§ 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.
§ 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 27 June 2018.
§ 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 Privacy Statement Aptitude Software Page 2 of 6 Company Privacy Statement
§ 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. The table below details the major categories of third party processors Third Party Processor Category Data hosting location and basis for transfer Personal Data Safeguards Email and Team Networking Software Provider Global Service Provider with multiple global locations| Transfers using Binding Corporate Rules (BCRs) or Standard Contractual Clauses (SCCs) Covered and detailed under Data Processing Agreement Inbound Marketing and Sales Software Global Service Provider with multiple global locations| Transfers using BCRs or SCCs Covered and detailed under Data Processing Agreement Background Check Vendors Located within European Union Covered and detailed under Data Processing Agreement
- 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. The table below details the retention period and criteria for major categories of data controlled by Aptitude Software. Personal Information Retention Period Retention Criteria Office Visitor Information Up to 3 months after office visit Only as long as required for use Website Visitor Information Up to 3 years after last interaction with our Website Only as long as required for use Privacy Statement Aptitude Software Page 4 of 6 Company Privacy Statement
- 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: o 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 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.