- (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.
Scope and applicability
2. Which data do we collect
- 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.
3. How is your personal data collected?
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
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
- 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;
- 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.
5. Disclosures of your personal data
- 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.
- Other third parties subject to you prior consent.
6. International transfers
7. Data security
8. Data retention
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