(a) sets out how we look after your Personal Data when you visit our Platform (regardless of where you visit it from) and/ or use any of our Services; and
(b) tells you about your rights and how the law in our jurisdiction protects you.
1.4 Capitalised terms used herein shall have the meanings given in our Terms and Conditions which can be found at www.myapril.co.uk . The following defined terms shall have the following meanings:
“Anonymous Data” means data that was originally Personal Data but that has been amended to the extent that it no longer contains any identifying information and thus, no longer constitutesPersonal Data;
“Children” any person under the age of 16;
“Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Dataare, or are to be, processed as outlined in the Data Protection Legislation; and,
“Processor” means any natural or legal person who processes the data on behalf of the Controller.
2. IMPORTANT INFORMATION AND WHO WE ARE
2.2 The Services provided by April are not intended for Children and we do not knowingly collect Personal Data relating to Children.
2.3 April is a data Controller in respect of Personal Data provided by Users and prospective users via the Platform, phone and/or by email.
2.4 It is important that the Personal Data we hold about you is accurate and current. Please tell us if any of your Personal Data changes during the Term.
2.5 The Website may include links to third-party websites, plug-ins and applications. Clicking on any of theselinks or enabling those connections may allow third parties not associated with April to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements or the means in which they process personal data.
3. THE PERSONAL DATA WE COLLECT ABOUT YOU
3.1 We may collect, use, store and transfer different kinds of Personal Data about you, which include but are not limited to, the following categories:
• Contact Data: means your contact information, such as your address; your email address andyour telephone number.
• Call Data: means data derived from calls that are made by you to our HelpLine, including the time, duration and a recording of the phone call.
• Financial Data: means your Payment Details.
• Identity Data: means your full name, the month and year of birth and your hobbies and interests.
• Marketing and Communications Data: means your preferences in receiving marketingcommunications from us.
• Technical Data: may include internet protocol (IP) addresses you may have visited, your login data for April, the type and version of browser you are using, the time zone setting and location from which you are accessing the Platform, browser plug-in types and versions, which operating system and platform are being used and other technology on the Devices you use to access the Platform.
• Transaction Data: means details about any payments made by you to April and the details of Services you have purchased from us.
• Usage Data: includes information about how you use of our Services such as the full uniform resource locations (URL) clickstream to, through and from the Platform (including date and time), pages you viewed or searched for, page response times, download errors, length of visits of certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and the Device used to access theServices.
3.2 We may 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 (which has been collected and processed lawfully) and will always be anonymised so that it does not constitute Personal Data under the Data Protection Legislation. An example of Aggregated Data might be “65% of Users in the NorthEast of England accessed content on the Platform relating to adding a signature to emails.”
3.3 We will not intentionally collect “Special Categories” of Personal Data about you. Special categoriesmean the kinds of data recognised by the Data Protection Legislation as being more sensitive in nature than Personal Data. 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.
3.4 The only circumstance where we may inadvertently collect Special Categories of Personal Data about you is if you disclose such Personal Data on a call to our Helpline. For example: “I struggle to type emails as I have arthritis in my hands.”
3.5 All calls to our HelpLine are recorded and retained for no longer than 90 days. The recording of any call between you and the HelpLine is not allocated to any profile we hold about you and will only be accessed in the event of a complaint or other issue as further set out in our Terms and Conditions.
How is your personal data collected?
3.6 We use different methods to collect Personal Data from and about you including through:
• Direct interactions. You may give us your Identity Data, Financial Data and Contact Data by registering your account or by corresponding with us by post, phone, or email. This includes Personal Data you provide when you:
o register or update your account with us; or
o use our Services, including any content you generate, or information related to yourinteractions with us; or
o request us for marketing material to be sent to you; or
o give us any kind of feedback.
• Automated technologies or interactions. As you interact with our Platform, 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. We may also receive Technical Data about you if you visit other websites employing our cookies.
4. HOW WE USE YOUR PERSONAL DATA
4.1 We will only use your Personal Data when and to the extent permitted by the Data Protection Legislation.Most commonly, we will use your Personal Data in the following circumstances:
(a) To assist you with accessing the Services provided by us.
(b) Where we need to notify you about changes to our Services.
(c) Where we need to contact you about your account and our Services.
(d) 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.
(e) Where we need to comply with a legal or regulatory obligation.
4.2 Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your Personal Data
4.3 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.
4.4 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 Personal 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.
4.5 For the avoidance of doubt, this table is not exhaustive of the ways in which April may use your Personal Data and there may be occasions where we require additional information.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a User||(a) Identity Data(b) Contact Data(c) Financial Data||(a) Performance of a contract with you|
|To provide you with information on Devices which you have indicated are of interest to you, or which we reasonably believe are of interest to you||(a) Identity Data(b) Contact Data(c) Call Data(d) Marketing and Communications Data||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to provide services to clients and/or candidates)|
|To provide specific assistance based on their interactions with us.||(a) Identity Data(b) Contact Data(c) Call Data(d) Usage Data(e) Marketing and Communications Data||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)|
|To administer and protect our business and the Platform(including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity Data(b) Contact Data(c) Technical Data||(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)|
|To use data analytics to improve the Platform, products/services, marketing, customer relationships and experiences||(a) Technical Data(b) Usage Data||(a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Platform updatedand relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about Services that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Marketing and Communications Data||(a) Necessary for our legitimate interests (to develop our Services and grow our business in a way that is compatible with the preferences of those using them)|
Marketing and Promotional offers from us
4.6 We may use your Identity Data, Contact Data, Technical Data, Usage Data and Call Data to form a view on what we think that you may want or need, or what we may be able to provide that would be of interest to you. This is how we decide which offers, services and marketing information may be relevant for you.
4.7 We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. Once you have given consent for us to contact you with this information, you may withdraw any consent given to receive direct marketing communications from us by clicking the opt-out link in any marketing email or by contacting us directly.
4.8 You may receive marketing communications from us if:
(a) you have requested information from us; or
(b) signed up to receive Services from us; or
(c) you provided us with your details when you entered a competition or registered for a promotion,
and, in each case, you consented to us using your Personal Data to contact you and have not yet exercised your right to opt out of receiving that marketing and promotional information.
4.9 You can ask us to stop sending you marketing messages or processing your Personal Data at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
4.10 Cookies are small pieces of text and data sent to your web browser by a website you visit. A cookie filecontains such information as how long was spent on that particular website, the site preferences andhow frequently the website is visited. These cookies are stored in your web browser and analysed by us to ensure that your preferences are stored. We also use the data from the cookies to assess which of the content on our Website appears to be more engaging and attractive to you. The data is then applied by us to try and ensure that any subsequent use of our Platform is both easier and more engaging for you and your preferences are recognised.
4.12 We may use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of thePlatform. If you block these cookies, the Platform will not operate properly.
• Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors navigate around the Platform when they are using it. Thishelps us to improve the way the Platform works, for example, by allowing us to tailor theservices to try and ensure that users are finding what they are looking for easily and their preferences are stored for future reference.
• Functionality cookies. These cookies are used to recognise you when you return to the Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Change of purpose
4.14 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 originalpurpose. 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.
4.15 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.
4.16 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.
5. DISCLOSURES OF YOUR PERSONAL DATA
5.1 We may have to share your Personal Data with third parties, including but not limited to those parties set out below, for the purposes set out in the table in paragraph 4 above.
• External third parties which include processors in the following categories:
o payment providers; or
o analytics providers; or
o the provider of our HelpLine; or
o our hosting provider.
5.3 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 which, for the avoidance of doubt, will be in accordance with the purposes for which the data was collected.
6. INTERNATIONAL TRANSFERS
6.1 Some of our external third parties may be based outside the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer of data outside the EEA.
6.2 Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
(a) Where we use certain service providers, we may use specific contracts approved by the European Commission which give your Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
(b) Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
6.3 Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Data out of the EEA.
7. DATA SECURITY
7.1 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. 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.
8. DATA RETENTION
How long will you use my personal data for?
8.1 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. Once these have been satisfied, the Personal Data will either be deleted or amended to the extent that it would be considered Anonymous Data.
8.2 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.
8.3 In some circumstances you can ask us to delete your Personal Data: see “request erasure” below for further information. In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you and would be considered Anonymous Data) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
9.1 Under certain circumstances, you have rights under the Data Protection Legislation in relation to your Personal Data.
9.2 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.
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 Datawhere 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 the Data Protection Legislation. 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. In addition, this does not provide you with routine access to our systems and processes and only the extraction of your Personal Data.
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.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
9.3 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
9.4 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
9.5 We try to respond to all legitimate requests within one month of the time we receive all of the information required to complete your request. 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 of the progress of your request.
10. QUESTIONS AND CONTACT
10.2 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.
10.3 Our details are:
Full name of legal entity: April Support Limited (company number 11792233)
Postal address: 85 Great Portland Street, London, United Kingdom, W1W 7LT.
10.4 If you wish to contact us regarding your rights, we reserve the right to request copies of your identification or any other information that may be reasonably required to verify your identity.