask you for further information in relationto your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within onemonth. Occasionally it could take us longer than a month if your request isparticularly complex or you have made a number of requests. In this case, wewill notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means theinterest of our business in conducting and managing our business to enable usto give you the best service/product and the best and most secure experience.We make sure we consider and balance any potential impact on you (both positiveand negative) and your rights before we process your personal data for ourlegitimate interests. We do not use your personal data for activities where ourinterests are overridden by the impact on you (unless we have your consent orare otherwise required or permitted to by law). You can obtain furtherinformation about how we assess our legitimate interests against any potentialimpact on you in respect of specific activities by contacting us.

Performance of Contract means processingyour data where it is necessary for the performance of a contract to which youare a party or to take steps at your request before entering into such acontract.

Comply with a legal obligation means processingyour personal data where it is necessary for compliance with a legal obligationthat we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Aptitude Advisors Limited Group andwho are based in Spain, India, and USA and provide IT and system administrationservices and undertake leadership reporting.

External Third Parties

• Service providers acting as processors based in the United Kingdom and outside the United Kingdom who provide IT and system administration services.
• Professional     advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom and outside of the United Kingdom who provide consultancy, banking, legal, insurance and accounting     services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personaldata (commonly known as a "data subject access request"). Thisenables you to receive a copy of the personal data we hold about you and tocheck that we are lawfully processing it.

Request correction of the personaldata that we hold about you. This enables you to have any incomplete orinaccurate data we hold about you corrected, though we may need to verify theaccuracy of the new data you provide to us.

Request erasure of your personaldata. This enables you to ask us to delete or remove personal data where thereis no good reason for us continuing to process it. You also have the right toask us to delete or remove your personal data where you have successfullyexercised your right to object to processing (see below), where we may haveprocessed your information unlawfully or where we are required to erase yourpersonal data to comply with local law. Note, however, that we may not alwaysbe able to comply with your request of erasure for specific legal reasons whichwill be notified to you, if applicable, at the time of your request.

Object to processing of your personaldata where we are relying on a legitimate interest (or those of a third party)and there is something about your particular situation which makes you want toobject to processing on this ground as you feel it impacts on your fundamentalrights and freedoms. You also have the right to object where we are processingyour personal data for direct marketing purposes. In some cases, we maydemonstrate that we have compelling legitimate grounds to process yourinformation which override your rights and freedoms.

Request restriction of processing of your personaldata. This enables you to ask us to suspend the processing of your personaldata in the following scenarios:

• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personaldata to you or to a third party. We will provide to you, or a third party youhave chosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automatedinformation which you initially provided consent for us to use or where we usedthe information to perform a contract with you.

Withdrawconsent at any time wherewe are relying on consent to process your personal data. However, this will notaffect the lawfulness of any processing carried out before you withdraw yourconsent. If you withdraw your consent, we may not be able to provide certainproducts or services to you. We will advise you if this is the case at the timeyou withdraw your consent.

11. Cookie Policy

Please contact us if you want more information about the cookies we use.

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