These principles apply to personally identifying information we ask for and that you provide. By this we mean information that individually identifies you, such as your name, physical address, e-mail address or other contact details.
Browsing of our web sites and most other services do not require any personally identifying information.
Apaya may collect limited information your browser makes available whenever you visit a website. This log information includes your internet protocol address, browser type, browser language, the date and time of your query and one or more cookies that may uniquely identify your browser. We use this information to better understand users’ behaviour and to further improve our offerings.
Some of our services require you to register for an account, e.g. for the access into the forum, or to use our services. Apaya asks you for some personal information in order to create an account and we will use that information to provide the service. When we require personally identifying information, we will inform you about the types of information we collect and how we use it. We hope this will help you make an informed decision about sharing your personal information with us. It is then up to you to decide if you want to provide the information or not.
Retaining and Deleting Personal Data
This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
1.1 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
1.2 We will retain your personal data as follows:
(a) Personal data category or categories will be retained for a minimum period of which it is required to deliver requested services, and for a maximum period of 72 hours following the end of purpose of the data OR your request to remove it.
1.3 Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Transfer of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
2.1 In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
2.2 Your principal rights under data protection law are:
(a) The right to access;
(b) The right to rectification;
(c) The right to erasure;
(d) The right to restrict processing;
(e) The right to object to processing;
(f) The right to data portability;
(g) The right to complain to a supervisory authority; and
(h) The right to withdraw consent.
2.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by emailing us at firstname.lastname@example.org.
2.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
2.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
2.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
2.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
2.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
2.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
2.10 To the extent that the legal basis for our processing of your personal data is:
(a) Consent; or
(b) That the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, And such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
2.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
2.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
2.13 You may exercise any of your rights in relation to your personal data by written notice to us.
3.3 Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some features or services on our sites may not function properly without cookies.
Cookies used by our service providers
4.1 This website is operated by Apaya (Services) Limited.
4.2 We are registered in England and Wales under registration number 12634595, and our registered office and principal place of business is at 7 Premier Court, Moulton Park, Northampton, Northamptonshire, NN3 6LF.
4.3 You can contact us:
(a) By post, to the postal address given above;
(b) Using our website contact form;
(c) By telephone, on +44 1604 498900; or
(d) By email, using email@example.com
Who we share data with
5.1 Should you choose to contact us in relation to our premium services using the contact pop up or via our contact form, the details you submit to us will be stored by Hubspot Inc.( 25 First Street, 2ndFloor, Cambridge, MA 02141, United States) who provide us with website marketing tools. We consider Hubspot to be a third-party data processor.
Hubspot will forward your details to Apaya via a secure encrypted Simple Mail Transfer Protocol (SMTP). Our own SMTP servers are fully secure and protected. The email content is then decrypted by our local computers and devices. This information is then stored on a cloud-based database hosted by Salesforce.com EMEA Limited (Village 9, Floor 26 Salesforce Tower, 110 Bishopsgate, London, EC2N 4AY) We consider Salesforce to be a third-party data processor.
Your details will remain within the Hubspot and Salesforce databases for as long as we continue to use them and in accordance with our data retention policies or until you specifically request removal.
5.2 This site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website. GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us.
Apaya uses a limited number of third party service providers to assist us with data processing activities. When we work with these service providers in our capacity as a data processor, the third-party service provider is a sub-processor of Apaya (“Sub-processor”).
This page identifies the Sub-processor, describes where they are located, and what services they provide to us. Before engaging any Sub-processor, we perform extensive due diligence, including detailed security and legal analysis. We do not engage a Sub-processor unless our quality standards are met. Our Sub-processors are all subject to contract terms that enforce compliance with applicable data protection laws.
We currently (as per the ‘Last updated’ date) use the following Sub-processors:
- Microsoft Azure, Cloud service provider, located in United States of America
- Microsoft 365, Email, file storage, located in United States of America
- Zoho, User relationship management, located in United States of America
- Squarespace, Website, Email, located in United States of America
- Mailchimp, Email, located in United States of America
- Pipedrive, Merchant relationship management, located in United States of America
- Hubspot Inc, Merchant marketing services, located in United States of America
Additional Statements for residents of California in the United States of America:
The following statements and rights are additional to all statements and rights set out above for residents of California in the United States of America under the California Consumer Privacy Act (CCPA): 1. You will not be discriminated against for exercising any rights under this policy or under the CCPA. 2. In addition to your rights to receive a copy of your personal data you also have the right to request, up to twice in a 12-month period, the categories of sources from which we collected personal information, the purpose for the collection of information, the categories of information collected and the categories of third parties to whom it was disclosed.
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Apaya take reasonable measures to ensure the quality of the data and other information produced by APAYA that is available on this website. However, information on this website may contain technical inaccuracies or typographical errors. Information may be changed or updated without notice. APAYA may also make improvements and/or changes in the products and/or the services described in this information at any time without notice.
Neither APAYA nor any of its directors, employees or agents will be liable for damages arising out of or in connection with the use of this site or the information in it. This is a comprehensive limitation of liability that applies to all damages of any kind, including (without limitation) compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage to property and third party claims, save that nothing shall exclude or restrict liability for death or personal injury resulting from the negligence of APAYA, its directors, employees or agents.
APAYA reserves the right at any time to revise the information and other details given on the sites within its control without notice.
Certain links, including hypertext links, in this site will lead you to web sites or pages that are not under the control of APAYA. Links are provided for convenience and inclusion of any link does not imply endorsements in any way of the site to which it links to. These disclaimers and exclusions shall be governed and construed in accordance with English Law. If any provision of these disclaimers and exclusions shall be unlawful, void or for any reason unenforceable then that provision shall be deemed severable and shall not affect the validity and enforceability of the remaining provisions.
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