Policies

This policy (together with our terms of use) 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. This policy complies with the requirements of the UK General Data Protection Regulations as set out in the Data Protection Act 2018 and all other provisions of that Act ”Data Protection Legislation”.

For the purpose of the Data Protection Legislation, the data controller is AKT II Limited of White Collar Factory, 1 Old Street Yard, London, EC1Y 8AF, and AKT II’s data protection officer is Gary Davison, Company Secretary.

Information we may collect from you

We may collect and process the following data about you:

• Information you give us. You may give us information about you by filling in forms on our site www.akt-uk.com (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you, participate in social media functions on our site, or any other activity carried out from time to time on the website where we may use data collection and also when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number.
• Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • information about your visit, including the full Uniform Resource Locators (URL) click-stream to, through and from our site (including date and time); pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

We may also receive data about you from various third parties including technical data from the following parties:

• analytics providers (Google Analytics, Hotjar)

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our cookie policy.

Uses made of the information

AKT II takes your privacy seriously and will only use your personal information to provide the services you have requested from us. We will only use this information subject to your instructions, relevant Data Protection Legislation and our duty of confidentiality. Most commonly, we will use your personal data in the following circumstances:

• 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.
• Where we need to comply with a legal obligation.

For Business-to-Business Clients and Contacts, our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.

For Business-to-Consumer Clients and Contacts, our lawful reason for processing your personal information will be “A contract with the individual” e.g. to supply services you have requested, or to fulfil obligations under a contract. This also includes steps taken at your request before entering into a contract.

We collect information on our website to process your enquiry, deal with your event registration, give advice based on survey data and improve our services. If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.

Data analytics and benchmarking

We may use the information generated and stored during your use of our services for our legitimate business interests to enable us to give you the best service and/or solutions and the best experience. These purposes include to:

• deliver advertising, marketing or information to you which may be useful to you, based on your use of services; or
• carry out research and development to improve our services; or
• develop and provide new and existing functionality and services.

Disclosure of your information

We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

We may share your information with selected third parties including:

• Analytics and search engine providers that assist us in the improvement and optimisation of our site;
• our service providers and agents (including their sub-contractors) or third parties which process information on our behalf (e.g. internet service and platform providers, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the services and information you have requested or which we believe is of interest to you or for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the services and we have contracts in place that require them to keep your information secure and not to use it for their own direct marketing purposes;
• law enforcement agencies so that they may detect or prevent crime or prosecute offenders;
• any third party in the context of actual or threatened legal proceedings, provided we can do so lawfully (for example in response to a court order);
• any third party in order to meet our legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;
• another organisation to whom we may transfer our agreement with you;
• government departments where reporting is mandatory under applicable law.

We may disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of AKT II LIMITED, our customers, or others.

The data that we collect from you may be transferred to, and stored at, a destination outside of the UK and the European Economic Area (“EEA”) only where it is compliant with Data Protection Legislation and the means of transfer provide adequate safeguards in relation to your data. It may also be processed by staff operating outside the UK or EEA who work for us. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

We will not share your information for marketing purposes with companies so that they may offer you their products and services.

Marketing

We would like to send you information about projects, services, events of ours and other companies in our group which may be of interest to you. You have a right at any time to stop us from contacting you for marketing purposes or giving you information.

If you no longer wish to be contacted for marketing purposes, please click here to unsubscribe.

Data storage

Data is held in the United Kingdom using different (multiple) servers. AKT II Limited does not store personal data outside the UK or EEA.

We review our retention periods for personal information on a regular basis. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

Your rights

If you are based within the UK, EEA or within another jurisdiction having similar data protection laws, in certain circumstances you have the following rights:

1. the right to be told how we use your information and obtain access to your information;
2. the right to have your information rectified or erased or place restrictions on processing your information;
3. the right to object to the processing of your information e.g. for direct marketing purposes or where the processing is based on our legitimate interests;
4. the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
5. where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
6. the right to object to any decisions based on the automated processing of your personal data, including profiling; and
7. the right to lodge a complaint with the supervisory authority responsible for data protection matters (in the UK the Information Commissioner’s Office).

