Privacy Notice

This privacy notice explains how APOSITIVE LIMITED (company number 16817993) and PARTNER IN PAYROLL LIMITED (company number 16817657) collect, use, hold and disclose personal information about individuals who interact with our UK website, make enquiries about our services, communicate with us, or otherwise deal with us in the course of our business operations.

APOSITIVE LIMITED operates this website and may collect personal information when individuals interact with the site, submit enquiries or otherwise communicate with us.

Depending on the service you interact with, either APOSITIVE LIMITED or PARTNER IN PAYROLL LIMITED may act as the data controller of your personal information.

Further details about how personal data is processed in connection with our specific services are provided in our product-specific privacy notices, including:

AFunding Privacy Notice

APayroll Privacy Notice

1. Our privacy assurance to you

Your privacy has always been important to us.  As our client, or someone in a business relationship with our client, we respect your right to be aware of who has information about you, what they are doing with it and why, and who else they are sharing it with.  

We have adopted a privacy compliance culture that cements this relationship with you.  Its foundation is the Data Protection Act 2018 and the UK GDPR (as that term is defined the Data Protection Act 2018) – together the Data Protection Legislation.

2. Overview

This privacy notice explains, in relation to personal information we collect in connection with our UK website and general business activities.

  • the kinds of personal information we collect and hold;
  • how we collect the personal information;
  • the purposes for which we collect, hold, use and disclose the personal information;
  • the lawful basis we rely upon when undertaking that processing;
  • whether we are likely to transfer the personal information to third parties outside of the UK or European Economic Area (EEA);
  • what rights an individual has in respect of the personal information about that individual that we hold; and
  • how an individual may complain to us, how we may deal with the complaint, and how an individual may complain to the Information Commissioners Office if they unsatisfied with how we have dealt with their complaint.

3. Categories of persons whose Personal information we collect and process


We may collect and process personal information about:

  • Visitors to our UK website
  • individuals who contact us or request information from us
  • representatives, employees, officers, contractors and consultants of our clients, prospective clients, suppliers and service providers
  • individuals who subscribe to receive updates or marketing from us
  • other individuals who interact with us in the course of our business operations
  • We collect and process personal information from individuals who are clients or their employees, members of staff, workers, contractors or consultants (“Associates”).

4. The kinds of personal information we collect and process

We may collect and hold the following types of personal information:

  • identification information such as name, title, employer, job title and business contact details
  • contact information such as email address, telephone number and correspondence address
  • information you provide when you contact us, request information, complete forms on our website or otherwise communicate with us
  • records of correspondence and communications with us
  • information relating to our business relationship with you or the organisation you represent
  • technical and usage information collected through the website such as IP address, browser type, device information and information about how you use our website
  • marketing preferences
  • any other personal information you choose to provide to us

We do not intentionally collect special category personal data through our general website or ordinary enquiry channels. If such data is provided, we will only process it where permitted by law.

5. How we collect personal information

We collect personal information in a variety of ways, including:

  • directly from you when you contact us, submit an enquiry or complete forms on our website
  • from the organisation you work for or represent
  • from persons acting on your behalf
  • from publicly available sources such as company websites or professional networking platforms
  • from suppliers, advisers and business partners
  • automatically through our website using cookies and similar technologies

Where possible, we collect personal information directly from the individual concerned.

6. The purposes for which we collect and process personal information

We collect and process personal information for the following purposes and lawful bases:

• Responding to enquiries

To respond to enquiries, requests and communications including requests for demonstrations or follow-up contact.
Lawful basis: legitimate interests and steps prior to entering a contract.

• Managing business relationships

To evaluate and manage relationships with clients, prospects, suppliers and partners.
Lawful basis: legitimate interests.

• Providing product and service information

To provide information about our products and services where individuals request information or where permitted by law.
Lawful basis: legitimate interests or consent.

• Marketing communications

To send marketing communications to client contacts or individuals who have requested information from us.
Lawful basis: legitimate interests or consent.

• Website administration and improvement

To administer and improve our website, systems and services including monitoring usage and troubleshooting.
legitimate interests.

Protecting our business

To detect, prevent and investigate misuse, fraud, security incidents or other harmful activities.
Lawful basis: legitimate interests or legal obligations.

• Legal and regulatory compliance

To comply with legal, regulatory or reporting obligations.
Lawful basis: legal obligation.

Where we rely on legitimate interests, we ensure that these interests do not override individuals’ rights and freedoms.

Individuals may opt out of marketing communications at any time using unsubscribe links or by contacting us.

7. Cookies and similar technologies

Our website uses cookies and similar technologies to operate effectively, improve functionality, analyse usage and support our communications and marketing activities.

