Data protection and privacy policy
The purpose of AP Capital Holding’s (depending on geographical area: (i) England: AP Capital Holding Limited, (ii) England: AP Capital Holding England Oy, (iii) England: AP Capital Holding Poland sp. z o.o., (iv) England: AP Capital Holding - hereafter "LTD") Personal Data Policy is to explain how we collect, treat and protect personal data.
AP Capital Holding has a clear ambition to limit the use of personal data as much as possible and to create a high degree of transparency regarding how data is used.
This policy will therefore inform you about which types of data that we deal with, how we go about this and which rights you have regarding your data.
Introduction
This data protection and privacy policy (the “Policy”) describes how AP Capital Holding (“us”, ”we” or ”our”) collects and processes personal data relating to the purchase of services, membership, products or general use of our website.
The Policy is prepared and made available to comply with the general data protection regulation (2016/679 of 27 April 2016) (the ”GDPR”) and the rules included herein on information to be provided to you.
Collecting personal data with cookies
By visiting and using our website(s), cookies are collected and used on the basis of consent. Information in these cookies include browser type, IP address, search terms on our website(s). (hereinafter 'Cookiedata').
Cookiedata is used for improvement of the website(s) and the user experience, to deliver our products, services or goods. We also use Cookies for the purpose of tracking statistics on the number of visitors to our website and to display resolution and preferences.
Our use of cookies for the purpose of collecting personal data is being carried out in accordance with the Cookie Order (No. 1148 of 9 December 2011), section 3.
If you wish to limit or decline the cookies placed on your computer when visiting our website you can do so at any time by changing your browser settings. However, you should be aware that if you decline or reject cookies it will impact the functionality of the website which means that there are features on the website that you will not be able to see. Any browser allows that you delete cookies collectively or individually. How this is done depends on the used browser. Remember to delete the cookies in all browsers, if you use several different browsers.
Types of personal data processed
If you visit our website, we collect data about your IP address and computer control system, your mobile unit, your internet browser and what you do on the website, for example, your searches. We do not collect this information unless you have given your permission.
If you submit an inquiry via our contact formular, we will gather the following data: name, e-mail, telephone number, country and any information that you state in your inquiry.
If you are a business partner, investor or have another relationship to AP Capital Holding, we will collect name, address and other relevant personal data to facilitate a business relationship.
If we need to collect more personal data than what is specified above, we will inform about this. Such information may be provided by our updating of this Policy.
Purposes for processing the personal data
We only process personal data for legitimate purposes in accordance with the GDPR. Depending on the circumstances, the personal data is processed for the following purposes:
- To deliver products or services to a user, customer or member
- To facilitate our business activities building.
Legal basis for processing personal data
We only process your personal data when we have a legal basis to do so in accordance with the GDPR. Depending on the specific circumstances, the processing of personal data is done on the following legal basis:
- If we have asked for a consent for the processing of specific personal data, the legal basis for such personal data is a consent, cf. article 6(1)(a) of the GDPR, as the consent can always be withdrawn by contacting us via the contact details provided at the end of this Policy, and, if the consent is withdrawn, the personal data processed on the basis of consent is deleted, unless it can or must be processed, for example, in order to comply with legal obligations.
- The processing is necessary for the performance of a contract to which the data subject is party, cf. the GDPR, article 6(1)(b), the first indent.
- The processing is necessary in order to take steps at the request of the data subject prior to entering into a contract, cf. the GDPR, article 6(1)(b), last indent.
- The processing is necessary for compliance with applicable legislation, cf. the GDPR, article 6(1)(c).
- The processing is necessary for the purposes of the legitimate interests where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, cf. the GDPR, article 6(1)(f).
Disclosure and transfer of personal data
We only pass on personal data to others when the law allows it or requires it. Our organisation is part of a concern/company group where personal data is shared between the group companies depending on the circumstances.
We transfer personal data to the following recipients from the EU/EEA:
- Banks (for example in connection with payments etc.)
- Data processors
- Partners and
- Investors.
From time to time we use external companies as suppliers to assist us in delivering our services. The external suppliers will not receive or process personal data unless the applicable law allows for such transfer and processing. Where the external parties are data processors, the processing is always performed on the basis of a data processor agreement in accordance with the requirements hereto under GDPR. Where the external parties are data controllers, the processing of personal data will be performed based on said external parties’ own data privacy policy and legal basis which the external parties are obligated to inform about unless the applicable legislation allows otherwise.
We may transfer personal data to countries or international organisations outside the EU/ EEA in the following circumstances:
We may use Microsoft services to process personal data. You can read more about Microsoft's protection of personal data and their use of sub processors on this link: https://privacy.microsoft.com/
Erasure and retention of personal data
We ensure that the personal data is deleted when it is no longer relevant for the processing purposes as described above. We also retain personal data to the extent that it is an obligation from applicable law, as is the case with for example accounting and bookkeeping materials and records. If you have any questions about our retention of personal data, please contact the email mentioned in the last section of this Policy.
Data subject rights
Data subjects have a number of rights under the GDPR. If a data subject wants to make use of his or her rights, he or she can contact us. The rights include the following:
- The right of access: Data subjects have a right to ask for copies of the information that we process about them, including relevant additional information.
- The right to rectification: Data subjects have a right to ask for rectification of inaccurate personal data concerning him or her.
- The right to erasure: In certain circumstances data subjects have a right to obtain the erasure of personal data concerning him or her before the time when erasure would normally occur.
- The right to restrict processing: Data subjects have, in certain situations, a right to have the processing of his or her personal data restricted. If a data subject has the right to have the processing of his or her personal data restricted, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest in the European Union or of a European member state.
- The right to object: Data subjects have, in certain situations, a right to object to the legal processing of his or her personal data.
- The right to data portability: Data subjects have, in certain situations, a right to receive his or her personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller without hindrance from the data controller to which the personal data has been provided.
More information about data subject rights can be found in the guidelines of the national data protection authorities.
If a data subject wishes to make use of his or her rights as described above, the data subject is asked to use the contact details provided at the end of this Policy.
We strive to do everything to meet wishes regarding our processing of personal data and the rights of data subjects. If you or others despite our endeavours wish to file a complaint, this can be done by contacting the national data protection authorities.
Changes to this Policy
We reserve the right to update and amend this Policy. If we do, we correct the date and the version at the bottom of this Policy. In case of significant changes, we will provide notification in the form of a visible notice, for example on our website or by direct message.
Contact
If you have questions or comments to this Policy or if you would like to invoke one or more data subject rights, please contact us at email: GDPR@ap-holding.co.uk.
Website usage terms and conditions
The information on the website is correct at the time of publishing, as far as reasonably possible. AP Capital Holding does not guarantee that information, links or other data retrieved from the website are correct. AP Capital Holding is not liable under any circumstances for any errors or omissions in the website content. AP Capital Holding reserves the right to make changes or corrections at any time without prior notice. Interruptions of service may occur at any time due to site maintenance or other reasons. AP Capital Holding does not accept liability arising from any interruptions of service or other disruptions that may occur on the website.
Copyright
The content on this website is the property of AP Capital Holding and is protected by copyright law. Unless otherwise stated, the content must not be reproduced, transmitted, copied, distributed or stored without prior permission from AP Capital Holding.