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Privacy Policy

When you use and interact with our websites or services, communicate with or otherwise contact us or visit our premises or attend our events, we may collect, use, share and process information relating to you (“Personal Data”). Our Privacy Policy describes our Personal Data processing practices as Data Controller and your related rights.

In our privacy policy we detail:

  • Our identity and contact details;
  • Our purposes in processing your Personal Data;
  • Categories of Personal Data we typically process;
  • Our legal basis for processing your Personal Data;
  • Who we may send your Personal Data to;
  • The location of your Personal Data on our systems;
  • How long we store your Personal Data for;
  • Your rights regarding our processing of your Personal Data;
  • Our policy on Cookies;
  • Complaints.

Where we refer to “processing”, we mean any operation carried out on Personal Data, including collecting, organising,  storing, adapting, retrieving, using, making available, combining, and erasing.

Our identity and contact details

We are MWS Technology Limited. We are registered with the Information Commissioners Office and our registration number is: Z1900970. Our address is 3 Harmood Grove, London, NW1 8DH and our email address for privacy related matters is dpo@aptem.co.uk. Our telephone number is 020 7870 1000. Our Data Protection Officer is Paz Kaur.

Our purposes in processing your data

We process your Personal Data we under this Policy for one or more of the following purposes:

  • You have made an enquiry or information request to us;
  • You wish to attend, or have attended, one of our events;
  • You have submitted a support request to us;
  • You have applied for a job with us;
  • You are representing your organisation;
  • To process your request to register online or place an order for any of our products or services;
  • Accept job applications;
  • Maintain communication and contact;
  • Permit you to use or view our website;
  • Process your orders and manage your account;
  • Provide you with client support;
  • Promote our various solutions to you;
  • Email you with updates that we believe will be of interest to you;
  • Process your job application;
  • Complying with applicable legal obligations, including government reporting and specific local law requirements;
  • Running day-to-day business relationships;
  • Processing payments, expenses and reimbursements;
  • Business Development Activities;
  • Preventing fraud;
  • Maintaining network security;
  • Internal administration not included above;
  • Our actual or proposed corporate activities, such as sale or merger;
  • Complying with legal requirements, legal processes, and company policies.

Please note that if your Personal Data has been added to the Aptem SaaS platform by one of our clients, that client is the Data Controller and we are the Data Processor in respect of the processing of your Personal Data on that platform. That client’s privacy policy applies and we process your data according to its instructions.

Categories of personal data

We typically collect your name, company name (if relevant), email address and telephone number. If you are submitting a job application we will also receive any additional information that you choose to include in your CV.

With the exception of any data that you may choose to include in a CV, we do not generally process any special categories of personal data.

Our legal basis for processing your data

The legal bases for our processing your Personal Data are as follows, depending on the specific purpose(s) of the processing:‎

  • performance of a contract – in some cases we need to process Personal Data to perform a contract with you or your employer or to ‎take steps at your request before entering into a contract;
  • consent – in certain cases, we may process Personal Data with your specific, freely given consent: if so, we will inform you at the time of the purpose of the processing and your right to withdraw consent at any time;
  • legal obligation – where the purpose indicated above is that the processing is needed to comply with a relevant legal ‎obligation, that is also the legal basis of processing;
  • in very rare cases, we may need to process your Personal Data to protect the vital interests of the data subject or ‎of another person;
  • legitimate interest – in all other cases, the purposes described above represent our legitimate business interests and the ‎processing is a reasonable and proportionate way of achieving them and does not override your interests, fundamental rights or freedoms.
To whom do we provide your Personal Data

We provide your Personal Data to third parties who provide services to us, for example Zendesk for customer support. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct. 

The location of your data

Your data is stored on cloud based servers in secure data centres and will not be transferred outside the area comprising the UK and the EEA.

How long we store your Personal Data for

The period for which we store your Personal Data depends on the circumstances.  Typically the periods are as follows:

  • where we have a contract with you (or your employer) for six years after the end of the contract, unless there is any outstanding claim or complaint at the end of that period, in which case we will keep it for one year from final resolution;
  • three years from our last active communication from you;
  • for unsuccessful job applicants two years from the end of the application process.
Your rights

Under data protection law you have the following rights you should be aware of.

Your right of access

You have the right to ask us for copies of your Personal Data which we are processing.. You can read more about this right here.

Your right to rectification

You have the right to ask us to correct Personal Data you think is inaccurate. You also have the right to ask us to complete Personal Data you think is incomplete. You can read more about this right here.

Your right to erasure

You have the right to ask us to erase your Personal Data in certain circumstances. You can read more about this right here.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your Personal Data in certain circumstances. You can read more about this right here.

Your right to object to processing

You have the right to object to processing  in certain circumstances. You can read more about this right here.

Your right to data portability

In some cases you have the right to ask that we transfer your Personal Data to another organisation, or give it to you. You can read more about this right here.

Automated decision making or profiling

We do not use automated decision making or profiling.

Cookies

We use the following website cookies to understand how you use our website and improve your experience on our website.

Cookie Function
Google Analytics Web tracking for collecting information about how visitors use and behave on our site.
Hotjar Web tracking to understand how visitors are using our site.
LinkedIn Analytics To track interactions between our LinkedIn page and our website.
Intercom Live chat help system to answer customer questions.
Vimeo Video display software capturing views of video content.

You can find out more about cookies and how to manage them at: https://www.aboutcookies.org.uk/

Complaints

All complaints, comments, queries and requests relating to our use of your Personal Data are welcomed and should be addressed to:

Data Protection Officer, MWS Technology Ltd, 3 Harmood Grove, London, NW1 8DH

Or emailed to dpo@aptem.co.uk.

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the Information Commissioner’s Office. Information on doing this is at: https://ico.org.uk/make-a-complaint/

Policy updated May 2021