Aptimore Limited (“We”, “our” or “Aptimore”) manages data as required by the General Data Protections Regulations (GDPR). We are committed to protecting and respecting your personal information.
This policy (together with our User Terms and Terms of Supply and any other documents referred to in these) sets out the basis on which we will process any personal data we collect about you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting and continuing to use this site, you are accepting and consenting to the practices described in this policy.
Capitalised terms are defined in the User Terms (terms and conditions for individual users) or the Terms of Supply (terms and conditions for corporate account holders who fund, facilitate and/or administer the accounts of one or more Account Users).
This site [www.aptimore.com] (the “Site”) is controlled by Aptimore Limited, a company registered in England with company number 08581507 and whose registered office is located at 3rd Floor, 86-90 Paul Street, London EC2A 4NE. For the purposes of the Data Protection Act 1998, Aptimore Limited is the data controller, registered with the Information Commissioner’s Office under number ZA102369.
Information we may collect from you
We may collect and process the following information about you:
- Information you give us. You may give us information about yourself by filling in forms or answering surveys or questions or sending messages to us on our Site, or by corresponding with us by e-mail, phone or otherwise. This includes information you provide when you register to use our Site, create a user profile, subscribe to our service, search for, request, order or complete training, request further services, and when you report a problem with our Site. The information you give us may include your name; address; place of employment; e-mail address and phone number; profiling information; details of your experience, aptitudes, skills and preferences; financial and credit card information; personal description, and such other information as you may give us from time to time.
- Information we collect about you that is automatically logged: each time you visit our Site we may collect (automatically or otherwise) the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
- information about you which we have derived and/or calculated based on the information with which you have provided us.
- Information from Social Media. Information from your interactions with us on social media and other online platforms and your social media profile where you share this.
- Apti-analytics – a single session cookie to track authentication and enable access to members only pages; and
- Google Analytics – two persistent cookies to identify unique users and throttle request rates.
We will use this information to:
- provide you with the Services and the Materials, personalise our Site’s content to you; maintain records of your training history and development and feedback; make recommendations for further services and to provide you with any other services that you request from us;
- provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
- provide you with information about services, courses and opportunities we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about services similar to those which you have already accessed through the Site or have expressed an interest in.
- notify you about changes to our Services;
- ensure that content from our Site is presented in the most effective manner for you and for your computer.
- administer our Site and Services, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- allow you to participate in interactive features of our Services, when you choose to do so;
- help keep our Site safe and secure;
- in our interactions with you on social media sites where you choose to engage with us; and
- to create aggregate data which does not identify you to develop and improve our Site and the Services.
Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 and with our service providers.
We may share your information:
- If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our User Terms and Terms of Supply and other agreements; or to protect the rights, property, or safety of Aptimore, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
- in the event that we sell or buy any business or assets, in which case we may disclose personal data to the prospective seller or buyer of such business or assets;
- in the event that Aptimore Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Many of our users have access to our services provided or funded by their employer or place of work. We will never disclose the results or outcomes of your Program to any third party. After you have completed your Program, Aptimore may offer you additional follow-on services (including online activities or training units). At times, you may wish to share results or outcomes of those follow-on activities, training units or other services with specific third parties (such as your employer or a prospective employer). However, we will never disclose the results or outcomes of any such activities or training undertaken with us unless requested in writing to do so by you, or with your explicit consent.
If your Aptimore membership is funded by a third party, that third party may have access to the following information:
- when you have been sent your log-in details;
- when you have registered with us;
- when you have begun and completed your individual questionnaire (but not any of your answers to the questionnaire, or any of our recommendations or feedback based on your answers);
- when you have begun and completed each of the training units (either those units contained within the Program or any follow-on units that you choose to share), and
- when you have completed your development report at the end of the program (but not the content of your development report).
If you have been registered with Aptimore as part of a corporate group of 3 or more persons (a “Group”), the following feedback may be made available to your Account Manager in aggregated form: (1) a summary of areas where the Group would be interested in learning more and (2) a summary of how much new insight the Group felt they gained within the Aptimore program on a presented list of topics or similar summary information. These summaries will not show responses made by individual users.
In addition, your Account Manager may choose to create a leaderboard to allow the people in your Group to compare progress. The leaderboard may show summary information such as the number of training units you have begun or completed, but will not show any of your individual responses.
Where we store your personal data
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.
Where we have given you (or where you have chosen) a password which enables you to access certain features or parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Whilst we operate security measures in line with industry standards, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; 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 unauthorised access.
We hope that you will find Aptimore useful at different times throughout your career. For this reason, unless you contact us with alternative instructions, we will retain your account information after your membership expires for a period of five (5) years, as our experience shows there may be a time in the future when you would like to access your account again. Please let us know if you would like us to:
- delete any of your personal identifying information associated with your account;
- dissociate your User Membership from the account of your Account Manager; or
- associate your User Membership with a new Account Manager (for example, if you have moved employers).
You can contact us to ask what data we hold and also to have your data removed in line with the General Data Protection Regulations (GDPR).
You have the right to ask us not to process your personal data for marketing purposes. We will inform you before we collect your data if we intend to use your data for such purposes. You can exercise your right to prevent such processing by checking (or un-checking) certain boxes on the forms we use to collect your data, by clicking the ‘unsubscribe’ button on any email you receive from us, or by contacting us at firstname.lastname@example.org.
Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
Access to information
The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a small fee to meet our costs in providing you with details of the information we hold about you.
Children under 12 years of age
This Site is not intended to be used by children under 13 years of age and children will not be given a profile or password by us. Any information obtained about children under 12 years of age shall be deleted.
Last updated: 8th April 2020