Privacy Policy

1. Information we collect

Depending on how you interact with APX, we may collect:

Identity and contact information

This may include your:

• name;
• email address;
• telephone number;
• country of residence;
• business or employer;
• professional position;
• website;
• LinkedIn or other professional profile information; and
• other information you choose to provide.

Membership information

We may collect:

• membership level;
• selected sectors and interests;
• content preferences;
• saved articles or listings;
• membership history;
• account settings;
• verification status; and
• records relating to membership applications.

Verification information

For services requiring identity, eligibility, professional or compliance verification, we or specialist service providers acting on our behalf may process information necessary to complete those checks.

Depending on the service, this may include identification information, verification results and associated compliance information.

Where possible, APX will avoid retaining copies of identity documentation where the required verification can be performed by an appropriate specialist provider.

Partner and commercial information

Where you advertise, contribute, publish content or list opportunities on APX, we may process:

• company information;
• contact details;
• listings;
• articles and editorial submissions;
• photographs and media;
• campaign information;
• approvals and correspondence;
• contractual information;
• invoices;
• payment status; and
• records of services purchased.

Payment information

Payments may be processed using specialist third-party payment providers.

Where card payments are processed directly by a payment provider, APX does not normally receive or store complete card numbers or security codes.

We may retain transaction details including the amount, date, currency, invoice information, payment status and transaction or payment reference.

Communications

We may retain correspondence sent to or from APX, including enquiries, support requests, membership correspondence, partner communications and introduction requests.

Technical and usage information

When you access APX, we may collect technical information such as:

• IP address;
• device and browser information;
• approximate geographic information derived from an IP address;
• pages viewed;
• dates and times of visits;
• referring pages;
• session information; and
• interaction with website features.

Some of this information may be collected using cookies and similar technologies.

2. How we use personal information

We may use personal information to:

• create and administer APX accounts;
• personalise a member's APX experience;
• provide content based upon selected sectors and interests;
• process membership applications;
• conduct appropriate membership or identity verification;
• provide listings and partner services;
• process and administer payments;
• provide requested introductions;
• communicate with members and partners;
• respond to enquiries;
• publish authorised contributor and partner information;
• maintain the security of APX;
• prevent fraud, abuse and unauthorised access;
• comply with legal and regulatory requirements;
• maintain accounting and contractual records;
• improve APX products and services;
• understand use of the platform; and
• send relevant communications where permitted by law.

3. Our lawful bases

Under UK data protection law, APX must have an appropriate lawful basis for processing personal information. Depending upon the circumstances, we may rely upon:

Contract

Where processing is necessary to provide a membership, commercial service or other service you have requested.

Legitimate interests

Where processing is reasonably necessary for APX's legitimate business interests and those interests are not overridden by your rights and interests. These interests may include:

• operating and improving the APX platform;
• maintaining platform security;
• understanding how services are used;
• managing professional and commercial relationships;
• preventing fraud and misuse;
• protecting APX's legal rights; and
• communicating appropriately with existing members and business contacts.

Consent

Where the law requires consent, including certain marketing activities, cookies or other processing for which we have specifically requested your permission. You may withdraw consent at any time.

Legal obligation

Where processing is required for APX to comply with a legal, accounting, tax, regulatory or other statutory obligation.

4. Personalisation

APX may use the sectors and interests selected by members, together with their activity on the platform, to determine which intelligence, listings, Partner Insights, opportunities or other content is most relevant to them.

This enables APX to provide a more individually curated member experience. This personalisation does not itself constitute investment, financial or other professional advice.

5. Marketing and member communications

Where permitted by law, APX may send information concerning:

• APX Intelligence;
• relevant opportunities;
• membership;
• APX services;
• events;
• partner content; and
• other APX updates.

Where consent is required, we will request it. You may opt out of marketing communications at any time using the unsubscribe facility contained within the communication or by contacting APX.

Opting out of marketing does not prevent APX from sending essential service or account communications. APX may retain limited suppression information after an unsubscribe request to ensure that your marketing preference continues to be respected.

6. Sharing personal information

APX does not sell personal information to advertisers or other third parties.

