Privacy Policy
PRIVACY NOTICE
APTLY MANAGED LIMITED.
INTRODUCTION
Aptly Managed Limited registered office 24 Wandsworth Road, London, SW8 2JW. Company registration number 13145031.
Aptly Managed Limited is registered with the ICO ZB035058
This privacy notice describes how we collect, use and store personal information about you during and after your business relationship with us, in accordance with the Data Protection Act 2018 / UK GDPR. This privacy notice applies to both www.aptlymanaged.com and the Aptly Managed mobile app, available on Android and Apple platforms.
Aptly Managed Limited is a “data controller”. This means that we are responsible for deciding how we hold and use and store personal information about you. We are required under the DPA 2018 / UK GDPR to notify you of the information contained in this privacy notice.
It is important that you read this notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using your personal information.
Table of contents.
1 Data protection principles
2 The kind of information we hold about you
2a For our clients and suppliers
2b For our suppliers
2c For end users
3 Information we collect about children under 16
4 How your personal information is collected
5 How we will use information about you
6 If you fail to provide personal information
7 Sharing your information
8 Data retention
9 Transfer of data outside the UK
10 Marketing
11 Your data protection rights
12 Cookie statement
13 How to contact us
14 How to make a complaint
1. DATA PROTECTION PRINCIPLES
We will comply with all relevant data protection law (including the DPA 2018 / UK GDPR). This requires that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have informed you about.
6. Kept securely.
2. THE KIND OF INFORMATION WE HOLD ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified, whether directly or indirectly. It does not include data where the identity has been removed (anonymous data).
There are also “special categories” of sensitive personal data which require a higher level of protection.
2a. For our clients we will collect, store, and use the following categories of personal information about you:
* Your contact information including name, address, email address, phone number;
* Your concierge name, email, profile picture, building address, clock in/out records, timesheets and Rota.
* Technical data which includes your IP address when you visit our website;
* Marketing & Communications data including your marketing preferences with us.
2b. For our suppliers we will collect, store, and use the following categories of personal information about you:
* Your contact information including name, address, email address, phone number;
* Bank account information when we make a payment to you;
* Marketing & Communications data including your marketing preferences with us.
2c. For our end users we will store the information provided by you on our cloud based server. This is purely to facilitate the operation of the platform. During registration with us you will need to provide data including your name and email address to your concierge or building management. They will create your account for you. We do not have the right to create an account for a resident. Only the Concierge can do this. Once created you will be emailed with your username and password and we advise the password is changed instantly so only you have access to this.
Our team is available to support the development of these profiles upon receipt from the concierge team. This process ensures that the concierge team has obtained the necessary confirmation for account creation from their residents prior to our involvement.
The UK GDPR defines special category data as:
Personal data revealing racial or ethnic origin;
Personal data revealing political opinions;
Personal data revealing religious or philosophical beliefs;
Personal data revealing trade union membership;
Genetic data;
Biometric data (where used for identification purposes);
Data concerning health;
Data concerning a person’s sex life;
Data concerning a persons sexual orientation;
Criminal offence data.
We do not routinely collect any special category data.
3. INFORMATION WE COLLECT ABOUT CHILDREN UNDER 16
We do not routinely collect data from children under 16. If we do notice that a child of that age has accessed our website, any data collected will be deleted immediately.
4. HOW YOUR PERSONAL INFORMATION IS COLLECTED
We typically collect personal information about you through our online contact forms, and cookies via the websites. Any data collected on the platform will have been supplied by the end user either in their registration process or entered manually by them.
5. HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
To enter into a contract with our clients;
To facilitate the operation of our concierge platform;
For the purposes of billing and accounting;
To inform you of news, events and promotions we feel may be of interest to you - based on the marketing preferences we hold about you.
We need all the categories of information detailed in the list above primarily to allow us to perform our contract with you and to enable us to comply with legal and regulatory obligations. In some cases, we may use your personal information to pursue legitimate interests of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below.
* Administering the contract we have entered into with you and providing our products and services to you
* Making arrangements for the termination of our contracting relationship.
* Dealing with legal disputes involving you, or any disputes that may arise under the contract that we have with you or the way in which we provide our products and services to you.
* To prevent fraud.
* To ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.
* We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues as well as making sure we resolve any other complaints.
Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and modify this Privacy Policy.
