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(A) THIS NOTICE
Summary – This Notice.

This Notice explains how we Process Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates.

This Notice is issued by each of the Controller entities listed in Section (R) below (together, “aptember.com”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, visitors to our Sites, users of our Apps, other users of our products or services, and visitors to our premises (together,below.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

(B) COLLECTION OF PERSONAL DATA

Summary – Collection of Personal Data

We collect or obtain Personal Data: when those data are provided to us (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, products, or services; or when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).

Collection of Personal Data: We collect or obtain Personal Data about you from the following sources:

Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card, or when you submit a job application).
Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., we provide a service to you, or to your employer).
Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
App data: We collect or obtain Personal Data when you download or use any of our Apps.
Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, Apps, products, or services.
Content and advertising information: If you interact with any third party content or advertising on a Site or in an App (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).

(C) CREATION OF PERSONAL DATA

Summary – Creation of Personal Data

We create Personal Data about you (e.g., records of your interactions with us).

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, and details of your past interactions with us. We may also combine Personal Data from any of our Sites, Apps, products, or services, including where those data are collected from different devices.

(D) CATEGORIES OF PERSONAL DATA WE PROCESS
Summary – Categories of Personal Data We Process

We Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.

We Process the following categories of Personal Data about you:

Personal details: given name(s); preferred name; and photograph.
Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
Contact details: correspondence address; shipping address; telephone number; email address; details of Personal Assistants, where applicable; messenger app details; online messaging details; and social media details.
Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent). Purchase details: records of purchases and prices; consignee name, address, contact telephone number and email address.
Payment details: invoice records; payment records; billing address; payment method; bank account number or credit card number; cardholder or accountholder name; card or account security details; card ‘valid from’ date; card expiry date; BACS details; SWIFT details; IBAN details; payment amount; payment date; and records of cheques.
Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information.
Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions.
Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.

(E) SENSITIVE PERSONAL DATA
Summary – Sensitive Personal Data

We do not seek to collect or otherwise Process Sensitive Personal Data. Where we need to Process Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or
Consent: We may Process your Sensitive Personal Data where we have, in with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

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