This privacy notice will help you understand how Apto uses and protects your personal data.

We are Apto DC Limited, registered in England and Wales at 10th Floor, 5 Churchill Place, London, E14 5HU with company number 14376995.

You can contact our voluntarily appointed Data Protection Officer at simon.ghent@aptodc.com if you have any concerns or wish to exercise your rights.

1. Our Promises

We’re committed to your data privacy and security. As such we give you these promises:
We will only collect data about you that is relevant and necessary
Your data will only be held on systems that meet compliance standards
Your data will only be accessed by those who need it and we will minimise the amount of data that is processed, wherever possible.
We won’t share or sell your data to any third party, except for the marketing of our own services to you, unless either you have agreed, we are required to share it by law or we need to fulfil our service commitments to you through a third party that meets our own privacy standards
We will always remember that it is your personal data, not ours. As such we will ensure complete transparency and openness with you wherever possible
We respect your rights as outlined in the next section and will respond to all requests promptly

2. Your Rights

You have the following rights over any data we hold about you:
Right to object to processing at any time
Right to opt out of marketing at any time
Right to have inaccurate data corrected
Right to erasure of personal data from our database
Right to export of personal data
You can read more about your rights here.
If you would like to uphold your rights then please contact our Data Protection Officer at simon.ghent@aptodc.com.
If you are in dissatisfied with our response you also have the right to lodge a complaint with the Data Protection Authority. This can be done at https://ico.org.uk/concerns/

3. How we Collect your Data

We mainly only process the data you have provided to us. This may be from:
Filling in a form on our website
Attending one of our events
Interactions on Social Media
Should you purchase our products and services we may also carry out KYC checks. We will let you know in advance of us doing this.

If you belong to an organisation, we may also source your information from public databases and other sources for our Legitimate Interests.

4. What Data we Collect

We try and minimise the data held and the exact data elements we hold will be dependent on your journey with us.
Typically, data elements we collect include:
Name
Telephone Number
Work Email Address

5. How we Process your Data

Data is processed/stored mainly on encrypted cloud services such Microsoft 365, Azure, AWS.
If we connect on Social Media platforms we may transfer this information to our platforms to track our interactions.
Further to Section 119A of the Data Protection Act 2018 and noting Case C-311/18 in the European Court of Justice, if your outside of the UK or EEA we ensure the safeguards of International Data Transfer Agreements (IDTAs) or Addendums are enforced. Where this is not possible, we ensure that European Standard Contractual Clauses are entered.
We regularly review suppliers for data security compliance to ensure your data is safe and track where your data is held.
All our processes are subject to various internal policies to ensure that your data privacy and security is upheld.

6. What we use your Data for

We process your data for several reasons:
To better understand your needs
To develop our services and products and deliver these to you
To send invitations to events and follow these up if you have signed up to them
To send you promotional emails containing the information we think you will find interesting
To contact you to fill out surveys and participate in other types of market research
To customize our website according to your online behaviour and personal preferences
We ensure we have a “legal basis” to use your data for the purpose we have collected it for.

7. Who we share your data with

We share information where agents, resellers or suppliers are involved in the delivery of your service. These include:
Construction Companies who you will purchase your property from
Joint agents with us such as funders
Representatives or professional advisers such as solicitors, accountants and surveyors
Other entities associated directly with Apto
If required by law to do so
We use remarketing services from third parties. These may rely on the use of cookies. You can read more about these in our Cookie policy.

Our website and other materials sent to you may contain links to other third-party websites. We may also offer buttons to social media that link to third party services. We’re not responsible for the content or your data privacy these sites provide through their tools or sites.

8. Data Retention

Dependent on the data you provide us and for what purpose it is provided, we may need to retain your data based on your journey with us. Typically, we will retain your data for 3 years.
If you wish to find out more about your specific data retention, please contact us.

9. Data Permissions

Every marketing email sent from us allows you to opt out of receiving emails from us, except for the purposes of fulfilling any contractual arrangements.
You can also contact us at the email address above and request to opt out, view, export or delete your data.
If you request for your data to be deleted, your name and email address will be added to an exceptions list and all other data removed to the extent possible.

10. Legal Compliance

We seek to uphold our legal obligations as covered by the Data Protection Act 2018 and the General Data Protection Regulation 2016. Our Data Protection Authority is designated as the ICO and where we’re registered as a Controller.