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Home > Privacy Statement


PRIVACY STATEMENT - EFFECTIVE AS OF


OCTOBER 5, 2023



Committed to Protecting Your Information




COMMITTED TO PROTECTING YOUR INFORMATION

Aptean is committed to protecting personal information that we collect from you
or that you provide to us and to using such personal information in compliance
with applicable laws and regulations. This privacy statement aims to tell you
how we process your personal information as a data controller whether received
from our websites or collected by other means and will also tell you about your
privacy rights. This website is not intended for children and we do not
knowingly collect data relating to children. It is important that you read this
privacy statement together with any other privacy notice or fair processing
notice we may provide on specific occasions when we’re collecting or processing
personal data about you so that you are fully aware of how and why we’re using
your data. This privacy statement supplements other notices we may provide and
is not intended to override them.

This privacy statement contains the following subjects. Please also use the
Glossary to understand the meaning of some of the terms used in this Privacy
Statement.

 * Who We Are

 * Data We Collect About You

 * How Is Your Personal Data Collected

 * How Do We Use Your Personal Data

 * Who Do We Disclose Your Personal Data To

 * International Transfers

 * Data Security

 * Data Retention

 * Your Legal Rights

 * Aptean Group of Companies

 * Glossary

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1. WHO WE ARE

Aptean is made up of different legal entities, including without limitation
those stated below under ‘Aptean Group of Companies.’ This Privacy Statement is
issued on behalf of the Aptean Group of Companies and references to “Aptean”
“we” and “our” means any one or all of the Aptean group of companies.

This Privacy Statement covers the information practices of websites that link to
this Privacy Statement, including without limitation: Aptean.com, Aptean.co.uk,
Aptean.fr, Aptean.de, Aptean.es, Aptean.cn, and Aptean.jp (collectively referred
to as “Aptean’s websites”, “our websites” or “the Company’s websites”).

We have appointed a data protection officer who is responsible for overseeing
questions in relation to this Privacy Statement. If you have any questions about
this Privacy Statement, including any requests to exercise your legal rights,
please contact the DPO using the details set out below.


CONTACT DETAILS

Email address: privacy@aptean.com

Postal address: the Data Protection Officer, Lincoln House, Wellington Crescent,
Fradley Park, Lichfield, United Kingdom, WS13 8RZ


CHANGES TO THIS PRIVACY STATEMENT

This Privacy Statement may change from time to time so please re-visit this page
as often as you wish. Changes to this Privacy Statement are effective at the
time they are posted to our websites.


YOUR DUTY TO INFORM US OF CHANGES

It is important that the personal data we hold about you is accurate and
current. Please keep us informed if your personal data changes during your
relationship with us.


THIRD PARTY LINKS

Aptean's websites may contain links to third party websites. While we try to
link only to websites that share our high standards and respect for privacy, we
are not responsible for the content, security, or privacy practices employed by
other websites. When you leave our website we encourage you to read the privacy
notice of every website you visit.

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2. THE DATA WE MAY COLLECT ABOUT YOU

Personal data, or personal information, means any information about an
individual from which that person can be identified. It does not include data
where the identity has been removed (anonymous data). In general, the list below
refers to data we have collected in the past 12 months from our customers,
prospective customers, prospective employees, partners, vendors and other
individuals we interact with.

Depending on whether you are a customer, prospective customer, prospective
employee, partner, vendor or other individual we interact with, we may collect,
use, store and transfer different kinds of personal data about you which we have
grouped together as follows:

 * Identity Data - includes first name, last name, username or similar
   identifier, title, department and reporting relationship.

 * Contact Data - includes billing address, delivery address, email address and
   telephone numbers.

 * Job Recruitment Data - includes details about your qualifications, skills,
   experience, employment history, current level of remuneration, including
   benefit entitlements, whether or not you have a disability and information
   about your entitlement to work in the country where you seek employment.

 * Transaction Data - includes details of products and services you have
   purchased from us.

 * Technical Data - includes internet protocol (IP) address, your login data,
   browser type and version, time zone setting and location, browser plug-in
   types and versions, operating system and platform and other technology on the
   devices you use to access the websites.

 * Profile Data - includes purchases or orders made by you, your interests,
   preferences, feedback and survey responses.

 * Usage Data - includes information about how you use our websites, products
   and services.

 * Marketing and Communications Data - includes your preferences in receiving
   marketing from us and our third parties and your communication preferences.

We 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 but is not considered personal data in law as this data
does not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data with
your personal data so that it can directly or indirectly identify you, we treat
the combined data as personal data which will be used in accordance with this
privacy notice.


