INTRODUCTION

This privacy notice is provided to you by Aardent Limited of 20 Old Bailey, St Paul’s, London, England EC4M 7LN (Aardent, us or we).

You are:

  1. a customer (Customer) of Aardent, who has executed a Software as a Service agreement or Consultancy agreement with us (the Agreement), which shall include all duly authorised employees, agents and independent contractors of such Customer; or

  2. a client of the Customer, which shall include all duly authorised employees, agents and independent contractors of such client of the Customer; or

  3. a customer of Aardent who has engaged Aardent to provide services, which shall include consultancy services; or

  4. a third party, whereupon (if appropriate) we have occasion to process your personal data pursuant to your relationship to us, a Customer, or generally.

For the purposes of this privacy notice, and as the case may be, your access to us shall include but not limited to any interaction with us either through the Aardent website at www.aardent.com and the SOWaas website at www.sowaas.com.

THE GENERAL DATA PROTECTION REGULATION 16/679; DATA PROTECTION ACT 2018

In this statement, we have used certain terms which are set out in the EU’s General Data Protection Regulation as is amended under the Data Protection Act 2018 and thereafter applied as a result of the departure of the United Kingdom from the European Union (the Data Protection Law):

  • Personal data means: any information relating to an identified or identifiable natural person (data subject).

  • Controller means: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data.

  • Processor means: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

  • Processing means: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

To the extent that the terms noted above are used in this Privacy Notice, they shall have the meaning set out in the Data Protection Law.

IMPORTANT INFORMATION AND WHO WE ARE

 

The Agreement

Under the terms of the Agreement, the Customer has agreed to licence certain Aardent services (known here as the Software) and any related printed materials and any online or digital documents (the Documentation).

In all cases relating to the Agreement, this notice assumes that you are an Authorised User, which is a defined term set out in the Agreement and shall have the same meaning when set out in this privacy notice. Where necessary you should use the Glossary below which sets out the meaning of the key terms used in this privacy notice.

Purpose of this privacy notice

This privacy notice aims to give you information on how Aardent Limited collects and processes your personal data through your use of the Software and the Documentation, and generally.

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.

Controller

Depending on the circumstances, Aardent shall be the controller or the joint controller of personal data. We may also be the processor or the sub-processor of personal data.

Contact Details

If you have any questions about this privacy notice or our privacy practices, please contact Aardent Limited as follows:

Full name of legal entity: Aardent Limited

Email address: team@aardent.com

Postal address: 20 Old Bailey, St Paul’s, London, England EC4M 7LN

Right to Complain

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator 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.

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

We keep our privacy notice under regular review at all times. 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.

Third-party links

The Software and the Documents 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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data 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, store and transfer different kinds of personal data about you which we have grouped together as set out below. This list may represent part or all of personal data we collect about you:

  • 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.

  • Financial Data includes bank account and payment card details.

  • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

  • 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 the Software and the Documentation.

  • Marketing and Communications Data

 

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 Software feature.

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, which includes details about your race or ethnicity, religious or philosophical beliefs, private 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 the Agreement, 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. In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED?

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

  • Direct interactions. You may give us your identity and contact data, for example, by filling in forms. This could include personal data you provide when you:

  1. create an account using our Software;

  2. subscribe to our service or publications;

  3. act as an Authorised User; or

  4. 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 personal data by using cookies and other similar technologies you visit other websites employing our cookies.

  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources such as the Customer or any client of the Customer.  

  • Technical Data. From analytics providers such as Google.

  • Contact, Financial and Transaction Data. Where for example, financial data is provided when the Client executes the Agreement.

  • Identity and Contact Data.

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:

  • Where we need to perform the terms of the Agreement.

  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

  • Where we need to comply with a legal obligation.

  • Where we have, on occasion, need for and obtain your consent.

 

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message.

You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

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

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