§ 1.1 Aim of the Privacy Statement
Aptitude Software (includes “Aptitude Software Limited”, “Aptitude Software, Inc.”, “Aptitude RevStream, Inc., “Aptitude Software (Canada) Limited”) is committed to international compliance with privacy laws. This statement applies worldwide to Aptitude Software (also referred to as “the Company”, “we”, “us”, “our”) and is based on globally accepted, basic principles of privacy. Ensuring data privacy is the foundation of trustworthy relationships with customers and suppliers and the reputation of Aptitude Software as an employer committed to protecting personal data.
§ 1.2 Organization and Content
This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both from individuals themselves or by other data controllers. To address the need to provide specific information to individuals or groups of individuals regarding the processing of their personal data, our privacy statement is organized in the following sections:
- Customer Privacy Notice: This notice addresses the personal information we collect in the usual course of our business, including through our websites, our products and services and through other means such as our customer events and visits to our offices.
- Applicant Privacy Notice: This notice addresses the personal information we collect in connection with our recruiting efforts.
- California Consumer Privacy Notice: This notice addresses the personal information we collect from individuals based in California, United States.
§ 1.3 Changes to our Privacy Statement
We recognize that transparency is an ongoing responsibility so we will keep this privacy statement under regular review. This privacy statement was last updated on November 5, 2019.
§ 1.4 Data Controller and Contact Information
The data controller is Aptitude Software Limited (a Limited Company registered in England and Wales under registration no. 03475849 and with its registration address at Old Change House,128 Queen Victoria Street, London EC4V 4BJ) and other Aptitude Software Companies that are contracting parties for the purposes of providing or receiving services. If you have any questions about this privacy statement or how and why we process personal data, please contact us using the details below: Data Protection Office Aptitude Software Limited Old Change House 128 Queen Victoria Street London EC4V 4BJ Phone: +44 (0)20 7496 8196 Email: firstname.lastname@example.org
§ 1.5 Customer Privacy Notice:
Aptitude Software is committed to protecting the privacy of our website visitors, customers, business/alliance partners, office visitors, and event attendees. This Privacy Notice describes the privacy practices that apply to the collection, use, retention and disclosure of personal information through our websites, office facilities, products, and services, as well as in connection with our sales events and marketing activities. This notice does not cover any customer or vendor (third party) personal data transferred by customers within Aptitude service platforms or systems. Such data is covered by the relevant third party’s privacy policies and Aptitude Software acts as a controller for such data. Aptitude Software may provide additional disclosures or information about the data collection, use and sharing practices of specific websites, products and services, and programs. These notices may supplement or clarify our privacy practices in the circumstances described or may provide you with additional choices about how we process your data. If you have any questions about this Privacy Notice, please contact us at email@example.com.
- How do we use your information: Your information is utilized for a number of purposes including the following:
- To provide you and your employer organization with our products and services per license agreements and service contracts
- To provide you and your employer organization with information regarding our services
- To provide you with a user-friendly navigational experience when you visit our website
- To provide you with a pleasant and hassle-free experience during your in-person visit to our office facilities
- To ensure the continued physical and logical security of your personal data and your organization’s confidential information
- To enable you and your employer organization to obtain full details regarding our products and service during your visit to our sales, marketing and promotional events.
- Legal Basis for Processing: We may utilize your personal data for pursuing contractual requirements and legitimate business interests through the following:
- Questionnaires and surveys: Aptitude Software may invite you to participate in questionnaires and surveys. These questionnaires and surveys will be generally designed in a way that they can be answered without any personal data. If you nonetheless enter personal data in a questionnaire or survey, we may use such Personal Data to improve our products and services. Privacy Statement Aptitude Software Page 3 of 6 Company Privacy Statement o Recording of calls for quality improvement purposes
- Recording of CCTV videos of your visits to our facilities for security purposes
- Recording of audios, videos and photographs and other personal data from your visits to our sales events, business seminars and trainings to obtain your feedback or improve future such events or related services or improve an existing or future business relationship.
- Customer Relationship Management through inbound marketing and sales partners
- How we share and transfer your information with third parties: Aptitude Software uses a wide variety of third-party processors and service providers based within and outside the EU to support our efforts to provide you with our products and services. All data transfers within and outside the EU are performed using legally acceptable methods and security measures. We may also share your information with government bodies and law enforcement agencies per legal requirements.
- Security and Confidentiality: We take the security of all the data we hold very seriously and have implemented appropriate safeguards and security measures to protect your data. We adhere to documented security standards and a formal information security management system. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure. All access to personal data is limited to personnel who need to view or access the data for the purposes listed under ‘How we use your information’.
