Privacy policy

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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.

Table of Content

Apolitical Group Limited Privacy Notice

Thank you for visiting Apolitical. We have provided this Notice (“Privacy Notice”) 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.

1. Introduction

Apolitical is a company registered in England and Wales with company number 09812036, whose registered office is at 20-22 Wenlock Road, London, N1 7GU. References in this policy to “We”, “Us” or “Our” are references to Apolitical.

At Apolitical our core value is ‘public service first’, and your privacy is important to us. This Privacy Notice 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.

2. Information we collect from you

Whilst some of our platform’s features may be accessed without sharing personal data, in order to use many features of our service, you may be required to share your personal data. This privacy notice 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. We only collect personal data when it is necessary for us to operate our services.

  1. Account data: in order to use our services, you may need to create an account which requires that you provide your name, username, password and a professional email address. We use this information to enter into a contract with you or perform our contract while providing services to you.
  2. Profile data: you may choose to provide personal information including a photograph, job title, organisation or institution, the sector you work in, your areas of expertise, interest and geographical area and/ or other biographical information that you provide when you register and use our service. We use this information to enter into a contract with you or perform our contract while providing services to you.

    3. You may chose to make your email address visible to other platform members who you use our Connections feature to connect with. You maintain control about what information is visible to other platform members, which can be amended at any time in the Privacy & Settings tab in your profile. We use this information for our legitimate interests to build social networking on the Apolitical platform.

  3. Course and event data: When you register for a course or event on our service, we collect your account and profile data as well as engagement data, including enrollment, attendance and completion rates, quiz scores, and comment and chat data. This is for our legitimate interests to be able to provide and improve our services to users. We may also have a contractual obligation to share this data with our partners
  4. Content you upload when using our service: in the course of using our service, you may upload user generated content that contains personal data, including but not limited to writing a comment on an article or in our Q+A, engaging in the chat feature in a live event, or posting in a Community. You may also provide your personal data to be featured in a directory for cohort-based courses. We do this to improve the quality of our content offering to users. We may also use this data, in an identifiable or anonymised and/or aggregated form, to promote our service or share with our current or potential partners. This is for our legitimate interests to be able to provide and improve our services to users. We may also have a contractual obligation to share this data with our partners. If we wish to use your personally identifiable information for promotional or marketing material, we will seek your consent before we do so.
  5. Payment information: in order to facilitate payment for our premium services, we use a third party processor, Stripe. Stripe will collect billing information including address, debit or credit card information and contact details. We collect this data in order to fulfil a contract with you, and it is also within our legitimate interests to recover debts due to us.
  6. Special category data: from time to time, we may seek your explicit consent to share your gender or ethnicity data in order to better understand our user demographics, and improve the inclusivity of our website. You may decline to provide this, or revoke consent at any time. We do not solicit any other kinds of special category data, however, in the course of interacting with our services, you may make other types of special category data manifestly public.
  7. Communications: We collect your personal data including name, email address, the nature of your query and any other information contained in the communication between you and Apolitical. This may include when you contact our Community Support team (via concierge@apolitical.co) or our partnerships team (via partnerships@apolitical.co). We have contractual obligations with some partners to provide customer support to our members. We also process your communications data because it is within our legitimate interests to provide high quality support and resolve any user issues.
  8. Marketing: You may receive electronic marketing material from Apolitical. As specified in our Terms and Conditions, by creating an Apolitical account, you agree that you are registering as a professional, or corporate subscriber, and therefore that consumer law does not apply in regards to marketing regulations. Apolitical may therefore send you electronic marketing material without an opt-in. We only ever send emails to our members with information we believe is of value to your work and career. You can manage your marketing communications preferences at any time via your profile on the Apolitical website, and you may opt-out of receiving marketing material at any time. We process your data for marketing purposes because it is within our legitimate interests.
  9. Survey data: in order to improve the Apolitical platform and content, we may ask you to participate in surveys. We do not require you to input personal data into these surveys, but we may be able to identify your profile if you participate in a survey whilst you are logged in. We may use the aggregated survey results with our partners or to other third parties, but we will not share any data that can identify individuals without consent. You may additionally choose to consent to provide Personal Data in a survey, including Your name and contact details, so that an Apolitical colleague can reach out to you about your survey responses.
  10. Usage data: We collect information about how you interact with our site such as how long you spend on a page and how you navigate through the platform, including information about your browser, operating system, IP address, general geographic location, language and device identifiers. This is in our legitimate interest to deliver and improve our services and promptly identify issues in our platform.
  11. Cookie data: we collect tracking and cookie data in line with our Cookie Policy. This is in our legitimate interest to deliver and improve our services and promptly identify issues in our platform.
  12. Data from third parties: we may collect your personal data from a third party including:
    • If you are an institutional user (as defined in our Terms and Conditions), we will be provided with your personal data by your institution to enrol you on the appropriate cohort, including your name, email address, location, department and job title. We process this data to fulfil contractual obligations
      1. Your institution may also provide your information to be included in an Apolitical Community or a cohort directory. You may opt out of this processing at any time by contacting concierge@apolitical.co.
    • Publicly available sources, including social media sites such as LinkedIn. We may use these to create content on our service including top 100 lists, as well as to contact you about contributing content such as being an event speaker. From time to time, we may also use public databases to retrieve contact information for prospective leads, partners and members. This is within our legitimate interests to create content to be published on our service.
    • When you are referred to our service by one of your colleagues or connections, they will provide your name and email address for us to invite you to our service via email. If you don’t register as an Apolitical user, we will delete your information after 30 days. We process this data because it is within our legitimate interests to grow our membership.
    • Other users of our service may post, publish, or link to data about you as part of their use of the service. This data is processed for our legitimate interests to improve our content offering for our users.
    • We provide share buttons against some of our content to enable you to easily share it. You should only share content with other users of our Services or other public servants that may have a professional interest in our services. We can see when you have clicked on a share button but we cannot see any information about the people you share our content with.
  13. Metadata: Metadata is 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. This is in our legitimate interest because it allows us to understand what content is most important to our users, and to continue meeting user demand.
  14. Recruitment: If you apply for a role with Apolitical, we will process data associated with your application. This will include account and profile data, as well as any data you provide in support of your application, including cover letters, CVs and references. This is within our legitimate interests to hire new staff.