COOKIES

For each visitor to our websites, our web server may automatically recognize and
store information, such as the visitor's IP address/domain name combination; the
full Uniform Resource Locators (URL) clickstream to, through and from our
websites (including date and time); products you viewed or searched for; page
response times; download errors; length of visits to certain pages and page
interaction information (such as scrolling, clicks, and mouse-overs).

When you visit our websites, or advertisements appearing on it, or use one or
more of our website services, we may use "cookies". A cookie is a small file of
letters and numbers that we store on your browser or the hard drive of your
computer if you agree. Our websites use cookies to distinguish you from other
users of our websites and contain information to customize your experience,
better match your interests and preferences, or to simply facilitate signing in
to use our services. We use the following cookies:

Strictly necessary cookies.

 * These are cookies that are required for the operation of our websites. They
   include, for example, cookies that enable you to log into any secure areas of
   our websites.

Analytical/performance cookies.

 * These allow us to recognize and count the number of visitors and to see how
   visitors move around our websites when they are using them. This helps us to
   improve the way our websites work, for example, by ensuring that users are
   finding what they are looking for easily.

Functionality cookies.

 * These are used to recognize you when you return to our websites. This enables
   us to personalize 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 our websites, the pages you have visited
   and the links you have followed. We will use this information to make our
   websites and the advertising displayed on them more relevant to your
   interests. We may also share this information with third parties for this
   purpose.

Except for essential cookies, all cookies will expire after 10 years

Most browsers will allow you to erase cookies from your computer hard drive,
block acceptance of cookies, or receive a warning before a cookie is stored.
However, if you block or erase cookies, we may be unable to restore previously
specified preferences or customization settings and our ability to personalize
your online experience may be limited. Please refer to your browser instructions
or "help" screen to learn more about these functions.

In addition, you may provide us with information about yourself by filling in
forms on our websites or by corresponding with us by phone, e-mail or otherwise.
This includes information you provide when you use our websites, subscribe to
our communications, search for a product, participate in discussion boards or
other social media functions on our websites, enter a competition, promotion or
survey, report problems on our websites or participate in other authorized
activities on the websites. Please do not provide us with personal information
that we do not request as we will have no responsibility or liability to you for
the consequences of your doing so.


IF YOU FAIL TO PROVIDE PERSONAL DATA

The information that is associated with your individual profile enables you to
participate in activities, apply for a job or complete a registration using our
websites. If you fail to provide that data when requested, we may be unable to
complete your registration or application and we may not be able to permit you
to participate in the activity that you are interested in.

Where we need to collect personal data by law, or under the terms of a contract
we have with you and you fail to provide that data when requested, we may not be
able to perform the contract we have or are trying to enter into with you (for
example, to provide you with goods or services). In this case, we may have to
cancel a product or service you have with us but we will notify you if we have
to take this course of action.

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3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

(i) Direct interactions. You may give us your personal data in person at trade
shows or meetings, when you register for user events or in other circumstances,
or by filling in forms including job applications or by corresponding with us by
post, phone, email or other direct communications. This includes personal data
you provide when you:

 * are interested in possibly purchasing our products or services;

 * seek information about or make an application for employment;

 * opt in to our communications;

 * enter a competition, promotion or survey; or

 * give us some feedback

 * Submit a web form

 * Call Sales Line and speak to someone

(ii) Automated technologies or interactions. As you interact with our websites,
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. Please see our cookie
section above for further details.

(iii) Third parties or publicly available sources. We may receive personal data
about you from various third parties and public sources including without
limitation those as set out below:

 * Technical Data from the following parties:
   
   * analytics providers such as Google;
   
   * advertising networks; and
   
   * search information providers.

 * Identity and Contact Data from data brokers or aggregators.

 * Identity and Contact Data from publicly availably sources including without
   limitation LinkedIn, Companies House and the Electoral Register.

 * Aptean partners.

