Privacy Policy

Thank you for visiting Apolitical. Please read our Privacy Policy, as you must agree to this document in order to be permitted to use our Service.

APOLITICAL GROUP LIMITED

PRIVACY POLICY

Thank you for visiting Apolitical. We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe.

Plain English

Apolitical’s Privacy Policy

At Apolitical our core value is ‘public service first’. We place paramount importance on maintaining your trust and take the protection and security of our users’ information very seriously. This privacy policy explains how we collect, use and share your data if you use the platform. We will provide notice of any updates to this policy on our website. Please do not hesitate to contact us with any questions at help@apolitical.co

  1. INTRODUCTION
    1. Apolitical Group Limited (“Apolitical” or “We” or “Us”) is a company registered in England and Wales with company number 09812036, whose registered office is at 12 Hammersmith Grove, London, W6 7AP, United Kingdom.
    2. This policy (the “Privacy Policy”) relates to the use of information we gather through use of any mobile applications, website(s), subscription forms, and software provided or made available by Us (the “Service”). It should be read in conjunction with our Terms. The Privacy Policy sets out the basis on which any data, text, files, images, videos, photos or profiles you upload via the Service (the “Content”) or any personal data that We collect from You or You provide to Us, will be processed by Us.
    3. Our Privacy Policy explains how We collect, use and share your Content. In particular please see sections 3 and 4 which set out how we use your information and the basis upon which we may share it with others. You understand and agree that Content you upload may be shared publicly. This means that other users may search for, see, use or share Content that you have made publicly available through the Service.
    4. We reserve the right to update the Privacy Policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.
    5. The easiest way to check for updates is by looking for the latest version of this policy on our website (link) or you can contact us (using the details in section 12 of this Policy) to ask us to send you the latest version of our policy. If You do not agree with the Privacy Policy, You should stop using the Service immediately. If You have any queries about the Service or the Privacy Policy, You can contact Us using the details as set out in section 12 of this Policy.

When you use our service, we collect the following information from you:

    1. Information you provide us directly when creating your user account,allowing us to contact you.
  1. INFORMATION WE COLLECT FROM YOU
  2. We collect and process the following types of data about You.

    1. Information You provide Us directly:
    2. Your username, password and e-mail address, name, job title, organisation, the sector you work in, your area of expertise and geographical area when You register for an Apolitical account and the Content You upload, plus any profile information that You provide for any user profile, Your name, email address and the sector You work in when You subscribe to Apolitical briefing products, and any personal information You provide in any communication between You and Apolitical.

  1. Information related to your usage of the site together with the information you upload about your interests, helping us improve your experience of the platform.
    1. Analytics information:
    2. We use third-party analytics tools to help Us measure traffic and usage trends for the Service. These tools collect information uploaded to the Service by you (eg name, job title, employer, location), together with information related to your usage of the Service, including any web pages You visit, the number and times of visits, information downloaded, click throughs, add-ons, and other information that assists Us in analysing usage of the Service by you personally (both individual visits and aggregated usage), and users generally, improving the user experience, and providing more targeted services.

  1. Cookies and similar technology, in order for us to provide features and services to you. Any content provided by commercial partners, which will be clearly labelled as ‘sponsored content’, may also use cookies.
    1. Cookies and similar technologies:
    2. Our Service uses cookies to distinguish You from other users. When You use the Service, We use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how You use the Service and how we may provide features to You. Commercial partners may serve sponsored content or services to Your devices, which may use cookies or similar technologies placed by Us or the third party. More information can be found in section 10.

  1. Information capturing your usage of the site such as click-throughs and page visits, allowing us to understand how the platform is being used and adding value.
    1. Log file information and URL:
    2. Log file information is automatically reported by Your browser each time You make a request to access a web page. It can also be provided when the content of the webpage or app is downloaded to Your browser or device. When You use our Service, Our servers automatically record certain log file information, including Your web request, Internet Protocol (“IP”) address, browser type, referring/exit pages and full Uniform Resource Locators (“URL”) clickstream to, through and from Our Service of products and content that You viewed or searched for, length of visits, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse Our Service.

  1. Device Identifiers, small data files which help us understand the devices users use to access our services and allow us to deliver personalised content.
    1. Device identifiers:
    2. When You use a mobile device like a tablet or phone to access Our Service, We may access, collect, monitor, store on Your device, and/or remotely store one or more “device identifiers.” Device identifiers are small data files or similar data structures stored on or associated with Your mobile device, which uniquely identify Your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by Apolitical. A device identifier may deliver information to Us about how You browse and use the Service and may help Us provide reports or personal content.

