Privacy Policy

FM Management Services Ltd (“FMMS”, “we” or “us”), recognises the importance of the protection of personal information. This Privacy Policy (“Policy”) sets out our practices in relation to information that is gathered from persons who visit our website www.aprireunaltd.com (“Site”), as amended from time-to-time, or otherwise where information that is shared with us and is defined as Personal Information (collectively: “Users”).

Personal Information is information, when taken individually, or collectively, has the ability, by reasonable means, to identify a person, whether that be a User or any other person.

We are registered with the Information Commissioners Office (ICO) as a Data Controller, registration number ZA616164. Our registered office is:  52 High Street, Victoria House, 2nd Floor, Sevenoaks, England, TN13 1JG.

1.          Grounds for Data Collection

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

Gathering Personal Information will also be necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and for compliance with legal and financial regulatory obligations to which we are subject.

We encourage Users to carefully read the Privacy Policy and use it to make informed decisions about whether to use our services or otherwise share Personal Information with us. 

2.          What information do we collect?

We collect two types of data and information from Users. 

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-Identifiable Information”).

We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The type of Personal Information we collect includes:

  • Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
  • Contact information: If you choose to contact us you will be asked to provide us certain details such as: full name; e-mail or physical address, and other relevant  information which the User may provide but will constitute Personal Information.   

 

  • Information provided by you at the time of registering for our service such as: name; telephone number; email address; residential address; date of birth; nationality; bank account information, other identification details (e.g. passport) and transactional information.  This information may also be input by you when reporting a problem with our Site or other services;

 

  • Any correspondence sent to Us by you; and/or

 

  • Navigation data. The computer systems of the Site collect some Personal Information that is required in the use of Internet communication protocols. This information is not collected to be associated with you, but by its very nature could, through processing and association with data held by third parties, allow you to identify yourself. This data is used to obtain anonymous statistical information on the use of the Website and to check its correct functioning.

3.          How do We receive Personal Information about you?

We receive your Personal Information from various sources:

  • When you voluntarily provide us your Personal Information in order to register on our Site, or to make contact with us in some way;
  • When you use or access our Site in connection with your use of our services;
  • From third party providers, services and public registers (for example, traffic analytics vendors).

4.         How do We use the Personal Information we collect?

We may use the information for the following:

  • Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may
  • Conducting statistical and analytical purposes, intended to improve the Site.
  • The execution of a contract of which you are a party or to the execution of pre-contractual measures taken on your request (e.g.: the provision of your services)
  • To allow the correct delivery of the various features you requestedg. to carry out your transaction instructions or issue you with a current account
  • To fulfil any obligations required by applicable laws, regulations or Community legislation, or satisfy requests from authorities
  • To notify you of any change to our service
  • To develop new products
  • To conduct analysis to track business performance and aid in the operation and protection of the business
  • To ascertain, exercise or defend a right in court or whenever the jurisdictional authorities exercise their jurisdictional duties;
  • To allow navigation of the Website and the provision of our services
  • To find specific requests addressed to us

5.          How We Share Your Personal Information

In addition to the different uses listed above, we may transfer or disclose Personal Information to our parent company and subsidiaries as defined in section 1159 of the UK Companies Act 2006, as well as affiliated companies and subcontractors in relation to services that we provide to you.

We may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 

  • Providing the services we provide;
  • Hosting and operating our Site
  • Performing research, technical diagnostics or analytics

We do not rent, sell, or share Users’ information with third parties except as described in this Privacy Policy.

We may also disclose information if we have good faith to believe that disclosure of such information is helpful or reasonably necessary to:

  • comply with any applicable law, regulation, legal process or governmental request;
  • enforce our policies (including our Agreement), including investigations of potential violations thereof;
  • investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues;
  • to establish or exercise our rights to defend against legal claims;
  • prevent harm to the rights, property or safety of us, our users, yourself or any third party; or
  • for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights

6.         Marketing

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third-party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.  These communications will include:

  • To carry out direct marketing via e-mail for services similar to those signed by you, subject to your refusal to receive such communications, which may be expressed during registration or on subsequent occasions by contacting privacy@aprireunaltd.com
  • To carry out marketing activities such as: preparing studies, research, market statistics; send informational and promotional material relating to the activities, services and products FMMS and our commercial partners (without any communication of Personal Information held by us to the aforementioned Partners)
  • Send you surveys to improve the service (“customer satisfaction”). Such communications may be made by e-mail, in-app, or text message, by mail and / or the use of the telephone with operator and / or through the official pages of FMMS on social networks
  • For statistical purposes, without being able to trace your identity.

