Avanty: Website Privacy Notice

By “Personal Information” we refer to information collected or held by Avanty, that identifies and relates to you as an individual.

Avanty is the trading name of Avanty with its business address at 85 Great Portland street, London, W1W 7LT (“Avanty”).

For the purposes of the Data Protection Act 2018, the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), Avanty will be the ‘data controller’ for all personal information we determine the means and purpose of processing.

We gather and use personal information in the following circumstances.

When you become a Avanty client we will collect the information required to set up an account including your name, email address, work, (and if required) home telephone number, business address and details, your role within the business that contracts with Avanty and any additional information we need to identify what services you will require from us. 

We collect transactional information informing us of the services you have purchased from Avanty and we may also need to collect payment and invoice information to collect fees for our services unless you are using our online payment portal (see below).

We may also track user activity on our system to audit usage, customer experience, utility of the system and for security and commercial purposes to enhance our services. We do this under our legitimate business interest to promote our business and protect our customers personal information.

We may collect additional information you volunteer to us when calling our support staff regarding any elements of our service. We will only retain the personal information pertinent to delivering your services.

We require of all this information to process the contract you have us asked to perform for you. 

If we engage your services as a supplier to Avanty, we may require information such as your name, contact details (electronic or otherwise depending on the circumstance), your role within the business supplying services to Avanty and any additional information we request from you to enable a secure delivery of your services to Avanty.

We may also need invoice information to process payment for your services. We will collect transactional information regarding the services you have provided us for the purpose of maintaining our accounts, as mandated by legal obligation or monitoring our business performance under our legitimate business interest.

If you have opted in to receive our updates and marketing communications we will handle your personal information (including: your name, email address, telephone number and business details) to provide you with marketing communications in line with any preferences you have told us about.

You are not under any obligation to provide us with your Personal Information for marketing purposes. 

Every email we send to you for marketing purposes will also contain instructions on how to unsubscribe from receiving them. You can withdraw your consent to process Personal Information at any time by emailing [email protected].

If we rely on the legitimate interest of our business as the legal grounds to process your information for marketing purposes, we will always notify you of this and your right to object to this processing. Please see “Your right to object” below. All of our marketing communications will always contain clear instructions on how to unsubscribe from future communications.

The information we request via the contact form on our “Contact” web page is processed specifically to provide you with the services you have requested or respond to your enquiry appropriately.

We may also collect technical information about you when you visit the Website. This information may include the IP address used to connect your computer to the Internet, your browser type, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page. 

This information is stored and used for aggregated and statistical reporting. The collected information is used to provide an overview of how people are accessing and using the Website.

Any processing of personal information undertaken to secure our website is processed under our legitimate business interest.

When you phone us, we may also handle your personal information (your name, contact details and the other details you provide to us during the call) in order to service your enquiry or provide the customer services you have asked us to perform.  

If you fail to provide us with Personal Information

You always reserve the right to withhold your personal information, but this may affect how we provide our services

Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time. 

Card payment details taken for fees are processed and managed via Stripe. Further details regarding Stripe can be found at https://stripe.com/gb

We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the services you have requested from Avanty and unless stated, all of the above processing is conducted under the legal basis of performance of a contract.  

We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we consider the new purpose to be incompatible with the original purpose of collection, we will conduct a Privacy Impact Assessment or contact you to request your consent for further processing. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected].

We take our security obligations very seriously and constantly monitor for breaches and potential weaknesses.

Avanty is committed to ensuring that data is stored, archived or disposed of in a safe and secure manner. We have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect. 

We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to personal information only for those employees who require it to fulfil their job responsibilities. 

However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.

We shall not transfer any Personal Information to any country outside of the European Union unless we ensure that such Personal Information is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation. If you wish to access your Personal Information, we will inform you of the transfers we make (if any) and the legal safeguards we have employed to ensure the ongoing security and protection of your data.

If and when we share your data, we always do so under a legal obligation or a written agreement governing how your data must be protected.

Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Policy. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies. However, sometimes we may share your information with third parties in the following ways: 

• we may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement. We currently store our data on the Microsoft Azure system, within data centres based in the EU;
• analytics and search engine providers that assist us in the improvement and optimisation of the Website; and
• if Avanty is acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets. We process your Personal Information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Information in this way, the relevant seller or buyer of our business may not be able to provide services to you.

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.

You have the right to object to us handling your personal information when:

• we are handling your personal information based on our legitimate interests. If you ask us to stop handling your personal information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your personal information should continue; or
• for marketing purposes. If you ask us to stop handling your personal information on this basis, we will stop.

You can exercise the following rights to your data by contacting us at [email protected]

You are entitled to receive confirmation as to whether your personal information is being processed by us, as well as various other information relating to our use of your personal information. You also have the right to a copy of the personal information which we are handling regarding you. 

You have the right to require us to rectify any inaccurate personal information we hold about you. You also have the right to have incomplete personal information we hold about you completed, by providing a supplementary statement to us.

You can restrict our processing of your personal information where:

• you think we hold inaccurate personal information about you;
• our handling of your personal information breaks the law, but you do not want us to delete it;
• we no longer need to process your personal information, but you want us to keep it for legal reasons; or
• we are handling your personal information because we have a legitimate interest (as described in the “Information we collect and use” section above, and are in the process of objecting to this use of your personal information.

Where you exercise your right to restrict us from using your personal information, we will then only process your personal information when you agree, except for storage purposes and to handle legal claims.

You have the right to receive the personal information we hold about you in a structured, standard machine-readable format and to send this to another organisation controlling your personal information.

You have the right to require us to erase your personal information which we are handling in the following circumstances:

• we no longer need to use your personal information for the reasons we told you we collected it for;
• where we needed your consent to use your personal information and you have withdrawn your consent;
• you object to our use of your personal information and we have no compelling reason to carry on handling your personal information; 
• our handling of your personal information has broken the law; or
• to comply with any laws that we are subject to.

You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).

We may change this Privacy Notice at any time to ensure it always accurately reflects the way we collect, use and safeguard your Personal Information. 

Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Information handling practices. The date of the changes will be listed in the 'Last updated' section below. We will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.

We recommend that you print a copy of this page for your reference.

Please contact us at [email protected] if you have any questions, comments or requests regarding this Privacy Notice.

Last updated October2019