Privacy Policy

1. Controller and Contact Details This Privacy Policy (the "Policy") is issued by AFFPRO GROUP LTD (the "Company", "We", "Us", "Our"), a company registered in England and Wales with company number 16481921, whose registered office is at 4 Montpelier Street, Suite 118, London, England, SW7 1EE. We are the "data controller" in respect of your personal data for the purposes of the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018. This means that we are responsible for deciding how and why we hold and use your personal data. If you have any questions about this Policy or how we handle your personal data, please contact us at contact@affprogroup.com. This Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By accessing, browsing, or otherwise using our website located at https://affprogroup.com/ (the "Website"), you acknowledge that you have read, understood, and accepted the practices described in this Policy. If you do not agree to this Policy, you must not use our Website. We may update this Policy from time to time. The date of the most recent revision will appear at the top of this document. It is your responsibility to review this Policy periodically. Your continued use of the Website following the posting of changes constitutes your acceptance of those changes. 2. Definitions and Interpretations 2.1. For the purposes of this Privacy Policy, the terms defined herein shall have the meanings set forth below. Any terms used but not defined in this Policy shall have the meaning ascribed to them in the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. 2.2. "Account" means a unique digital profile, comprising authentication credentials and associated data, created by and for the User to access and utilise the Service or specific functionalities thereof. 2.3. "Affiliate" means, with respect to a party, any legal entity that, directly or indirectly, controls, is controlled by, or is under common control with such party. For the purpose of this definition, "control" (including the terms "controlled by" and "under common control with") means the possession, directly or indirectly, of the power to direct or cause the direction of the management and policies of such entity, whether through the ownership of more than fifty percent (50%) of the voting securities, by contract, or otherwise. 2.4. "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. For the purposes of this Policy, the Controller is AFFPRO GROUP LTD. 2.5. "Cookies" means small text files that a website places on the User's terminal equipment (e.g., computer, mobile device), which may store information to facilitate navigation, enable certain functionalities, and collect data regarding the User's interaction with the Website. 2.6. "Personal Data" means any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person. 2.7. "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. 2.8. "Processor" means a natural or legal person, public authority, agency, or other body which processes Personal Data on behalf of the Controller, pursuant to its documented instructions. 2.9. "Service Provider" means any third-party company or individual, engaged by the Controller as a Processor, to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service, or assist the Company in analysing how the Service is used. 2.10. "Usage Data" means data collected automatically, which is generated either by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit, IP address, browser type and version, device identifiers, and browsing patterns). 3. Information We Collect and Process 3.1. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows. This data is collected through your direct interactions with us or automatically as you use our Website. 3.2. Personal Data You Provide to Us This includes information you voluntarily provide when you contact us, request our services, or correspond with us. Specifically: ● Identity Data: First name, last name. ● Contact Data: Email address, telephone number. ● Profile Data: Your company affiliation, and the contents of any messages you send us via contact forms, email, or other channels. ● Professional Data: Information about your business needs and marketing goals that you share with us when requesting our services. You provide this data when you: ● Submit an inquiry using our "Contact Us" forms. ● Complete a "Book a Call" or similar service request form. ● Contact us directly via email or other official channels. 3.3. Automated Technical and Usage Data As you interact with our Website, we may automatically collect the following data about your device and your browsing actions: ● Technical Data: Internet protocol (IP) address, your 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. ● Usage Data: Information about how you use our Website, such as the full URLs, clickstream to and from our site, pages you viewed, time spent on pages, navigation paths, and any page interaction information. 3.4. Mobile Device Data When you access our Website via a mobile device, we may collect additional device information, such as: ● The type of mobile device you use. ● Your mobile device's unique identifier. ● Your mobile operating system. ● The type of mobile internet browser you use. 4. Purposes of Processing and Legal Bases 4.1. We will only use your personal data for the purposes for which we collected it, as set out below. If we need to use it for a new purpose that is compatible with the original purpose, we will notify you and explain the legal basis. 4.2. Service Provision and Contractual Performance: We use the personal data you provide to us (Identity, Contact, and Profile Data as detailed in clause 3.2) to: 4.2.1 Respond to your inquiries and manage your requests 4.2.2 Schedule and perform consultations or calls 4.2.3 Provide you with the requested information, services, and support 4.2.4 Deliver our performance marketing and customer acquisition services This processing is necessary for the performance of a contract with you or to take steps at your request prior to entering into a contract, in accordance with Article 6(1)(b) UK GDPR. 4.3. Our Legitimate Interests: We use the Technical and Usage Data we collect automatically (as detailed in clause 3.3) for our legitimate interests to: 4.3.1 Ensure the security, stability, and integrity of our Website and IT systems 4.3.2 Analyse how our Website is used to improve its functionality, content, and user experience 4.3.3 Maintain and enhance the quality and performance of our services This processing is necessary for the purposes of our legitimate interests in maintaining and improving our Website, pursuant to Article 6(1)(f) UK GDPR. We have conducted a balancing test and determined that our interests are not overridden by your data protection rights. 4.3.4 Develop new services and marketing strategies for our business 4.4. Compliance with Legal Obligations We may process your personal data where necessary to comply with a legal obligation under UK law, including: 4.4.1 Retaining personal data for tax and accounting purposes 4.4.2 Responding to valid requests from law enforcement or regulatory authorities This processing is necessary for compliance with a legal obligation to which we are subject, under Article 6(1)(c) UK GDPR. 4.5. Legal Claims We may process your personal data where necessary for the establishment, exercise or defence of legal claims. This processing is necessary for the purposes of our legitimate interests in protecting and enforcing our legal rights, under Article 6(1)(f) UK GDPR. 4.6. Marketing We will not use your personal data for direct marketing communications via email or similar electronic means without your prior, explicit consent. Where consent is required, we will ask for it separately and clearly. You have the right to withdraw your consent to marketing at any time by contacting us. 4.7. Automated Decision-Making We do not use fully automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you 5. Use of Cookies and Tracking Technologies 5.1. Our Website uses cookies and similar tracking technologies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our site. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. 5.2. Types of Cookies We Use We use the following categories of cookies: 5.2.1 Strictly Necessary Cookies. These are essential for the Website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block these cookies, but some parts of the site will not then work. 5.2.2 Performance or Analytics Cookies. These allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. 5.2.3 Functionality Cookies. These enable the Website to provide enhanced functionality and personalisation, such as remembering your preferences (like your language or region). They may be set by us or by third-party providers whose services we have added to our pages. 5.2.4 Targeting Cookies. These cookies are used to deliver relevant advertisements and track advertising performance. They may be set by our advertising partners, including Meta (Facebook) and Google Ads, to build a profile of your interests and show you relevant ads on other sites. 5.3. Managing Your Cookie Preferences You may also refuse to accept or delete cookies by activating the appropriate settings on your browser. Please be aware that if you disable or reject cookies in your browser, some parts of this Website may become inaccessible or not function properly. 6. Data Security and Retention 6.1. How Long We Keep Your Personal Data 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. 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 unauthorized use or disclosure, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances we will 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. 6.2. Our Security Measures 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 are subject to a duty of confidentiality. We have implemented procedures to deal with any suspected personal data breach. In accordance with our legal obligations, we will notify the Information Commissioner's Office (ICO) of a personal data breach without undue delay where we are legally required to do so. If a personal data breach is likely to result in a high risk to your rights and freedoms, we will also notify you as required by law, unless an exception applies under Article 34(3) of the UK GDPR. 6.3. Data Transmission Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. 7. Data Sharing and International Transfers 7.1. Sharing Your Personal Data We may share your personal data with the following categories of recipients in the circumstances described below: 7.1.1 Service Providers (Data Processors): We share your data with trusted third-party companies and individuals ("Service Providers") who provide services on our behalf, such as cloud hosting, customer relationship management, analytics, and communication tools. These Service Providers are strictly contractually bound as "processors" under Article 28 UK GDPR. Our contracts with them require them to only process your data on our documented instructions, ensure confidentiality, and implement appropriate security measures. 7.1.2 Professional Advisors and Public Authorities: We may disclose your data to professional advisors (such as lawyers, auditors, and insurers) where necessary for the provision of their services. We may also be required to disclose your data to comply with a legal obligation, or to respond to valid requests from public authorities (such as courts or law enforcement agencies) to the extent permitted or required by UK law. 7.1.3 Business Transfers: In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company, your data may be transferred to the new owners. We will ensure that any successor entity is bound by the terms of this Privacy Policy. 7.2. International Transfers of Your Data Your personal data is processed and stored in the United Kingdom. However, as part of the services provided by our third-party Service Providers, your data may be transferred to, and processed in, other countries outside the UK. Whenever we transfer your personal data outside the UK, 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 personal data to countries that have been deemed by the UK government to provide an adequate level of protection for personal data. For transfers to countries without an adequacy decision, we use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. These include the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses. In specific situations where the above safeguards are not applicable, we may rely on a derogation under Article 49 UK GDPR, such as your explicit consent or the necessity for the performance of a contract with you. You can obtain more details about the specific mechanisms we use to facilitate international data transfers by contacting us. 8. Your Data Protection Rights Under data protection law, you have rights including: 8.1 Your right of access - You have the right to ask us for copies of your personal information. 8.2 Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. 8.3 Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances. 8.4 Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances. 8.5 Your right to object to processing - You have the right to object to the processing of your personal information which is based on our legitimate interests (or those of a third party). 8.6 Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in a machine-readable format, in certain circumstances. 8.7 Your right to withdraw consent - When we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. This does not affect the lawfulness of processing that took place before the withdrawal. You are not required to pay any charge for exercising your rights. We have one month to respond to you after we have received a valid request and verified your identity. Please contact us using the details provided in Clause 11 if you wish to make a request. 9. Children's Privacy 9.1 Our Website is a business-to-business service and is not intended for or directed at children under the age of 16. We do not knowingly collect or solicit any personal data from children under 16. 9.2 If we become aware that we have collected personal data from a child under the age of 16 without verification of parental consent, we will take prompt steps to delete that information from our records, unless we have a legal obligation to retain it. 9.3 If you are a parent or guardian and you believe that your child under 16 has provided us with personal data without your consent, please contact us using the details provided in the "Contact Us" section. We will then make reasonable efforts to delete such data from our files. 10. Changes to This Privacy Policy 10.1 We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date at the top of this Policy. 10.2 We will also endeavour to provide you with prior notice of any material changes, where feasible, through the Service or via the contact information you have provided. 10.3 You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of our Website after any such changes constitutes your acceptance of the revised Policy. 11. Contact Us and Your Right to Complain 11.1. Contacting Us If you have any questions about this Privacy Policy or wish to exercise any of your data protection rights, please contact us at: Email: contact@affprogroup.com. 11.2. Lodging a Complaint 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.