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists. 

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

7.          Rights Available to Individuals

Data Protection legislation has granted you the below rights in relation to your Personal Information:

  • Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you (see section 10).
  • Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data corrected, however, we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information 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 Information 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 Information to comply with local law. Please be aware that we may not always be able to comply with your request of erasure for legal reasons which will you will be advised of at the time of your request.
  • Object to processing of your Personal Information. This is in situations 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 information for direct marketing purposes. In some cases, we may be able to show that we have compelling legitimate grounds to process your information which override your rights. Due to regulatory requirements, FMMS has numerous obligations to process and retain certain personal information for compliance purposes, these requirements supersede any right to objection requests under applicable data protection laws. If you object to the processing of certain personal information, we may not be able to provide you with our services and it is likely we will have to terminate your account.
  • Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information 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. Please be aware that any requests in relation to the restriction of the processing of your data means that we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel your use of our services but we will notify you if this is the case at the time.
  • Request the transfer of your Personal Information to you or to a third party. We will provide you with your personal information in a structured, commonly used, machine-readable format, which you can then transfer to an applicable third party. Please be aware 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 Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. Please be aware, if you withdraw your consent, we may not be able to provide our services to you and we will advise you of this following receipt of your request.

Should you wish to access any of your rights, please contact us at privacy@aprireunaltd.com

8.         Data Retention

We will retain your personal information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion or as requested by you.

9.         Where Is Your Personal Information Stored?

Personal Information that is collected from you may be transferred to and stored at a location outside of the European Economic Area (EEA).  Staff working for on behalf of FMMS located outside the EEA may also process your Personal Information.  This may be to process your payment or to provide various support services.

Prior to your Personal Information being transmitted outside the EEA, we will ensure that either the destination country is the subject of an EU Adequacy Decision or there are measures in place that are equal to EEA standards to ensure the security of your data.

Whilst we undertake to do our best to ensure your Personal Information is protected, and procedures and features are in place to prevent unauthorised access, any transmission of data to our Site is at your own risk.  This is because we are not able to guarantee the security of your data transmitted to our Site as the transmission of data via the Internet is not completely secure. 

10.   Data Subject Access Requests (DSAR)

Should you wish to request access to the Personal Information we hold about you, you are entitled to make a DSAR, by contacting privacy@aprireunaltd.com.  Please provide an outline of what data you are requesting, and the reason for your request.  You will not have to pay a fee; 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.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information 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.

We try to respond to all DSAR requests within one month. Occasionally it may take us longer than a month 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.

11.   Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy. 

12.   Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at: privacy@aprireunaltd.com

13.   Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).  We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

14.   Changes to this Privacy Policy

FMMS reserves the right to modify or simply update its content, in part or completely, due to changes in the applicable legislation. We will inform you of these changes as soon as they are introduced, and they will be binding as soon as they are published on the Site. FMMS invites you to visit this section regularly to get to know the most recent Policy.

15.   Cookie Policy

When you access or use our content, products and services, information about your general internet usage may be obtained by way of a cookie file.  This is stored either on your browser or the hard drive of your computer (both Mobile or Web). Cookies perform various different functions, and the purpose of this policy is to give you a clearer understanding these.

What Are Cookies?

Cookies are small files which are stored on your computer or a website (both Mobile or Web). They are designed to hold a small amount of data specific to a particular client and website and can be accessed either by the website or your computer. Your browser makes cookies available each time you visit our Site.

Why Do We Use Cookies?

Cookies are used to improve your online experience and to ensure that relevant content and functions are delivered and used more effectively.

We use both session cookies and persistent cookies to perform various functions across our Site.

Session cookies are downloaded to your device temporarily for the period that you browse a particular website; these cookies might allow you to navigate between pages more efficiently or enable websites to remember the preferences you select. Persistent cookies can be used to help websites remember you as a returning visitor or ensure the online adverts you receive are more relevant to you.

How Do We Use Cookies?

When you visit our Site, Cookies will be placed on your device in two ways. Cookies placed by FMMS, as the site operator, are called “first party” Cookies. Cookies may also be placed on your device by a party, and these are known as “third party” cookies. Examples of the uses of third-party cookies include collecting information about browser habits and providing tailored content to you.  Customer experience and usage metrics will also be extracted from all our products.

While there are many different uses for first and third-party cookies, the cookies used by us all fall into one of the following four main categories of cookies:

  • Strictly Necessary Cookies
  • Functionality Cookies
  • Performance Cookies
  • Third Party Marketing / Targeting Cookies

Set out below is more information on these categories of cookies, including their purpose and whether these cookies collect Personal Information:

Strictly Necessary Cookies

These cookies are strictly necessary to enable you to navigate our Site and provide you with a more personalised service. They are used to provide content to you, as a user, and to provide products and services that you have requested.

