APT Initiatives Ltd Privacy Notice
APT Initiatives Ltd is committed to protecting and respecting the privacy of individuals’ personal data and ensuring the accuracy of any personal data held. ‘Personal data’ is any information relating to an identified or identifiable person, which is not already in the public domain. An identifiable person is one who can be directly identified or indirectly identified by reference to an identifier, eg a number which is personal to them (such as a National Insurance number).
This privacy notice explains who we are and how we can be contacted, our lawful bases for processing personal data, the type of personal data we hold, how we obtain personal data, who has access to the personal data we hold, where and how our data is stored, our data retention periods, and the rights of individuals regarding the personal data we hold.
Any questions regarding this privacy notice should be sent in writing - by email, fax or post. Our contact details are provided below.
Who we are and how we can be contacted
APT Initiatives Ltd provides educational resources, seminars and courses relating to Business and Economics. Our contact details are:
Millstone Lodge, Eaton Upon Tern, Market Drayton, TF9 2BX
Telephone: 01952 540877
Fax: 01952 541230
Our legal bases for processing personal data
Contract: to fulfil contracts to provide our products and services; or provide information (eg quotes for seminars) before entering into a contract to provide our products and services.
Legal obligation: to comply with legal obligations to file accounting and payroll information with HMRC and Companies House (eg VAT returns, annual accounts, tax returns and employee salary details).
Legitimate interest: to inform our target markets ie teachers, tutors and students of business and economics, about our products and services; to provide sample material to individuals who have requested sample material; to provide updates on products and services purchased and / or sample material received; to obtain feedback on existing products and services; to obtain suggestions for other products and services. Note: When notifying or updating our target audiences about our products and services recipients will always have a choice whether to read or opt-out of such updates - by clicking on the unsubscribe button at the end of any electronic communication, or writing to us directly - by email, fax or post.
Consent: to use feedback received in the marketing of our products and services, having first obtained consent to use the individual’s name in connection with this feedback. This consent can be withdrawn at any time by writing to us directly - by email, fax or post.
What personal data we hold
The personal data we hold might include an individual’s name, position held (where relevant), postal address and / or email address and telephone number, as well as the subjects they teach / are studying or are interested in, payment history, any comments made about our products and services, and / or suggestions for new ones.
How we obtain personal data
The personal data we obtain may come direct from the data subject (via our website, email, social media, phone, fax), or from a third party, such as educational marketing companies and social media sites.
Further details on the data we collect and how we use it
Visiting our website: When you visit www.apt-initiatives.com we will use a third party service, Google Analytics, to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone. Our agreement with Google does not permit them to make any attempt to find out the identities of those visiting our website.
Registering interest in our products / services: If you register your interest in our products / services via our website, or by other means (eg email, social media, phone, fax or post) we may use the contact details you provide us with (eg your name or school / college name, school / college or home address, telephone number and email) to inform you about our products and services in the future. You can unsubscribe to mailings at any time - by clicking the unsubscribe link at the bottom of any of our emails or by contacting us directly.
Requesting and receiving sample material: Prior to receiving sample material via our website (or by email or post) we ask for your contact details ie your name, school / college name (where applicable) and address (email or postal). We will use this information to send you relevant updates to our sample material and to notify you of any other products / services in which you might be interested. You can unsubscribe to mailings at any time - by clicking the unsubscribe link at the bottom of any of our emails or by contacting us directly.
Ordering, paying for and receiving products / services: When you order any of our products or services via our website (or by other means) we ask for your name, address, email and phone number. This is provided in order to: despatch your order to you; send you any updates regarding your order; send out receipts or invoices as applicable; notify you of other products / services you may be interested in the future. As stated above - You can unsubscribe to mailings at any time by clicking the unsubscribe link at the bottom of any of our emails or by contacting us directly. If you purchase a product or service from us, your payment details are collected by third party payment processors, who specialise in the secure online capture and processing of credit / debit card transactions. We do not collect of store any card payment information.
Giving feedback: If you contact us to give us feedback (eg via our website, email, phone or fax) we may use this feedback to help promote our products and services. We will only use your name in connection with this feedback where you have given permission for us to do so.
Completing surveys / questionnaires: When you complete surveys / questionnaires we may ask you for your contact details to clarify any responses and to notify you of any products / services which may be of interest to you.
Recipients of personal data - Who has access to your personal data
We will not share your personal data with any other organisation for marketing, market research or commercial purposes, other than in connection with publicising feedback received on our products and services, having first obtained consent to use your name in connection with this feedback.
When individuals use our secure online payment facilities, payments are processed by a third party payment processor, who specialises in the secure online capture and processing of credit / debit card transactions.
The transmission of information via the Internet is not within our control and not completely secure and, therefore, we can’t guarantee the security of your data while it is in transit. Once we have your data we have procedures and security features in place to prevent unauthorised access and to keep your data secure.
Where and how your data is stored
The data we hold is stored at our secure premises in the UK. A backup copy is stored on US based servers by companies complying with the EU-US Privacy Shield Framework.
Data retention periods
We are legally required to hold some types of personal data to fulfil our statutory obligations, such as that relating to accounting and finance. Sales records and customer correspondence, and staff payroll and salary records are held for a period 6 years.
Whilst APT Initiatives Ltd is in possession of or processing your personal data, under the General Data Protection Regulations (GDPR), which came into force on 25 May 2018, individuals (data subjects) have the following rights regarding their personal data:
the right to be informed about the personal data we hold - through this privacy notice.
the right of access - you have the right to request a copy of the information we hold about you. Requests can be emailed to our Data Protection Officer: firstname.lastname@example.org. In the event that APT Initiatives Ltd refuses your request under rights of access, we will provide you with a valid reason as to why, which you have the right to legally challenge.
the right to rectification - you have the right to have the personal data we hold about your rectified if it is inaccurate or incomplete. In order to maintain the accuracy of data held, if you change your email address, or any of the other information we hold is inaccurate or out of date, please let us know in writing using the contact details provided above.
the right to erasure - you have the right to have the data we hold about you erased from our records, if it is no longer necessary in relation to the purpose for which it was originally collected, or where you object to the processing and there is no overriding legitimate interest for continuing the processing.
the right to restrict processing - you have the right to restrict processing. This allows us to store personal data but not to process it further.
the right to data portability - you have the right to receive the personal data we hold about you in a safe and structured, commonly used and machine readable form, so that you or other organisations can use the data without hindrance.
the right to object - you have the right to object to certain types of processing such as direct marketing. If you do not wish to receive information about our products or services then you can opt-out / unsubscribe by writing to us with this request by email, fax or post, or clicking on the ‘unsubscribe’ link which is present in our emails.
the right not to be subject to automated decision-making including profiling - you have the right not to be subject to the legal effects of automated processing or profiling. Automated individual decision-making is a decision made by automated means without any human involvement. Profiling is ‘any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to the natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements’. [Article 4(4)]
In the event you wish to make a complaint about how your personal data is being processed by APT Initiatives Ltd you have the right to complain to APT Initiatives Ltd’s Director via email: email@example.com, fax or post. If you do not get a response within 30 days you can complain to the Information Commissioner’s Office (ICO) at Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Telephone 0303 123 1113 or email: https://ico.org.uk/global/contact-us/email/.
Changes to this Privacy Notice
This Privacy Notice is kept under regular review. It was published on 18 May 2018, according to the new GDPR Regulations, which came into force on 25 May 2018.