ARISTOTLE INTERNATIONAL EUROPE LIMITED (“AEI”, “the Company”, “we”, “us”, “our”) is committed to protecting and respecting your privacy.

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.

For the purpose of the Data Protection Act 1998 (the Act), the data controller is:

Aristotle International Europe Limited

2 St. Giles Square

London, WC2H 8AP, Company number 04714039.

AEI takes the protection and security of your personal information seriously and this policy sets out our responsibilities under the General Data Protection Regulation 2016 (‘GDPR’) and other applicable laws in England and Wales relating to the processing and security of personal information.

AEI is a global leader in identity verification, Know-Your-Customer (“KYC”), Anti-Money Laundering (“AML”), evaluate credit, fraud and age verification, herein referred to as “Verification”. We have global customers who use the services of AEI to provide Verification and assess credit worthiness to their customers. AEI uses data under license, publicly obtained or through acquisition to support our customers with these business needs.

This policy explains to you how AEI uses and secures your personal information as a data processor to its customers and at www.aristotleint.co.uk.

If you have any questions about how your personal information is used by AEI, please contact our Data Protection Officer by email at [email protected]

AEI reviews our Privacy Policy on an annual basis, sooner if changes to regulation require it or AEI changes the way we process personal information.

This policy was last updated on 13 May 2019.

Use of your data

What personal information does AEI collect and why?

Browsing our website: When you browse our website www.aristotleint.co.uk, we will collect the Internet Protocol (IP) address of the device you are using, but will be unable to identify you at this point. We collect this data so that we can identify where and how customers are accessing the website, are dropping out of the website and to identify areas of improvement to make the experience more engaging for our customers.

We use cookies on our website.

Requesting a demo or information: Your name (so that we contact the right individual).

• Your first and last name.
• Your contact telephone number (so that we contact the right individual).
• Your reason for contact (so that we can direct your call back to the right team who will respond to you directly).
• Your Company.
• Email address (so that we send the marketing to the right place).

Entering into an agreement with AEI: When your organisation enters into an agreement with AEI to provide its services, we will collect additional information, which is necessary for:

• The performance of the contract we have with your organisation, such as billing information; and
• Providing service updates related to the products/services AEI are providing to you.

All personal information we collect is held electronically within our Customer Relationship Management system (CRM), which is located in the United States

Accuracy of your personal information

As part of the account management process, AEI will on a regular basis enquire if the personal information we hold about you is correct. You can also ensure your personal information is correct by:

• Contacting AEI at [email protected].

Alternatively, if your organisation has an agreement with AEI for the provision of services, you can contact your AEI account manager, who will ensure they update your record on our CRM system.

Data retention

How long do we retain your personal information for and why?

For account management purposes, we will retain the personal information for as long as we have the relationship with your organisation. If AEI no longer has a relationship with your organisation, then we will only keep the relevant information, such as invoices, for audit purposes for 6 years after the relationship with AEI has ended.

Once AEI is informed you are no longer the contact we need to liaise with or you leave your organisation, we will remove your details from our system.

For personal information received from AEI clients to process for Verification purposes, AEI will retain the personal details based upon instructions from those AEI clients.

Transfers outside of the European Economic Area (EEA)

As a global organisation, we have sales teams located all over the world and a global approach to Verification. It will be necessary for your personal information to be transferred to them for account management activities with your consent. AEI will ensure the transfer of any personal data outside of the EEA is subject to appropriate safeguards and treated as if it was in the EEA under GDPR requirements.

AEI may transfer personal data outside of the EEA to its parent organisation Aristotle International Inc. under the US-EU Privacy Shield Agreement and governed under EU GDPR requirements as outlined under that Agreement

Data Security

Your rights under the GDPR are protected by an active focus on Data Security as a primary and continued responsibility of AEI. All access to personal data is on a strict need to know and only enabled as required by the role that AEI provides as a data processor for its customers.

The GDPR and your rights

As an individual, you have rights under the GDPR regarding the use of your personal information, these are:

• The right to withdraw consent – you can withdraw consent at any time.
• The right to erasure – you can request that AEI remove your personal information from our systems.
• The right to restrict processing – you can request that AEI only process your personal information for the purposes you specify. AEI only uses your personal as provided by its client for the purposes of Verification for that client.
• The right to data portability – you can request that the personal information you have provided through the AEI customer to AEI be ported to another organisation.
• The right to access your personal information – You have a right to know what personal information AEI holds on you and for what purpose we are processing your personal information. This is known as a Subject Access Request (SAR).
• The right to rectification – you have the right to ask us to rectify any information you believe is inaccurate as provided by the AEI client. You also have the right to ask us to complete information you think is incomplete.
• The right to object to processing – you have the right to object to processing if we are able to process your information because the processing is in our legitimate interests.

You can send these requests to DPO@aristotle.com or by post to:

Privacy & Data Compliance Team
Aristotle International Europe Limited

17 Coates Crescent
Edinburgh
EH3 7AF
Telephone: 0131 538 8887

You are not required to pay any charge for exercising your rights. We have one calendar month to respond to you. If AEI is unable to comply with your request, we will provide you with an explanation.

How to complain

We appreciate that at AEI may not always meet your expectations and it is regrettable for us as an organisation when we receive a complaint. We take all complaints seriously and can assure you we will do our best to deliver a satisfactory outcome. If you do wish to complain about how your personal information is used by AEI then please write to us at:

Aristotle International Europe Limited
17 Coates Crescent
Edinburgh
EH3 7AF
Telephone: 0131 538 8887

Alternatively, you can email us at [email protected] .

AEI will investigate and respond within 10 working days. This allows us time to investigate your complaint thoroughly.

Supervisory Authority Details

Where you believe that AEI has not taken our responsibilities with your personal information seriously, you have the right to complain to the UK Supervisory Authority. Its details are:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone number: 0303 123 113

Fax: 01625 545 745

Email: [email protected]

Purpose and legal basis for processing

We process the information mentioned in this section in order to be able to reply to any queries we receive and enhance the services we provide, which we believe also benefits our customers. The legal basis we rely on to process your personal data is Article 6(1)(f) of the GDPR, which allows us to process personal data when it is necessary for the purposes of our legitimate interests.

Visitors to our website

Cookies

We use various types of cookies in order to identify and track users and to store information about your preferences. Users may disable cookies; however, please keep in mind that if you decide not to accept all of the cookies, some parts of the site might not work properly.

Security and performance

AEI places high value on data security for information collected by users. Any traffic data we process in order to monitor our website is anonymised when required for analytics.

Purpose and legal basis for processing

We process the information mentioned above for carefully considered and specific purposes mentioned in each section, which are in our legitimate interests to enable us to enhance the services we provide, which we believe also benefits our customers. This is in accordance with Article 6(1)(f) of the GDPR.

Purpose and legal basis for processing

We use this system to make signing in visitors more efficient and rely on legitimate interests as the lawful basis for processing such data under Article 6(1)(f) of the GDPR.

Use of data processors

AEI may share your information with third party service partners, who are acting on behalf of AEI as our data processor and are required to meet GDPR requirements as AEI is required to perform.

CHANGES TO OUR PRIVACY POLICY

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

CONTACT

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to:

Mr. William Somervail
Director
Aristotle International Europe Limited
17 Coates Crescent
Edinburgh
EH3 7AF
Telephone: 0131 538 8887
Email: [email protected]