INTRODUCTION

This privacy notice is provided to you by Aardent Limited of 20 Old Bailey, St Paul’s, London, England EC4M 7LN (Aardent, us or we).

You are:

  1. a customer (Customer) of Aardent, who has executed a Software as a Service agreement or Consultancy agreement with us (the Agreement), which shall include all duly authorised employees, agents and independent contractors of such Customer; or

  2. a client of the Customer, which shall include all duly authorised employees, agents and independent contractors of such client of the Customer; or

  3. a customer of Aardent who has engaged Aardent to provide services, which shall include consultancy services; or

  4. a third party, whereupon (if appropriate) we have occasion to process your personal data pursuant to your relationship to us, a Customer, or generally.

For the purposes of this privacy notice, and as the case may be, your access to us shall include but not limited to any interaction with us either through the Aardent website at www.aardent.com and the SOWaas website at www.sowaas.com.

THE GENERAL DATA PROTECTION REGULATION 16/679; DATA PROTECTION ACT 2018

In this statement, we have used certain terms which are set out in the EU’s General Data Protection Regulation as is amended under the Data Protection Act 2018 and thereafter applied as a result of the departure of the United Kingdom from the European Union (the Data Protection Law):

  • Personal data means: any information relating to an identified or identifiable natural person (data subject).

  • Controller means: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

  • Processor means: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

  • Processing means: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

To the extent that the terms noted above are used in this Privacy Notice, they shall have the meaning set out in the Data Protection Law.

IMPORTANT INFORMATION AND WHO WE ARE

 

The Agreement

Under the terms of the Agreement, the Customer has agreed to licence certain Aardent services (known here as the Software) and any related printed materials and any online or digital documents (the Documentation).

In all cases relating to the Agreement, this notice assumes that you are an Authorised User, which is a defined term set out in the Agreement and shall have the same meaning when set out in this privacy notice. Where necessary you should use the Glossary below which sets out the meaning of the key terms used in this privacy notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how Aardent Limited collects and processes your personal data through your use of the Software and the Documentation, and generally.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice 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 notice supplements other notices and privacy policies and is not intended to override them.

Controller

Depending on the circumstances, Aardent shall be the controller or the joint controller of personal data. We may also be the processor or the sub-processor of personal data.

Contact Details

If you have any questions about this privacy notice or our privacy practices, please contact Aardent Limited as follows:

Full name of legal entity: Aardent Limited

Email address: team@aardent.com

Postal address: 20 Old Bailey, St Paul’s, London, England EC4M 7LN

Right to Complain

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.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review at all times. It is 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.

Third-party links

The Software and the Documents 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 notice of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data 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 set out below. This list may represent part or all of personal data we collect about you:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

  • Contact Data includes billing address, delivery address, email address and telephone numbers.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • Technical Data includes 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].

  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses. 

  • Usage Data includes information about how you use the Software and the Documentation.

  • Marketing and Communications Data

 

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 Software feature.

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 notice.

We do not collect any Special Categories of Personal Data about you, which includes details about your race or ethnicity, religious or philosophical beliefs, private life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of the Agreement, 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. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

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 and contact data, for example, by filling in forms. This could include personal data you provide when you:

  1. create an account using our Software;

  2. subscribe to our service or publications;

  3. act as an Authorised User; or

  4. give us feedback or 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 you visit other websites employing our cookies.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as the Customer or any client of the Customer.  

  • Technical Data. From analytics providers such as Google.

  • Contact, Financial and Transaction Data. Where for example, financial data is provided when the Client executes the Agreement.

  • Identity and Contact Data.

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 terms of the Agreement.

  • 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.

  • Where we have, on occasion, need for and obtain your consent.

 

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.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, in a table format, a description of the ways we may 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.

We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal 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.​

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.

DISCLOSURE OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

  • External Third Parties as set out in the Glossary.

  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

INTERNATIONAL TRANSFERS

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 safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

  • Where we use certain service providers, we may use specific contracts approved for use in the UK which gives personal data the same protection it has in the UK.

 

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

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 have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

DATA RETENTION

How long will you use my personal data for?

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.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers.

In some circumstances you can ask us to delete your data.

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.

YOUR LEGAL RIGHTS

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

  • Request access to your personal data.

  • Request correction of your personal data.

  • Request erasure of your personal data.

  • Object to processing of your personal data.

  • Request restriction of processing your personal data.

  • Request transfer of your personal data.

  • Right to withdraw consent.

 

If you wish to exercise any of the rights set out above, please contact us at:

Email address: team@aardent.com

Postal address: 20 Old Bailey, St Paul’s, London, England EC4M 7LN

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). 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.

 

What we may need from you

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.

Time limit to respond

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.

 

YOUR LEGAL RIGHTS

You have the right to:

 

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 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:

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

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

  • 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.

  • 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.

 

COOKIES

The Aardent website may place and access certain Cookies on your computer. We use cookies to improve your experience of using the Website and to improve our range of services.  We have carefully chosen these Cookies and taken steps to ensure that your privacy is protected and respected at all times.

All Cookies used by our website are used in accordance with current UK and EU Cookie Law. Before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Aardent to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended. This Website may place the following Cookies:

 

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, use a shopping cart or make use of e-billing services.

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.

 

You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings. For more information generally on Cookies, including how to disable them, please refer to aboutcookies.org. You will also find details on how to delete cookies from your computer.

GENERAL

Changes of business ownership and control: Aardent may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of personal data to the new owner or newly controlling party who will, under the terms of this privacy notice, be permitted to use such personal data for the purposes for which it was originally supplied to us. We may also disclose personal data to a prospective purchaser of our business or any part of it. In the above instances, we will take steps with the aim of ensuring your privacy is protected at all times.

Transfer of rights: we may transfer our rights under this privacy notice where we reasonably believe your rights will not be affected.

Enforceability: if any court or competent authority finds that any provision of this privacy notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

Change: Aardent reserves the right to change this privacy notice as we may deem necessary from time to time or as may be required by law.

Governing Law: unless otherwise stated, the content of this privacy notice shall be governed by English law and subject to the exclusive jurisdiction of the courts of England and Wales.

GLOSSARY

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Cookies means A small text file (up to 4KB) created by a website that is stored in the user's computer either temporarily for that session only or permanently on the hard disk (persistent cookie). Cookies provide a way for the website to recognize you and keep track of your preferences.

External Third Parties

  • Service providers acting as processors who provide IT and system administration services.

  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

  • HM Revenue & Customs, the ICO, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Aardent

20 Old Bailey, St Paul's
London, EC4M 7LN

Tel: 0207 315 4278

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