- Data Retention: Where Aptitude Software is the controller of your information, we retain your information only as long as we need to retain it for the purpose for which the information was collected. Legal requirements in certain jurisdictions may require us to retain certain information for specified time periods which may exceed use-based criteria for data retention. In case Aptitude Software is the processor of personal information, the retention period is determined by the controller of the information. We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time that we need to keep it.
- Your Privacy Rights: Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.
- Access to personal data: You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing our Data Protection Office at firstname.lastname@example.org. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits (currently 30 days).
- Amendment of personal data: To update personal data submitted to us, you may email us at email@example.com. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.
- Withdrawal of Consent: Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at firstname.lastname@example.org or, to stop receiving an email from a marketing list, please click on the unsubscribe link in the relevant email received from us.
- Other Data Subject Rights: This notice is intended to provide information about what personal data we collect about you and how it is used as well as rights of access and amendment referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure and deletion, to restrict or object to our processing of personal data and the right to data portability. To exercise any of these rights, please email email@example.com
- Complaints and Concerns: Please raise any concerns regarding your personal data with the data protection office at firstname.lastname@example.org. If you are unsatisfied with our responses, you have the right to lodge a complaint with the data protection supervisory authority. The data protection authority can be contacted at https://ico.org.uk/concerns.
§ 1.6 Cookie Notice:
Cookies are small data files stored on your computer by the websites that you visit. They are widely used to make websites work, or work more efficiently, as well as to provide business and marketing information to the owners of the site.
If you have any questions about this Privacy Notice, please contact us at email@example.com.
§ 1.7 Applicant Privacy Notice
- Scope of this Privacy Notice: This Privacy Notice applies to all personal data of job applicants processed by Aptitude Software in the context of our job recruitment process. Such data are processed under the responsibility of Aptitude Software. This is a notice of privacy practices; this is not a contract or agreement. If you have any questions about this Privacy Notice, please contact us at firstname.lastname@example.org.
- Recruitment Process: When you apply for a position with Aptitude Software, you may have to provide personal data to us in connection with the recruiting process. Aptitude Software and our service providers may process personal data for recruitment purposes including organizing selection procedures and to manage applications.
- Type of data we collect: When you interact with Aptitude Software in connection with the recruitment process, we may ask or receive certain personal data, including, but not limited to:
- Personal data allowing identification of the candidate and practical organization: first name, surname, address and country of residence, email address, telephone number.
- Personal data allowing the verification of the eligibility and selection criteria as laid down in the vacancy notices: education and training (diploma awarded), professional experience (job title, employment dates, company name, company type, and web address of company (optional), main tasks and responsibilities), linguistic and job-related skills and competencies and areas of interest.
- In certain countries, including the US, we may ask for information such as gender, race, and ethnicity for the purposes of monitoring equal opportunity.
- Third parties: Your personal data may be processed and stored by our trusted third-party partners involved in providing and facilitating recruitment background checks, website hosting, and email services. Any disclosures to other third parties will only be made when required by law. Aptitude requires these third parties to provide a comparable level of protection to your personal data as we provide, to keep your personal data confidential, to only process your personal data for the purposes for which it was disclosed and to only access the minimum amount of data they need to deliver a specific service related to the recruitment process.
- Transfers: Your personal data may be processed and transferred to countries outside of your country or jurisdiction during the recruitment process. These countries or jurisdictions may not have similar data protection laws. If Aptitude Software transfers your data or allows a third party to transfer your personal data, we will take steps to protect your privacy rights through the use of contractual arrangements or other means, which will provide a comparable level of protection while the information is being processed by our third parties.
- Data Retention: Aptitude will take reasonable steps to ensure that we retain your personal data only for so long as is necessary for the purpose for which it was collected, or as required under any contract or Privacy Statement Aptitude Software Page 6 of 6 Company Privacy Statement by applicable law. Pre-employment information provided maybe be retained for up to 3 months after completion of the employment process.
- Please see § 1.5 Customer Privacy Notice for additional common information regarding data subject rights and data security.
§ 1.8 California Consumer Privacy Notice
- Scope of this Privacy Notice: This Privacy Notice applies to all personal data of California Consumers processed by Aptitude Software in the context of our organizational processes. Such data are processed under the responsibility of Aptitude Software. This is a notice of privacy practices; this is not a contract or agreement. If you have any questions about this Privacy Notice, please contact us at email@example.com.
