APU Commercial Information Services and its subsidiaries ("APU") want you to be familiar with how we collect, use and disclose information from and about you because we respect your concerns about privacy, and we want to maintain your trust.
2. WHAT WE COLLECT
APU and our service providers collect Personal Data to offer services you have requested or that we have a legitimate interest to believe are of interest to our customers, to manage the relationships we have with our customers and partners, and to perform activities based on your consent.
APU and our service providers may collect the following information from and about you:
Identity information, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact information, such as billing address, delivery address, email address and telephone numbers.
Profile information, such as your username and password, purchases or orders made by you or on behalf of an organization, your interests, preferences, feedback and survey responses.
Transaction information, such as payment related information. And details about payments to and from you and other details of products and services you have purchased from us.
Technical information, such as internet protocol (IP) address, your login data, browser type and version, location, operating system and platform and device and cookie IDs on the devices you use to access this website and our other web-based products.
Usage information, such as information about how you use our website, products and services. Our technologies automatically collect and log certain information to help us administer, protect, and improve our services, analyse usage and improve user experience.
Marketing and communications information, such as your preferences in receiving marketing from us and, where applicable, third parties and your communication preferences.
Other information relating to you which you may provide to us, for example in the correspondence that you send to us
2.1 Personal Data
We collect Personal Data when you submit it to us, such as when you register for or subscribe to certain products or services; create a profile; take a survey; use an interactive feature (such as chat or article sharing options); participate in a community forum; or contact customer service. The information you submit may include your name, postal address (including billing and shipping addresses), first name, last name, job title, company name, email address, telephone number, mobile number, credit or debit card number, gender, username, or profile picture.
This information is processed on the grounds of legitimate interest for the purpose of:
- identifying if you are key-decision maker in any of the sectors in which we operate.
- ensuring that the information we hold about you is relevant, accurate and up to date.
- ensuring that we have the information we reasonably require to provide or offer you with a relevant product or service; helping us to provide the best possible service in the most efficient manner; and to enhance marketing efficiencies for our customers in the sectors in which we operate.
2.1.1 Personal Data We Receive From Third Parties
2.1.2 How do we collect your personal information?
We use different methods to collect personal information from and about you as follows:
Direct contact with you during the course of business you provide when you:
- subscribe to our products or publications
- create an account on our website
- request marketing information to be sent to you
- respond to our surveys
- provide us with some feedback on our products or services
- provide us with your contact details for us to assist you with using our products
- interact with us at events and meetings
Automated interactions with our website where we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please see our Cookies Policy for further details including details regarding the consequences if we are not able to use these technologies.
Using third party or publicly available sources, where we may receive personal information about you from:
- Your employer or organization for whom you work where that organization is a client, supplier, commercial partner or other company with whom we have a business or contractual relationship. The terms of our contract with your employer or organization may require us to process your personal information in order to comply with our obligations under that contract or to exercise our rights under it.
- Analytics providers such as Google Inc. based outside the EU
- Survey and marketing companies based inside and outside the EU
- Contact, financial and transaction data from providers of technical, payment and delivery services who host our data inside and outside of the EU.
- Identity and contact data from publicly availably sources.
2.2 Other Information
Any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, geolocation data obtained with your consent where required by applicable law, and aggregated information.
Non-personal information about Users whenever they interact with our Website. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Website, such as the operating system and the Internet Service Provider’s utilised and other similar information.
2.2.1 Other Information You Submit
We collect Other Information when you submit it to us. This may include your password, birthday, education, occupation, financial information (such as your income, investments, portfolio transactions and value, and other information), and interests.
2.2.2 Other Information We Receive From Third Parties
We may receive Other Information about you from third parties, including, for example, demographic data, social media account number, information about your interests, and information about your activities on other websites.
2.2.3 Other Information Collected Automatically
APU or Access Programs / Subscription Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with an APU or Access Programs / Subscription Services, even though they are not operated or maintained by us.
3. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION
Any personal data that you give us will be treated with the utmost care and security. The personal data we collect is used to provide you with the service that you have requested or to respond to an enquiry that you have made.
We may use the Personal Data we collect from and about you for the purposes set forth below.
We process your personal information to comply with our legal obligations including:
- to verify the accuracy of information we hold about you;
- to keep a record relating to the rights you exercise in connection with our processing of your personal information;
- to respond to mandatory requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; and
- to respond to and resolve your complaints relating to the services we provide.
APU uses User personal information we have collected for the following purposes:
- to personalise User experience: we may use information individually or aggregated to understand how our Users use the services and resources provided on our Website.
- to improve our Website offerings based on the information and feedback we receive from you.
- to improve customer service: your information helps us to more effectively respond to your customer service requests and support needs.
- to process transactions: we may use the information Users provide when placing an order to service that order, as well as provide relevant information about our other products. We do not automatically share this information with third parties except to the extent necessary to provide the service or when explicitly given permission by the User. The User can at any time change its preferences by contacting us via our Website.
- to administer Website features: such as content, promotions and surveys and to send Users information they agreed to receive about topics we think will be of interest to them
- to send periodic email and updates pertaining to placed orders as well as respond to inquiries and requests or provide relevant information about our other products.
We process your personal information for the following purposes on the basis that the processing is necessary for us to pursue our legitimate interests as a business:
- Account setup and administration: We use your personal information such as your name, email and domain address, phone number, and information to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.
- Hosted services: Some of our services provide data and document storage as part of the product or solution offering. Documents and data stored by our customers may contain personal information or information classified as "confidential" by the organization you work for or are affiliated with. Any information stored by or on behalf of our customers is controlled and managed by and only made accessible to those customers or others our customers may authorise from time to time. Our access to this information is limited to APU personnel with a critical business reason.
- Personalisation: We use your personal information to deliver and suggest tailored material content to personalise your experience with our services and websites.
- Marketing and events: We use your personal information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online.
From time to time we may tailor and personalise marketing communications that we send to you, for example, by notifying you of products, services, offers or promotions that apply to your interests, location, industry sector, employer or job role. If you do not wish to receive marketing communications from us, you can opt-out at any time by using the unsubscribe link inside the email Please remember that even if you opt out of receiving marketing emails, we may still send you important service information related to your accounts and subscriptions.
Research and development: We use your personal information for internal research and development purposes and to improve our services.
General administration: We use your personal information for the following legal and administrative purposes:
- to administer our websites and our social media pages and for internal operations, including troubleshooting, testing and statistical reporting purposes;
- to enable us to make payments to contractors and freelancers who provide services to us;
- for the prevention of fraud and other criminal activities;
- to meet our internal and external audit requirements;
- for network and information security purposes in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request);
- for the purposes of a corporate restructure or reorganization or sale of our business or assets;
- for efficiency, accuracy or other improvements of our databases and systems e.g. by combining systems or consolidating records we or our group companies hold about you;
- to enforce or protect our privacy, safety, property or contractual and other legal rights or to bring or defend legal proceedings;
- to respond to non-mandatory requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; and
- for general administration including managing your queries, complaints, or claims, to send service messages and to provide you with important information about our business.
We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data, we treat the combined information as Personal Data.
To improve the quality of our products and services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal and Other Information we collect with information relating to your use of other APU products, services and websites. In addition, we may supplement the Personal Data and Other Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources, and information from APU Affiliates or business partners.
Through third party analytics providers, ad networks, and advertisers, we can track your online activities over time and across third party websites, apps and devices, by obtaining information through automated means.
This information, along with information we gather when you log in, can be used to help improve our products, remember your preferences, provide content recommendations, and show you advertisements on the APU and Access Programs / Subscription Services or other third party websites and apps that may be tailored to your individual interests.
If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Website.
