Privacy Policy
DATA PRIVACY POLICY
INTRODUCTION
Section 1
This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.aptr.group
By providing us with your data, you warrant to us that you are over 13 years of age.
Harbor & Union is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).
Contact Details
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Our full details are:
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Full name of legal entity: Harbor & Union
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Email address: compliance@diakoniagroup.com
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Postal address: 230 Franklin Road, Building 2, Franklin TN 37064
It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at compliance@diakoniagroup.com
WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT
Section 2
Personal data means any information capable of identifying an individual. It does not include anonymized data. We may process the following categories of personal data about you:
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Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
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Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.
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User Data that includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back- ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.
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Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.
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Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.
We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business).
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Sensitive Data
We do not collect any Sensitive Data about you. Sensitive data refers to data that 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. We do not collect any information about criminal convictions and offenses.
Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.
We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at compliance@diakoniagroup.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
We do not carry out automated decision making or any type of automated profiling.
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Candidates
Aptr.group is the international site of the Harbor & Union and as such, applications are managed locally by each Harbor & Union entity according to their local rules and privacy policies depending on the country selected when applying. In this respect, we would like you to read the privacy policy applicable to the Harbor & Union entity to which you have applied.
We use your personal data when providing our recruitment, which include services in the field of recruitment and selection, mediation, secondment, payroll, personal development, career guidance, coaching, planning, and personnel and salary administration (collectively “Recruitment”).
In general, Harbor & Union’s activity as a service provider justifies Harbor & Union’s legitimate interest in keeping your data in order to offer you job opportunities that match your skills. Harbor & Union also processes personal data related to recruitment with your consent in order to offer you opportunities in line with your expectations.
What personal data do we collect and process about you as a candidate:
Identification information – we may process your name, contact information (including home address, home phone number and mobile phone number), citizenship and country of residence, date of birth, gender, digital signature and languages spoken.
CV/resumes and other recruitment information – we may process your CV/resume, work history, information about your skills, your experience and educational background and other relevant information (such as your photograph, interview notes and personal data included in the cover letter or as part of the application process).
Compensation and benefits information – we may process personal data relating to your current compensation and benefits including (without limitation) your current bonus, recurring payments and benefits.
Photographs and video footage – when participating in recruitment-related events, meetings, conferences etc., we may process photographs or videos of you.
Visitor information – when accessing our buildings, we may collect your name, contact details, car plate number, and other identification for security reasons.
Information you choose to share with us – we may process additional personal data if you choose to share that with us.
This data may be obtained directly or indirectly from you.
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Why We Need Your Personal Data
Harbor & Union processes your personal data only for the purposes specified below:
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Purposes for which we process your personal data | Legal grounds for the processing of your personal data
To propose you job offers in accordance with your profile. For example, we may process your personal data to recommend jobs to you based on your profile and to provide you with tailored job opportunities
The processing of your data and the use of automated systems is based on our on our legitimate interest or your express consent
Updating of systems/statistical purposes concerning Harbor & Union’s Recruitment. Some of the systems that we use to provide our Services are based on machine learning technology. In order for that technology to function reliably, it needs to be trained and updated on the basis of existing data. We may also process personal data in an aggregated manner for statistical purposes.
Based on our legitimate interest in training and updating our systems. We have implemented mitigating measures to limit the privacy impact, such as de-identification and an easy opt-out in your choices.
Dispute management and litigation
Processing is necessary for the purpose of the legitimate interests pursued by Harbor & Union which include the protection of company assets, protecting its legal interests and managing legal claims/disputes
Compliance with labor, tax and social security laws and other legal or regulatory requirements (e.g. equal opportunity and workplace diversity requirements)
Processing is necessary for compliance with employment and social security legal obligations
To administer and manage the contractual relationship between Harbor & Union and our clients and suppliers
Necessary for the performance of the contract between Harbor & Union and the client or supplier
Business development (including sending direct marketing and offers)
This may be based on our legitimate interest to maintain good relations with our current or prospective clients and suppliers.
HOW WE COLLECT YOUR PERSONAL DATA
Section 3
We may collect data about you by you providing the data directly to us (for example by filling in forms on our site or by sending us emails). We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this aptr.group/cookies.
We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, such as search information providers such as Google based outside the EU, providers of technical, payment and delivery services, such as data brokers or aggregators.
We may also receive data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
MARKETING COMMUNICATIONS
Section 4
Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).
Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.
Before we share your personal data with any third party for their own marketing purposes we will get your express consent.
You can ask us or third parties to stop sending you marketing messages at any time by emailing us at compliance@diakoniagroup.com at any time.
If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.
DISCLOSURES OF YOUR PERSONAL DATA
Section 5
We may have to share your personal data with the parties set out below:
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Other companies in our group who provide services to us.
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Service providers who provide IT and system administration services.
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Professional advisers including lawyers, bankers, auditors and insurers
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Government bodies that require us to report processing activities.
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Third parties to whom we sell, transfer, or merge parts of our business or our assets.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
INTERNATIONAL TRANSFERS
Section 6
We share your personal data within our group of companies which involves transferring your data outside the European Economic Area (EEA).
We are subject to the provisions of the General Data Protection Regulations that protect your personal data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:
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We may transfer your personal data to countries that the European Commission have approved as providing an adequate level of protection for personal data by; or
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If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or
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Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe.
If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
DATA SECURITY
Section 7
We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.
We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.
DATA RETENTION
Section 8
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.
When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.
For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.
In some circumstances we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Section 9
Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.
You can see more about these rights at:
If you wish to exercise any of the rights set out above, please email us at compliance@diakoniagroup.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 or 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 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.
We try to respond to all legitimate 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.
If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.
THIRD-PARTY LINKS
Section 10
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 statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
COOKIES
Section 11
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. For more information about the cookies we use, please see aptr.group/cookies.
CALIFORNIA PRIVACY RIGHTS
Section 12
For individuals located in the State of California, we comply with the data protection laws in your state, and if applicable, you have the following rights:
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To know what personal information is being collected about you.
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To know whether your personal information is sold or disclosed and to whom.
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To say no to the sale of personal information.
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To access your personal information.
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To request the deletion of any personal information.
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To equal service and price, even if you exercise your privacy rights.
OTHER PRIVACY RIGHTS
Section 13
Under the laws of some jurisdictions you may have the right to request additional information about the personal information we collect, request access to the personal information we process, correct an error or omission, delete personal information, or object or limit further processing. We adhere to applicable data protection laws and will respect individual rights requests under those laws.
Notification of Changes
This Privacy Policy is subject to periodic review and change. In order to view the current Privacy Policy, simply check this section of the website.
If we materially change our Privacy Policy, we will post those changes to this Privacy Policy and other places we deem appropriate, so users are aware of what information we collect, how it is used, and under what circumstances, if any, we disclose it. In some cases where we post a notice, we may also email users who have opted to receive communications from us, notifying them of the changes in our privacy practices.
Change History