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1. Introduction

This privacy policy sets out how Active Profile Ltd uses and protects any information that you give when you use this website or share when communicating with us.

Active Profile Ltd is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this policy.

Active Profile Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from April 9 2018.


2. Who we are

“We”, “us” and “our” in this policy means us, Active Profile Ltd.

Our registered business address is:

Unit 5
Baltic View
14 Brick Street
L1 0BN

Our company number is: 05192225

We are registered with the Information Commissioner’s Office (the ICO), and our registration number is: Z8804253


3. Contact us

If you have any comments, questions or concerns about how or why we use your data, how long we keep it or what rights you have over it, please get in touch.

You can contact us by IM on our website, by emailing info@activeprofile.co.uk, by calling +44 (0)151 556 7050 or by writing to us at the address above (please mark FAO Data Protection).


4. Your information

This section describes how we collect and use your personal information.

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 (such as anonymous data).

We will only use your personal information when the law allows us to. The law says that we must identify a lawful basis for each use of your personal data. We rely on a number of lawful bases, including:

1. Where we have obtained freely given, specific, informed and unambiguous consent from you to use your personal information in certain ways.

2. Where we need to perform a contract that we have entered into with you.

3. Where we need to comply with a legal obligation.

4. Where it is necessary for us to use your personal information to pursue our legitimate interests (or those of a third party) and we believe that using your personal information in that way is not overridden by your interests or your fundamental rights.

Below, we have set out the purposes for which we use each category of your personal data and the lawful bases which are relevant to those purposes.


4.1. The kind of information that we hold about you

We collect, store and use some or all of the following categories of personal information about you:

* Usage information: IP address, location, browser details, operating system details, referral source, duration of visit, page views, website navigation information and service use details. We use usage information to analyse the use and performance of our website and services. Our lawful basis for this processing is our legitimate interest in delivering our services, and monitoring and improving our website and services.

* Account and profile details: name, address, telephone number, email address, usernames, passwords, profile picture, title, gender, data of birth, relationship status, education information, employment information. We use this information to provide our services, enable certain parts of our website, to ensure the security of your information and to inform our communications with you. Our lawful basis for this processing is our legitimate interest in the proper administration of our website and services.

* Service information: details about you in either your personal or professional capacity that you disclose to us in the course of us providing our services to you, including data that you provide for the purposes of publishing. We use this information in the course of providing our services to you. Our lawful basis for this processing is that it is necessary in order for us to perform our contract with you.

* Communication information: email address, address, telephone number, social media account usernames, communications content, communications metadata, enquiries. We use this information to communicate with you, including responding to your questions, or providing information about our services, website or relationship. Our lawful basis for this processing is our legitimate interest in building our relationship and communicating with you.

* Subscription details: email address, subscription preferences. We use this information to send you relevant newsletters and marketing information. Our lawful basis for this processing is consent.

We may also process your personal information where we have a legal obligation to do so. This may include disclosing personal information to regulators, the courts or law enforcement bodies.


4.2. If you fail to provide personal information

If you fail to provide certain personal information when we request it, we may not be able to perform our contract with you properly (meaning we may not be able to provide our services properly) or we may be prevented from achieving our legitimate interests (such as ensuring that our website is up to date and works properly).


4.3. Change of purpose

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another purpose and that purpose is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so.


5. Security

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure the information we collect online.

This includes:

* securely encrypting your data;

* testing our security and conducting audits to ensure that it stays up to date; and

* putting contractual terms in place with third parties that process your data to ensure that your data and your rights are secured.


6. Data transfers

We may share your data with third parties, including third-party service providers, suppliers, subcontractors and other entities in the group. We require all third parties to respect the security of your data and to treat it in accordance with the law.

All third parties are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow third parties to use your personal data for their own purposes. We only permit them to access your personal data for specific purposes and in accordance with our instructions, or in the case of clients for the specific purposes that we have agreed with them in advance.

We may share your personal information with other third parties, for example in with a potential purchaser in the context of a potential sale or restructuring of the business. We may also need to share your personal information with a regulator to comply with the law.

We may transfer your personal information outside the EU. If we do, you can expect a similar degree of protection in respect of your personal information.

Transfers will always be subject to adequate safeguards.

These safeguards may take the form of an adequacy decision. Adequacy decisions are made by the European Commission in respect of certain countries. An adequacy decision means that the countries to which we transfer your data are deemed to provide an adequate level of protection for your personal information.

To ensure that your personal information does receive an adequate level of protection in the absence of an adequacy decision, we will put in place binding corporate rules or standard contractual clauses approved by the European Commission or the ICO to ensure that your personal information is treated by those third parties in a way that is consistent with and respects the EU and UK laws on data protection. If you require further information about these protective measures, please contact us using the details at the top of this page.


7. 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 cookies to monitor how people use our website including estimating audience size and patterns of use in order to help us to provide you with a better service. Cookies make it easier for you to log on and use the website during future visits. They also allow us to personalise the content of the website for you by storing information about your preferences. We use the following cookies:

* Strictly necessary cookies. These are cookies that are required for the operation of our website.