We may, however, share information where reasonably necessary with carefully selected organisations that help us operate APX. These may include:

• website and cloud-hosting providers;
• database and technology providers;
• email and communications providers;
• payment processors;
• identity and verification providers;
• analytics providers;
• security and fraud-prevention providers;
• professional advisers including lawyers and accountants; and
• other service providers processing information on our behalf.

These organisations may only use personal information as permitted by their contractual relationship with APX and applicable law.

We may also disclose information:

• where required by law;
• pursuant to a valid court order or regulatory requirement;
• where necessary to establish, exercise or defend legal rights;
• to prevent fraud or serious misuse;
• in connection with the sale, restructuring or acquisition of all or part of the APX business; or
• where you have specifically requested or authorised disclosure.

7. Introductions

APX is designed to facilitate selected professional and commercial introductions. We will not ordinarily disclose a member's private contact information to another member or commercial partner merely because they have requested an introduction.

Where appropriate, APX may contact the relevant parties first and disclose information necessary to facilitate an introduction once an appropriate basis for doing so has been established.

8. Public and third-party information

In some circumstances APX may obtain business or professional information from publicly available sources, corporate websites, professional directories, LinkedIn or other legitimate third-party sources.

Where required by data protection law, APX will provide appropriate privacy information concerning such processing.

9. International transfers

APX operates in an international environment and some service providers or recipients may be located outside the United Kingdom.

Where personal information is transferred outside the UK, APX will take appropriate steps to ensure that the transfer complies with applicable data protection law. Depending on the destination and circumstances, this may include relying upon UK adequacy regulations or implementing appropriate contractual and other safeguards.

10. How long we keep information

APX retains personal information only for as long as reasonably necessary for the purpose for which it was collected, including satisfying legal, accounting, contractual and regulatory requirements. For example:

• active membership information may be retained for the duration of membership;
• commercial and contractual records may be retained after a relationship ends where reasonably required for legal, accounting or tax purposes;
• correspondence may be retained where relevant to the ongoing relationship or a legal issue;
• marketing suppression information may be retained to ensure an opt-out continues to be respected; and
• information which is no longer required will be deleted, anonymised or securely archived where appropriate.

11. Security

APX uses reasonable technical and organisational measures designed to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

No internet-based service is completely secure and APX cannot guarantee absolute security. Users are responsible for keeping their own account credentials confidential and should notify APX if they believe an account has been compromised.

12. Cookies and similar technologies

APX may use cookies and similar technologies to operate the website, maintain sessions, remember preferences, understand website use and provide relevant functionality.

Some technologies are necessary for the operation of the site. Others, including certain analytics or advertising technologies, may require your consent. Where consent is required, non-essential technologies will not be used until the required permission has been obtained.

13. Your data protection rights

Depending upon the circumstances and applicable law, you may have rights including the right to:

• request access to your personal information;
• ask us to correct inaccurate information;
• ask us to erase information;
• request restriction of processing;
• object to certain processing;
• receive certain information in a portable format;
• withdraw consent where processing relies upon consent; and
• object to the use of your information for direct marketing.

These rights are not absolute in every circumstance. To exercise a data protection right, contact: [email protected]

We may need to verify your identity before responding to a request.

14. Direct marketing objections

You have the right to object to the use of your personal information for direct marketing at any time. If you ask APX to stop using your information for direct marketing, we will do so.

We may retain limited information on a suppression list so that we can ensure you are not inadvertently added to future marketing campaigns.

15. Complaints

If you have concerns about APX's handling of your personal information, please contact us first so that we can investigate.

You also have the right to raise a concern with the UK Information Commissioner's Office (ICO). Information about exercising your rights and raising concerns is available from the ICO at ico.org.uk.

16. Children

APX is intended for adults and professional users and is not directed towards children. We do not knowingly seek to collect personal information from children for membership purposes.

17. Third-party websites

APX may link to websites operated by third parties. Those organisations are responsible for their own privacy practices and APX recommends reviewing their privacy information before supplying personal information to them.

18. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect changes in APX services, technology, law or data-processing practices. The latest version will be published on APX.money together with the date of the most recent update.

Where an amendment materially affects the way we use existing personal information, we will take appropriate steps to notify affected individuals where required.

19. Contact

For privacy enquiries or to exercise your data protection rights, contact: