Online Privacy is a constantly evolving landscape and Apt plans to take all reasonable efforts to maintain up-to-date and effective online privacy standards and practices. We have linked every page of our website to this page for your convenience and you may also contact us at firstname.lastname@example.org with any questions or concerns that you may have.
This website is owned and controlled by Apt Energy Limited, located at 27 Camborne Road, London SW18 4BH. By accessing this website, you acknowledge the terms and conditions set forth herein. We reserve the right to change these policies from time to time, without notice, and at our sole discretion.
Who we are
We are Apt Energy Limited, a company registered in England and Wales with company registration number 10738647. Our registered office is at: 27 Camborne Road, London SW18 4BH, United Kingdom. Please see our ”Contact Us” section for more information.
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this policy. If you have any questions about this policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager, Philip Yoxall on Philip.Yoxall@AptEnergySolutions.com.
Further guidance on your rights is available from your local data protection regulator. If you would like the contact details of your local data protection regulator, please let us know. We would appreciate the chance to deal with your concerns before you approach the local data protection regulator so please contact us in the first instance.
This privacy notice does not override any applicable national data privacy laws and regulations in countries where Apt operates.
What information do we collect from you?
Apt collects information from our users at several different points on our website. In general, you can visit the Apt website without telling us who you are or revealing any personal data or personal information about yourself. We track visiting domains, internet addresses of the domains from which people visit us to track a user’s session and the user’s browser also lets us know the type of computer and operating system being used. This allows us to analyse the information as to which parts of our site users spend their time and their length of stay but does not give us any personal data about the user. Specifically, a user’s session will be tracked, but the user will be anonymous.
Sometimes however, we will ask you to voluntarily provide information about yourself which may include:
- identity data, being your first name, last name, username or similar identifier, title and date of birth;
- contact data, being billing address, delivery address, email address and telephone number;
- recruitment data, which may include special category personal data as identified in the EU General Data Protection Legislation including nationality for the purpose of right to work checks and for meaningful equal opportunity monitoring and reporting, including disability status, information about your race or national or ethnic original, religious, philosophical or moral beliefs, or your sexual life or sexual orientation;
- technical data, being internet protocol (IP) address, your log in data, time zone setting and location, operating system and platform and other technology on the devices you use to access this website; and
- marketing and communications data, being your preferences in receiving marketing from us and your communication preferences.
Occasionally, we may use this information when we notify you about important changes to the website.
You make the decision whether to proceed with any activity that requests personal information. If we need to collect such personal data by law, or under the terms of a contract we have with you, and you do not wish to provide the requested information, you may not be able to complete the applicable transaction and we may have to cancel a product or service you have with us.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, 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.
How Apt collects and will use information collected
Generally this information is requested when you are asked for one or more of the following: 1) to register before downloading software; 2) registering for attendance to an online seminar, demo or a seminar or tradeshow; 3) filling out a sales information request or contact form; 4), viewing a recorded event; 5) becoming a registered user; 6) signing up for a mailing list; 7) during correspondence with us; 8) completing a survey that we use for research, and 9) any other such activities as we deem necessary.
We will only use your personal data when the law allows us to.
When we cure such information about your session or about you, we may use it for:
- where we need to perform the contract we are about to enter into or have entered into 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, such as research for developing our products, growing our business for marketing and improving our website and the services we offer you; or
- where we need to comply with a legal or regulatory obligation.
The media in which we may contact you are including but not limited to e-mail, telephone, or postal mail (for example, to send you information or special offers, or for other marketing purposes). You have the right to unsubscribe from our marketing communications at any time by contacting us or unsubscribing Opt Out or, in the case of email marketing communications, in the link provided in the email communication we send.
We may use third party sub-processors to store your Personal Data. We ensure that any such third party sub-processors are subject to an agreement which sets out the sub-processor’s appropriate obligations in respect of data protection legislation and such third party sub-processors can only process your Personal Data on our instructions. Currently, Apt engage HubSpot (https://www.hubspot.com/), and Azure (https://www.azure.com) as third party sub-processors and reserves to right to engage further sub-processors as appropriate.
Additionally, we will use information to assist us in creating content that is relevant to you, to assist us in creating better products and services to meet your needs, to provide you with access to services or otherwise engage in activities you select, and to help you quickly find software, services, or product information important to you.
We may, from time to time, make announcements containing aggregate information about our users, such as industries or geographic region. We will never include personal data of our users in these announcements.
Cookies and Other Tracking Technologies
Some of our Web pages utilise “cookies” which are small text files placed on your computer’s hard drive that are read by the server that placed them, are unable to execute any code or virus and cannot take any additional information from your hard drive. These cookies allow the Apt website to recognise you when you revisit the site, and are able to remember certain information about you, such as your preferences in the site and the type of content you find of interest so that we can better serve you with more tailored information when you return to our site.
You can set your browser to notify you when you are sent a cookie, giving you the chance to decide whether or not to accept it.
Links to other Websites and Third Parties
This website and Apt’s marketing communications may contain links to third-party websites, plug-ins and applications. We have not reviewed and will not review these websites. We do not control such third-party websites, do not endorse any external sites and are not responsible or liable for any content, advertising, products, or other materials that may appear or may be available on, from or through any such third-party website. When you leave our website or click on a link to a third-party website from our website, you should read the privacy statements of each and every website that collects your personal data.
With whom this information is shared
If you share your personal data on our website, you are sharing that personal data only with the Apt Group unless specified otherwise. If you disclose personal data to one member in the Apt Group, this may be shared by members within the Apt Group. We may offer a service or promotion in conjunction with business partners, for example, a joint seminar or a product integration solution. In cases such as these, information collected may be shared by both companies and we will notify you of this prior to you sharing your personal data with us.
We may partner with another party to provide specific services. When the user signs up for these services, we will share your personal data, being first and last names, or other contact and billing information that is necessary for the third party to provide these services. These parties are not allowed to use your personal data except for the purpose of providing these services.
Apt may disclose your personal data when legally required to do so or when we believe, in good faith, that the law requires such a disclosure. For example, we will share such information if we have reason to believe that the information is necessary to identify, contact or bring legal action against someone who may be either causing injury to or interference with our rights or property, or our customers or affiliates.
What is Apt’s policy on allowing you to update, correct, or delete your personally identifiable information?
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include:
- Request access to your personal data. This is commonly known as a “data subject access request” and it 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: (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.
If you wish to exercise any of the rights set out above, please contact us.
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.
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.
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.
What security precautions are in place to protect the loss, misuse, or alteration of your information?
To protect the privacy of any personal data you may have provided, Apt employs appropriate industry-standard controls including physical access controls, Internet firewalls, intrusion detection, and network monitoring. Additionally, only authorised administrators and staff have access to systems containing such personal data and they are subject to a duty of confidentiality. Backup data are securely stored and not shared with third parties.
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.
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.
In some circumstances, you can ask us to delete your data as specified above.
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.