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Privacy Policy

Your Data Privacy is One of the Main Reasons That the ICE Program was Developed. This Section Gives Details of the Various Aspects of Privacy and Data Protection. 

APG IT Inc
US Privacy Policy
Privacy, Data Use and Retention Policy
updated: 1st May 2022

1. WHO WE ARE

This data privacy, use and retention notice (the “Privacy Policy”) applies to all personal information collection and processing activities carried out by APG-IT Limited and its group (together, “APG-IT”). APG-IT is a data controller in respect of personal information that we process in connection with our business (including the products and services that we provide through the APG-IT app). In this notice, references to “we”, “us” or “our” are references to APG-IT. Our registered address is 200 CAMPUS DR. C/O WILSON ELSER FLORHAM PARK, NEW JERSEY 07932 and our privacy email address is [email protected] We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Notice is to explain how we collect and use personal information in connection with our business. “Personal information” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Notice from time to time. When we do we will communicate any changes to you and publish the updated Privacy Notice on our website. We would encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it. 

2. THE INFORMATION WE PROCESS

We collect and process various categories of personal information at the start of, and for the duration of, your relationship with us. We will limit the collection and processing of information to information necessary to achieve one or more legitimate purposes as identified in this notice. Personal information may include: 

3. HOW WE OBTAIN INFORMATION

Your information is made up of all the financial and personal information we collect and hold about you/your business and the proprietors, officers and beneficial owners of that business and your transactions. It may include: 

4. YOUR RIGHTS

We want to make sure you are aware of your rights in relation to the personal information we process about you. We have described those rights and the circumstances in which they apply in the table at Schedule A. If you wish to exercise any of these rights, if you have any queries about how we use your personal information that are not answered here, or if you wish to complain to our Data Protection team, please contact us at [email protected]. Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account and/or provide certain products and services to you through the APG-IT app. In the event our relationship with you terminated (for example, you choose to close your APG-IT Account), you may request the erasure of your personal data by contacting [email protected]. Please note that APG-IT will only comply with such requests to the extent it is legally obligated to and depending on your account activity until that date, certain personal data may be maintained in accordance with anti-money laundering and counter-terrorist financing legislation to which APG-IT is subject. 

5. CHANGES TO THE WAY WE USE YOUR INFORMATION

From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to operate your account and/or provide certain products and services to you through the APG-IT app.

6. HOW WE MAY USE AND SHARE YOUR INFORMATION WITH OTHER APG-IT GROUP COMPANIES

We will only use and share your information where it is necessary for us to lawfully carry out our business activities. Your information may be shared with and processed by other APG-IT group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail in a table in Schedule B – Purposes of Processing. 

7. SHARING WITH THIRD PARTIES

We will not share your information with anyone outside of the APG-IT group except: 

If you ask us to, we will share information with any third party that provides you with account information or payment services. If you ask a third-party provider to provide you with account information or payment services, you’re allowing that third party to access information relating to your account. We are not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you. In the event that any additional authorized users are added to your account, we may share information about the use of the account by any authorized user with all other authorized users. APG-IT will not share your information with third parties for their own marketing purposes without your permission. 

8. TRANSFERRING INFORMATION OVERSEAS

We may transfer your information to or your information may be collected directly by organizations in other countries (including other APG-IT group companies, for example in United Kingdom or Ireland (where APG-IT’s Customer Support function is located) on the basis that anyone to whom we pass that information or who collects it directly protects it in the same way we would and in accordance with applicable laws. In the event that we transfer information to countries outside of the United States we will only do so where: 

9. MARKETING INFORMATION

Upon signing up to, and continued use of APG-IT’s services, you consent to hear from us regarding marketing updates. We will send you relevant marketing information (including details of other products or services provided by us or other APG-IT group companies which we believe may be of interest to you) by postal or electronic communication methods, including but not limited to email and SMS. If you change your mind about how you would like us to contact you, or you no longer wish to receive marketing material from us, you can simply unsubscribe from: 

10. COMMUNICATIONS ABOUT YOUR ACCOUNT

We will contact you with information relevant to the operation and maintenance of your APG-IT account (including updated information about how we process your personal information), by a variety of means including via, email, text message, and in-app notifications. If at any point in the future you change your contact details you should tell us promptly about those changes. We may monitor or record calls, emails, text messages or other communications in accordance with applicable laws for the purposes outlined in Schedule A – Purposes of Processing. 

