Privacy Policy
Last updated: March 2026
1. Introduction
ApertureChina Ltd (“ApertureChina”, “we”, “us”, or “our”) is committed to protecting and respecting your privacy. We are a company registered in England and Wales under company number 15769435, with our registered office at 1 Mentmore Terrace, London, E8 3PN.
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website www.aperturechina.com (the “Website”), subscribe to our newsletters, use our services, or otherwise interact with us. It also tells you about your privacy rights and how the law protects you.
For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, ApertureChina Ltd is the data controller.
2. Data Protection Officer
We have not appointed a dedicated Data Protection Officer as we are not required to do so under applicable data protection law. However, if you have any questions about this Privacy Policy or our data protection practices, please contact us using the details provided in Section 13.
3. Personal Data We Collect
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
3.1 Information You Provide to Us
• Identity Data: your first name, last name, and job title.
• Contact Data: your email address, telephone number, company name, and postal address.
• Communications Data: information contained in any correspondence you send to us, including via our Website contact form, email, or social media.
• Subscription Data: your email address and preferences when you subscribe to our newsletter “Following the Yuan” or other email communications.
• Client Data: information provided in connection with our professional services engagements, including business information, project briefs, and related correspondence.
3.2 Information Collected Automatically
• Technical Data: your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
• Usage Data: information about how you use the Website, including the pages you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.
• Cookie Data: information collected through cookies and similar tracking technologies. Please see our Cookie Policy for further details.
4. How We Collect Your Personal Data
We use different methods to collect data from and about you, including through:
• Direct interactions: You may give us your Identity, Contact, Communications, Subscription, and Client Data by filling in forms on our Website, subscribing to our newsletter, corresponding with us by email or social media, or engaging our Services.
• Automated technologies: As you interact with our Website, we may automatically collect Technical, Usage, and Cookie Data. We collect this data by using cookies, server logs, and other similar technologies. Please see our Cookie Policy for further details.
• Third parties: We may receive Technical Data from analytics providers such as Squarespace Analytics and social media platforms.
5. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
To respond to your enquiries and provide our Services:
We process identity, contact, communications, and client data in order to respond to your enquiries and deliver our services.
Our lawful basis for this processing is the performance of a contract, or our legitimate interests in responding to enquiries and operating our business.
To send you our newsletter and marketing communications:
We process identity, contact, and subscription data to send you marketing communications.
We rely on your consent to do so. You can withdraw your consent at any time by unsubscribing.
To administer and protect the Website:
We process technical and usage data to maintain, secure, and improve our website.
This is necessary for our legitimate interests in running our business, upkeeping IT administration and network security.
To analyse Website usage and improve our content and services:
We process technical, usage, and cookie data to understand how users interact with our website and improve our services.
We rely on legitimate interests to analyse usage data, and on your consent for non-essential cookies.
6. Data Sharing
We may share your personal data with the following categories of recipients:
• Service providers: third-party companies that provide services on our behalf, such as website hosting (Squarespace), email delivery (Substack), and analytics. These service providers are only permitted to use your personal data in accordance with our instructions and applicable data protection law.
• Professional advisers: our lawyers, accountants, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Regulatory or governmental bodies: HM Revenue & Customs, regulators, and other authorities who require reporting of processing activities in certain circumstances.
• Business partners: where we collaborate with strategic partners (such as our partner in Shanghai) to deliver our Services, we may share necessary project-related information. Any such sharing will be subject to appropriate data protection safeguards.
We do not sell your personal data to third parties.
7. International Transfers
7.1. As ApertureChina operates across the United Kingdom and the People’s Republic of China, some of your personal data may be transferred to, stored, or processed in jurisdictions outside the United Kingdom, including China.
7.2. Whenever we transfer your personal data outside the UK, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards, including:
• Transferring to countries that have been deemed to provide an adequate level of protection for personal data by the UK Secretary of State.
• Using the International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses approved by the Information Commissioner’s Office (ICO).
• Implementing additional technical and organisational measures where necessary to ensure the security of your data.
7.3. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
8. Data Retention
8.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements.
8.2. 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, regulatory, tax, accounting, or other requirements.
8.3. In general, we retain contact and communications data for the duration of our business relationship and for a period of six (6) years thereafter. Newsletter subscription data is retained until you unsubscribe. Technical and usage data is typically retained for twenty-four (24) months.
9. Your Legal Rights
Under the UK GDPR, you have certain rights in relation to your personal data. These include the right to:
• Request access to your personal data (commonly known as a “subject access request”).
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing of your personal data.
• Request the transfer of your personal data to you or to a third party (data portability).
• Withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us using the details in Section 13. You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We will try to respond to all legitimate requests within one month.
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection. The ICO can be contacted at www.ico.org.uk.
10. Data Security
10.1. 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.
10.2. 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.
11. Third-Party Links
The Website may include links to third-party websites, plug-ins, and applications (including social media platforms such as LinkedIn, Bluesky, and Substack). 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. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The updated version will be indicated by the “Last updated” date at the top of this Privacy Policy. We encourage you to review this Privacy Policy periodically.
13. Contact Us
If you have any questions about this Privacy Policy, or if you wish to exercise your data protection rights, please contact us at:
ApertureChina Ltd
1 Mentmore Terrace, London, E8 3PN
Email: yaling@aperturechina.com
Website: www.aperturechina.com