Privacy Policy

1. Who We Are

Aptitude Advisors Limited (trading as Aptitude Global) is the data controller responsible for your personal data.

Registered address: 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom

Data Protection Officer: Mr Mark Butterworth

‍Email: mb@aptitudeglobal.com

‍ICO Registration Number: ZB866951

We are registered with the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection.

2. Scope of This Policy

This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website at aptitudeglobal.com or contact us by email.

It applies to all visitors to our website and anyone who contacts us directly.

We are committed to handling your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. Where we serve clients or process the data of individuals located in the European Union, we also comply with the EU General Data Protection Regulation (EU GDPR 2016/679).

3. What Personal Data We Collect

3.1 Data you provide to us directly

When you choose to contact us by clicking the "Contact Us" link on our website, your email client opens a new message pre-addressed to us. If you send that email, we will receive:

• Your name (if included in your email or signature)
• Your email address
• Any other personal information you choose to include in your message

We do not operate contact forms or collect personal data through the website itself.

3.2 Data collected automatically

Our website is hosted by Webflow, Inc. As part of their standard hosting infrastructure, Webflow may place a small number of functional session cookies on your device when you visit the site. These cookies are strictly necessary for the website to operate correctly and do not collect personal data about you, track your browsing behaviour across other sites, or identify you as an individual.

We do not deploy any analytics tools, advertising trackers, or third-party tracking technologies on this website.

4. How We Use Your Personal Data

We use the personal data you provide when contacting us for the following purposes:

• Responding to your enquiry — Legal basis: Legitimate interests (Article 6(1)(f) UK/EU GDPR). It is in both our and your interests to respond to contact you have initiated.
• Taking steps prior to entering a contract for our services — Legal basis: Pre-contractual steps (Article 6(1)(b) UK/EU GDPR).
• Complying with legal obligations — Legal basis: Legal obligation (Article 6(1)(c) UK/EU GDPR).

We do not use your personal data for automated decision-making or profiling.

5. Cookies

Our website uses only the functional session cookies set by Webflow as part of its hosting platform. These are:

• Strictly necessary cookies — required to enable core site functionality
• Session-duration — these expire when you close your browser
• They do not contain personally identifiable information and are not used for marketing or tracking

As these cookies are strictly necessary for the website to function, they do not require your consent under UK PECR (Privacy and Electronic Communications Regulations) or the EU ePrivacy Directive. No consent banner is required.

If you wish to block or delete cookies, you can do so through your browser settings. Please note this may affect certain aspects of website functionality.

6. How We Share Your Data

We do not sell, rent, or trade your personal data with third parties.

Your data may be shared with the following categories of third parties, only where necessary:

Webflow, Inc. — Our website hosting provider. Webflow processes data on our behalf as a data processor. Webflow is based in the United States. Data transfers to Webflow are safeguarded by Standard Contractual Clauses (SCCs) approved by the relevant data protection authorities, providing appropriate protection for your data in accordance with UK GDPR and EU GDPR requirements. For more information, see Webflow's privacy policy at webflow.com/legal/privacy.

Professional advisors — Such as solicitors or accountants, where legally required.

Regulatory or law enforcement authorities — Where we are legally required to disclose information.

7. International Data Transfers

As noted above, our website is hosted by Webflow, Inc., a US-based company. Some data (such as server logs associated with website visits) may be transferred to and processed in the United States. Webflow implements Standard Contractual Clauses to ensure that any such transfers meet the requirements of UK GDPR and EU GDPR.

If you have questions about these safeguards, please contact our Data Protection Officer at mb@aptitudeglobal.com.

8. How Long We Retain Your Data

We retain personal data only for as long as is necessary for the purposes for which it was collected, in accordance with UK GDPR principles.

• Email enquiries (no engagement) — 12 months from the date of your last contact.
• Email enquiries that become client relationships — Duration of the engagement plus 6 years, to comply with legal and contractual limitation periods.
• Website functional cookies — Session only; deleted when you close your browser.

After the applicable retention period, personal data is securely deleted or anonymised.

9. Your Rights

Under UK GDPR and EU GDPR, you have the following rights in relation to your personal data:

Right of access — You may request a copy of the personal data we hold about you.

Right to rectification — You may ask us to correct inaccurate or incomplete personal data.

Right to erasure — You may ask us to delete your personal data where there is no compelling reason for us to continue processing it.

Right to restriction of processing — You may ask us to restrict how we process your data in certain circumstances.

Right to data portability — Where processing is based on your consent or a contract, you may request that we transfer your data to you or a third party in a structured, commonly used, machine-readable format.

Right to object — You may object to processing based on our legitimate interests, including for direct marketing purposes.

Rights related to automated decision-making — We do not use automated decision-making or profiling, but you have the right not to be subject to decisions made solely by automated means where they produce a legal or similarly significant effect.

To exercise any of these rights, please contact our Data Protection Officer:

Email: mb@aptitudeglobal.comPost: Mark Butterworth, Data Protection Officer, Aptitude Advisors Limited, 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ

We will respond to your request within one calendar month. There is no charge for exercising your rights, unless a request is manifestly unfounded or excessive, in which case we may charge a reasonable fee.

We may need to verify your identity before processing your request.

10. The Right to Lodge a Complaint

If you are located in the United Kingdom, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: ico.org.uk

‍Telephone: 0303 123 1113

‍Post: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

If you are located in the European Union, you also have the right to lodge a complaint with the data protection supervisory authority in your country of residence or place of work.

We would, however, appreciate the opportunity to address your concerns before you contact a supervisory authority, so please do contact us in the first instance.

11. Security

We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. Email communications are inherently not fully secure; if you have concerns about the sensitivity of information you wish to share with us, please contact us to discuss a more secure channel.

12. Children's Data

Our website and services are not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data relating to a child, please contact us immediately and we will take steps to delete it.

13. Links to Other Websites

Our website may contain links to third-party websites. This Privacy Policy applies only to aptitudeglobal.com. We are not responsible for the privacy practices of third-party websites and encourage you to review their policies before providing any personal data.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or in applicable law. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically.

15. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer:

Mr Mark Butterworth, Data Protection Officer, Aptitude Advisors Limited (trading as Aptitude Global), 71–75 Shelton Street, Covent Garden, London, WC2H 9JQ

‍Email: mb@aptitudeglobal.com

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