11. FRAUD PREVENTION

We may access and use information from fraud prevention agencies when you open your account and periodically to: 

Application decisions may be taken based solely on automated checks of information, for example from fraud prevention agencies and internal APG-IT records. To help us make decisions on verifying your APG-IT account, as well as transaction limits on your APG-IT account, we look at information you give us when you apply for a APG-IT Account; including biometric data such as your photograph and/ or facial scan, information regarding your location, age, nationality and/ or citizenship and other information which enables us to verify your identity and perform a risk assessment for money laundering and fraud prevention purposes. You have rights in relation to the automated decision-making used in the verification process, including a right to attempt account verification again, or contact our Customer Support team if your application is refused. We will also profile your APG-IT Account to assign a risk rating for the purposes of fraud and unusual transaction monitoring and unauthorized access prevention. The information we will use to profile you will include your age, bank country of residence and status as a politically exposed person or otherwise. We will continue to collect and monitor information about how you manage your APG-IT account including your account balance, payments into your account, the regularity of payments being made, and any default in making payments, while you have a relationship with us. This information may be made available to other organizations (including fraud prevention agencies and other financial institutions) so that they can take decisions about you. If false or inaccurate information is provided and/or fraud is identified or suspected, details will be passed to relevant fraud prevention agencies. Law enforcement agencies and other organizations may access and use this information. We cooperate fully to the extent of our legal obligations in the prevention of fraud, money laundering and counter-terrorism. If we, or a fraud prevention agency, determine that you pose a fraud, money laundering or other criminal risk, we may refuse to provide the services you have requested, or we may stop providing existing services to you. A record of any fraud, money laundering or other criminal risk will be retained by the fraud prevention agencies, and may result in others refusing to provide services, financing or employment to you. Fraud prevention agencies can hold your information for different periods of time, and if you are considered to pose a fraud or money laundering risk, your data can be held for up to six years. When fraud prevention agencies process your information, they do so on the basis that they have a legitimate interest in preventing fraud and money laundering, and to verify your identity, in order to protect their business and to comply with laws that apply to them. 

12. CALIFORNIA RESIDENTS

Pursuant to the California Consumer Privacy Act of 2018 (CCPA) subject to a submitting a verifiable request to [email protected], and you shall have the right to: 

13. HOW LONG WE KEEP YOUR INFORMATION

By providing you with products or services, we create records containing your information, such as customer account records and activity and transaction records. Records can be held on a variety of media (physical or electronic) and formats, but they are primarily held electronically. We manage our records to help us to better serve our customers (for example for operational reasons, such as dealing with any queries relating to your account) and to comply with legal and regulatory requirements. Records help us demonstrate that we are meeting our responsibilities and to keep as evidence of our business activities. Retention periods for records are determined based on the type of record, the nature of the activity, product or service, the country in which the relevant APG-IT company is located and the applicable local legal or regulatory requirements. We (and other APG-IT group companies) normally keep customer account records for up to six years after your relationship with APG-IT ends. Retention periods may be changed from time to time (or waived where deemed low-risk) based on business or legal and regulatory requirements. Where there has been no activity on your APG-IT account since it was opened, we may delete your data after a period of 6 months, as you will be deemed an “unactivated user”. If there has been any transactional activity on your account, we will maintain your data until you request that we delete it, unless we are obligated to maintain such data to comply with our legal obligations. We may on exception retain your information for longer periods than those stated above, particularly where we need to withhold destruction or disposal based on an order from the courts or an investigation by law enforcement agencies or our regulators. This is intended to make sure that APG-IT will be able to produce records as evidence, if they’re needed. If you would like more information about how long we keep your information, please contact us at: [email protected]-IT.com 

Schedule A – Your Rights Rights Description

Access – You have a right to get access to the personal information we hold about you.

Access – You have a right to get access to the personal information we hold about you.
Rectification – You have a right to rectification of inaccurate personal information and to update incomplete personal information.
If you believe that any of the information that we hold about you is inaccurate, you have a right to request that we restrict the processing of that information and to rectify the inaccurate personal information. Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you through the APG-IT app. For more information on how to rectify your information and the documents we need you to submit, please email [email protected] You will be required to complete a form outlining your request and will also need to provide proof of your identity (to ensure we are dealing with the account owner).
Erasure – You have a right to request that we delete your personal information.

