Acturis Group Privacy Policy

December 2022

This privacy policy sets out how we use and protect any personal information that you give us. We take your privacy seriously therefore we urge you to read this policy carefully because it contains important information about us and:

  • the personal information we collect about you, as a website user, a customer contact, a prospective customer, supplier, other business contact, or job applicant;
  • what we do with your information; and
  • with whom your information may be shared.

Acturis is committed to ensuring your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, by completing a survey, registering for an event or a webinar hosted by us or interacting with us as a business contact or a job applicant, then you can be assured that it will only be used in accordance with this privacy policy.

Acturis may be required to make updates to this privacy policy from time to time. You should check this page regularly to ensure that you are happy with any changes. This policy is effective from 16th June 2020.

Who we are

This privacy policy applies to the Acturis Group (the “Group”). The Group is made up of different legal entities, details of which can be found here. This privacy policy is issued on behalf of the Group so when we mention “Acturis”, the “Company”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data. Acturis Limited and any affiliate noted above with which you have a direct business relationship is a ‘Data Controller’ for the purposes of processing personal data as described in this privacy policy.

What personal information we may collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). Information you may give us, or we may collect from you, may include the following:

  • identity data including first name, last name, address, the name of the company you work for, job title;
  • contact information including email address, telephone number;
  • technical information, including your Internet Protocol (IP) address, your login data, browser type and version;
  • marketing and communications data, including your preferences in receiving marketing and your communication preferences;
  • questions, queries or feedback you leave if you contact us;
  • answers to questions including feedback on our products and services and ways for us to improve;
  • information on how you use the website, use cookies and page tagging techniques;
  • your current and former employment information;
  • information about your use of our products and services; and
  • business information, including information provided in the course of the contractual or client relationship between you or your organisation and Acturis, or otherwise voluntarily provided by you or your organisation.

How we collect personal information

We may collect and process your personal information in the following circumstances:

  • when you visit the website;
  • when you register with us to attend events or webinars hosted by us;
  • when you contact us through the website, by telephone, email or through any other means;
  • when you complete one of our voluntary surveys that we use for research and service improvement purposes;
  • when you apply directly to us for employment;
  • when you disclose your information to us, or we collect your information from you, in any other way, through this website or otherwise.

If you provide us with personal information on behalf of someone else you confirm that the other person has appointed you to act on his or her behalf and agreed that you can. In addition, where you give us personal information belonging to someone else you must ensure that you have the necessary grounds, consents or authorisations to provide it to us.

Purposes for which we will use your personal information

In accordance with data protection legislation, we will only process your personal data where we have a lawful basis for doing so. These bases are: (i) where it is necessary for the performance of a contract we have with you or your organisation, or pre-contract activities made at your request; (ii) where you have provided your consent; (iii) where it is necessary for us to comply with a legal obligation that we are subject to; or (iv) where it is in our (or a third party’s) legitimate interests and such interests are not overridden by your interests or fundamental rights and freedoms. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

The purposes for which we may process your personal data and the lawful basis on which we carry out such processing may include the following:

Where it is necessary for the performance of a contract

  • for administration of contract negotiations;
  • for management of the contract and our products and services;
  • for administration of your registration and attendance at one of our events (including webinars);
  • to manage our relationship with you including asking you to leave a review or take a survey;
  • to communicate with you including responding to your enquiries.

Where you have provided your consent

  • for sending you any third party direct marketing communications, if any.

Where it is necessary for us to comply with a legal obligation

  • to meet legal, regulatory and compliance requirements, including responding to requests from regulators, and financial reporting.

Where it is in our (or a third party’s) legitimate interests and such interests are not overridden by your interests or fundamental rights and freedoms

  • to understand your needs, answer your query and get back in touch with you to respond, where appropriate;
  • to carry out surveys from time to time to assess areas for us to improve upon as a business;
  • for customer administration e.g. for invoicing and maintaining internal records;
  • for administration and protection of our business operations and websites;
  • for monitoring, reviewing and performing analysis of your use of our products and services in order to develop and improve our products and services;
  • for administration of our hosted events (including webinars);
  • informing you about our products, services and events that may be of interest to you, or that are similar or relate to products and services you have purchased from us;
  • to carry out recruitment and administer work placement activities;
  • to perform lead scoring for marketing purposes, which use automated profiling to analyse your potential interest in our products, services, or events, based on your use of our website and related queries made of us.

Disclosures of your personal information

We may share your personal information with the following parties for the purposes we set out above:

