Introduction Welcome to the APS Group Limited's privacy notice (this “Privacy Policy”). In this Privacy Policy, we refer to APS Group Limited as “we”, “us” or “our”. We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit the Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. Important information and who we are 1. Purpose of this Privacy Policy This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Website, including any data you may provide through the Website when you contact us. The 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 notice or fair processing notice 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 the other notices and is not intended to override them. Controller We are part of a group made up of different legal entities, details of which can be found here (the “APS Group”). This Privacy Policy is issued on behalf of the “APS Group” so when we mention "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the APS Group responsible for processing your data. APS Group Limited is the controller and responsible for the 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, including any requests to exercise your legal rights as set out in paragraph 10 below, please contact the [data privacy manager] using the details set out below. Contact details Our full details are: Full name of legal entity: APS Group Limited Name or title of [data privacy manager]: John Phibbs Email address: J.phibbs@apsgroup.uk.com Postal address: Enterprise House 97 Alderley Edge Wilmslow Cheshire SK9 1PT You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority 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 this Privacy Policy and your duty to inform us of changes This version was last updated on 29/05/2018. 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. 2. Third-party links The 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 the Website, we encourage you to read the privacy notice of every website you visit. The data we 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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows: Identity Data includes [first name and last name]. Contact Data includes [address, email address and telephone numbers]. Technical Data includes [internet protocol (IP) address, 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 the Website]. Usage Data includes [information about how you use the Website]. 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 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 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 3. If you fail to provide personal data 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 this is the case at the time. 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 and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: contact us through the Website request marketing to be sent to you give us some feedback Automated technologies or interactions. As you interact with the Website, 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. Please see paragraph 4 below for further details. 4. Cookies The Website use cookies. Cookies are tiny text files which identify an Individual’s computer or device to our server as a unique user when they visit certain pages on the Website and they are stored by their Internet browser on their computer or device's hard drive. Cookies can be used to recognise an Individual’s Internet Protocol address, saving them time while they are on the Website. We only use cookies for an Individual’s convenience in using the Website and not for obtaining or using any other information about the Individual (for example targeted advertising). The Individual’s browser can be set to not accept cookies, but this would restrict their use of the Website. If you want to find out more information about cookies, go to http://www.allaboutcookies.org or to find out about removing them from your browser, go to http://www.allaboutcookies.org/manage-cookies/index.html. Please note that we collect data from the Website about use of the Website using a web analysis tool which uses cookies that are (able to be) used to generate pseudonyms for a user’s profile. This means that cookies (which may be stored on an Individual’s computer or Device) can store information about their visit. Our website has been built using Squarespace. Please view Squarespace's cookie policy for more information https://www.squarespace.com/cookie-policy/ 5. How 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: Where we need to perform the contract, we are about to enter or have entered 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 or regulatory obligation. See paragraph 11 below to find out more about 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 for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal data We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. 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 contact us 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 in the table below. Purpose / Activity Type of data Lawful basis for processing including basis of legitimate interest To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Responding to enquiries or other communications that you make with us (a) Identity (b) Contact (c) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how users access the Website) To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation To deliver relevant Website content to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Usage (e) Marketing and Communications (f) Technical Necessary for our legitimate interests (to study how users access the Website, to grow our business and to inform our marketing strategy) To use data analytics to improve the Website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage Necessary for our legitimate interests (to develop our products/services and grow our business) 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 and Usage 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). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing. Third-party marketing We will get your express opt-in consent before we share your personal data with any company outside the APS Group of companies for marketing purposes. Opting out You can ask us or third parties to stop sending you marketing messages at any time 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, product/service experience or other transactions. 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 contact us. 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. 6. Disclosures of your personal data 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. We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above. Internal Third Parties as set out in paragraph 11 below. External Third Parties as set out in paragraph 11 below. 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. 7. International transfers 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. 8. Data Security [We do not transfer your personal data outside the European Economic Area (“EEA”).] We have put in place appropriate security measures to prevent your personal data 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. 9. Data retention 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. How long will you use my personal data for? 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 us. In some circumstances you can ask us to delete your data: see paragraph 10 below for further information. 10. Your legal rights 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. Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see paragraph 11 below to find out more about these rights: 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 reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond 11. Glossary We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Lawful Basis Legitimate Interest means the interest of our business in conducting and managing our business to enable us to 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 positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES Internal Third Parties Other companies in the APS Group acting as joint controllers or processors and who are based in the UK. External Third Parties Service providers, acting as processors, based in 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 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 personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. Object to processing of your personal data 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 to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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 personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Get in touch Whether you are a talented individual looking for your next career move or interested in working with us as a supplier or customer here's how to get in touch. © 2016 A Pearson Holdings Ltd All Rights Reserved Privacy and cookies policy Terms of use Design by Bate Brand