Avrios Privacy Policy

Effective date: December 1st, 2020

1. Introduction

At Avrios, we respect your privacy and we are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you

  • (i) visit our websites (regardless of where you visit it from),
  • (ii) request information about and evaluate our services,
  • (iii) request or create a customer account on the Avrios Platform
  • (iv) apply for a job or
  • (v) otherwise communicate, interact, or enter into a business relationship with us.

It tells you about your privacy rights and how the law protects you in accordance with the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (GDPR). This Privacy Policy is issued on behalf of the “Avrios Group” so when we mention ”Avrios”, ”we”, ”us” or ”our” further below, we are referring to the relevant company in the Avrios Group responsible for processing your data. The Avrios Group includes Avrios International AG, a limited company registered in Switzerland under company number CHE-480.579.000 and with registered offices at Weststrasse 50, 8003 Zurich, Switzerland, and its subsidiaries (currently: Avrios Germany GmbH and Avrios Poland sp. z o.o.). In respect to our websites, the responsible legal entity and data controller is Avrios International AG.. It is important that you read this Privacy Policy together with any other privacy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.

Scope and applicability

This Privacy Policy applies to personal data that we process as a data controller. Where personal data about you is uploaded or managed via a Customer Account on the Avrios Platform, we are not the controller of that personal data but a processor. In those circumstances we process such personal data in accordance with the agreement between us and the organization associated with the respective Customer Account and as per the instructions of such organization.

Third-party links

Our websites and the Avrios Platform may include links to third-party websites, plug-ins and applications. 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 policies and practices.

Changes to the Privacy Policy and your duty to inform us of changes

We keep our Privacy Policy under regular review and may update it from time to time. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. Which data do we collect

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you and your organisation depending on the Avrios services you use and your relationship with us. We may process the following categories of information:

  • Identity Data includes first name, maiden name, last name, marital status, title, date of birth, and gender.
  • Contact Data includes address, email address, and telephone numbers.
  • Professional Data includes your company name, title, role, team, and other information about your profession.
  • Technical Data includes internet protocol (IP) address, your login data, 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 our websites or the Avrios Platform.
  • Profile Data includes usernames and passwords, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our websites and the Avrios Platform.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • Employment Data includes your current and past employment experience, qualifications, skills, interests and any other information disclosed by you in relation to an application for a job within Avrios.

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy. We do not collect any “Special Categories of Personal Data” about you such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. Nor do we collect any information about criminal convictions and offences. Our websites and services are not intended for children and we do not knowingly collect data relating to children.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions.
You may give us your personal data by filling in forms on our websites or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our services;
  • request or create an account on our website;
  • subscribe to our services;
  • meet with one of our employees;
  • participate in an event which we have organised;
  • apply for a role at Avrios;
  • request marketing to be sent to you; or
  • give us feedback or contact us.‍

Automated technologies or interactions
As you interact with our websites or the Avrios Platform, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. You can control the use of Cookies on our websites via the settings of your browser. Please see our Cookie Policy for further details.

‍Third parties or publicly available sources
We may receive personal data about you from various third parties, including:

  • Technical Data from the analytics providers such as Google;
  • Employment, Identity and Contact Data from third party recruitment agencies;
  • Marketing and Communications Data from respective data service providers.

4. Purposes for which we will 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:

  • where we need to comply with a legal obligation;
  • where we need to perform the contract we are about to enter into or have entered into with you or your organisation;
  • 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; and/or
  • where you have given us explicit consent to do so;

Typical cases for which we may use your personal data include:

  • to set up your customer account and manage your user credentials;
  • to manage our relationship with you including notifying you about changes to our terms or policies,
  • to enable you to complete a survey or give feedback;
  • to administer and protect our business, websites and software (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • to deliver relevant content to you and measure or understand the effectiveness of the content we serve to you;
  • to perform analytics to improve our website, products/services, marketing, and customer relationship experiences;
  • to make suggestions and recommendations to you about services that may be of interest to you;
  • to publish your testimonials about our services on our website and in our marketing materials;
  • to process applications for roles at Avrios.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Generally, we do not rely on consent as a legal basis for processing your personal data. However, we will not send you any marketing communications and we will not share your personal data with any third party for marketing purposes without your prior explicit opt-in. You have the right to withdraw consent to marketing by following the opt-out links on any marketing message sent to you or by contacting us at any time.

5. Disclosures of your personal data

We may share your personal data with the parties set out below:

  • Avrios group companies.
  • Third party service providers who perform a variety of services on our behalf in accordance with this policy (IT service providers and system administrators, third parties who host and manage data or provide programming or technical support, deliver our products and services, conduct reference checks on candidates on our behalf, etc.).
  • Professional advisers including lawyers, bankers, auditors and who provide consultancy, banking, legal, insurance and accounting services.
  • Third-party analytics partners to analyse website traffic and understand user or customer needs and trends or our third-party marketing service providers to help us to communicate with users or customers.
  • Third parties if we are required to do so by law, or if we believe that such action is necessary to: (i) fulfil a government, or regulatory authority request; (ii) conform with the requirements of the law or legal process; (ii) protect or defend our legal rights or property, our websites, users or customers.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. Upon a respective change of control event the new owners may use your personal data in the same way as set out in this privacy policy.
  • Other third parties subject to you prior consent.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

Some of our external third parties may be based outside the EEA so their processing of your personal data may involve a transfer of data outside the EEA. Where we transfer your personal data to countries outside the EEA that have not been deemed to provide an adequate level of protection for personal data by the European Commission we will undertake to incorporate contractual clauses approved by the European Commission which give your personal data the same protection it has in Europe.

7. Data security

We have put in place appropriate technical and organisational measures to prevent your personal data from being accidentally lost, used, altered, disclosed or accessed in an unauthorised way. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. Those will only process your personal data on our instructions and they are subject to a duty of confidentiality. 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.

8. Data retention

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. 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. 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. By law we have to keep basic information about our customers (including Contact and Identity Data) for six years after they cease being customers for tax purposes. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In some circumstances you can ask us to delete your data as per the provisions in the following sections.

9. Your legal rights

You have the right to:

  • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • You want us to establish the data’s accuracy.
  • Our use of the data is unlawful but you do not want us to erase it.
  • You need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Usually no fee required You will not have to pay a fee to access your personal data or to exercise any of your rights listed above. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We aim to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact and Complaints

If you have any questions about this Privacy Policy or a related topic, including any requests to exercise your legal rights, please contact us at  privacy@avrios.com. You have the right to make a complaint at any time to the applicable data protection supervisory authorities in the EU/EEA/Switzerland. You can find the list of the EU data protection authorities here . We would, however, appreciate the chance to deal with your concerns before you approach such authorities, so please contact us in the first instance.