We use the information we collect from and about you to provide our products, services and features to you, including: to process and fulfill your subscription, to create and manage your accounts, to send you information about your relationship or transactions with us, to measure and improve services and features, to allow you to engage with us (e.g., to comment on content and participate in online games, contests, promotions, special events, rewards programs, surveys or market research), to use collaboration tools to share content and collaborate with other users, to provide you with customer support, including online chats, and to respond to inquiries. If you choose to use the collaboration tools, some of your Personal Data may be included in a directory that can be viewed and used by other users of these collaboration tools. In addition, if you have multiple product subscriptions, we may use your information to allow you to sign in to several APU or Access Programs / Subscription Services websites with the same user ID.
4. HOW WE SHARE YOUR PERSONAL DATA AND OTHER INFORMATION
4.1 Our Disclosure of Personal Data and Other Information
We may use third party service providers to help us operate our business and the Website or administer activities on our behalf, such as sending out newsletters or surveys.
4.1.1 To Manage Corporate, Third Party, and School SubscriptionsIf your subscription is provided in whole or in part by your employer, school or other third party, we may share with them information about your access to and use of your subscription. If you have a subscription associated with a professor or school, we may also contact your professor or school to confirm your subscription. When providing this information, we may reveal limited amounts of your Personal Data such as your name or email address.
4.1.2 To Allow Third-Party Service Providers to Assist us in Providing and Managing our Services
We may make your Personal Data available to third party service providers, such as contractors, agents or sponsors, or APU Affiliates, who help us manage or provide our products and services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; processing data or statistics; and serving, customizing or delivering marketing. These third party service providers are required to protect Personal Data entrusted to them and not use it for any other purpose than the specific service they are providing on our behalf.
4.1.3 To Provide Co-Branded Services and Features
4.1.4 To Allow Social Sharing Functionality
4.1.5 To Protect the Rights of APU and Others
4.1.6 To Complete a Merger or Sale of Assets
If APU sells all or part of its business or assets, or is otherwise involved in a merger, reorganization, or transfer of all or part of its business, as part of that transaction, APU may transfer your information to the party or parties and their advisors involved in the transaction.
4.2 Information Made Public Through Use of Our Services and User Privacy Settings
Certain features offer you an opportunity to interact with us and others. These may include the collaboration tools, community forums, chats, submitting a letter to the editor, creating community profiles, and rating, tagging, and commenting on articles. When you use these features, you should be aware that any information you choose to submit, including your name, user name, location, email address, profile information, picture or image, likes, status, and comments, including any political or religious or other beliefs you express, may be publicly available to anyone, including other users, search engines, advertisers, third party application developers, and anyone else with access to the APU Site. We are not responsible for any information you choose to submit and make public through these interactive features.
APU only shares or discloses personal information when necessary to provide its services or conduct our business operations as described below. When we share personal information, we do so in accordance with our documented data privacy and security requirements. We may share non-personal, anonymised, and statistical data with third parties, including survey findings from our online consumer panels, employees and clients. Below are the parties with whom we may share your personal information and the reasons that we share that information.
Our suppliers, service providers and other recipients
We may share your information with our third party service providers, agents, subcontractors and other organizations for the purposes of providing services to us or directly to you on our behalf.
- Professional services (Auditors, Legal advisers)
- Marketing (advertising and digital)
- Banks, payment processors and financial services providers
- Financial (banking)
- Cloud storage providers
- Direct marketing service providers
- Financial auditing services
- Government tax administration offices
- IT support service providers
- Security access control services
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
When we share your personal information with third parties that are controllers of that information, they may disclose or transfer it to other organizations in accordance with their data protection policies. This does not affect any of your data subject rights as detailed below. In particular, where you ask us to rectify, erase or restrict the processing of your information, we take reasonable steps to pass this request on to any such third parties with whom we have shared your personal information.
Other ways we may share your personal information
- Our material content and event partners: We occasionally partner with other organizations who provide material content, or host events, which may be held anywhere in the world. As part of these arrangements, we and our partners may collect and share information about you. We will handle personal information in accordance with this policy.
- Third parties for re-organization: We may disclose your personal information to any third party who is restructuring, selling, buying or acquiring some or all of our business or assets (or contemplating doing so) or in the event of a merger, re-organization or similar event to with any parties involved in those processes or transactions.