3. Data accuracy

Plain English

It is your responsibility to keep your data up to date.

Apolitical's Privacy Policy

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.

4. Sharing and disclosure of your information

We rely on third party providers to help us deliver our service. Where we must share your personal data with third party processors, we carefully assess and select providers against their data privacy and security capabilities. 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.

We maintain GDPR-compliant data processing agreements with third parties and ensure that we have adequate safeguards in place with all of our third party providers with whom we share personal data. You can find a list of the third party providers we use to run our service, including the agreements we have in place with them, here. Please contact us (by using the contact details referenced in Section 13 of this Privacy Notice) if you need further details about our selected third party providers and the extent to which they are required to process your personal data.

Any personal data that you (or other users) share on our service can be seen by other platform members, and may become available to the wider 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 13 of this Privacy Notice or reporting the content on our service).

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.

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

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.

If you have been granted access to our services by your institution, or one of our partners, we may share your personal data with that organisation or institution. This includes sharing information about your engagement with the Apolitical Platform and content, as well as redemption of access codes and any decision which you may make to cancel your subscription to our services.

5. How we use your personal information for marketing

We may share aggregated or anonymised data with our current or prospective partners. The information we share with them will not allow you to be identified. We do not sell your data to third parties.

6. Your rights

You have certain data and privacy rights, including to:

  • know what personal data we hold about you – this is called the right of subject access
  • have your data deleted- this is also known as the right to erasure
  • 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.

You can exercise these rights by sending us a request at any time. You may email dpo@apolitical.co, or contact us via email using the contact details in Section 13 of this Privacy Notice. We will respond within 30 calendar days to your request.

You can find full details of your personal data rights on the Information Commissioner’s Office website at

www.ico.org.uk

.

7. Where your personal data is processed

Your personal data may be stored and processed by us or our third party providers in the United Kingdom, the United States, the European Economic Area (EEA) or any other country in which Apolitical and our third party providers maintain facilities. These countries may not have the same data protection laws as those applicable in your jurisdiction.

We will only transfer personal data outside of the UK or European Economic Area UK 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.

Information about where your data is processed by our third party processors can be found here.

Some of our contractual partnerships have more specific data location processing obligations. If you have any questions about this, please contact your institution, or Apolitical’s data protection officer at

dpo@apolitical.co

8. How we keep your personal data safe

We take every care to ensure that Your personal data is kept secure. The organisational security measures we take include ensuring that our staff receive regular data protection 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. We also prohibit unauthorised access to our offices.

The technical security measures we take only storing our personal data on secure servers and maintaining back ups of our data. We also hold Cyber Essentials Plus certification and carry out in-depth checks to ensure that all third party processors handling personal data have appropriate security controls in place, including being ISO 27001 or SOC Type 2 certified.

We use commercially reasonable safeguards 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.

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 information with anyone else.

Where you have been provided with an access code or access link allowing you to access ur premium services by a third party, such as your employer, 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.

9. How long we keep your personal data

You can delete your user account at any time. 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.  To delete your account, you should email concierge@apolitical.co and request your account to be deleted.

After your account has been deleted, we will keep records of your information in accordance with our retention policy. We may process your information where it is reasonably necessary for us to comply with any legal, regulatory, tax, accounting or reporting requirements.  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 these purposes.

If your account includes access to our premium services and either you or your institution removes your access to premium services, your account will continue to exist. We will continue to process 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. You may email concierge@apolitical.co to request that your account be deleted at any time.

When you request that we delete your account, we will inform any relevant third party processors and ask them to delete your data. Your data may be subject to their retention policies- please refer to their Privacy Notices, available here, for further information.

We may retain Publicly Available Information for up to 5 years from our last interaction with the individual to whom it relates.

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 may 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.

10. 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.

11. How you can make a complaint

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 13 of this Privacy Notice.

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.

12. General

This Privacy Notice only applies to our service and not any linked third party websites or services, which will abide with their own Privacy Notices.

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.

13. Contact us

You can contact our Data Protection Officer by email at dpo@apolitical.co, by telephone on +44 203 608 2241 or by post via our correspondence address at 251 Southwark Bridge Road, London, SE1 6FL.

For general enquiries, please contact our Community Support team by email at concierge@apolitical.co, by telephone on +44 203 608 2241 or by post via our correspondence address at 251 Southwark Bridge Road, London, SE1 6FL.

Last Updated: March 2023