Aptos, LLC along with, as applicable, its subsidiaries, affiliates, successors, and assigns (“Aptos”, “we”, “us” or “our”) provides this Privacy Policy (“Privacy Policy”) to help you understand how we collect, store, use and disclose information, including personal information that you may provide to us or that we may obtain through our partners where we act as a data processor. This Privacy Policy applies to www.aptos.com (the “Site”) and any applications hosted within the Aptos environment. We may update this Privacy Policy from time to time, so please check back here periodically.
Information collected and our lawful basis to process that data
This section includes details of the purposes for which we use personal information and also the different legal grounds upon which we process that personal information. We use personal information to provide and improve services and for other purposes that are in our legitimate interests, as well as for compliance purposes. Further information is set out below. Some laws require us to explain our lawful reason for processing your personal information. We process personal information about you on the basis that it is:
- necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfil that contract
- in our or a third parties’ legitimate interests (e.g., provision of services that we are contractually obliged by a third party)
- where you give us your consent: we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent for compliance with a legal obligation (e.g., to respond to a court order or a regulator)
We use personal information for a number of legitimate interests, including to provide and improve services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.
As a Processor: In submitting your information to our partners and/or clients, you do so subject to their own privacy policies. In return, our partners share your information across our applications in order to meet your transactional needs. The information we collect is only that information required to process your transactions on behalf of our partners or clients. This may include your name, address, telephone number, email address and other contact information.
As a Controller: Where you give us your personal information in order to do business with us, we would again view that data as necessary to perform a contract, or to reach a stage where we could enter into a contract.
Where you are an event registrant:
When you register to attend an Aptos event, Aptos will use the information you provide to register you for the event, make necessary arrangements for your participation at the event, gain feedback, and to inform you of future events. We process the personal data that you submit including your name, contact details, and travel information. Aptos’ event planning staff may need to share some of these details with third parties who are providing services to Aptos in connection with the event (eg. hotels, caterers, venues, transportation companies, etc.) including virtual platform providers such as Bizzabo and E-180. We only retain business contact information (and no personal information) following the event. This information is used to track historical attendance and inform you of future events. You are entitled to access any personal data that the Aptos event planning team holds about you and have it corrected where necessary, or request that it be deleted from record. Please contact us at events@aptos.com for more information or to request corrections or deletions, or contact the Data Protection Officer whose details can be found at the bottom of this Privacy Policy.
Data sharing
As a Processor or a Controller: Aptos may share personal information within the Aptos organization (including our worldwide partners and other members of the Aptos group of companies) to fulfil its obligations to you and operate its business consistent with this Privacy Policy and applicable data protection law.
As a Processor: We may need to share your personal data in order to provide support to our partners or clients where we operate as a processor. This data transfer may include transferring the data overseas to our support teams, some of which may be subcontracted. This is subject to our contractual arrangements defined to secure your data and to provide a legal framework for the transfer.
Your rights
Because Aptos operates globally, we may transfer your personal information within our global operations to fulfil our obligations to you, but always subject to the limitations of applicable data protection law and this Privacy Policy. Privacy laws differ across the globe. Depending on your geographic region, you may be entitled to the following rights: This Privacy Policy applies solely to information collected by Aptos on its Site.
- Right of Access. You have the right to obtain from us confirmation as to whether or not personal data concerning you are processed, and, where that is the case, you have the right to request and get access to that personal data.
- Right to Rectification. You have the right to obtain from us the rectification of inaccurate personal data and you have the right to provide additional personal data to complete any incomplete personal data.
- Right to Erasure (“Right to be Forgotten”). In certain cases, you have the right to obtain from us the erasure of your personal data.
- Right to Restriction of Processing. You have the right to obtain from us restriction of processing, applicable for a certain period and/or for certain situations.
- Right to Data Portability. You have the right to receive from us in a structured format your personal data and you have the right to (let us) transmit such personal data to another controller.
- Right to Object. In certain cases, you have the right to object to processing of your personal data, including with regard to profiling. You have the right to object to further processing of your personal data in so far as such data has been collected for direct marketing purposes.
- Right to be Not Subject to Automated Individual Decision-Making. Aptos does not undertake automated decision making.
- Right to File. You have the right to file complaints with the applicable data protection authority on our processing of your personal data. In the case of Aptos, our principal Data Protection Authority is the ICO in the UK. They can be contacted here: https://ico.org.uk/global/contact-us/
How to Contact Aptos
If you have any questions, comments, or concerns about this Privacy Policy, please email us at legal@aptos.com or write to us at:
Aptos, LLC.
945 East Paces Ferry Rd. NE, Suite 2500
Atlanta, GA 30326
Attention: Legal Department
Or the Data Protection Manager: dpmanager@aptos.com