Privacy Policy
By accessing this page and using the Web Site www.apaxon.co.uk you signify your acceptance of our Privacy Policy. If you do not agree to this policy, please do not use our site. Your continued use of the Apaxon Limited site following the posting of changes to these terms will mean that you accept these changes.
1.0 General
Apaxon® Limited trading as Apaxon® IT Support (“we”, “us” or “Apaxon® IT Support”) take the privacy of your information very seriously.
This Privacy Notice is designed to explain our practices regarding the collection, use and disclosure of personal information we may hold about clients and customers, suppliers, and other third parties.
This privacy notice does not apply to information we hold in relation to our staff and contractors which is covered by a separate privacy notice.
This notice applies to any personal information we hold about individuals (other than staff), whether they are a client or otherwise. In this notice “you” refers to any individual whose personal data we hold or process.
This notice is governed by the EU General Data Protection Regulation (the “GDPR”) from 25 May 2018.
This notice applies to personal data we hold about you. “Personal data” means information that relates to you as an identified or identifiable person.
2.0 Legal basis on which we process personal data
2.1 Personal data we hold about you will be lawfully processed based on one of the following legal reasons (known as a “legal basis”):
2.1.1 Because the processing is necessary for a “legitimate interest”, a legitimate interest in this context means a valid interest we have, or a third party has, in processing your personal data which is not overridden by your interests in data privacy and security;
2.1.2 Because the processing is necessary in order for us to comply with our obligations under a contract between you or your employer and us; or;
2.1.3 Because you have consented to the processing.
3.0 Personal data which we collect
3.1 We may collect and process the following personal data about you:
3.1.1 Contact information which we hold because you are employed or engaged by a client of ours, or have registered an interested in finding out more about our services (for instance your email address or contact telephone number) (“Client Contact Information”);
3.1.2 Any other personal information which you provide to us as your client or in your capacity as an employee of our client, as part of our service provision (“Validation Information”);
3.1.3 Contact information which we hold because you are a third party relevant to the services we provide to our clients (you may for example be a supplier or vendor) (“Third Party Contact Information”);
3.1.4 Records of emails and other correspondence between you and us and our employees (“Communication Information”);
3.1.5 Other public information which is generally available (“Public Information”).
You do not have to supply any personal information to us and you may withdraw our authority to process your personal data at any time.
4.0 How we process your Personal Data
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| When you or your employer engage us to provide services |
Client Contact Information
Validation Information |
Performance of a contract
Necessary for our legitimate interests (to establish necessary information about you in order to provide our services). |
| When we provide services to you / your employer |
Client Contact Information
Validation Information Communication Information Third Party Contact Information |
Performance of a contract |
| When we communicate with third parties on behalf of our clients in the provision of our services |
Client Contact Information
Third Party Information |
Performance of a contract |
| To manage and administer our relationship with you as a client or third party |
Client Contact Information
Third Party Contact Information |
Performance of a contract |
| Dealing with a complaint or services enquiry |
Client Contact Information
Communication Information |
|
| Invite you to events on behalf of our clients or to general events in given areas of interest or concern |
Client Contact Information
Third Party Information |
5.0 Data Retention
Our current data retention policy is to delete or destroy (to the extent that we are able to) the personal data we hold about you in accordance with the following;
| Category of personal data | Length of retention |
|---|---|
| Records relevant for tax purposes | 8 years from the end of the tax year to which the records relate |
| Personal data processed in relation to a contract between you (or your employer) and us | 7 years from the end of our contract with you or your employer |
| Personal data held on general contact databases | 3 years from the last date on which you have interacted with us |
5.1 For any category of personal data not specifically defined in this Notice, and unless otherwise specified by applicable law, the required retention period for any personal data will be deemed to be 7 years from the date of receipt by us of that data.
5.2 The retention periods stated in this Notice can be prolonged or shortened as may be required (for example, in the event that legal proceedings apply to the data or if there is an on-going investigation into the data).
5.3 We review the personal data (and the categories of personal data) we are holding on a regular basis to ensure the data we are holding is still relevant to our business and is accurate. If we discover that certain data we are holding is no longer necessary or accurate, we will take reasonable steps to correct or delete this data as may be required.
6.0 Sharing your information
We do not disclose personal information you provide to any third parties other than as follows:
6.1 As part of the provision of services we may disclose information to suppliers, and third parties as part of the performance of a contract (although we will not disclose personal contact information without your consent);
6.2 If we are sub-contracting services to a third party we may provide information to that third party in order to provide the relevant services;
6.3 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime);
6.4 in order to enforce any terms or agreements for our services;
6.5 to protect our rights, property and safety, or the rights, property and safety of our users or any other third parties. This includes exchanging information for the purposes of fraud protection.
Other than as set out above, we will not disclose any of your personal information unless you give us permission to do so. If we do supply your personal information to a third party we will take steps to ensure that your privacy rights are protected and that third party complies with the terms of this notice.
7.0 Security
7.1 We will take all reasonable steps to ensure that appropriate technical and organisational measures are carried out in order to safeguard the information we collect from you and protect against unlawful access and accidental loss or damage.
7.2 This notice and our procedures for handling personal data will be reviewed as necessary.
7.3 All SARs and other requests or notifications in respect of your above rights must be sent to us in writing to info@apaxon.co.uk.
7.4 We will endeavour to comply with such requests as soon as possible but in any event we will comply within one month of receipt (unless a longer period of time to respond is reasonable by virtue of the complexity or number of your requests).
8.0 Data Breaches
If personal data we hold about you is subject to a breach or unauthorised disclosure or access, we will report this to the Information Commissioner’s Office (ICO) and/or our data protection manager or officer (if an officer has been appointed).
If a breach is likely to result in a risk to your data rights and freedom, we will notify you as soon as possible.
9.0 Transferring your information outside Europe
9.1 Our services are international in nature. As part of the services we provide information may be transferred to, processed and stored at, countries or international organisations outside of the EEA.
9.2 We will not transfer any data in a systematic way outside of the EEA but there may be circumstances in which certain personal information is transferred outside of the EEA, in particular:
9.3 We may communicate with individuals or organisations outside of the EEA in delivering our services, those communications may include personal information (such as contact information);
9.4 We may be required to provide certain personal information as part of a legal reporting obligation to an entity outside the EEA (for example the US Federal Government) and some of that information may be made public;
9.5 From time to time your information may be stored in devices which are used by our staff outside of the EEA (but staff will be subject to our cyber-security policies).
9.6 If we transfer your information outside of the EEA, and the third country or international organisation in question has not been deemed by the EU Commission to have adequate data protection laws, we will provide appropriate safeguards and your privacy rights will continue to be enforceable against us as outlined in this notice.