- Third parties for legal reasons: We will share personal information only when we believe it is required, such as:
- if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or police, court or government request, which may include such authorities outside your country of residence;
- to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities; and to protect our rights, users, systems, and services
5. HOW WE PROTECT AND RETAIN PERSONAL DATA
APU uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorised access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Website.
Sensitive and private data exchange between the Website and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures. Our Website is also in compliance with PCI vulnerability standards in order to create as secure of an environment as possible for Users.
We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service in accordance with the instructions below.
Securing your personal information
APU uses appropriate technologies, policies, processes and procedures to protect personal information. Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed and updated regularly to reflect changes in legislation and in business needs.
Examples of the technologies, policies, processes and procedures we maintain are:
- we have measures in place to protect against accidental loss and unauthorised access, use, destruction, or disclosure of data;
- we have a Business Continuity and Disaster Recovery strategy that is designed to safeguard the continuity of our service to our clients and to protect our people and assets;
- we place appropriate restrictions on access to personal information;
- we implement appropriate measures and controls, including monitoring and physical measures, to store and transfer data securely;
- we regularly conduct security awareness training for employees and contractors;
- we take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions;
- we require, through the use of contracts and security reviews, our third-party vendors, service providers and their sub-contractors to protect any personal information with which they are entrusted in accordance with our security policies and procedures.
How long do we keep your data?
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
The length of time we retain your personal information is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We determine the period of retention of your personal information based on the following criteria:
- Retention in case of queries. We will retain your personal information in case of queries from you, including on behalf of an organization for whom you work.
- Retention in case of claims. We will retain certain of your personal information for the period in which you or a third party might bring claims against us.
- Retention in accordance with legal and regulatory requirements. We will carefully consider whether we need to retain your personal information after the period described above in case of a legal or regulatory requirement.
The exceptions to the above are where:
- you exercise your right to require us to retain your personal information for a period longer than our stated retention period;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law;
- we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible; or
- in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
When we no longer need your personal information, we securely delete or destroy it.
Your right regarding your personal information
The European Union's General Data Protection Regulation and other applicable data protection laws provide you with rights over your personal information.
APU respects your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information. Please remember, that on occasions your personal information may have been shared with you by your employer or by other organizations, such as educational institutions, to which you belong, if they use our services and products.
If you wish to exercise any of your rights listed below, please contact our Data Protection Department. Except in rare cases, we will respond to you within 1 month after we have received this information or, where no such information is required, after we have received full details of your request.
- Information regarding processing: You have the right to be informed about why, how and by whom your personal information is processed (which is what this policy sets out to do).
- Access to personal information: If you request access to a copy the personal information we hold about you, we will gladly comply, subject to any relevant legal requirements and exemptions, including completing our identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.
- Request correction: You have the right to correct or amend your personal information if it is inaccurate or requires updating.
- Request deletion: You have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by using the "Contact Us" option within the relevant service.
- Object to processing: If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect your choice in accordance with our legal obligations.
- In relation to Marketing preferences: You can opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or visit the applicable email preference centre.
- Restriction of processing: You can ask us to suspend the processing of your personal information if you want us to establish the accuracy of the information; where our use of the information is unlawful but you do not want us to erase it; where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; and you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request personal information transfer ("data portability"): We will provide to you, or a third party you have chosen, your personal information 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: You have the right to withdraw your personal information where we are relying on consent to process it. 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.
Making a complaint: If you are not satisfied with how APU manages your personal information, you have the right to make a complaint to a data protection regulator in Europe, in particular in a country you work or live or where your legal rights have been infringed.________________________________________
6. YOUR RIGHTS AND CHOICES
6.1 Your Choices Regarding Our Use and Disclosure of Your Personal Data
We give you many choices regarding our use and disclosure of your Personal Data for marketing purposes.
6.1.1 To Opt Out Of Direct Marketing from APU and APU Affiliates
You may opt out of receiving electronic communications from us (including surveys, notifications, or promotions from us on behalf of third parties), or our sharing of your Personal Data with APU Affiliates for their direct marketing purposes, by changing your account settings through the appropriate link on the website account services page or following the unsubscribe instructions at the bottom of each email. You can opt out of direct marketing from APU Affiliates by using the unsubscribe links they provide or following the steps in their applicable policies.
Please note that there are certain service notifications that you may not opt out of, such as renewal notices and notifications of changes to APU products and services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
6.1.2 To Opt Out of Online Interest-Based Advertising
Third party websites and Advertising and Tracking Analytics
Users may find advertising or other content on our Website that link to the sites and services of our partners, suppliers, advertisers, sponsors, licensors and other third parties. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly changing. These sites and services may have their own privacy policies and customer service policies. Browsing and interaction on any other website, including websites which have a link to our Website, is subject to that website’s own terms and policies.
In addition to our own usage analytics, we use several third-party services to process personal information for the purposes listed above. While some of the services listed beneath may not be enabled at any specific time, services we use include:
6.2 How to Access, Correct or Update Your Personal Data
You can access, review, correct, update, delete or modify your registration or subscription profile information and modify your marketing preferences by contacting Customer Service, as indicated below. Most subscribers and registered users can also update their Personal Data online by signing on to their accounts and visiting the appropriate account management sections of our websites separately.
You may change the privacy settings for APU apps by accessing and updating privacy settings and permissions within the mobile app or on your mobile device.
Where you have provided your consent for our use of your Personal Data, you have the right to withdraw your consent and we will apply your preferences going forward.
You can also object to or restrict the processing of your Personal Data. If you are in the European Economic Area (“EEA”), you can also exercise your right to data portability.
For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion).
7. OTHER IMPORTANT INFORMATION
7.3 Collection of Personal Financial Information by a Payment Service
8. YOUR ACCEPTANCE OF THESE TERMS and Records Deletion
- Right to complaint
- Right to data portability (new)
- Right of access by the data subject
- Right to rectify or object to data
- Right to be forgotten or informed
- Right to oppose automated individual decision-making
- Right to a data protection officer (DPO) as safeguard (new)
- Right to restriction of processing
Should you request that we amend or suppress records containing your personal data we will endeavour to do so as promptly as practical; however you may receive communications for a transitional period whilst we process your records. Information Retained For Extended Time Periods for Limited Purposes Sometimes business and legal requirements require us to retain certain information for specific purposes for an extended period of time. For example, when you submit an entry in a competition, we may retain this information for a longer period of time to guard against cheating, for example, or for legal purposes. Reasons we might retain some data for longer periods of time include:
- Security, fraud & abuse prevention
- Financial record-keeping
- Complying with legal or regulatory requirements
- Ensuring the continuity of our services
Enabling Safe and Complete Deletion When you delete data in your APU account, we immediately start the process of removing it from the product and our systems. First, we aim to immediately remove it from view. We then begin a process designed to safely and completely delete the data from our storage systems. Safe deletion is important to protect our users and customers from accidental data loss. Complete deletion of data from our servers is equally important for users’ peace of mind. This process generally takes around 2 months from the time of deletion. This often includes up to a month-long recovery period in case the data was removed unintentionally. Each of our storage systems from which data gets deleted has its own detailed process for safe and complete deletion. This might involve repeated passes through the system to confirm all data has been deleted, or brief delays to allow for recovery from mistakes. As a result, deletion could sometimes take longer when extra time is needed to safely and completely delete the data. Our services also use encrypted backup storage as another layer of protection to help recover from potential disasters. Data can remain on these systems for up to 6 months. As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and timeframes defined in this article. We maintain systems designed to detect and remediate such issues.________________________________________
9. CONTACT US
Or you may write to: Attention: Privacy - APU Commercial Information Services LLC
Office no:1406, Business Bay, Makani, Dubai, United Arab Emirates.
We will respond to your questions and complaints about our processing of your Personal Data. Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.