Privacy

Privacy

Last updated: 2nd May 2018

This Privacy Notice (the “Notice”, for short) is intended to provide you with information about how we gather and use your personal data and about your legal rights under the General Data Protection Regulation – or “GDPR” – the European law on the use of personal data.

APITS Limited (“APITS”) respects your privacy and is committed to protecting your personal data. We maintain electronic and paper versions of this Notice and the electronic version is provided in an indexed format, so you can click through to the specific areas set out below.

The Glossary at the end of the Notice explains what some of the terms used in the GDPR and this Notice mean.

1. IMPORTANT INFORMATION AND WHO WE ARE

2. THE DATA WE COLLECT ABOUT YOU

3. HOW IS YOUR PERSONAL DATA COLLECTED

4. HOW WE USE YOUR PERSONAL DATA

5. DISCLOSURES OF YOUR PERSONAL DATA

6. INTERNATIONAL TRANSFERS

7. DATA SECURITY

8. DATA RETENTION

9. YOUR LEGAL RIGHTS

10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice
This Notice aims to give you information on how APITS collects and processes your personal data, whether you have provided it to us directly or whether we’ve obtained it from other people and organisations.
We may provide you with more specific privacy information where we collect information from you for certain specific purposes. If we do so, you should still refer to this Notice so that you are fully aware of how and why we are using your data and how we may use it in future. This privacy notice adds to the other notices and is not intended to replace them.

Controller
APITS is the data controller and responsible for your personal data (when we refer to “APITS”, "we", "us" or "our" in this Notice, that’s who we’re talking about).
We have appointed a data privacy manager who is in charge of answering questions in relation to this Notice. If you have any questions about it or if you want to use any of your legal rights, please contact the data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: APITS Limited, a company registered in England and Wales with registered number 06760085
Name or title of data privacy manager: Samantha Nelmes
Email address: samantha.nelmes@aplaceinthesun.com
Postal address: 4th Floor, 291-299 Borough High Street, London SE1 1JG

If you do have a problem, question or concern about our use of your personal data, we would appreciate the chance to try to help you, so please feel free to contact us in the first instance using the data privacy manager’s contact details above.

You always have the right to make a complaint about our use of your personal data at any time to the Information Commissioner's Office (“ICO”). The ICO is the UK’s supervisory authority for data protection issues (www.ico.org.uk).

You can contact us about data privacy issues in other ways, but if you contact the data privacy manager, that will make it much easier for us to help you.

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

This Notice was last updated on 30 April 2018.

The data protection law in the UK will change on 25 May 2018 when GDPR comes into force. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until then as we are still working towards getting our systems ready for some of these changes.

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.

2. The data we collect about you

Personal data” means any information about an individual, held by a data controller, from which the controller can identify a specific, living person. It does not include data about a living person that the controller can’t identify.

Some personal data falls into “Special Categories” under the GDPR and are given greater protection. These include any personal data revealing your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, and information about your health, as well as genetic and biometric data. Information about criminal convictions and offences is also treated differently from ordinary personal data under the GDPR.

We may collect, use, store and transfer different kinds of personal data about you. The personal data we collect will depend on the relationship you have with APITS.

If you are:

We may also collect, use and share Aggregated Data on visitors to our website, people who register for or attend exhibitions, people who register for online accounts with us and anyone who submits a query or request for further information (whether from APITS or a partner organisation) via our website. This may include statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature or evaluate the level of interest in a service, property or feature of our website. However, 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 (this includes details about your race or ethnicity, religious or philosophical beliefs, sex 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 a contract we have with you 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

4. 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:

See below to find out more about the types of lawful basis that we will rely on to process your personal data.