You may request that we delete your personal information if you believe that:

A. we no longer need to process your information for the purposes for which it was provided;

B. we have requested your permission to process your personal information and you wish to withdraw your consent; or

C. we are not using your information in a lawful manner.

Please note that if you request us to delete your information, we may have to suspend the operation of your account and/or the products and services we provide to you. For more information on how to request erasure of your information and the documents we need you to submit, please email [email protected] You will be required to complete a form outlining your request and will also need to provide proof of your identity (to ensure we are dealing with the account owner).

Restriction – You have a right to request us to restrict the processing of your personal information.

You may request us to restrict processing your personal information if you believe that:

A. any of the information that we hold about you is inaccurate;

B. we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or

C. we are not using your information in a lawful manner.

Please note that if you request us to restrict processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you. For more information on how to request a restriction of processing of your information and the documents we need you to submit, please email [email protected] You will be required to complete a form outlining your request and will also need to provide proof of your identity (to ensure we are dealing with the account owner).

Portability – You have a right to data portability

Where we have requested your permission to process your personal information or you have provided us with information for the purposes of entering into a contract with us, you have a right to receive the personal information you provided to us in a portable format. You may also request us to provide it directly to a third party, if technically feasible. We’re not responsible for any such third party’s use of your account information, which will be governed by their agreement with you and any privacy statement they provide to you. If you would like to request a copy of the personal information you provided to us, please email us at [email protected] .

Objection – You have a right to object to the processing of your personal information.
You have a right to object to us processing your personal information (and to request us to restrict processing) for the purposes described in Section C of Schedule B – Purposes of Processing (below), unless we can demonstrate compelling and legitimate grounds for the processing, which may override your own interests, or where we need to process your information to investigate and protect us or others from legal claims. Depending on the circumstances, we may need to restrict or cease processing your personal information altogether or, where requested, delete your information. Please note that if you object to us processing your information, we may have to suspend the operation of your account and/or the products and services we provide to you.
Marketing – You have a right to object to direct marketing.

You have a right to object at any time to processing of your personal information for direct marketing purposes, including profiling you for the purposes of direct marketing. For more information see Section 9.

Withdraw consent – You have a right to withdraw your consent

Where we rely on your permission to process your personal information, you have a right to withdraw your consent at any time. We will always make it clear where we need your permission to undertake specific processing activities.

Lodge complaints – You have a right to lodge a complaint with the regulator

If you wish to raise a complaint on how we have handled your personal

information, you can contact our Data Protection Officer at

[email protected] who will investigate the matter. We hope that

we can address any concerns you may have, but you may contact the

Federal Trade Commission (FTC). For more information, visit

ftc.gov/complaint.

Schedule B – Schedule of Purposes of Processing

We will only use and share your information where it is necessary for us to carry out our lawful business activities. Your information may be shared with and processed by other APG-IT group companies. We want to ensure that you fully understand how your information may be used. We have described the purposes for which your information may be used in detail below. 

13.1 Contractual Necessity

We may process your information where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to: 

13.2 Legal obligation

When you apply for a product or service (and throughout your relationship with us), we are required by law to collect and process certain personal information about you. Please note that if you do not agree to provide us with the requested information, it may not be possible for us to continue to operate your account and/or provide products and services to you. This may include processing to: 

13.3 Legitimate Interests of APG-IT

We may process your information where it is in our legitimate interests do so as an organization and without prejudicing your interests or fundamental rights and freedoms. a) We may process your information in the day-to-day running of our business, to manage our business and financial affairs and to protect our customers, employees and property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business. 

This may include processing your information to: 

It is in our interest as a business to ensure that we provide you with the most appropriate products and services and that we continually develop and improve as an organization. This may require processing your information to enable us to: 

We may perform data analysis, data matching and profiling to support decision-making with regards to the activities mentioned above. It may also involve sharing information with third parties who provide a service to us. c) It is in our interest as a business to manage our risk and to determine what products and services we can offer and the terms of those products and services. It is also in our interest to protect our business by preventing financial crime. This may include processing your information to: 

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