  • internal third parties: other companies within our Group acting either as joint controllers or processors: and who are based in the United Kingdom, the EEA or Canada
  • external third parties including the following:
    • service providers acting as processors based in the United Kingdom, the EEA, the US or Canada who process personal information on our behalf, based on our instructions and any other appropriate confidentiality and security measures. Such businesses will be required to act in accordance with the instructions we give them and to meet the requirements of the Data Protection Act 2018 as well as the General Data Protection Regulation (“GDPR”), or other local legislation as applicable to that entity or the personal information. Such entities may include service providers whom we instruct to assist with the management of our products and services, providers of certain business support tasks and providers of business development and marketing support services.
    • professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom, the EEA or Canada who provide consultancy, banking, legal, insurance and accounting services.
    • external hosting providers: the Acturis website is hosted by an external website hosting provider. As a result, this provider and any resellers who provide user support to Acturis will have access to your information (including your email and other data). This external hosting provider may also be able to view statistics regarding your use of the website as well as any personal information you send to us.
    • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom, the EEA or Canada, who require reporting of processing activities in certain circumstances.
    • companies, organisations or individuals outside of the Group for legal reasons if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
      • meet any applicable law, regulation, legal process or enforceable governmental request
      • enforce applicable Terms of Service, including investigation of potential violations
      • detect, prevent, or otherwise address fraud, security or technical issues and
      • protect against harm to the rights, property or safety of Acturis, our users or the public as required or permitted by law
    • third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Mobile App: the Acturis mobile application is hosted by external app store providers. When you download the mobile app from the App Store or Google Play, such providers may be able to view statistics regarding your use of the mobile app as well as see any personal information you send to them. This will be governed by such provider’s privacy policy.

We may share non-personally identifiable information publicly and with our partners. For example, we may share information publicly to show trends about the general use of our services.

If you wish to know more about the parties with whom we share personal information, please contact us at info@acturis.com.

International transfers

We may transfer your personal information to a third party or other Group companies in countries within or outside the European Economic Area (EEA) or Canada, as applicable, for further processing in accordance with the purposes for which your personal information was originally collected or for purposes to which you have consented or that are otherwise permitted by applicable law.

If we transfer your personal information to a country outside of the EEA, or Canada, as applicable. we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the Information Commissioner’s Office, or European Commission, or other data protection regulator as applicable to that personal data;
  • where we use certain service providers, we may use specific contracts approved by the Information Commissioner’s Office, or European Commission, or the relevant data protection regulator, as applicable, which gives personal data the same protection it has in the jurisdiction;
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between UK, Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or Canada.

Data security

We are committed to ensuring that your information is secure. We have implemented technical and organisational measures designed to secure your personal information from accidental loss and from unauthorised access, use, alteration or disclosure. We require third parties receiving personal information from us to ensure that your personal information is protected by technical and organisational measures.

How we use cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then all data is removed from the system.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Learn more about the cookies we use.

Links to other websites

Our website may contain links to other websites. Once you have left our site, we are no longer responsible for the protection and privacy of any information which you provide whilst visiting such sites. You should exercise caution and look at the Privacy Policy of any third party website before submitting any personal information to them.

Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

  • when completing the ‘Get in Touch’ form on the website, tick the box to indicate that you would like to receive marketing communications relating to the services offered by the Acturis Group.
  • If you do not wish to receive marketing emails, postal marketing, or other forms of direct marketing from us, please contact us at marketing@acturis.com with “Marketing Unsubscribe” in the subject heading and provide the details of your request. You may also unsubscribe from marketing emails from us by using the Unsubscribe link at the bottom of our marketing emails. We acknowledge that our use of your personal information for these purposes is at your option and we will not refuse you access to any product or service merely because you have instructed us to stop using your personal information for these purposes.
  • when responding to a customer survey or event invitation, click to indicate you do not want us to follow up with you on any of your feedback.
  • you can also object to the processing of your personal information by us at any time and ask us to restrict or stop such processing by notifying us directly at info@acturis.com.

We will not sell, distribute or lease your personal information to third parties unless you have consented for us to do so or are required to do so by law.

Your legal rights

If our legal basis for processing your personal information is based upon your consent, you have the right to withdraw consent at any time.

You may object to our processing of your personal information where we do so based upon our legitimate interests. Where required under applicable law, we will stop any such processing and notify you if that changes.

If we made a decision about you that was based solely upon the automated processing of your personal information, including profiling, and our decision produces a legal effect for you or similarly significantly affects you, you may have the right to contest that decision and ask for human review on our part.

You may request that we disclose to you certain details regarding our processing of your personal information, or that we correct, amend, delete, or restrict the processing of, or provide to you, the personal information we hold about you. Where required under applicable law, we will notify any third party recipients of this, where possible. Please note, however, that requests are subject to any applicable legal and ethical reporting or data retention obligations imposed on us.

You may exercise these or any other rights available to you under applicable law by emailing us at info@acturis.com with your specific request.

Upon receipt of your written request and enough information to permit us to identify your personal information, we will try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If we are unable to take action on your request, we will, as required by applicable law, annotate the personal information under our control with a note that action was requested but not made. In this event, we will notify you without undue delay of the reasons for not taking action.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee, where allowed by applicable law, based on our administrative costs in complying with your requests; for instance, where you request further copies of the information we hold about you, or where requests are unfounded or excessive.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period where required by applicable law or where we have a legitimate and lawful purpose to do so for example, to provide you with an answer to a question you have asked or to comply with applicable legal requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Contact

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer at: info@acturis.com.

You have the right to make a complaint at any time to the relevant supervisory authority, depending on your jurisdiction, for data protection issues. The UK supervisory authority for data protection issues is the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Leadoo

User tracking We use Leadoo’s tracking service to follow what users are doing on the site and combine this behavioral data with other data we can gather from e.g. chat interactions. Leadoo uses etag tracking in order to hook together the same users behavior over several sessions – in practice this works similarly to cookie based tracking. Please check out Leadoo Marketing Technologies Ltd’s Privacy Policy.