Effective date: December 1st, 2020
- (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).
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..
Scope and applicability
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.
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 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?
- 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:
- Third parties or publicly available sources. We may receive personal data about you from various third parties, including:
4. Purposes for which we will use your personal data
Most commonly, we will use your personal data in the following circumstances:
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
6. International transfers
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 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
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
- 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.
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
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.