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4. HOW DO WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we
will use your personal data in the following circumstances:

 * When You Contact Us: To respond to your inquiries or to process your requests
   (such as to receive promotional materials)

 * Managing Online and Business Operations: To administer our websites and for
   internal operations, including work planning, management and strategic
   decision making, troubleshooting, data analysis and hygiene, for updating and
   validating databases, product development, testing, system maintenance,
   support, reporting and hosting of data research, statistical and survey
   purposes

 * Website: To deliver relevant website content to you

 * Marketing: To deliver marketing communications to you and measure or
   understand the effectiveness of these we serve to you

 * Products and Services: To offer Aptean products and services to you, whether
   directly or indirectly;

 * Analytics: To use data analytics to improve our website, products/services,
   marketing, customer relationships and experiences

 * Prizes and Surveys: To enable you to partake in a prize draw, competition or
   complete a survey

 * Customer Registration: To register you as a new customer

 * Contract Requirements: To administer all parts of our contract with you
   including without limitation processing and delivering your order, managing
   payments, fees and charges and collecting and recovering money owed to us

 * Relationship Management: To manage our relationship with you including
   without limitation notifying you about changes to our terms or privacy policy
   and asking you to leave a review or take a survey

 * Job Application: To process your job application

 * Legal Obligations: To comply with our legal obligations. For example, it is
   mandatory to check a successful applicant’s eligibility to work in certain
   countries before employment starts

 * To Fulfill Your Request: We will release information about you if you direct
   us to do so, if we are required by law to do so, or in other legally limited
   circumstances (for example, to protect you from fraud).

 * Changes in Business Structure/Ownership: If Aptean or one of its affiliates
   is sold (either through a merger into another entity or the sale of all or
   substantially all of the assets of the selling entity), we may disclose your
   personal information to the prospective buyer because personal information
   about the selling entity’s customers is typically one of the assets that is
   transferred to the buyer.

Domain name information that we collect is not used to personally identify you
and instead is aggregated to measure the number of visits, average time spent on
the websites, pages viewed and to improve the content of our websites.


MARKETING

We strive to provide you with choices regarding certain personal data uses,
particularly around marketing and advertising.




PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact, Technical, Usage and Profile Data to form a
view on what we think you may want or need, or what may be of interest to you.
This is how we decide which products, services and offers may be relevant for
you (we call this marketing).

Prospective customers may receive marketing and other communications from us if
you have:

 * requested information from us or if you provided us with your details when
   you entered a competition or registered for a promotion and, in each case,
   you have not opted out of receiving that marketing; and

 * consented in advance, to us providing you, and/or permitted selected third
   parties to providing you, with information about products, services,
   promotions or events that may interest you. Where you have consented, Aptean
   and these selected third parties may contact you by telephone, mail or by
   other means for these purposes.

Existing customers may receive marketing and other communications from us
provided you have not opted out of receiving those communications.




OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any
time by checking or unchecking relevant boxes to adjust your marketing
preferences or by following the opt-out links on any marketing message sent to
you or by Contacting us at any time. Where you opt out of receiving these
marketing messages, this will not apply to personal data provided to us as a
result of a product/service purchase, warranty registration, product/service
experience or other transactions.




COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you
when websites set or access cookies. If you disable or refuse cookies, please
note that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see our cookie
section above.




LEGAL BASES FOR PROCESSING

We have set out below a description of some of the legal bases we rely on to
process your personal data. 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 data. Please email: privacy@aptean.com or write to the Data Protection
Officer, Lincoln House, Wellington Crescent, Fradley Park, Lichfield, United
Kingdom, WS13 8RZ 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 below.

 * 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. The following are non-exhaustive examples of where Aptean relies
   on legitimate interest to process personal data:
   
   * Aptean has a legitimate interest in processing personal data during the
     recruitment process and for keeping records of the process. Processing data
     from job applicants allows us to manage the recruitment process, assess and
     confirm a candidate's suitability for employment and decide to whom to
     offer a job; and
   
   * Aptean has a legitimate interest in processing personal data relating to
     our existing customers in order to manage our business relationship and
     provide communications and information that may be of interest.
   
   * Aptean has a legitimate interest in using cookies as outlined above in the
     cookie section of this privacy policy.

 * Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your
personal data.




CHANGE OF PURPOSE

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 original purpose. If you wish to get an
explanation as to how the processing for the new purpose is compatible with the
original purpose, please email: privacy@aptean.com or write to the Data
Protection Officer, Lincoln House, Wellington Crescent, Fradley Park, Lichfield,
United Kingdom, WS13 8RZ.

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.

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.

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5. WHO DO WE DISCLOSE YOUR PERSONAL DATA TO

We may have to share your personal data with the parties set out below where
they are involved in providing services to us. We will only share personal
information about you that is reasonably necessary for the other companies to
have in order to provide their services to Aptean. These companies are
contractually bound to use personal information we share with them only to
perform the services we have engaged them to provide. We collect the following
categories of information: identifiers, California Customer Records information,
protected classifications, commercial information, online activity, employment
information, and profile information. We may share all of the information we
collect about you with third parties as indicated below:

 * Affiliates, Subsidiaries, and Locations: We may share your personal
   information with our different locations, affiliates, and subsidiaries. If we
   share your information, we will share only the information that is necessary
   and we will take reasonable steps to make sure that third parties take
   prudent steps to protect your information. These partners may act as
   processors and/or joint controllers.

