Privacy Policy

Introduction

Welcome to Aperture’s privacy policy.

We respect your privacy and are committed to protecting your personal data. This privacy policy informs you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements any other such notices and privacy policies and is not intended to override them.

We keep our privacy policy under regular review to ensure that it is accurate and current. It is also important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

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‍Who we are

This website is operated by Glow Grow Ltd (trading as Aperture), a company registered in England and Wales with company registration number 14212044. Our registered office is at 71-75 Shelton Street 71-75 Shelton Street, London, WC2H 9JQ.

We are the controller responsible for your personal data and are registered as a data controller with the Information Commissioner's Office (ICO). Our ICO registration number is: ZB666773.

If you have any questions about this privacy policy or our privacy practices, please contact us by email at hello@aperture.london.

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The data we collect about you

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). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes your first name, maiden name, last name, marital status, title, date of birth and gender.
Contact Data includes your address, email address and telephone number.
Usage Data means information about how you use our website, products and services.
Financial and Transaction Data means details about transactions carried out between you and us and payments to and from you and other similar information, including where applicable your bank account and payment card details.
Technical Data includes your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
Marketing and Communications Data means your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We may on occasion collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) if you choose to share such data with us, which may then be anonymised and form part of our Aggregated Data, for example for the purposes of demographic data relating to the users of our services. We do not collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

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How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us by post, phone, email or otherwise interacting with us directly. This includes personal data you provide when you apply for our products or services; attend events we hold or interact with us in person; subscribe to or participate in our services or publications; request marketing to be sent to you; or give us feedback or otherwise contact us.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookies policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

o Technical Data from analytics providers such as Google, advertising networks, and search information providers

o Contact, Financial and Transaction Data from providers of technical, payment and delivery services; and

o Identity and Contact Data from publicly available sources such as Companies House.

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How we use your personal data

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 we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

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Purposes for which we will use your personal data

We have set out in the table below 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.

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 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.

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Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase or other transactions.

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Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We share your personal data with our staff for the business purposes described above, such as providing services to you and operating this website. In addition, we may share your personal data with the parties set out below for the purposes set out in the table above:

Third-party vendors, processors, service providers, freelancers, consultants, contractors or agents who perform services for us or on our behalf and who require access to such information to do that work, such as:

o IT maintenance and service providers, providers of software applications through which our IT systems and document management activities are carried out, as well as the hosting of these software applications;

o banks and payment services providers;

o data analysis, data statistics, surveys/feedback, and customer service providers; and

o service providers for our administrative/secretarial services, internal organisational flows, such as our digital productivity, collaboration, and organisational app, video-conferencing solutions and calendar application services.

Professional advisers such as our lawyers, bankers, auditors and insurers.
Governmental, legal, regulatory, tax or similar authorities, ombudsmen, central and/or local government agencies; and/or law enforcement officials (if mandated by law and regulation or if required for the protection of our legitimate interests).
Any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security in accordance with applicable law and regulation.
Any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation) or the assets or business of any of our funds.

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.

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International transfers

Our company is located in the United Kingdom but some of our staff, freelancers, service providers and external third parties may be based outside, or have part of their operations outside, the UK so their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following conditions applies:

that the country in question has been deemed to provide an adequate level of protection for your personal data; and/or
that appropriate measures are in place in our contractual arrangements with third parties to ensure an adequate level of protection for your personal data.

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Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

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Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected personal data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.

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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 in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, namely:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o If you want us to establish the data's accuracy.

o Where our use of the data is unlawful but you do not want us to erase it.

o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

o You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at hello@aperture.london.

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 if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We 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.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (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.

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Cookies:

Our website uses cookies to distinguish you from other users of our website. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. Cookies helps us to provide you with a good experience when you browse our website and allows us to improve our site. Some of the cookies we use are essential for the site to operate. They enable us to:

estimate our audience size and usage pattern;
store information about your preferences, and to allow us to customise our site according to your individual interests;
speed up your searches; and
recognise you when you return to our site.

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We may use the following cookies from time to time:

Strictly necessary cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.
Analytical or performance cookies: These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily.
Functionality cookies: These are used to recognise you when you return to our website. This enables us to personalise our content for you and remember your preferences regarding certain areas of the website.
Targeting cookies: These cookies record your visit to our website, the pages you have visited and the links you have followed.
Flash cookies: Our website may from time to time use the Adobe Flash Player to deliver audio and video content. The Flash Player uses a Flash Cookie (or Local Shared Object as it is technically known) to provide functionality features such as saving video playback preferences.

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You can block cookies by activating the option on your browser that allows you to refuse the setting of all or some cookies. Advice on blocking cookies on a variety of popular browsers can be found online and you may be able to consult the ‘help’ section of your browser for instructions on how to block cookies. Please note that if you use your browser settings to block all cookies (including essential cookies) you may not be able to access parts of our website. Moreover, disabling Flash cookies may result in you being unable to play content through our media players.

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privacy policy