Avnio Ltd (Avnio, we, our, us) respects your privacy and is committed to protecting your personal data. This policy is intended to help you understand how we use and protect the personal data you provide to us. It also explains your privacy rights and protections.
Introduction & Contents
- Important information & our details
- The data we collect about you
- How your personal data is collected
- How we use your personal data
- Disclosures of your personal data
- International transfers
- Data security
- Data retention
- Your legal rights
1. Purpose of this Privacy Notice
This privacy notice gives you information about how we collect and process personal data you provide to us, including any data you provide via our website (https://www.avnio.com/) (our Site), when you register with us, use our software or platform (together, Platform) or receive services or when you contact us via our website, partner websites such as G2, Capterra, TrustRadius or software marketplaces such as the Salesforce AppExchange or Microsoft AppSource.
This privacy notice should be read together with any other privacy notice or fair processing notice we may provide when we are collecting or processing personal data about you. This privacy notice supplements any other notices and is not intended to override them. Our business offering is not intended for children and we do not knowingly collect data relating to children.
Our Contact Details and Role
We are the data controller responsible for your personal data. Our full details are:
Name: Avnio Limited
Company registration number: 12039041
Email address: firstname.lastname@example.org
Postal Address: International House, 24 Holborn Viaduct London EC1A 2BN United Kingdom
If you have any questions about this privacy notice, including any requests to exercise your legal rights (see section 9 below), please contact us via email at email@example.com
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk), which is the supervisory authority for UK data protection issues. However, we ask that you contact us in the first instance and give us the opportunity to address your concerns before you consider contacting the ICO.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current, so please let us know if your personal data changes at any time.
Our Site and our Platform may include links to third-party websites, vendor offerings or other applications, plug-ins and/or 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 statements. When you leave our website, you should read the privacy notice of any website you visit.
2. The data we collect about you
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 the following kinds of personal data about you, which we have summarised into categories:
- Identity Data includes [first name, maiden name, last name, username or similar identifier, title, date of birth and gender].
- Contact Data includes [billing address, delivery address, email address and telephone numbers].
- Usage Data includes [information about how you use our website, products and services].
- Marketing and Communications Data includes [your preferences in receiving marketing from us and our third parties and your communication preferences].
The above categories are used as defined terms elsewhere in this privacy notice, in particular section 4.
We do not collect any Special Categories of Personal Data about you (this includes 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.
If you fail to provide personal data
Where we need to collect personal data 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 our obligations under our contract with you. In that case, we may have to cancel a product or service but we will notify you if so.
3. How your Personal Data is Collected
We use different methods to collect your personal data including through:
Directly from you. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
This includes personal data you provide when you:
- apply for our products or services
- create an account on our website
- subscribe to our service or publications
- request marketing information to be sent to you
- enter a competition, promotion or survey
- give us some feedback
- Automated technologies or interactions. As you interact with our Site or our Platform, we may 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.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
Technical Data from the following parties:
- analytics providers (such as Google based outside the EU);
- search information providers (such as Google based [inside OR outside] the EU).
- Identity and Contact Data from publicly availably sources [such as Companies House and the Electoral Register based inside the EU].
4. How we 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 perform our contractual obligations to 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 or regulatory obligation.
- Legitimate Interest means the interest of conducting and managing our business to enable us to give you the good services/products and a good and secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Please contact us if you would like any further guidance concerning how we assess legitimate interests against any potential impact on you.
- Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or SMS. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and legal bases we rely on in doing so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a customer||Performance of a contract with you|
|To process and deliver goods or services to you including:|
a. Manage payments, fees and charges
b. Collect and recover money owed to us
|a. Performance of a contract with you|
b. Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:|
b. Asking you to leave a review or take a survey
|a. Performance of a contract with you|
b. Necessary to comply with a legal obligation
c. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||a. Performance of a contract with you|
b. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business, our Site and our Platform (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||a. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group|
b. Necessary to comply with a legal obligation
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||a. Identity|
e. Marketing & Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Site, Platform, products/services, marketing, customer relationships and experiences||a. Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing|
|To make suggestions and recommendations to you about goods or services that may be of interest to you|
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms regarding our marketing activities:
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage and Profile Data to decide what we think you may want or need, or what may be of interest to you.
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or by following the optout links on any marketing message sent to you or by contacting us at any time].
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of Purpose
We will only use your personal data 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 need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, where this is required or permitted by law.
5. Disclosures of your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
The following internal third parties:
- Other companies within our group of companies [acting as joint controllers or processors] and who are based in India or the United States and provide support or development services to you under the terms of our contract with your company.
The following external third parties:
- Service providers acting as processors based in India or United States who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide [consultancy, banking, legal, insurance and accounting services].
- HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based [in the United Kingdom] who require reporting of processing activities in certain circumstances.
- 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. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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
Our technology platform provider, Salesforce, is based outside the European Economic Area (EEA) so their processing of your personal data may involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They 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
How long will you use my personal data for?
We will only retain your personal data 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 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 requirements.
[Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us OR set out in the table in paragraph 4 above OR By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request Erasure below for further information.
In some circumstances we may 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.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where 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; or (d) 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.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may 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 try to respond to all legitimate requests within one month. Occasionally it may 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 informed.