We rely on consent as a legal basis for processing your personal data in relation to sending direct marketing communications to you via email or text message. Where you have purchased products or services from us, including tickets to an exhibition or event, we consider that you have an interest in those products or services and similar products or services offered by or through us, and we are permitted under data protection legislation to send those communications to you. We comply with data protection legislation in our electronic marketing and you have the right to withdraw consent to marketing at any time by emailing the data protection manager at samantha.nelmes@aplaceinthesun.com

Purposes for which we will use your personal data

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

Note that we may process your personal data for more than one legal basis, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data, where more than one has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a customer where you purchase products or services from us (for example, tickets to an exhibition or subscribe to our magazine) (a) Identity
(b) Contact
Performance of a contract with you
To process and deliver your order (for example, tickets to an exhibition or a magazine subscription) including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us

(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services and those of our partners offered via our website)
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications

(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)  (a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
Necessary for our legitimate interests (to develop our products/services and grow our business)
To provide you with information relating to products, services or information offered by our commercial partners and to pass your data on to our partners where you make an enquiry about their products or services using our website (a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to run and grow our business, put you and our commercial partners in touch with each other, and to inform our marketing strategy)

Promotional offers from us 

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what products or services from us or our commercial partners we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have purchased services from us, if you opted to receive these communications when you requested information from us or a commercial partner, or if you entered a competition or registered for a promotion, and in each case you have not since opted out of receiving that marketing.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. When you opt-in to receive information, offers or promotions from us or from our partners, we will ask you to tell us what other products or services may be of interest to you.

Third-party marketing

When you request information on products, services or properties provide by our commercial partners via our website, we will pass your personal data on to them and they may contact you regarding those products, services or properties. We will get your express opt-in consent before we share personal data provided for that purpose with any other company or organisation (other than ourselves) for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting samantha.nelmes@aplaceinthesun.com at any time.
Where you opt out of receiving these marketing messages, this will not prevent us from continuing to hold and process personal data for other lawful reasons, or to the extent necessary to ensure that our marketing database is kept up to date and that we respect your opt-out.

Cookies

As part of offering and providing customisable and personalised services, our website uses cookies to store and sometimes track information about you and to store your preferences.

A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive. All areas on the site where you are prompted to log-in or that are customisable ask that you accept cookies. Most Web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. More information about the cookies we use is set out below:

Cookie Cookie Name Purpose
AppNexus sess It is used by the Platform to test whether a browser is configured to accept cookies from AppNexus.
AppNexus icu The icu cookie is used to select ads and limit the number of times a user sees a particular ad. It contains information such as the number of times an ad has been shown, how recently an ad has been shown, or how many total ads have been shown.
App Nexus anj The anj cookie contains data denoting whether a cookie ID is synced with our partners. ID syncing enables our partners to use their data from outside the Platform on the Platform.
App Nexus uuid2 This cookie contains a unique randomly-generated value that enables the Platform to distinguish browsers and devices. It is matched against information – such as advertising interest segments and histories of ads shown in the browser or device – provided by clients or other third parties and stored on the Platform. This information is used by clients to select advertisements for delivery by the Platform, and to measure the performance of, and attribute payment for, those advertisements. In addition, to enable clients to use non-PII they collect outside the Platform or acquire from other third parties, this cookie is sometimes matched to clients’ or other third parties’ cookies that contain such non-PII. For more information about information collected and used on the Platform, see our platform privacy page.
Google DoubleClick for Publisher __gads This cookie is associated with the DoubleClick for Publishers service from Google. Its purpose is to do with the showing of adverts on the site, for which the owner may earn some revenue.
Google DoubleClick for Publisher IDE Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user.
Google DoubleClick for Publisher DSID Used by Google DoubleClick to link your activity across devices if you’ve previously signed in to your Google Account on another device
Google googtransopt The cookie stores the translation preference of Google Translate
Google S / NID / SIDCC / SID / SAPISID / SSID / AID / 1P_JAR / APISID / HSID / CONSENT

Gathers information for Google advertising. We use these cookies to make advertising more attractive to users and more valuable for editors and advertisers.

