1. Who are we?
1.1 We are Apari Software Ltd. For privacy queries, you can contact us at email@example.com. Other contact details are on our website.
2. What’s the point of this policy?
2.1 It tells you what to expect when we collect your personal information via our website, app or otherwise. Please only use our service if you are completely happy with this policy.
2.2 Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.
3. Might the policy change?
3.1 Yes. We will give you notice of the new version by posting it on our service and communicating it otherwise if appropriate.
4. What do we collect?
4.1 Information which you upload to our service or otherwise give us such as:
- your name and contact details;
- other information you provide when you register with us or later such as your national insurance and tax reference numbers, bank account details and contract information;
- any personal information that you include in transactions, bank statements, contract lists and other similar information that you upload to our Service;
- details about your transactions on our service;
- your friend’s information if you use our “refer a friend” or similar service;
- information that you include in reviews or which you otherwise provide for display on our service or which you include in communications with us; and
- contact or other information which you give or allow us to use for newsletters or other marketing.
4.2 Automated information about your use of our service such as: the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, the site from which you arrived at our service, details of your activity with date / time stamps including pages you visited and your searches / transactions.
4.3 The following information about you may be provided to us by other people:
- Your accountant or other partner who introduced you to our service may input information about you directly into our system if you give them access.
- Limited billing information sent to us by our payment provider or the relevant app store for verification purposes e.g., your name, email address and billing address.
- If you log in via social media or other websites: Information from those companies potentially including your name and email address.
- Information from HMRC, such as income sources and tax liability, that are used to automatically pre-populate your tax returns.
5. What’s our reason / legal basis for collecting the information?
5.1 Because it’s necessary to take steps at your request to enter into a contract with you and/or to perform such a contract. This applies to initial enquiries and to contact and transaction details as well as tax reference and bank account information.
5.2 Because it’s in our “legitimate interests”, e.g., to send marketing communications to customers about our similar products/services, to manage and improve our service including tracking usage patterns and preventing or detecting fraud or abuse. This applies to automated usage data as well as to reviews which you display on our service and to “refer a friend” contact details. We may also use your contact information to carry out customer satisfaction surveys.
5.3 Because you’ve specifically agreed on our service (e.g, by ticking a consent box). This applies to contact or other information that you specifically agree to us using for certain kinds of marketing. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.
5.4 Because it’s necessary to comply with legal or regulatory obligations.
6. How long do we keep personal information?
6.1 We will generally hold your information for our default standard retention period of six years after the end of our contract/relationship with you, but we may delete it earlier/ later as set out below or in our terms and conditions.
6.2 We will keep your information that we use for email newsletters or other marketing until you tell us to stop sending you such messages.
6.3 We will generally keep automated browsing information for up to 14 months.
6.5 We will keep friend referral contact information that you supply us for up to 6 months.
7. To whom do we send or make available your personal information?
7.1 To other people who supply us with a service, e.g., other companies in our group who provide part of our service, hosts, payment providers, bank account access, customer service providers, and businesses which help us send communications or monitor our service and which provide us with e-commerce, online advertising, analytics, social media, video, customer survey and other services.
7.2 To other users (e.g., your accountant) if you give them access to your account on our service.
7.3 To HMRC if you include any personal information in a return.
7.4 To regulators, the police and other law enforcement authorities to help deal with fraud and abuse and/or comply with legal requirements.
7.5 To insurers and professional advisers in connection with our insurance cover or to deal with legal claims.
7.6 To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
8. Do we send your information outside the UK?
8.1 Your personal information (e.g., name, email address, IP address, browsing information) is transferred to companies outside the UK (generally to the US) by companies that provide us with hosting, e-commerce, analytics, advertising, app admin, security, customer management/support, email distribution, social media, surveys and other services. If so, we will ensure that there is a legal basis to do so, for example under contracts with standard contractual clauses sanctioned by the Information Commissioner that are designed to provide adequate safeguards for your personal information.
9. What rights do you have?
9.1 If the legal requirements are met: To ask us for access to your personal information, to rectify it if there are mistakes, to delete it or restrict its use in certain circumstances or to “data portability” or to withdraw any consent you’ve given (e.g. marketing).
9.2 You may also have the right to object to use of your personal information in certain circumstances.
9.3 If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you have the right to complain to the Information Commissioner’s Office (ICO).
9.4 For more information about your rights, visit the ICO’s website: www.ico.org.uk.