Cookies are small text files placed on a user’s device when visiting a website. They allow the website to recognise a device and store information about preferences or past actions.

We use cookies and similar technologies for the following purposes.

• Essential cookies

These cookies are necessary for the website to function properly and cannot be switched off in our systems. They are usually set in response to actions such as setting privacy preferences or submitting forms.

•  Analytics and performance cookies

We use analytics tools to help us understand how visitors interact with our website and to improve the performance and usability of the website.

Examples include:

Google Analytics: Used to analyse website traffic and understand how users interact with our website.

ContentSquare: Used to analyse user interactions with the website such as navigation behaviour, engagement with content and user journeys. This may involve aggregated behavioural analytics, heatmaps and session-level interaction analysis to help improve the user experience.

These tools may collect information such as:

  • pages visited
  • time spent on pages
  • navigation paths
  • browser and device information
  • general location derived from IP address

•  Advertising and marketing cookies

We may use third-party cookies and similar technologies to measure advertising performance and help deliver relevant advertising.

These include:

Google Ads: Used to measure advertising effectiveness and interactions with advertisements.

LinkedIn Ads and LinkedIn Insight Tag: Used to analyse engagement with advertising campaigns and marketing content on LinkedIn.

These technologies may collect information such as:

  • IP address
  • browser and device details
  • website interactions
  • referral sources
  • advertising engagement

Where required by law, we obtain consent before placing non-essential cookies on your device.

You can manage or withdraw your consent at any time by clicking “Change Cookie Preferences” in the footer of our website.

For more information about how we use cookies and similar technologies, please see our Cookie Notice.

8. How we protect the personal information

We take reasonable steps to ensure that personal information is protected from misuse, interference, loss and unauthorised access.

These safeguards include:

  • secure systems and networks
  • restricted access to personal information
  • authentication controls
  • staff confidentiality obligations
  • regular review of security practices

9. Disclosure of personal information to third parties

To operate our business effectively we may share personal information with trusted third parties including:

  • APositive Pty Ltd (Australia)
  • VA Platinum Pty Ltd as a service provider supporting group operations
  • professional advisers
  • technology and hosting providers
  • regulators and law enforcement authorities where required by law
  • third parties involved in business transfers or restructuring

We require service providers to process personal information only for specified purposes and in accordance with our instructions.

10. International Transfers

We may transfer personal information to companies within our corporate group or service providers located outside the UK, including Australia and the Philippines.

Where personal information is transferred outside the UK, we ensure appropriate safeguards are in place such as International Data Transfer Agreements (IDTAs) or other legally recognised mechanisms.

11. Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected and to comply with legal or regulatory requirements.

Retention periods are determined based on:

  • the nature of the data
  • the purpose of processing
  • legal and regulatory obligations
  • potential legal claims

12. Individuals legal rights

Under UK data protection law individuals have rights including:

  • the right to access personal information
  • the right to correct inaccurate data
  • the right to request deletion in certain circumstances
  • the right to object to processing based on legitimate interests
  • the right to restrict processing
  • the right to data portability where applicable
  • the right to object to direct marketing

Where processing is based on consent, individuals have the right to withdraw consent at any time. Withdrawal will not affect the lawfulness of processing carried out before consent was withdrawn.

Requests to exercise rights can be made using the contact details below.

13. How to contact us

If you have any questions about this privacy notice or how personal information is handled, you may contact our Data Protection Officer:

Mark Wood
Data Protection Officer
mark.wood@apositive.com.au

APOSITIVE LIMITED
Company number 16817993
Registered office:
1 Park Row
Leeds
United Kingdom
LS1 5AB

14. How an individual may complain and how we will deal with the complaint

Individuals have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). However, before doing so please make sure you have first made your complaint to us or asked us for clarification if there is something you do not understand. The ICO will expect you to have done this before reviewing your complaint. Complaints can be made using the contact details above.

15. Definitions

In this privacy notice:associate” means a person who is or may become an officer or employee of the client, the guarantor or debtor; “client” means a party to whom we have provided a factoring, invoice discounting or other facility including the provision of commercial credit and includes a person who has applied for, or may apply for, a facility of that type; “debtor” means a person who owes, or may owe, an account (also known as a book debt) which the client has sold to us or may sell to us or in which the client has granted, or may grant, a security interest to us; “guarantor” means a person who has guaranteed, or may guarantee, the obligations which a client has or may have to us; and “we”, “us” and “our” means Partner in Payroll Limited (company number 16817657). Words which are defined in the Data Protection Legislation have the same meaning in this privacy notice.

16. Changes to this notice

We may update this privacy notice from time to time. Any updates will be published on this page.

Last updated: 16 March 2026

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