Aurora World Ltd respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data and tell you about your privacy rights and how the law protects you.
Although this privacy notice is provided in a concise, transparent, and intelligible manner, please use the Glossary to help you understand the meaning of some of the terms used throughout this privacy notice. If you are unclear about anything or if you wish to exercise your legal rights please contact us using the details set out below.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. AUTOMATED DECISION MAKING
8. DATA SECURITY
9. DATA RETENTION
10. YOUR LEGAL RIGHTS
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 the other notices and is not intended to override them.
Aurora World Ltd is the controller and responsible for your personal data (collectively referred to as "Aurora", "we", "us" or "our" in this privacy notice). We form part of a worldwide group of companies with headquarters in South Korea, Hong Kong and USA.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Full name of legal entity: Aurora World Ltd
Name or title of DPO: Keith Gray
Postal address: Aurora House, Hampshire Intl Business Park, Crockford Lane, Basingstoke, RG24 8WH
Telephone number: +44 (0)1256 374260
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 (). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on 21st May 2018. 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.
Our website and any correspondence between us 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. Whenever you visit a third party website, we encourage you to read their privacy notice.
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).
· Customers - Information we collect when setting up your account with us, be it on your own behalf or on behalf of your employer / representative organisation, by filling in forms on our website or otherwise, including your contact details such as your name, e-mail address, username, telephone number, your organisation, financial information and your role.
· Suppliers / vendors and agents - Information we collect prior to and throughout the negotiation and conclusion of our business relationship with you and/or with your employer / representative organisation (as the case may be). This would include your contact details such as your name, e-mail address, telephone number, your organisation, financial information, billing address, and your role.
· Transaction data about yourself and/or your employer / representative organisation.
· If you contact us, we may keep a record of that correspondence.
· Information about you posted on third party websites such as Facebook and Twitter.
· If you contact us to report a problem with our site or for technical or customer support, we may keep a record of that correspondence or conversation.
· Information that you upload to or share through our website by using our services.
· Personal information, including contact and financial information, for third parties (see section 3 below for more information).
· Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, internet protocol (IP) address, login details, browser type and version, time zone setting and location, browser plug-in types, operating systems and versions, and .other technology on the devices you use to access our website.
· Information about your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate the data concerning your usage of our website 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 notice.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us or cancel / fail to enter into the contract with you or your respective organisation. If this is the case we will notify you at the time.
· Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email, by allowing us to scan your badge at a trade show or otherwise. This includes personal data you provide when you:
· apply for our products or services;
· create an account with us;
· interact with us to discuss the goods and services we provide;
· subscribe to our service or publications;
· request marketing to be sent to you;
· request marketing to be sent to you;
· enter a competition, promotion or survey;
· give us some feedback.
· Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below.
· Technical data from the following parties:
(a) analytics providers such as google based outside the EU
(b) advertising networks such as T.F.W.A (Tax Free World Association), VisitConnect
(c) search information providers such as Facebook, Google, Bing and any similar search engine inside and outside of the EU.
· Personal data necessary for the completion of financial transactions from providers of technical, payment and delivery services such as Shopify, Worldpay and Paypal.
· Personal information from publicly availably sources such as Companies House, online and the Electoral Register based inside the EU.
· Contact information from your employer or a third party whom you have had previous dealings who has provided us with your contact information.
· Agents, buying groups, member groups
· Lists of attendees made available at trade shows that we visit or are part of.
· Where we need to perform the contract we are about to enter into or have entered into with you.
· 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.
See section 10 ‘Glossary’ to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in some circumstances in relation to 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.
We have set out below, in a table format, a description of all the ways we plan to 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.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your 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.
Lawful basis for processing including basis of legitimate interest
To register new customers and carry out our obligations arising from any contracts entered into between you, your respective organisation and us.
Performance of a contract with you
Where you are our vendor / supplier or where you are an authorised representative from one of our vendor(s) / supplier(s), to enter into negotiations and subsequently carry out our obligations arising from any contracts entered into between you, your respective organisation and us.
(a) Performance of a contract with you or your organisation
(b) Legitimate interests (to enter into negotiations with you regarding the services you perform that we require)
To process and deliver orders including:
(a) Confirming an order including but not limited to confirming the delivery time and location.
(b) Managing payments, fees and charges
(c) Collecting and recovering money owed to us
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you / your organisation which will include:
(b) Administering and maintaining our records
(c) Asking you to leave a review or take a survey
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To send you business-to-business marketing and in particular information about our products and services that we feel are of interest.
Necessary for our legitimate interests (to develop our products/services, grow our business)
To enable you to participate in interactive features of our service including partaking in a prize draw, competition or completing a survey when you choose to do so.
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products / services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website and marketing materials updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
To carry out research, statistical analysis, internal customer service monitoring and market research
Necessary for our legitimate interests (to develop our products/services, grow our business, improve the services we deliver to customers and inform our marketing strategy)
To facilitate the administration of the wider Aurora Group business and in particular to maintain our internal records and databases and to provide a more streamlined and efficient business system for our customers and those who interact with us.
Necessary for our legitimate interests (to develop our products/services, grow our business, improve the services we deliver and ensure a consistent corporate strategy)
To perform our duties and carry out our contractual obligations arising by virtue of our role as a principal and maintaining our agency relationship with you.
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to promote our business across all the territories which we serve)
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
Other than as is set out above, you will receive marketing communications from us if you have requested information from us or purchased goods from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Where you are a sole trader or in a partnership and you have not purchased goods from us in the past, we will only contact you for marketing purposes if you have specifically consented to receiving electronic mail from us.
We will get your express opt-in consent before we share your personal data with any company outside the Aurora Group of companies for marketing purposes.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
· Internal Third Parties as set out in the Glossary.
· External Third Parties as set out in the Glossary.
· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
· We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
· We may use specific contracts and transfer agreements approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
· 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 personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
3. Automated decision making
We never make decisions about you using only technology, where none of our employees or any other individuals have been involved.
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 they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
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 requirements.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may 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.
· Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
· Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
· Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal information to another party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
If you wish to exercise any of the rights set out above, please contact us in writing.
No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
Time limit to respond
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 and keep you updated.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Practice Manager. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or your organisation are a party or to take steps at your or your organisations request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Other companies in the Aurora Group acting as joint controllers or processors as the case may be and who are based in South Korea, Hong Kong, USA, China, Indonesia and provide IT and system administration services and undertake leadership reporting.
· Service providers acting as processors based in UK & South Korea who provide IT and system administration services.
· Professional advisers including lawyers, bankers, auditors and insurers based in UK, Germany and France who provide consultancy, banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators and other authorities based in UK and France who require reporting of processing activities in certain circumstances
· We may pass your details onto Fraud Prevention Agencies if requested to do so within the course of our business.
· Our agents acting on our behalf throughout the European Union including in UK, Germany, Austria & France.