Apse Capital Limited (“Apse Capital”) is incorporated as a Private Limited Company in England and Wales. Registration No. is 11620219.
Apse Capital Limited has its registered office and principal address at 21 Gloucester Place London W1U 8HR.
Apse Capital Limited is an appointed representative of GMT Communications Partners LLP which is authorised and regulated by the Financial Conduct Authority with Firm Reference Number 441230.
Personal Data That We Collect
When you interact with our Website, we collect information that, alone or in combination with other information, could be used to identify you (“Personal Data”).
Personal Data You Give Us. When you sign up for or use the Services, you voluntarily give us certain Personal Data, including your name, email address and username.
Information collected automatically. Each time you visit our site we may automatically collect the following information:
- Technical information including the internet protocol (“IP”) address used to connect your computer to the internet, your log-in information, browser type and version, browser plug-in types and versions, time zone setting, operating system and platform; and
- Information about your visit, including the Uniform Resource Locators (“URL”) clickstream to, through and from our site (including date and time); items you searched for; page response times; download errors, length of time spent on pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page and any phone number used to call us.
2. How We Use Data
We use the data we collect, described above:
- To authenticate users, provide the Services and respond to your requests. For users located within the EU, this use is necessary to perform the contract with you.
- As necessary for certain legitimate business interests, which include the following:
- To customize the user experience.
- To better understand how visitors interact with our Website and ensure that our Website is presented in the most effective manner for you, and as part of our efforts to keep our Website, network and information systems secure.
- To conduct analytics to inform our marketing strategy and enable us to enhance and personalize our communications and the experience we offer to our users.
- If you ask us to delete your data or to be removed from our marketing lists and we are required to fulfil your request, to keep basic data to identify you and prevent further unwanted processing.
- We may anonymize, de-identify and/or aggregate the information that we collect and use such anonymized, de-identified and/or aggregated data for commercial, statistical and market research purposes, including sharing it with affiliates and business partners.
- Marketing: We will send you updates and information about our news or upcoming events by email. Where required by law, we will only send you marketing information if you consent to us doing so at the time you provide us with your Personal Data or if doing so under a legitimate interest. You may opt out of receiving such emails by following the instructions contained in each promotional email we send you or by updating your user settings. In addition, if at any time you do not wish to receive future marketing communications, please contact us at firstname.lastname@example.org. We will continue to contact you via email regarding the provision of our Services and to respond to your requests.
3. Sharing And Disclosure
We may share your Personal Data and other information with certain third parties in the following circumstances:
- Service Providers: To assist us in meeting business operations needs and to perform certain services and functions your Personal Data may be shared with third-party providers of hosting, email communication and customer support services, analytics, marketing, advertising. Following our instructions, these parties may access, process or store Personal Data in the course of performing their duties for us.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of a service to another provider, your Personal Data and other information may be transferred to a successor or affiliate as part of that transaction.
- Legal Requirements: If required to do so by law, applicable regulation or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Apse Capital, (iii) act in urgent circumstances to protect the personal safety of users of the Website or the public, or (iv) protect Apse Capital against legal liability.
4. Data Retention
5. Update Your Information
If you need to change or correct your Personal Data, or wish to have it deleted from our systems, you may contact us. We will address your request as required by applicable law. You are also able to update your Personal Data yourself from your user settings.
6. Your Rights. You have the following rights in relation to your Personal Data:
- Right of access: If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.
- Right to rectification: If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we shared your Personal Data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to erasure: You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable). If we shared your data with others, we will alert them to the need for erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data with so you can contact them directly.
- Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it (please read below for information on your right to object). We will tell you before we lift any restriction on processing. If we shared your Personal Data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your Personal Data so you can contact them directly.
- Right to object: You may ask us at any time to stop processing your Personal Data, and we will do so:
- If we are relying on a legitimate interest (described under the “How We Use Data” section above) to process your Personal Data — unless we demonstrate compelling legitimate grounds for the processing; or
- If we are processing your Personal Data for direct marketing.
- Right to withdraw consent: If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
- Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorised to hear those concerns.
7. Publicly Posted Information
We take reasonable administrative and technical steps to protect the Personal Data from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet is 100% secure. Therefore, while we strive to protect your data, we cannot guarantee its absolute security.
11. Contact Us
If you are not satisfied with our response to any queries or complaints you raise with us or believe we are not processing your personal data in accordance with the Data Protection Laws and Regulations, you have the right to lodge a complaint at the Information Commissioner’s Office (ICO) (https://ico.org.uk/).