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.

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 (“Privacy 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 personal data for the purpose of providing our Service (the Apolitical website, platform, and email products). We will provide notice of any updates to this policy on our website. Please do not hesitate to contact us with any questions at dpo@apolitical.co

Changes to this policy apply to your use of our Service after the date on which such changes take effect. 

1. INTRODUCTION

  1. Apolitical Group Limited (“Apolitical”) is a company registered in England and Wales with company number 09812036, whose registered office is at Public Hall, 1 Horse Guards Avenue, London, United Kingdom, SW1A 2EP. References in this policy to “We”, “Us” or “Our” are references to Apolitical.
  2. We provide a multimedia website, publishing, educational and networking platform, and email update service, all of which support professional social networking, collaboration and the sharing of information and ideas across government, public services and the public sector, allowing You to upload content and download information as well as using any applications We may make available to You. Throughout this policy, We refer to these activities as Our “Service”. Our Service includes Our free-of-charge services and the services which We provide if You have subscribed for Our ‘premium services’. References in this Privacy Policy to “You” or “Your” are references to a person using, or wishing to use, Our Service.
  3. This Privacy Policy details how We will collect and use Your personal data in the course of providing Our Service. It should be read in conjunction with Our terms and conditions. Please take particular note of sections 4, 6, 7 and 9 of this Privacy Policy which set out how We use Your personal data and the basis upon which We may share it with others. As a result of the use of Our Service by You or by others, some of the personal data You provide, such as Your name and job title, may become publicly available and visible to individuals who are not users of Our Service. References in this Privacy Policy to “personal data” refer to any information relating to You from which You can be identified directly or indirectly.
  4. We may update this Privacy Policy from time to time. This may be to reflect a change in Our Service or to Our internal procedures, or it may be to reflect a change in the law.
  5. The easiest way to check for updates to this Privacy Policy is by looking for the latest version of this Privacy Policy on Our website or You can contact Us (using the contact details in section 15 of this Privacy Policy) to ask Us to send You the latest version of this Privacy Policy. You can find the date on which this Privacy Policy was last updated at the end of this Privacy Policy.
  6. If You continue to use Our Service after We have updated this Privacy Policy that means that the collection, use and sharing of Your personal data is subject to the updated Privacy Policy as of its effective date. If You object to any changes to this, or any updated, Privacy Policy, You may close Your account for Our Service.
  7. If You have any queries about Our Service or this Privacy Policy, You can contact Us using the contact details as set out in section 15 of this Privacy Policy.
When you use our service, we collect the following information from you:

  1. Information you provide us directly when signing up or using any of our services, or publicly available information about you.
  2. Our users may post or provide data related to other individuals.
  3. Information related to your usage of the site, such as the frequency of your visits, the pages you view and the devices you view them on.
  4. Data associated with user content and activity.
  5. Publicly available information.
2. INFORMATION WE COLLECT FROM YOU

We collect and process the following types of data about You:

  • Profile and Content Data You provide to Us: Your username, password and email address, photograph, name, job title, organisation or institution, the sector You work in, Your areas of expertise, interest and geographical area that You provide when You register or subscribe for and use Our Service, including personal data contained in any content You upload when using Our Service and any personal data You provide in any communications between You and Apolitical.
  • Data provided by other users: Any personal data that may be included by other users of Our Service when they use Our Service.
  • Usage data:
    1. Information uploaded to Our Service, together with information related to Your usage of Our Service, any web pages You visit, the times and lengths of visits and any interactions You have with the web pages.
    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.
  • Metadata: Metadata is usually technical data that is associated with Your use of Our Service or any content You post. For example, metadata can describe how, when and by whom a piece of user content was posted and how that content is formatted.
  • Publicly Available Information: Personal data obtained from public sources, such as Your organisation’s or institution’s website which is used by Us to contact individuals who are not currently signed up to Our Service, in relation to Our offerings, as well as to help Us improve Our Service.
It is your responsibility to keep your data up to date.