* Analytical/performance cookies. They 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 (for example, your choice of language or region).

* Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

We also use Web Beacons. Some of the pages on our website and e-mail newsletters may contain electronic images called web beacons, sometimes known as one pixel GIFs, clear GIFs or pixel tags. These allow us to measure engagement with our communications They are not used to access personally identifiable information without your consent.

Please note that third parties may also use cookies, over which we have no control.

We use Google Analytics to analyse the usage of our website. Google Analytics uses cookies to collect information about website use. You can find more information about Google Analytics in Google’s privacy policy here: https://www.google.com/policies/privacy/.

We also use HubSpot to report on website activity. HubSpot uses cookies to collect information that tracks activity across our site. You can find more information on these cookies in HubSpot’s privacy policy here: https://legal.Hubspot.com/privacy-policy.

We may use cookies to:

* Analyse our web traffic using an analytics package. Aggregated usage data helps us improve the website structure, design, content and functions.

* Test content on our website. For example, 50% of our users might see one piece of content, the other 50% a different piece of content.

* Store information about your preferences. The website can then present you with information you will find more relevant and interesting.

* To recognise you. We may show you relevant content, or provide functionality you used previously. We may also use cookies to display relevant advertising material.

* To secure your account. Cookies help to prevent anyone gaining unauthorised access to your account.

Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.

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

Unless you have changed your browser to refuse cookies, our website will issue cookies when you visit it. To learn more about cookies and how they are used, visit www.allaboutcookies.org.

If you have any questions please contact us using the details at the top of this page.


8. Links to other websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.


9. How long we hold your data

We will only hold your data for as long as we need it for the purpose that we are using it for.

When we provide services to you under an agreement, we will hold your data for as long as our relationship lasts and for up to 1 year afterwards (just in case you re-engage with us, or we need to contact you about our work).

Where we are using your data for one of our legitimate interests, we will only hold your data for as long as we have that interest. In certain circumstances, you can ask us to stop using your data earlier. You can find more information about your rights below, alternatively you can contact us at any time using the contact details at the top of this page.

10. Your rights


10.1. You have the rights to be informed

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this policy to do just that, but if you have any questions or require more specific information, please contact us using the details at the top of this page.


10.2. You have the right to access your data

You have the right to ask us to confirm whether or not we hold any of your personal information. If we do, you have the right to have a copy of your information and to be informed of the following:

* why we are using your information;

* what categories of information we are using;

* who we have shared your information with; and

* how long we envisage holding your information.

In order to maintain the security of your information, we will have to verify your identity before we provide you with a copy of the information we hold.


10.3. You have the right to correct our records

Where you have requested a copy of the information we hold about you, you may notice that there are inaccuracies in the records, or that certain parts are incomplete. If this is the case you can contact us so that we can correct our records.


10.4. You have the right to be forgotten

There may be times where it is no longer necessary for us to hold personal information about you. This could be if:

* the information is no longer needed for the original purpose that we collected it for;

* you withdraw your consent for us to use the information (and we have no other legal reason to keep using it);

* you object to us using your information and we have no overriding reason to keep using it;

* we have used your information unlawfully; or

* we are subject to a legal requirement to delete your information.

In those situations you have the right to have your personal data deleted.


10.5. You have the right to data portability

You have the right to obtain a copy of your personal data for your own purposes. This right allows you to move, copy or transfer your personal data more easily from one IT system to another, in a safe and secure way. If you would like us to transfer a copy of your data to you or another organisation we will provide a structured, commonly use and machine-readable file (such as a .CSV file).


10.6. You have the right to object to direct market

You can tell us at any time if you would prefer not to receive direct marketing from us. A link to this policy and an unsubscribe link OR instructions on how to unsubscribe are included in all our marketing communications.


10.7. You have the right restrict how we use your information

You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:

* you have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify this;

* you have objected to us using your information for our own legitimate interests and we are in the process of considering your objection;

* we have used your information in an unlawful way, but you do not want us to delete your data; and,

* we no longer need to use the information, but you need it for a legal claim.


10.8. You have rights related to automated decision making and profiling

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. You have the right not to be subject to automated decision-making which will have a legal effect upon you or otherwise similarly effect you.

We use automated-making solely to personalise our communications with you, for example by presenting personalised website or email messages.


10.9. Concerns about your rights

If you have any questions or concerns about your rights, you would like more information, or you would like to exercise your rights, please contact us at any time using the contact details at the top of this page.


11. Concerns?

If you have any concerns over how we use your data, please contact us in the first instance so that we can try to help. Our contact details are listed at the top of this page.

If you are not satisfied that we have addressed your concerns properly, you can lodge a complaint with the Information Commissioner’s Office (the ICO). Their contact details are below:

Information Commissioner’s Office
Wycliffe House
Water Lane
Tel: 0303 123 1113 Web: www.ico.org.uk