 * Service Providers, Suppliers, Agents, and Business Partners: Other companies
   sometimes provide certain services to us or on our behalf (e.g., maintenance,
   IT support, analysis, development, security). Unless we tell you differently
   or as described elsewhere in this Privacy Policy, our service providers are
   not permitted to use your information except to assist us. These third
   parties may be acting as processors or joint controllers located globally who
   provide services, including marketing services, to the Aptean Group of
   Companies.

 * Professional Advisors: We may share your personal information with
   professional advisors acting as processors or joint controllers for the
   Aptean Group of Companies. These professional advisors may include lawyers,
   bankers, auditors, and insurers located globally, and we may share your
   personal information with them only to the extent needed to provide
   consultancy, banking, legal, insurance, and accounting services and advice to
   the Aptean Group of Companies.

 * Compliance with Legal Obligations: We may need to disclose certain
   information to auditors, government authorities, law enforcement, regulatory
   agencies, our legal counsel, third party litigants and their counsel, or
   other authorized individuals in order to comply with laws that apply to us,
   or other legal obligations such as contractual requirements.

 * Changes in Business Structure/Ownership: Third parties to whom we may choose
   to sell, transfer, or merge parts of our business or our assets.
   Alternatively, we may seek to acquire other businesses or merge with them.
   This could include reorganization, merger, sale, joint venture, assignment,
   transfer, or other disposition of all or any portion of the Company's
   business, assets, or ownership interest (including any bankruptcy or similar
   proceedings). If a change happens to our business, then the new owners may
   use your personal data in the same way as set out in this privacy notice.



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.

--------------------------------------------------------------------------------

We have not sold any categories of personal data, including children's personal
data, in the past 12 months. In addition to the purposes described in this
notice, we may share your personal data for the business purposes listed below.

 * Products and Services. To provide you with products and services, including
   customer service, processing orders or transactions, verifying consumer
   information, and processing payments.

 * Website Improvement. To improve our websites, including responding to
   inquiries and improving functionality.

 * Complying with Your Requests. To comply with your requests, including sending
   your information to third parties if you ask us to do so.

 * Employment. For job applications and in the course of employment.

 * Marketing. To provide you with marketing materials and information.

 * Business Operations. To perform activities we need to operate our business,
   such as maintenance, IT support, analysis, development, security, and legal
   compliance.



CALIFORNIA PRIVACY CHART

California law requires us to tell you about the personal data we collect about
you in a certain way – specifically, we need to tie it back to "legal
categories" of personal data that are listed in the law. To do this, we bundled
the information we give you in this Privacy Notice and matched the different
types of personal data we collect about you with the legal category. To make
things easier to understand, we've put this information in a chart that shows
you four things: 1. The legal category of personal data, 2. The source from
which we collect the categories of personal data, 3. The purposes for which we
collect and use your personal data, and 4. The third parties with whom we share
your personal data for a business purpose. This chart is called the California
Privacy Chart, and we've included it at the end of this Privacy Notice.

--------------------------------------------------------------------------------


6. INTERNATIONAL DATA TRANSFERS

Aptean primarily stores the personal data we collect in the United States. To
facilitate Aptean’s global operations, staff who work for Aptean and/or our
service providers may transfer and access such personal data from locations
around the world. This will involve transferring your personal data outside the
European Economic Area (EEA).

We will take all steps reasonably necessary to ensure that your personal data is
treated securely and in accordance with this Privacy Statement.

Whenever we transfer your personal data out of the EEA, we will ensure one of
the following safeguards is implemented:

 * We will only transfer your personal data to countries that have been deemed
   to provide an adequate level of protection for personal data by the European
   Commission; or

 * We may use specific contracts approved by the European Commission which give
   personal data the same protection it has in Europe; or

 * We will ensure there is some other protection in place which has been
   approved by the European Commission as giving personal data the same
   protection it has in Europe.