3. DATA ACCURACY

         It is Your responsibility to ensure that You review and update the personal data linked to Your account from time to time to ensure it is complete, up to date and accurate. These details can checked within the ‘edit profile’ section of Our website.

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 our Service, notifying you of changes, and asking for your feedback.
  • Allowing network users to search and connect with other users via our 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.

4. HOW WE USE YOUR INFORMATION

  1. We will only use Your personal data when the law allows Us to. Most commonly, We will use Your personal data in the following circumstances:
    • where You have consented to Us using Your personal data for a specific purpose;
    • where We are carrying out Our obligations under a contract with You;
    • where it is necessary for Our legitimate interests (or those of a third party) and this will not interfere with Your privacy rights; and
    • where We need to comply with a legal obligation.
  2. We have set out below, in a table format, a description of all the ways We plan to use Your personal data, and which of the legal bases We rely on to do so. We have also identified what Our legitimate interests are where appropriate.
  3. Note that We may process Your personal data for more than one lawful ground depending on the specific purpose for which We are using Your data. Please contact Us (by using the contact details referenced in section 15 of this Privacy Policy) if You need details about the specific legal ground We are relying on to process Your personal data where more than one ground has been set out in the table below.
  4. In exceptional circumstances We may wish to use Your personal data for a purpose which is incompatible with the purpose for which We originally collected Your personal data. In these circumstances We will contact You to explain how We wish to use Your data and, if appropriate, to ask for Your consent to use Your personal data for the new processing purpose. You are not required to give Your consent just because We ask for it. If You do give Your consent You can change Your mind and withdraw it at a later date.
Purpose/Activity Type of personal data We process Lawful basis for processing including basis of legitimate interest
To register You as a user of Our Service. Profile and Content Data To perform a contract with You.
To process Your order to subscribe for Our ‘premium services’. Profile and Content Data To perform a contract with You.
To deliver Our ‘premium services’ to You including (a) managing and facilitating Your payment of subscription fees (b) collecting and recovering subscription fees owed to Us and (c) communicating information about the redemption of any access code with the organisation or institution which has provided the access code to You. Profile and Content Data To perform a contract with You.

Necessary for Our legitimate interests to recover debts due to Us.

To provide You with a personalised user experience, and recommendations around content, other users, and information. Profile and Content Data

Usage Data

Metadata

Necessary for Our legitimate interests to improve Our Service and provide greater value to users and future users.

To perform a contract with You.

To monitor and improve the effectiveness of Our Service. Usage Data

Metadata

Necessary for Our legitimate interests to understand Our users’ preferences and to keep Our website up to date and relevant and to inform Our future development strategy for the benefit of Our users and future users.
To allow users to search, discover and connect with each other via Our Service. Profile and Content Data Necessary for Our legitimate interests to improve Our Service and provide greater value to users and future users.

To perform a contract with You.

To allow Your Apolitical profile to appear in Internet searches. Profile and Content Data Necessary for Our legitimate interests (to develop and increase the number of users of Our Service).
To keep You informed about policies and the public service, the network and updates on Our networking platform as part of Our core Service. Profile and Content Data Necessary for Our legitimate interests (to present relevant information to users of Our Service, making it more user friendly).

To perform a contract with You.

To inform non-users about Our Service and its offerings. Publicly Available Information Necessary for Our legitimate interests (to grow Our user base and develop Our business).
To manage Our relationship with You which will include (a) notifying You about changes to Our terms and conditions and this Privacy Policy (b) asking You to leave a review or take a survey and (c) processing any request by You (or Your organisation or institution) to cancel Your subscription to Our ‘premium services’. Profile and Content Data Necessary for Us to comply with a legal obligation.

Necessary for Our legitimate interests (to keep Our records updated and to understand what Our users would like from Our Service).

To perform a contract with You.