6. IF YOU FAIL TO PROVIDE PERSONAL INFORMATION
If you fail to provide certain personal information when requested by us, we may not be able to perform the contract we have entered into with you (such as providing you with our services or guarantees), or we may be prevented from complying with our legal obligations (such as financial and tax reporting and insurance maintenance).
7. SHARING YOUR INFORMATION
In order to provide our services to you and to comply with our legal obligations, it may be necessary for us to share some data we hold with the following:
Financial organisations, credit reference agencies;
Suppliers and service providers which may include data storage facilities, Email host, IT service providers such as cloud providers;
Our own legal advisors.
8. Data retention
We will store your personal data for as long as we need to fulfil the purposes outlined in this Privacy Notice. Some data will have a different retention period, for example billing information may be held for up to 7 years to comply with Tax purposes, contact details from our website “contact us” page may be held for up to 12 months.
If you have any questions in relation to our retention of personal data, please contact us at info@aptlymanaged.com
9. TRANSFER OF PERSONAL DATA OUTSIDE THE UK
We may transfer your information outside of the country in which it was collected. Our core business platform is hosted in data centres within the EEA, however in some instances we transfer data to the US.
Such transfers of data may be to a country which may not provide the same level of privacy protection as the UK. However, we will take reasonable steps to ensure that your personal data are adequately protected by using the appropriate lawful means.
10. MARKETING
We may wish to send marketing materials to you on the basis of our legitimate interest. Where you have consented to marketing from one of our contact forms we will endeavour to adhere to the methods of marketing you have chosen.
It is the right of the individual to opt-out of, or unsubscribe from, any marketing material. Full details of how to do this will be included within each marketing communication. You may also opt-out by contacting us at the above contact details.
11. YOUR DATA PROTECTION RIGHTS
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
There are eight rights available to you, but not all of them will apply to every situation. It will depend on which lawful basis for processing we use to process your information. For more information on this please contact us at info@aptlymanaged.com
Your Rights:
The right of Access. You may submit a Subject Access Request – this enables you to receive a copy of the personal information we hold about you. To action this request, please contact us at info@aptlymanaged.com.
We require a suitable form of identification and under normal circumstances, we will supply this to you within one calendar month of your request and of identification being received. No fee is usually payable; however, we may apply an appropriate fee if the request is deemed to be excessive, or repetitive.
The right of Rectification – this enables you to have any incomplete or inaccurate information we hold about you corrected.
The right to Erasure – this enables you to request us to delete or remove personal information when there is no good reason for us to continue processing it.
The right to be Informed – you have the right to be informed of how we will collect and use your data, most of the information you will need is in this privacy notice.
The right to Object to processing – in certain circumstances, you have the right to request we suspend the processing of your data.
The right to Restrict processing – you have the right to request that we limit the way we use your data, whilst we are not obliged to delete the data, we have refrain from using it.
The right of Data Portability – you have the right to request the transfer of your personal data to a third party.
Rights in relation to automated decision making and profiling - you have the right not to be subject to a decision based solely on automated means including profiling.
Please contact us if you require more information on any of the rights available to you.
Right to Withdraw Consent – where we rely on consent to process your data, you have the right to withdraw this at any time, without giving reason. To withdraw your consent, please contact the Privacy Officer. Once received, we will not process your data for the reasons you have agreed to, unless we have another legal basis for doing so.
12. COOKIE STATEMENT
Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology
For further information, visit allaboutcookies.org
Cookie Consent and Opting Out.
You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.
How do we use Cookies?
Aptly uses cookies in a range of ways to improve your experience on our website, including;
Keeping you signed in;
Understanding how you use our website;
To load pages faster.
There are a number of different types of cookies, however, our website uses:
Functionality – Aptly uses these cookies so that we recognise you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
Advertising – Aptly uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. Aptly sometimes shares some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
The Our Company website contains links to other websites. Our privacy policy applies only to our website, so if you click on a link to another website, you should read their privacy policy.
13. contact us
We reserve the right to update this privacy notice at any time. If you have any questions about this privacy notice, please contact us at info@aptlymanaged.com
14. HOW TO MAKE A COMPLAINT
As an addition to the rights listed above, you also have the right to complain if you think we have made an error with your data. Of course, we would like you to contact us first to see if we can help to rectify any issues, but you also have the right to complain to the Information Commissioners Office (ICO). Their details are:
www.ico.org.uk/for-the-public/
The Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Phone number: 0303 123 1113
This Privacy Notice was last updated January 2024.