--------------------------------------------------------------------------------

Where our sharing of your personal information with our private equity sponsor
requires us to transfer your personal information outside of the EEA, please
refer to Section 6 of the Privacy Policy for further details on cross-border
transfers. In connection with the recruitment process, we transfer your personal
data outside of the EEA to Hirebridge, LLC and Criteria Corp., which provide
applicant tracking services. Hirebridge, LLC and Criteria Corp. both comply with
the EU-U.S. Privacy Shield Framework and ensure that your personal information
is adequately protected whilst outside of the EEA.

--------------------------------------------------------------------------------


7. DATA SECURITY

We maintain appropriate physical, electronic, and administrative safeguards that
are designed to protect your personal information 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. Employees who misuse personal information are subject to
disciplinary action.

Where we have given you (or where you have chosen) a password which enables you
to access certain parts of our websites, you are responsible for keeping this
password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal
information, we cannot guarantee the security of your data transmitted to our
websites; 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 unauthorized access.

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.

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8. DATA RETENTION

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.

Details of retention periods for different aspects of your personal data are
available in our retention policy which you can request from us by contacting
our DPO at privacy@aptean.com or by writing to The Data Protection Officer,
Aptean Limited, Lincoln House, Wellington Crescent, Fradley Park, Lichfield,
United Kingdom, WS13 8RZ.

By law we have to keep basic information about our customers (including Contact,
Identity, Financial and Transaction Data) for six years after they cease being
customers.

In some circumstances you can ask us to delete your 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) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.

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9. YOUR LEGAL RIGHTS

Under certain circumstances, individuals resident within the European Union have
rights under data protection laws in relation to your personal data as set out
below:

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 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 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.

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.

California Privacy Rights: In addition, under certain circumstances the
following rights are applicable to residents of California:

 * The right to know what personal information is being collected about you

 * The right to know whether your personal information is sold or disclosed and
   to whom.

 * The right to request deletion of personal information in some cases.

 * The right to access your personal information.

 * The right to receive equal service and price, even if customers exercise
   their privacy rights.

How to Make a Request: If you wish to exercise any of the rights set out above,
please contact us by providing your name, email address, and Company name using
any of the following methods: :

 * Email: privacy@aptean.com or

 * UK Mail: The Data Protection Officer, Aptean Limited, Lincoln House,
   Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ.

 * US Mail: The Data Protection Officer, 4325 Alexander Drive, Suite 100,
   Alpharetta, GA 30022-3740 USA.

To make a request, please provide your name, email address, and your Company
name. Responding to Requests: Your request will be evaluated to determine
whether the requested change meets legal regulatory requirements and does not
risk making our other data less secure or changing our other data. Verifying
Your Identity: To protect you and your information, we may ask you to confirm
certain information before we honor your request. For example, if you make a
request, we will ask you to confirm your name, email address, and/or any other
applicable data fields to verify your identity, so that we can help protect your
information. Requests from Authorized Agents: If you live in California, you may
designate an authorized agent to make a request for you. If you designate an
authorized agent to make a request on your behalf, we may require you to verify
your identity and provide the authorized agent's identity and contact
information to us. 2020 Requests – In 2020, we did not receive any of the above
requests.


NO FEE USUALLY REQUIRED

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

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

We try to respond to all legitimate requests within one month, or the period
required by applicable law if different. Occasionally we may need to extend such
period 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.

--------------------------------------------------------------------------------


10. APTEAN GROUP OF COMPANIES

The Aptean group includes but is not limited to the following companies:

 * ActivPlant Corporation

 * Affinitus Group Limited is a limited company registered in England and Wales.
   Registered number: 02634375. Registered office: Lincoln House, Wellington
   Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Agiles Informationssysteme GmbH

 * Apparel Business Systems LLC

 * Apparel Business Systems, Inc.

 * Apparel Business Systems International Sales, Inc.

 * Aptean Austria GmbH

 * Apprise Software Inc.

 * Apprise Software Pty. Limited

 * Aptean Asia Pacific Ltd.

 * Aptean Drink-IT B.V.

 * Aptean Drink-IT GmbH

 * Aptean Drink-IT Nederland B.V.

 * Aptean Drink IT Tunisia

 * Aptean Drink-IT UK Limited is a limited company registered in England and
   Wales. Registered number: 9730972. Registered office: Lincoln House,
   Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Aptean Fashion GmbH

 * Aptean France Solutions SARL

 * Aptean Germany GmbH

 * Aptean GmbH

 * Aptean Ibérica S.L.

 * Aptean Japan Co., Ltd

 * Aptean Limited is a limited company registered in England and Wales.
   Registered number: 03399429. Registered office: Lincoln House, Wellington
   Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Aptean MLM Solutions UK Limited is a limited company registered in England
   and Wales. Registered number: 04230389. Registered office: Lincoln House,
   Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Aptean Shenzhen Co., Ltd.