To send You optional updates and notifications of opportunities such as partner events and trainings, job postings, offers or initiatives for policy makers in accordance with Your contact preferences. Profile and Content Data We will send You these opportunities based on consent We obtain from You.
We will create a user profile for you based on your activity and interests, in order that we can personalise our Service and highlight content which we deem to be more relevant for you.

5. PERSONALISATION OF OUR SERVICE

         In order to allow individuals to more quickly find the content and contacts most relevant to them, We will create user profiles based on the information users have given Us and their activity on Our networking platform so that We can partially personalise users’ experiences on Apolitical, showcasing content and connections from Our networking platform that most closely match the user profile. If You wish to opt out of this, You can do so by emailing dpo@apolitical.co. You should note that this may result in You seeing content which may not be as relevant to You.

Where we must share your personal data with third party providers who help us deliver our Service, we will first encrypt your data before sharing it, except where strictly necessary for the functioning of our 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 our Service to carry out maintenance or development of our Service).

If you are required to pay us a subscription fee for use of our premium services, we use a selected third party to process your payment.

We have agreements in place with all of our third party providers with whom we share personal data. 

Any personal data you put on your profile and any content you post on our Service may be seen by others, and could be made public.

We will never sell your personal data.

Apolitical Group Limited is part of a group of companies. We share personal data with another company in our group based in Germany.

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

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

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

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

If you have subscribed to our premium services using an access code provided by your organisation or institution, we may share your personal data with that organisation or institution in particular regarding redemption of the access code and any decision which you may make to cancel your subscription to our premium services.   

6. SHARING AND DISCLOSURE OF YOUR INFORMATION

  1. We may share Your personal data with selected business partners, suppliers and sub-contractors that help Us provide Our Service to You (the “Third Party Providers”). Our Third Party Providers will be given access to Your personal data only as is reasonably necessary to provide and/or improve Our Service (for example, to provide analytics on user activities or delivering enhancements to Our Service). 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 data to enable them to provide such services and not for any other purpose. Save where reasonably necessary, any personal data provided to Third Party Providers will be transferred in an encrypted form as part of Our security measures.
  2. Please note that if We accept Your order to subscribe to Our ‘premium services’ or if You are renewing Your annual subscription to Our ‘premium services’ Your personal data will be processed by Our selected third party payment processor solely for the purpose of obtaining, and confirming to Us, payment of Your subscription fee.
  3. We maintain GDPR-compliant data processing agreements and ensure that We have adequate safeguards in place with all of Our Third Party Providers with whom We share personal data. We remain responsible for how such Third Party Providers use the personal data We share with them.
  4. Please contact Us (by using the contact details referenced in section 15 of this Privacy Policy) if You need further details about Our selected Third Party Providers and the extent to which they are required to process Your personal data.
  5. Any personal data that You (or other users) voluntarily disclose for posting and sharing with other users of Our Service, may become available to the public. You should carefully consider what information You are willing to share about Yourself in a public forum. If posting content in which You identify other individuals You must comply with Our terms and conditions and, in particular, ensure You do not post anything defamatory about other individuals. If You become aware that another user has posted personal data about You on Our Service that You are uncomfortable with, please contact Us (by using the contact details referenced in section 15 of this Privacy Policy).
  6. We will not sell Your personal data but We do share aggregated, anonymised data, such as aggregated, anonymised cookie or usage data with Our commercial partners or with a wider audience. Such information will not enable You to be individually identified.
  7. We may disclose Your personal data 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 and conditions or to protect Our rights. This may include responses to legal requests within or outside of the United Kingdom or if We believe it is necessary to detect, prevent or address fraud or any other illegal activity.
  8. We may disclose Your personal data to a prospective acquirer of Our business (or any part of it), provided that any disclosure is subject to reasonable confidentiality arrangements.
  9. In the day to day running of Our business We share Your personal data with Apolitical GmbH, based at Torstrasse 220, 10115 Berlin, Germany. Apolitical GmbH is part of the same group of companies as Apolitical. 
  10. Once You have publicly shared personal data on Our Service, this may be available to be re-shared by others. If You remove personal data that You posted to Our Service, copies may remain viewable in cached and archived pages of Our Service.
  11. If You are an ‘Institutional User’ (as defined in Our terms and conditions) or have been provided with an access code for subscribing to Our ‘premium services’, We may share Your personal data with Your organisation or institution or the organisation or institution which has provided You with such access code. This may include informing such organisation or institution about (a) the redemption (or non-redemption) of any access code provided to You and (b) any cancellation of Your subscription to Our ‘premium services’. 
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 send you any such generic emails if you have indicated that you want to receive them.