- Protecting the security and privacy of personal data for California based consumers (‘consumer’ as defined under the California Consumer Privacy Act (CCPA) of 2018) is important to Aptitude Software. We hope the policy outlined below will help you understand what data may be collected, how that data may be used and safeguarded, and with whom the personal data may be shared by the various Aptitude Software companies in the USA (“Aptitude Software”).
- Personal data: Through our internet sites, Aptitude Software will not directly collect any personal data about you (such as your name, address, telephone number or e-mail address), unless you voluntarily choose to provide it (such as by registration, survey or order placement), or unless otherwise required by applicable laws and regulations. From time to time, we may collect personal data about you indirectly from sources other than through our own internet sites. The personal data that we collect from various sources may be combined.
- Data Collected Automatically: When you access our internet sites or use our mobile applications, we may automatically (that is, not by registration) collect additional data (such as type of Internet browser, IP address, and operating system used, domain name of the internet site which directed you to our site, number of visits, average time spent on the site, pages viewed, information on your interaction with the site). We may use this data and share it with our worldwide affiliates or third parties to monitor the attractiveness of our internet sites and mobile applications, improve the performance or content, tailor content for you or for other marketing purposes
- Purpose of Use; Sharing: We may use your personal data to offer the site’s services and functions, to administer your use of the site, to respond to your inquiry or request, to process your order or to provide you with access to specific information or offers, to verify your identity, as well as to support our existing or potential customer relationship with you. Aptitude Software may store, analyze, and process personal data (on our own or via a third party on our behalf) and share it with our worldwide affiliates (meaning entities controlled by, controlling, or under common control with Aptitude Software) to understand better your business needs and how to implement and improve our business practices, products, and services. We (or a third party on our behalf) may use personal data for analytics, to contact you about an offer in support of your business needs, or to conduct online surveys to understand better our customers’ needs.
- We may employ third party companies and individuals to host or support our Internet sites, applications, or the services to which they relate. These third parties may have access to your personal data to perform such tasks. We do not sell or otherwise market your personal data to other third parties, except as described.
- To the extent required to help us fulfill your requests, we may share personal data with others, such as our business partners, vendors, and third-party service providers. We may transfer your personal data and process it outside your country of residence. We may transfer your personal data if we sell or transfer all or a portion of our business or assets, including to any successor company whether via merger or otherwise.
- “Cookies” – Information Stored Automatically on Your Computer or Device
We employ cookies on these websites. You may find information on this subject under 1.6 Cookie Notice.
- Use of Third-Party Analytics: Our Internet sites use a variety of third party analytics in order to improve the site, identify errors, and/or customize the information included in the site. In order to exclude your computer or device from the data aggregation and analysis by third parties due to your visit to this Internet site, a cookie will be placed on your machine. While the cookie contains no personal data, it enables third parties to recognize your preference. To manage your preferences regarding the third party analytics cookie, please see our Cookie Notice above.
- Marketing: In addition, we may advertise using online marketing technology. In doing so, a third-party will place or read a unique ad-serving cookie on your computer or device and will use non-personal information about your browser and your activity at this site to serve Aptitude Software ads on their content network. The ad-serving cookie is a persistent cookie. Please email firstname.lastname@example.org here for more information about remarketing or to opt-out of the remarketing cookie.
- Aptitude Software e-mail communications may include web beacons to determine whether the emails have been opened or whether any included links have been clicked on.
- International Data Transfers: Aptitude Software, Inc. may transfer your personal data to its parent company in the United Kingdom, Aptitude Software Limited, and to any worldwide affiliates when processing data. We may also transfer your data to a third party outside your country of origin.
- Do Not Track: At this time our Internet sites do not recognize or respond to “Do Not Track” browser signals. For more information on “Do Not Track”, please visit your browser’s support page.
- Children: Our website is not directed to children under the age of thirteen. We will not knowingly collect personal data from children under the age of thirteen without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent, pursuant to local law and regulations or to protect a child.
- Security: To protect your personal data against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, Aptitude Software uses reasonable physical, technical and organizational security measures. Unfortunately, there is no complete assurance of security in transit or storage of any data that you transmit. Your personal data may be accessed, disclosed, altered, or destroyed by a breach of any of the physical, technical, or organizational assets.
- California Privacy Rights: California’s “Shine The Light” law permits those of our clients who are California residents to annually request a list of their personal data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. At this time, we currently do not share any personal data with third parties for their direct marketing purposes.
- Aptitude Software Internet sites and mobile applications contain links to other Internet sites, such sites may have their own privacy statements or policies. Aptitude Software is not responsible for the privacy practices or the content of other Internet sites.