If you wish to exercise your right described above or for any question you may have, please contact us at privacy@akt-uk.com.

For complete information regarding your rights, please visit the Information Commissioner’s Office (ICO) website at https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights.

Changes to our privacy policy

We keep our privacy policy under regular review and we will place any updates on this web page. This privacy policy was last updated on 15th January 2022.

Other sites and social media

If you follow a link from our website, application or service to another site or service, this Privacy Notice will no longer apply. We are not responsible for the information handling practices of third party sites or services and we encourage you to read the privacy notices appearing on those sites or services.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Gary Davison, AKT II Limited, White Collar Factory, 1 Old Street Yard, London, EC1Y 8AF or privacy@akt-uk.com.

Our details

This website is owned and operated by AKT II Limited.

We are registered in England and Wales under registration number 07500271.

You can contact us:

• by post, to the postal address given above;
• using our website contact form;
• by telephone, on the contact number published on our website from time to time; or
• by email at privacy@akt-uk.com.

Information about our use of cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

Cookies are small files sent by web servers when you visit websites. The cookies are stored on your computer’s hard drive. Cookies uniquely identify your browser and are sent back to the web server each time your web browser requests a page from the webserver. This enables the web servers to identify and track activity of web browsers. Most web browsers automatically accept cookies, but you can refuse cookies by changing your browser setting (see further below).

Google Analytics

These cookies are used to collect information about how our visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

Hotjar

We use Hotjar script to better understand how visitors use and navigate our website. All of the tracking information Hotjar uses is found below. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.

An exhaustive list of Hotjar’s scripts used on our website can be found below;

Disclaimer cookie

This cookie relates to the pop-up disclaimer on our website. It enables the website to remember your user type so that our disclaimer does not pop up every time you visit our website.

Refusing cookies

Most browsers allow you to refuse to accept cookies, but without accepting cookies you may experience reduced website functionality. To refuse cookies:

• In Edge, you can refuse all cookies by clicking “Settings”, “Cookies and site permissions”, “Manage and delete cookies and site data” and sliding the “allow sites to save and read cookie data” selector to off.
• In Chrome, you can block cookies by clicking “Settings”, “Privacy and security”, “Cookies and other site data” and selecting “Block all cookies”.
• In Firefox, you can adjust your cookies settings by clicking “Tools”, “Options” and “Privacy”.

Blocking cookies will have a negative impact upon the usability of some websites.

General

This policy sets out the approach AKT II Limited and its subsidiary businesses (AKT) have taken to date, and those we continue to take to ensure that slavery and human trafficking are not occurring anywhere in AKT or our supply chains. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

This policy aims to communicate our responsibilities and highlight the risks that modern slavery and trafficking pose to our business, clients and supply chain. AKT II is an international design consultancy primarily focused on structural engineering. Integrity is one of the core values under which AKT II operates.

The Company Board of Directors have overall responsibility for ensuring this Policy complies with our legal and ethical obligations and that all those under our control comply with it. The Legal Director has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery. In addition, Senior Management are responsible for ensuring those reporting to them understand and comply with this Policy and are given adequate guidance/training on it and the issue of modern slavery in supply chains.

Our supply chain

AKT II is committed to continuously improving its practices to identify and eliminate any slavery and human trafficking in its business and supply chains, and to acting ethically and with integrity in all its business relationships. We have looked at all our suppliers and assessed the key ones in more detail to ensure that they have appropriate policies in place to minimise the risk of slavery and human trafficking in their business.

AKT II uses a wide range of suppliers who supply goods services and support our operations. We ensure that we expect the same standards from our suppliers that we hold our own business to, which is achieved through monitoring and review. We have adopted the following to mitigate the risks further:

• Third Party / Suppliers Policy which sets out internal requirements for buying goods and services;
• Ethical Conduct Policy covering issues of ethics, conduct, and standards to be expected by our staff, and our suppliers; and
• Whistleblowing Policy encourages staff to report concerns including any related to modern slavery/trafficking and child or forced labour.