    1. Data associated with user content and activity.
    1. Metadata:
    2. Metadata is usually technical data that is associated with Your use of the Service or the Content you post. For example, metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.

This information will be used for the purposes of:

  • Keeping our service safe and secure.
  • Providing you with a personalised user experience, content, and information.
  • Providing, improving and monitoring the effectiveness of our service to you.
  • Updating and developing the service, notifying you of changes, and asking for your feedback.
  • Allowing network users to search and connect with other users via the Service.
  • Sending you platform member emails – allowing you to get the most of the core Apolitical service
  • Sending you emails about wider updates and opportunities, intended to help you get the most out of Apolitical’s wider work and partnerships – in line with your marketing preferences.

Here is a simple explainer for the emails users can expect from Apolitical and ways to change your preferences.

  1. HOW WE USE YOUR INFORMATION
    1. In addition to some of the specific uses of information We describe in this Privacy Policy, We may use information that we receive to:
    • help You efficiently access Your information after You sign in and remember information so You will not have to re-enter it during Your next visit the Website;
    • provide personalised content and information to You and others;
    • provide, improve, test, and monitor the effectiveness of the Service;
    • monitor the number of visitors, traffic and demographic patterns;
    • automatically update the Service application;
    • notify you occasionally about important changes or developments to the Service;
    • allow users of the Service to access and search the people finder facility available via the Service and connect with other registered users of the Service;
    • notify You of changes to the Service;
    • keep Our Service safe and secure;
    • provide You with information We may think is of use to You; including through the emails described below. See Our explainer for emails members can expect from Apolitical and ways to change Your preferences.
    • contact you by email or telephone from time to time, in order to liaise with you directly as a member of the Apolitical network
    • send You Service related emails (e.g., notifications about your account, changes/updates to features of the Website, technical and security notices and emails to keep you informed about policies and the public service, the network and updates on the platform. You cannot opt out of these emails though you can adjust your email preferences.
    • send you emails about relevant professional opportunities and promotions such as jobs, partner events and trainings, information about expansion in Our Service, and occasionally, to ask for your views on the Service and/or any of the content on the Service, in accordance with your marketing preferences (see section 5 of this Policy);

Where we must share your data with third party providers who help us deliver the platform service, we will first encrypt and anonymise your data before sharing it, except where strictly necessary for the function of the service (for example, using email campaign software to communicate with users requires us to share your email with the software provider, or sharing information with technical support providers who require access to the Service to carry out maintenance or development of the Service).

    1. We may use information that we receive to share with selected business partners, suppliers and sub-contractors that help Us provide the Service to You (the “Third Party Providers”). Our Third Party Providers will be given access to Your information only as is reasonably necessary to provide and/or improve the Service (e.g. to provide analytics on user activities, delivering enhancements to the Service, or providing additional or ancillary services to users). Any such Third Party Providers will be carefully selected by us, and be entities or persons whom we believe to be reputable. They will only be provided with any personal information to enable them to provide such services and not for any other purpose. Save where reasonably necessary, any personal information provided to Third Party Providers will be encrypted so that it is not personally identifiable.

We will never sell your personally identifiable information. We may use our collective data about activity on the platform to sell trends and insights reports, or place sponsored content (content provided by commercial partners) in the most relevant areas on the platform. However you will never be personally identifiable or targeted from such activity unless your permission has been expressly sought.

    1. We will not sell your personally identifiable information. While we may share certain information such as cookie data with Our commercial partners or combine Your information with other information and share that aggregated information, in doing so, any such information will be anonymised, and will not enable you to be individually identified. Some content may be provided to users based on filters used by them when searching for content on the Service, however no targeted content will be based on your individual Service profile, without your prior consent. Save as provided above, or as specifically provided elsewhere in this privacy policy, we will not disclose your personally identifiable information to any other party unless you have specifically consented to us doing so.

Any information you put on your profile and any content you post on may be seen by others, and could be made public via other users.

  1. SHARING AND DISCLOSURE OF YOUR INFORMATION
    1. Any information or Content that You voluntarily disclose for posting and sharing with other users of the Service, may become available to the public (whether through disclosure on public forums on the Service or via other users). You should carefully consider what information you are willing to share in a public forum.

We share data with group companies.

    1. In the day to day running our business we share your data with other companies that are part of the Apolitical group including Apolitical GmbH, based at Torstrasse 220, 10115 Berlin, Germany.

As described above we provide anonymised data to third party partners, unless where it is essential for us to share personal data to provide platform services to you, or where we have sought your expressed consent.