7. 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 Our networking 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 to use Our Service. You can update Your current marketing preferences at any time by emailing Us using the contact details set out in section 15 of this Privacy Policy, or via the links which You will find at the bottom of Our mailings.
  4. We do not share Your personal data with third parties for marketing purposes.
You can request personal data held by us about you. Your other rights are listed here.

8. YOUR RIGHTS TO KNOW WHAT PERSONAL DATA WE HOLD 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 request at any time. Please mark Your letter “Subject Access Request” and send it to Us by email using the contact details in section 15 of this Privacy Policy. You also have rights to/in relation to:
    • be informed about how and why We process Your personal data;
    • have any personal data that is inaccurate or incomplete corrected or completed;
    • have certain categories of Your personal data erased when We no longer have a valid reason to process it;
    • restrict processing so Your personal data is only used for certain, limited purposes;
    • data portability, meaning that We will provide You or a third party You nominate with a copy of Your personal data in a commonly-used, machine readable format;
    • object to the purposes for which We process Your personal data; and
    • be provided with information explaining how and why We use automated decision making and profiling and, in some cases, object to such practices.
  2. You can find full details of Your personal data rights on the Information Commissioner’s Office website at www.ico.org.uk.
Apolitical and its Third Party Partners who help provide our 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.

9. WHERE YOUR PERSONAL DATA IS PROCESSED

  1. Your personal data collected through Our Service may be stored and processed by Us, Our group companies and Our Third Party Providers in the United Kingdom, the United States, the European Economic Area or any other country in which Apolitical, its group companies or its Third Party Providers maintain facilities. These countries may not have the same data protection laws as those applicable in Your jurisdiction.
  2. We will only transfer personal data outside of the European Economic Area (“EEA”) if:
    • the recipient is based in a country which is subject to an EU Commission adequacy finding; or
    • adequate safeguards sanctioned under the GDPR or the Data Protection Act 2018 have been implemented; or
    • where a derogation applies under the GDPR or the Data Protection Act 2018.
  3. We will take all reasonable steps to ensure that Your personal data is treated securely and in accordance with this Privacy Policy when transferred to a recipient outside of the EEA. You may contact Us (by using the contact details referenced in section 15 of this Privacy Policy) at any time to discuss international data transfers in more detail.
We have put in place security measures to protect your personal data. While we use all reasonable endeavours to protect your personal information, security on the internet can never by 100% guaranteed. 

You are responsible for the secrecy of your account password and login details and any use of our Service via your account.

You are responsible for the secrecy of any access code given to you to upgrade to our premium services.

10. HOW WE KEEP YOUR PERSONAL DATA SAFE

  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 protect 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.
  2. We use commercially reasonable safeguards (some of which are described above) to help keep the personal data collected through Your use of Our Service 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 Our website may not be accessed, disclosed, altered, or destroyed as the transmission of information via the internet is not completely secure.
  3. Where You have a password or login details to access Our Service, You are responsible for maintaining the secrecy of these. You should ensure that any password You choose is not obvious or common. You should not share Your password or other login details with anyone else.
  4. Where You have been provided with an access code allowing You to access Our ‘premium services’, You are responsible for keeping the access code confidential and not disclosing it to anyone else (except as directed by the organisation or institution which has provided You with the access code) until the access code has been redeemed to upgrade Your account to Our ‘premium services’.
You can delete your user account at any time. We will keep records of your information in accordance with our retention policy. 

