Privacy Notice

This is the privacy notice of Afentra plc. Afentra plc. is the parent company of a number of different legal entities (together, the “Afentra Group”). This privacy notice is issued on behalf of the Afentra Group so when we mention “Afentra”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Afentra Group responsible for processing your data. Afentra plc is the controller and responsible for your personal data (“data”).

Company number: 01757721 registered in England.

Registered and operating office: High Holborn House, 52-54 High Holborn, London, WC1V 6RL.

This privacy notice is to inform you of our policy on how we collect and process your data through your use of this website.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use and store different kinds of data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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. 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 policy.

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

 Direct interactions – You may give us your data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes data you provide when you:

• subscribe to our service or publications;

• request marketing to be sent to you; or

• give us feedback or contact us.

Automated technologies or interactions – As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies and other similar technologies. Please see our cookie policy for further details.

The law requires us to determine a lawful basis under which we may process different categories of your data, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

When you opt in to a service from us, or otherwise agree to our terms and conditions, a contract is formed between you and us.

In order to carry out our obligations under that contract we must process the data you give us.

We may use it in order to:

• verify your identity for security purposes; and
• provide you with our services.

We process this data on the basis that there is a contract between you and us, or on the basis that you have requested we use the data before we enter into a legal contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between you and us ends or is terminated by either party under the terms of the contract.

When you browse our website, subscribe to our services or using our contact details (see contact page), you provide your consent to us to process your data.

Wherever possible, we aim to obtain your explicit consent to process this data.

Sometimes you might give your consent implicitly, such as when you send us a message by e-mail to which you would reasonably expect us to reply.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

You may withdraw your consent at any time by instructing us via the Contact page. However, if you do so, you may not be able to use our website or our services further.

Sometimes, we must process your information in order to comply with a legal obligation.

For example, we may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order.

This may include your data.

News subscription service                                                              

If you register to receive our email news updates, the data you provide to us is processed in accordance with this privacy notice.

We continue to process your data on this basis unless or until you unsubscribe from our service. At any time you may unsubscribe from our email news subscription service by emailing info@afentraplc.com.

The data you provide to us is not used for any other purpose.

Data security

We have put in place appropriate security measures to prevent your data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Cookies

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

You can prevent their use through your browser settings, but you will then not be able to use all the functionality of our website.

We use cookies in the following ways:

• to record acceptance of cookie use;
• to provide functionality to logged in users; and
• to track activities for security purposes and spam protection.

We provide more information about the cookies we use in our cookie policy.

Personal identifiers from your browsing activity

Requests by your web browser to the server for web pages and other content on our website are recorded.

We record information such as your geographical location, your internet service provider and your IP address.

This information is used by our security systems to track events on the website and may be included in alerts of suspicious activity sent to the website administrator.

If combined with other information, the data possibly could be used to identify you personally, even if you are not signed in to our website.

Third parties

We may share your data with IT contractors and service providers. We require 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 service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. All our third party service providers are subject to a duty of confidentiality.

Third party advertising and links on our website

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Data may be processed outside the European Economic Area (EEA)

Our website is hosted on a server droplet in London and our subscription service is hosted in the United States of America. We may occasionally use outsourced services in countries outside the European Union from time to time in other aspects of our business.

Whenever we transfer your data outside of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your data to countries that have been deemed to provide an adequate level of protection for data by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give data the same protection it has in Europe.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to data shared between Europe and the US.

Access to your personal information

At any time you may review or update your data held by us for the purpose of providing our email news subscription service by emailing info@afentraplc.com. It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.

Removal of your information

At any time you may unsubscribe from our email news subscription service by emailing info@afentraplc.com. Your data will then be removed from the mailing list.

Verification of your information

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 as set out below). 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.

Your rights

Under certain circumstances, you have the following rights under data protection laws in relation to your data. The right to:

• request access to your data;
• request correction of your data;
• request erasure of your data;
• object to processing of your data;
• request restriction of processing your data;
• request transfer of your data; and
• withdraw consent.

If you wish to exercise any of the rights set out above, please contact us by emailing info@afentraplc.com.

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 could refuse to comply with your request in these circumstances.

This website is not intended for children and we do not knowingly collect data relating to children.

We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us.

Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.

If you are not happy with our privacy notice or if have a complaint then you should contact us.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner’s Office. This can be done at https://ico.org.uk/concerns.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

We keep our privacy notice under regular review and may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.

If you have any question regarding our privacy notice, please contact us at: info@afentraplc.com.