    1. We may share information as set out in 3.2 and 3.3 above. We may also provide additional anonymised information to our commercial partners, such as how often any sponsored content was clicked on by Our users. Such anonymised data may be used to provide targeted content to a specific audience (e.g. persons in a particular geographic location), however You would not be personally identified.

We will only disclose your information to a prospective acquirer of our business if suitable confidentiality arrangements are in place.

    1. We may disclose Your information to a prospective acquirer of our business, provided any disclosure is subject to reasonable confidentiality arrangements.

We may disclose your information to comply with legal obligations or prevent any illegal activity.

    1. We may disclose Your information, if We are under a duty to disclose or share Your personal data in order to comply with any legal obligation, or in order to enforce Our Terms or to protect Our rights. This may include responses to legal requests outside of the United Kingdom or, if in good faith, We believe it is necessary to detect, prevent or address fraud or any other illegal activity.

Please be aware that once you share any content on the service, it could remain retrievable even if you later delete it.

    1. Once You have publicly shared Content on the Service, this may be available to be re-shared by others. If You remove information that You posted to the Service, copies may remain viewable in cached and archived pages of the Service.

We only ever send emails to our members with information we believe is of value to your work and career. We can send you emails to help you get the most out of Apolitical’s wider work and partnerships, such as information about jobs, partner events and trainings and new Apolitical services – but will only do so if you have indicated that you want to receive them.

  1. HOW WE USE YOUR PERSONAL DATA FOR MARKETING
    1. We often come across and create opportunities that we believe are of value to Our users. These include relevant professional opportunities and promotions such as jobs, partner events and trainings, and new services from Apolitical, or additionally, wider and different types of coverage of policy and the policymaking community if You have only subscribed to an email product. We will only send You information about such opportunities and promotions by email if You have given Your prior consent to receiving them. We will never send You anything that we do not believe to be relevant and valuable to Your work and career in policymaking.
    2. Outside of the platform, we send You such communications by email. You can unsubscribe from these emails at any time, and when applicable, select preferences for individual types of marketing email.
    3. We may ask you to indicate your marketing preferences when you first register an account on our website and/or app. You can update your current marketing preferences at any time by emailing us using the details set out in section 12 below.
    4. We do not share your personal data with third parties for marketing purposes.

We will process your personal data lawfully, fairly and in a transparent manner.

  1. WHEN WE NEED YOUR CONSENT TO USE YOUR PERSONAL DATA
    1. Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it. In the day to day running of our business we may use your personal data without asking for your consent because:
    • we are entering into and carrying out our obligations under a contract with you, including to provide you with the Service that you have signed up for, including to stay informed about policy and the public service, and connect with peers, experts and partners.
    • we need to use your personal data for our own legitimate purposes, such as the effective running of our Service, the administration and management of our business and the improvement of our Service, and our doing so will not interfere with your privacy rights.
    1. If you have a legitimate reason for not wanting us to use your personal data for our own legitimate purposes (as set out above) we will take reasonable measures to address your concerns and tailor and/or anonymise, or restrict the use made of, the information we process as appropriate. If this is not possible, we will refrain from using such information. Please note that this may result in you not being able to use all or part of the Services.
    2. In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent. In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent. You are not required to give consent just because we ask for it. If you do give consent you can change your mind and withdraw it at a later date.
    3. Please refer to the section on How we use your personal data for marketing to read about marketing consents.
    4. You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our Service to you.

You can request personal data held by us about you and have certain other rights which are listed here.

  1. YOUR RIGHTS TO KNOW WHAT PERSONAL DATA WE HOLD AND CONTROL AND HOW WE USE IT
    1. You have a legal right to know what personal data we hold about you – this is called the right of subject access. You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us by email using the details in section 12 below. You also have rights to:
      • prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
      • have inaccurate personal data corrected, blocked or erased
      • object to decisions being made about you by automated means
      • object to our using your personal data in ways that are likely to cause you damage or distress
      • restrict our use of your personal data
      • require that we delete your personal data
      • require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file
    1. You can find full details of your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.
    2. We do not make use of automated decision making or profiling which produces significant legal effects concerning you or which otherwise significantly affects you.

Apolitical and its Third Party Partners who help provide the platform service operate in a range of countries. The information collected about you (as specified in Section 2) could be transferred and processed in any of these facilities.

  1. HOW WE STORE YOUR INFORMATION
    1. Your information collected through the Service may be stored and processed in the United Kingdom, the United States, the European Economic Area or any other country in which Apolitical, its group companies or Third Party Providers maintain facilities.