Such cookies are essential to help your device download or stream information so that you can navigate around our Site and use its features.

Some examples of strictly necessary cookies are:

  • To position information on your device or screen so that you can see and use our Site
  • Remember the language.

These cookies do not remember your preferences or username beyond your current visit.

Some of these cookies do collect your Personal Information in order to function. They may collect the following types of Personal Information:

  • IP address
  • Location data
  • Identify you as being logged in our Site

These cookies are deleted when you close your web browser (browser session). Click here to see how you can control the use of cookies.

Functionality Cookies

These cookies are used to recognise you when you return to our Site and allow us to remember the choices you make and to enable us to provide improved features. They also enhance the functionality of our Site by storing your preferences. Functional cookies record information about choices you’ve made (such as language preference) and allow us to provide more personal features.

Here are some examples of the uses of performance cookies:

  • To remember your preferences and settings such as language, location and marketing preferences, since your last visit;

Some of these cookies do collect your Personal Information, to enable us to provide the services as outlined above.

Functional cookies expire after a maximum 2 years. Functionality cookies can be deleted from your browser history at any point before their expiry time. Click here to see how you can control the use of cookies.

Performance Cookies

These cookies are used to collect information on website usage. Such cookies are used to provide aggregated statistics on visitors to our Site. These statistics are used for internal purposes to help us to analyse and improve the performance of our Site, providing a better user experience.

Here are some examples of the uses of performance cookies:

  • To provide statistics on how our Site is used;
  • To assess errors within the user experience.

While these cookies do not identify you personally while you are not logged in, they will collect your browser information and anonymised data, for the purposes outlined above.

In certain cases, some of these cookies are managed by third parties such as Google Analytics. These third parties are not capable of using these cookies for any purpose other than those outlined above, and they are unable to identify with these cookies.

Performance cookies are valid for varying periods. Some performance cookies are deleted once you close your browser, while others have an indefinite validity period. Such cookies can be deleted at any stage using your browser settings.

Third Party Marketing/Targeting Cookies

These cookies are used to deliver advertisements relevant to you, based upon your activity on our Site.

They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign.

These cookies record your visit to our Site, the pages you have visited and the actions you have taken. We will use this information to make our Site and the advertising displayed more relevant to you. We may also share this information with third parties for this purpose and to measure the effectiveness of an advertising campaign.

Targeting cookies are also used to:

  • Collect information about browser habits to target website content and to target advertising;
  • Link to social media networks who may use this information about your visit to target advertising to you;
  • To provide advertisers with information on your visit so that they can present you with adverts that you may be interested in;
  • Deliver content and marketing communications tailored to your interests based on information from your visit;
  • To perform site retargeting. A retargeting pixel (a tiny unit of code) on our webpage leaves a cookie in the user’s browser, which causes our adverts to be displayed or to not be displayed to you when you visit certain websites within the retargeting network (e.g. Google Display Network); and
  • To perform search retargeting, which allows our adverts to be displayed on third party webpages, based upon your previous web search activities.

Third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies on our Site. These cookies are likely to be analytical/performance cookies, or targeting cookies. Please note that no Personal Information is collected, an advertiser is unable to associate the cookie with a particular individual’s name, address or other personal information.

These cookies are placed by third party advertising networks with our permission.

Third party cookies are valid for varying periods. Some cookies expire up to 13 months after they are last updated. Click here  to see how you can control the use of cookies.

How can you control the use of Cookies?

You can amend your browser settings to block some or all cookies. To do this, follow the instructions provided by your preferred web browser. For your ease of reference, we have provided the links below which provide instructions on how to remove and delete cookies for some of the more common web browsers. Please be aware that if you block cookies from the websites, some or all the website’s functions may not perform as intended:

Firefox

Internet Explorer

Google Chrome

Safari

Mobile phone users may have to refer to their handset manual for details on how to block cookies using their mobile browser. For more information about online behavioural advertising cookies and opt-out controls, please go to http://www.youronlinechoices.eu/

16.  Our Contact Details

Should you wish to make any comments or requests in relation to anything in this Policy, please contact as follows:

  • Through our Contact Support feature (if applicable).
  • By email at: privacy@aprireunaltd.com or
  • Write to the Data Protection Officer at: FM Management Services Ltd, 52 High Street, Victoria House, 2nd Floor, Sevenoaks, England, TN13 1JG.
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