 * Aptean, Inc.

 * Aptean Vertriebs GmbH

 * Aptos Italy S.r.l

 * Axxos Industrisystem AB

 * Best Practice IT Solutions GmbH

 * cimdata Software GmbH

 * DIN Computers, B.V.

 * DocUnity LLC

 * Exenta, Inc.

 * Frontix B.V.

 * Greenfield Software Limited is a limited company registered in England and
   Wales. Registered number: 03172513. Registered office: Lincoln House,
   Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Gould Hall Computer Services Ltd is a limited company registered in England
   and Wales. Registered number: 07574113. Registered office: Lincoln House,
   Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * ImPuls GmbH

 * In2grate Business Solutions Limited is a limited company registered in
   England and Wales. Registered number: 04695575. Registered office: Lincoln
   House, Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * IndustryBuilt Software Corp.

 * IndustryBuilt Software Ltd.

 * JET ERP Betriebsgesellschaft mbH

 * Lascom S.A.S.

 * Logis Software-Entwicklung und Beratung GmbH

 * Merit Technology UK Limited is a limited company registered in England and
   Wales. Registered number: 08648371. Registered office: Lincoln House,
   Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Merlin Business Software Limited is a limited company registered in England
   and Wales. Registered number: 01274874. Registered office: Lincoln House,
   Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Mistral Informatique SAS

 * Objective Belgium BVBA

 * OBS Logistics Limited is a limited company registered in England and Wales.
   Registered number: 02439258. Registered office: Lincoln House, Wellington
   Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Open Systems, Inc.

 * Oxaion GmbH (Austria)

 * Paragon HDX Limited is a limited company registered in England and Wales.
   Registered number: 03031787. Registered office: Lincoln House, Wellington
   Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Paragon Software Systems Limited is a limited company registered in England
   and Wales. Registered number: 02634586. Registered office: Lincoln House,
   Wellington Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Prima Solutions Limited is a limited company registered in England and Wales.
   Registered number: 02576695. Registered office: Lincoln House, Wellington
   Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * ProducePro, Inc.

 * Proteus Software Ltd is a limited company registered in England and Wales.
   Registered number: 04403751. Registered office: Lincoln House, Wellington
   Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Respond Group Limited is a limited company registered in England and Wales.
   Registered number: 05240703. Registered office: Lincoln House, Wellington
   Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Sanderson Australia Pty Ltd

 * Sanderson Ltd. is a limited company registered in England and Wales.
   Registered number: 03743507. Registered office: Lincoln House, Wellington
   Crescent, Fradley Park, Lichfield, United Kingdom, WS13 8RZ

 * Schouw Informatisering B.V.

 * Totalogistix, Inc.

 * TLX Tech Solutions Private Limited

 * Trend MSV Softwarevertrieb GmbH

 * Trend SWM EDV-Beratung GmbH & Co. KG

 * Trend SWM Verwaltungs-GmbH



--------------------------------------------------------------------------------


11. GLOSSARY


LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and
managing our business to enable us to give you the best service/product and the
best and most secure experience. We make sure we consider and balance any
potential impact on you (both positive and negative) and your rights before we
process your personal data for our legitimate interests. We do not use your
personal data for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or permitted to by
law). You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities
by emailing privacy@aptean.com or writing to the Data Protection Officer,
Lincoln House, Wellington Crescent, Fradley Park, Lichfield, United Kingdom,
WS13 8RZ.

Performance of Contract means processing your data where it is necessary for the
performance of a contract to which you are a party or to take steps at your
request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data
where it is necessary for compliance with a legal or regulatory obligation that
we are subject to.




THIRD PARTIES

INTERNAL THIRD PARTIES

Other companies in the Aptean Group of Companies acting as joint controllers or
processors and who are located globally.



EXTERNAL THIRD PARTIES

 * Service providers acting as processors located globally who provide services
   to the Aptean Group of Companies

 * Service providers acting as processors and joint controllers located globally
   who provide marketing services to the Aptean Group of Companies

 * Aptean partners acting as processors and/or joint controllers

 * Professional advisers acting as processors or joint controllers including
   lawyers, bankers, auditors and insurers located globally who provide
   consultancy, banking, legal, insurance and accounting services.

 * Regulators and other authorities acting as processors or joint controllers
   located globally who require reporting of processing activities in certain
   circumstances.

--------------------------------------------------------------------------------

 * California Privacy Chart



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