Note that your profile will no longer be accessible via our Service if you delete your account but will be retained by us as detailed in our retention policy for internal purposes.

11. HOW LONG WE KEEP YOUR PERSONAL DATA

  1. References in this section to ‘Profile and Content Data’, ‘Data provided by other users’, ‘Usage data’, ‘Metadata’ and ‘Publicly Available Information’ refer to the types of data We collect and process about You as described in section 2 of this Privacy Policy.
  2. We will retain Your Profile and Content Data, Data provided by other users, Usage data and Metadata for 6 years from the date upon which We delete Your user account (after You have told Us that You wish to close Your user account) or, if later, from the resolution of any dispute, query or complaint You have made.
  3. You can tell Us at any time that You wish to close Your user account. You must do this by sending an email to Us as detailed in section 15 of this Privacy Policy. As soon as reasonably practicable after receiving Your email We will reply to You and then delete Your user account. When We delete Your user account Your profile will no longer be visible to other users of Our Service, but that does not mean that We will cease to hold and process Your personal data. Once We have deleted Your user account We will retain Your personal data for the period referred to in section 11.2 of this Privacy Policy and during such period may process Your personal data to the extent reasonably necessary to comply with any legal, regulatory, tax, accounting or reporting requirements which apply to Us.
  4. If Your account includes access to Our ‘premium services’ and (a) You decide to cancel Your subscription to Our ‘premium services’ (b) Your organisation or institution tells us that it wishes to cancel Your subscription to Our ‘premium services’ or (c) Your subscription to Our ‘premium services’ terminates, Your user account will not be deleted unless You have informed Us that You also wish to close Your account. Any personal data which You have provided to Us, or which We have obtained, for the purpose of allowing You to access and use Our ‘premium services’ will continue to be held and processed by Us in accordance with the terms of this Privacy Policy (unless You have informed Us that You wish to close Your account).
  5. If You do not use Your user account for a period of 6 years We will automatically delete Your user account so that Your profile is no longer accessible. We will continue to hold Your Profile and Content Data, Data provided by other users, Usage data and Metadata data in line with section 11.1 of this Privacy Policy.
  6. We will retain Your contact details on Our marketing database until the earlier of Your withdrawal of consent to receiving Our marketing communications or closing/deletion of Your user account (by You or by Us due to account inactivity).
  7. We may retain Publicly Available Information for up to 5 years from Our last interaction with the individual to whom it relates.
  8. Please note that We may anonymise Profile and Content Data, Data provided by other users, Usage data, Metadata and Publicly Available Information or use it for statistical purposes. We keep such 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 in running and improving our Service.

12. COOKIES

We use cookies for a variety of purposes to assist Us in running and improving Our Service. More information can be found within Our cookies policy.

You can contact us or the Information Commissioner’s Office if you are unhappy with the way we have used your personal data. 

We promise to treat any concerns about the use of your personal data by us seriously.

13. 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 15 of this Privacy Policy.
  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.
This Privacy Policy only applies to our Service and not any linked third party websites or services, which will abide with their own Privacy Policies. 

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

We are not responsible for the actions of third parties you allow to access your account.

14. 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.
  2. When You use a link to go from Our website to another website or service, this 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.
  3. We are not responsible and do not have control over any third parties that You allow to access Your account. If You allow access, You do so at Your own risk.
You can contact us by email, by telephone or by post using the contact details given here.

15. CONTACT US

You can contact Us by email at dpo@apolitical.co, by telephone on +44 203 608 2241 or by post at Public Hall, 1 Horse Guards Avenue, London, United Kingdom, SW1A 2EP.

Last Updated: October 2020