Although these countries may not have the same data protection laws as your jurisdiction we will do our utmost to ensure that your Content and information is treated security and in accordance with this Privacy Policy.

    1. Apolitical, its group companies, or Third Party Providers may transfer information that We collect about You across borders and from Your country or jurisdiction to other countries or jurisdictions around the world in order to provide the Service. We may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as Your jurisdiction. However, we will take all reasonable steps, so far as is possible, to ensure that Your Content and information is treated securely and in accordance with this Privacy Policy.

 We have put in place security measures to protect your personal data.

  1. HOW WE KEEP YOUR PERSONAL DATA SAFE AND HOW LONG WE KEEP YOUR PERSONAL DATA
    1. We take every care to ensure that your personal data is kept secure. The security measures we take include only storing your personal data on secure servers, ensuring that our staff receive regular data security awareness training, keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises.

While we use all reasonable endeavours to protect your personal information, security on the internet can never by 100% guaranteed.

    1. We use commercially reasonable safeguards (some of which are described above) to help keep the information collected through the Website secure and take reasonable steps to verify Your identity before granting You access to Your account. We cannot ensure the security of any information You transmit to Us or guarantee that information on the Website may not be accessed, disclosed, altered, or destroyed as the transmission of information via the internet is not completely secure.

You are responsible for the secrecy of your account and the use of the Service via your account.

    1. As highlighted in Our Terms, You are responsible for maintaining the secrecy of Your account and for controlling information and emails between You and Apolitical. Where the Service allows you to link to any other website, we are not responsible for the functionality, privacy, or security measures of any such other website.

You can delete your user account at any time. We will keep records of your information for at least three years after you cease being a member to deal with any follow up requests, or longer if required to comply with a legal obligation.

    1. We may retain Content and other profile/account information for so long as you remain a user of the Service, and, subject to any request from you that we delete your personal data, for at least 3 years afterward, in order to deal with any consequent queries or complaints you might have. We may refuse your request that we delete some or all of your personal data and/or retain personal data longer than 3 years if there is a legal reason or requirement to keep the information longer. You can delete Your user account at any stage.
    2. Please note that we may anonymise your personal data or use it for statistical purposes. We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.

Cookies help us recognise you when you return to the service, allowing us to provide a quicker and more customised service.

  1. COOKIES
    1. We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your device. Cookies are small files stored in your computer’s hard drive by your web browser. When you access the Service, if you have enabled cookies, our computer server will access these cookies so that it can recognise your device. These cookies help us to improve the Service and deliver a better and more personalised service. They enable us:
    • to estimate our audience size and usage pattern;
    • to store information about your preferences, and so allow us to customise the Service according to your individual interests;
    • to speed up your searches; and
    • to recognise you when you return to the Service
    • to see what web browsers and type of device you are using, your geographical location and, often, from which website or email link you have navigated to the Service.

You can change your cookie settings on your browser, or choose not to receive cookies on our site. Some aspects of the Service may not function in this case.

    1. When You first access the Apolitical site, we will give information about the cookies we use. By continuing to browse the Apolitical site You give your consent to the use of cookies.
    2. Most web browsers automatically accept cookies, and you can change your cookie settings at any time. Please note that in a few cases some features of the Service may not function if you remove cookies from your browser.

External media sites linked from the Service may contain cookies

    1. Please note that external sites including social media sites linked from the Service may also use cookies, and you should check carefully with these external sites what information is being collected using cookies.

You can contact us or the Information Commissioner’s Office if you are unhappy with the way we have used your personal data. Our promise is to seriously address any concerns about the use of your personal data with us.

  1. HOW YOU CAN MAKE A COMPLAINT
    1. If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in section 12 below.
    2. You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk. Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

We cannot take responsibility for website or services linked to and from our platform.

  1. GENERAL
    1. We are not responsible for the practices employed by any websites or services linked to or from our Service, including the information or content contained within them.

This Privacy Policy only applies to the Apolitical platform and not any linked third party websites or services, which will abide with their own Privacy Policies.

    1. When You use a link to go from our Website to another website or service, our Privacy Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. In addition, You agree that We are not responsible and do not have control over any third-parties that You allow to access Your User Content. If You allow access, You do so at Your own risk.

How to contact us

    1. All disclaimers and limitations on liability set out in the Terms and Conditions for users of the Service apply to this Privacy Policy.
    2. You can contact Us by email at help@apolitical.co, by telephone on +44 203 608 2241 or by post at 12 Hammersmith Grove, London W6 7AP, UK.
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Last Updated: 25th May 2018

Version: 2.0.1