This privacy policy sets out how we use and protect any personal information that you give us. We take your privacy seriously therefore we urge you to read this policy carefully because it contains important information about us and:

Acturis is committed to ensuring your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, by completing a survey, registering for an event or a webinar hosted by us or interacting with us as a business contact or a job applicant, then you can be assured that it will only be used in accordance with this privacy policy.

Acturis may be required to make updates to this privacy policy from time to time. You should check this page regularly to ensure that you are happy with any changes. This policy is effective from 16th June 2020.

Who we are

This privacy policy applies to the Acturis Group (the “Group”). The Group is made up of different legal entities, details of which can be found here. This privacy policy is issued on behalf of the Group so when we mention “Acturis”, the “Company”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data. Acturis Limited and any affiliate noted above with which you have a direct business relationship is a ‘Data Controller’ for the purposes of processing personal data as described in this privacy policy.

What personal information we may collect

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). Information you may give us, or we may collect from you, may include the following:

How we collect personal information

We may collect and process your personal information in the following circumstances:

If you provide us with personal information on behalf of someone else you confirm that the other person has appointed you to act on his or her behalf and agreed that you can. In addition, where you give us personal information belonging to someone else you must ensure that you have the necessary grounds, consents or authorisations to provide it to us.

Purposes for which we will use your personal information

In accordance with data protection legislation, we will only process your personal data where we have a lawful basis for doing so. These bases are: (i) where it is necessary for the performance of a contract we have with you or your organisation, or pre-contract activities made at your request; (ii) where you have provided your consent; (iii) where it is necessary for us to comply with a legal obligation that we are subject to; or (iv) where it is in our (or a third party’s) legitimate interests and such interests are not overridden by your interests or fundamental rights and freedoms. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

The purposes for which we may process your personal data and the lawful basis on which we carry out such processing may include the following:

Where it is necessary for the performance of a contract

Where you have provided your consent

Where it is necessary for us to comply with a legal obligation

Where it is in our (or a third party’s) legitimate interests and such interests are not overridden by your interests or fundamental rights and freedoms

Disclosures of your personal information

We may share your personal information with the following parties for the purposes we set out above:

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.

Mobile App: the Acturis mobile application is hosted by external app store providers. When you download the mobile app from the App Store or Google Play, such providers may be able to view statistics regarding your use of the mobile app as well as see any personal information you send to them. This will be governed by such provider’s privacy policy.

We may share non-personally identifiable information publicly and with our partners. For example, we may share information publicly to show trends about the general use of our services.

If you wish to know more about the parties with whom we share personal information, please contact us at info@acturis.com.

International transfers

We may transfer your personal information to a third party or other Group companies in countries within or outside the European Economic Area (EEA) or Canada, as applicable, for further processing in accordance with the purposes for which your personal information was originally collected or for purposes to which you have consented or that are otherwise permitted by applicable law.

If we transfer your personal information to a country outside of the EEA, or Canada, as applicable. we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or Canada.

Data security

We are committed to ensuring that your information is secure. We have implemented technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. We require third parties receiving personal information from us to ensure that your personal information is protected by technical and organisational measures.

How we use cookies

Information relating to the cookies used on our website can be found at the following link: Cookie Policy.

Links to other websites

Our website may contain links to other websites. Once you have left our site, we are no longer responsible for the protection and privacy of any information which you provide whilst visiting such sites. You should exercise caution and look at the Privacy Policy of any third party website before submitting any personal information to them.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

We will not sell, distribute or lease your personal information to third parties unless you have consented for us to do so or are required to do so by law.

Your legal rights

If our legal basis for processing your personal information is based upon your consent, you have the right to withdraw consent at any time.

You may object to our processing of your personal information where we do so based upon our legitimate interests. Where required under applicable law, we will stop any such processing and notify you if that changes.

If we made a decision about you that was based solely upon the automated processing of your personal information, including profiling, and our decision produces a legal effect for you or similarly significantly affects you, you may have the right to contest that decision and ask for human review on our part.

You may request that we disclose to you certain details regarding our processing of your personal information, or that we correct, amend, delete, or restrict the processing of, or provide to you, the personal information we hold about you. Where required under applicable law, we will notify any third party recipients of this, where possible. Please note, however, that requests are subject to any applicable legal and ethical reporting or data retention obligations imposed on us.

You may exercise these or any other rights available to you under applicable law by emailing us at info@acturis.com with your specific request.

Upon receipt of your written request and enough information to permit us to identify your personal information, we will try to respond to all legitimate requests within one month. Occasionally it could 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.

If we are unable to take action on your request, we will, as required by applicable law, annotate the personal information under our control with a note that action was requested but not made. In this event, we will notify you without undue delay of the reasons for not taking action.

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, where allowed by applicable law, based on our administrative costs in complying with your requests; for instance, where you request further copies of the information we hold about you, or where requests are unfounded or excessive.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period where required by applicable law or where we have a legitimate and lawful purpose to do so for example, to provide you with an answer to a question you have asked or to comply with applicable legal 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, regulatory, tax, accounting or other requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Contact

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer at: info@acturis.com.

You have the right to make a complaint at any time to the relevant supervisory authority, depending on your jurisdiction, for data protection issues. The UK supervisory authority for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.