Training

We continue to provide advice and guidance to those teams who have direct responsibility for relevant supply chains and our teams that procure suppliers have participated in further modern slavery training. We also maintain a Modern Slavery Act Guidance document on our Company intranet.

Looking ahead

We will continue to enhance our procedures to help us identify, prevent and mitigate any risks of modern slavery or human trafficking concerning new and existing suppliers.

Whistleblowing of suspected or known wrongdoing

You have several options if you would like to report suspected or known wrongdoing relating to the law, or to the policies or values of AKT II and the wider Tyréns Group.

Primarily, you are encouraged to report known or suspected wrongdoing to a manager or a manager’s manager. If you prefer, speak to someone in the Human Resources or Legal departments instead. If you feel uncomfortable doing this, you may report suspected or known wrongdoing through any of the channels listed below. You may report confidentially and anonymously.

Why do we have a whistleblowing system in AKT II?

Whistleblowing is part of our push for AKT II and the wider Tyréns Group to uphold strong values and ethics. It enables us to raise concerns about wrongdoing when we are not comfortable using other channels.

What can you report?

The whistleblowing system is intended for the reporting of suspected or known instances of wrongdoing that are:

• A breach of the law, such as anti-competition law, harassment and equal treatment laws, corruption laws, theft, fraud, intellectual property laws and other laws relating to AKT II’s activities.
• A breach of the Tyréns Group Code of Conduct, Business Ethics Policy, Sustainability Policy, Financial Reporting Policy or any other policy of AKT II or the Tyréns Group, relating to harassment, equal treatment, environment, conflict of interest, anti-competition, reporting standards, or other areas covered by the policies.
• In conflict with AKT II’s or the Tyréns Group values and/or
• In some way, may directly or indirectly damage the reputation of AKT II or the Tyréns Group.

Whistleblowing should not be used for:

• Business or employee negotiations, such as salary or contract negotiations,
• Quality complaints that do not constitute wrongdoing,
• Complaints regarding issues that do not constitute wrongdoing as listed above, and/or
• Rumours or misinformation.

You do not need to have firm evidence for expressing a suspicion, as long as it is done in good faith, that is, with the sincere intention of being fair, open, and honest.

Deliberately reporting false or malicious information constitutes an abuse of the whistleblowing process.

Which reporting options do I have?

If you feel uncomfortable reporting a known or suspected instance of wrongdoing to a Director, the Legal Director or, Human Resources, you may use any of the channels below.

Tyréns Group level

These channels are the ones available at Tyréns Group level. Reports are received by Frank Pedersen (Group Chief Legal Officer) who is the independent receiver of whistleblowing reports. He is employed by the Tyréns Group and he reports to the board of directors of Tyréns Group.

• E-mail. Send an e-mail to Frank.Pedersen@tyrens.se
• Telephone. Call Frank Pedersen on +46-10-4522720
• Meeting. Arrange a meeting with Frank Pedersen through e-mail or telephone above.
• Whistleblowing system. Click here to get directed to an encrypted whistleblowing system managed by an external supplier. In the link you can read more about how the system works and protects your anonymity. When your report has been submitted, it will be handled by Frank Pedersen.

As a whistleblower, you are protected

You can choose to be anonymous and your identity will not be disclosed, unless:

• such disclosure is strictly necessary for the proper handling of the report;
• you have given explicit consent to such disclosure in advance;
• such disclosure is required by law or in subsequent legal proceedings, or
• an Investigation has found that the report was submitted in bad faith.

It is expressly not allowed to attempt to identify a whistleblower.

As a whistleblower, you are also protected by a non-retaliation principle. Any negative consequences to you, as a consequence of reporting wrongdoing in good faith, is considered a serious offence and could lead to sanctions, including disciplinary action or termination of the business relationship.

Your report will be evaluated and feedback provided

After your report has been received, it will be evaluated and managed according to a set process. If the evaluation shows that there could be merit to your report, it will be investigated.

You can contact the receiver in question for information about the case.

When the process is complete, you will be contacted by the receiver and notified about the conclusions and results from your report, without details or information that may compromise the integrity of the investigation.