Google AdSense  S_adsense3-ui  
Google AdSense  DV  
Google Ad Services  AID Google conversion cookie which helps advertisers measure how many times individuals clicking on their advert end up purchasing their products.
A Place in the Sun  APITS.WebUser This is our cookie and allow us to store user information
A Place in the Sun __AntiXsrfToken This cookie is used to prevent Cross-site request forgery (often abbreviated as CSRF) attacks of the website. CSRF attacks exploit the trust that a site has in a user's browser.
A Place in the Sun XSRF-V This cookie is written to help with site security in preventing Cross-Site Request Forgery attacks.
A Place in the Sun XSRF-TOKEN This cookie is written to help with site security in preventing Cross-Site Request Forgery attacks.
A Place in the Sun UMB_UPDCHK This cookie is set by websites using the Umbraco web content management system. It is usually only seen by site administrators accessing the back end of the website, rather than general visitors.
A Place in the Sun apits_cookie_acceptance This cookie is written to your device when you have seen and accepted the cookie warning message. With this cookie present you will not be asked to confirm the cookie warning again.
A Place in the Sun ASP.NET_SessionId This cookie is automatically generated by asp.net. It is created the first time application is accessed over the browser.
Google Tag Manager  _dc_gtm_UA-XXXXXXXX-X Used to throttle request rate.
Google Analytics  _ga This cookie name is asssociated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners. The main purpose of this cookie is: Performance
Google Analytics _gid

This cookie name is asssociated with Google Universal Analytics. It stores and updates a unique value for each page visited. The main purpose of this cookie is: Performance

Cloudfare __cfduid Used by one of website hosting providers (Cloudflare) to override any security restrictions based on the IP address the visitor is coming from.
Facebook xs / sb / act / wd / c_user / presence / pl / datr / fr / dpr Cookies needed for the Facebook social plugin.
Optin Monster om-657648-closed  
  om-655300  
  om-657678  
  om-657678-closed  
  om-673099  
  om-806225  
  om-success-673099  
  om-success-cookie  
  om-655300-closed  
  om-657648  
  _omappvs This cookie is used by OptinMonster to identify new vs. returning visitors for behavioural marketing purposes.
  _omappvp This cookie is used by OptinMonster to identify new vs. returning visitors for behavioural marketing purposes.

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 email samantha.nelmes@aplaceinthesun.com 

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.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

We expect 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 data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes, in accordance with our instructions and with the data protection legislation.

6. International transfers

If you enquire about property located outside the European Economic Area (“EEA”) – for example, in Florida - your personal data will be provided to the advertiser. We may also from time to time offer information, products or services from partners outside the EEA in relation to properties in their country or location. In each case, this will involve transferring your data outside the European Economic Area (EEA).

In many cases where you submit an enquiry about products, services or properties offered by a commercial partner (such as an estate agent or private seller) outside of the EEA, we may be unable to ensure a similar degree of protection for your personal data as exists within the EEA. In these situations, we transmit your personal data directly to the advertiser or partner at your request and on your behalf . Separately, we may also use the data provided by you for our own business purposes, as set out in this Privacy Notice.

In limited cases, we may act as a data controller in determining whether to transmit and process your data outside of the EEA. In these situations, we ensure a similar degree of protection is afforded to your personal data as it would enjoy within the EEA by implementing at least one of the following safeguards:

Please contact samantha.nelmes@aplaceinthesun.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We use secure data networks protected by industry standard firewall and password protection systems. 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.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data 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.

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 requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting samantha.nelmes@aplaceinthesun.com.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may 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.

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:

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

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 30 days. Occasionally it may take us longer than 30 days 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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means our interest in conducting and managing our business for the benefit of its stakeholders, and to enable us to offer you the best products and services from APITS and our commercial partners and the best and most secure browsing experience when using our website. 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.

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

THIRD PARTIES

Internal Third Parties

Other companies in common ownership or control with APITS, acting as joint controllers or processors.

External Third Parties

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. 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 on 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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.