PRIVACY POLICY

INFORMATION ABOUT OUR USE OF YOUR PERSONAL DATA

The AvantEdge Group Ltd trading as AvantEdge (‘AvantEdge’, ‘we’ and ‘our’) take our responsibilities for looking after the privacy of your personal data very seriously. The General Data Protection Regulations (GDPR), the Data Protection Act 2018 and Privacy and Electronic Privacy Regulations (PECR), along with any other applicable legislation provide the framework for how we do this.

We act as a Data Controller for the personal data we process about our employees; our customers and suppliers (current and prospective); our visitors; enquirers and those who engage with our website and directly with us.

Where our website contains links to the websites of our partner networks, advertisers and any other third parties, please note that these websites will have their own privacy policies and that we do not accept any responsibility or liability for these policies.

CUSTOMERS / MARKETING CONTACTS / WEBSITE VISITORS

THE KINDS OF PERSONAL DATA WE MAY COLLECT

The following are examples of types of personal data that we may collect. The specific kind of information collected by us will depend on the Services provided:

Customer / Marketing Contact / Website visitors:

• Contact information (first name, last name, email address, phone number, address, company, job title)
• Payment information (billing address, bank account information)
• Your purchase or service history with AvantEdge
• Your location
• Your interests and preferences
• Business financial (including tax) information
• Personal details (including Anti Money Laundering Identification) and financial (including tax) information
• Demographic information
• Details about the computer/s and/or other devices, applications and networks (including IP address, browser details, device ID, operating system, or language preferences) you use when you visit our website.
• How you use our website or sub domain/s (i.e. how you interact with the site, or the pages you visit, and including referring URLs or dates and times of website visits)

How is the data collected?

We may collect data (which may include personal data about you) in a variety of ways:

Customers/Marketing contacts:

• When you register to get a quote on the AvantEdge website
• When you fill out one of the contact forms on the AvantEdge website
• When you speak to our customer service personnel (over the phone or at events (e.g. fairs, exhibitions))
• Explicitly via data capture measures, for example by entering competitions and completing surveys; and
• Implicitly via data capture measures such as studying which pages you read the most
• You purchase a product or service from us.

Marketing Contact information will be shared with “partners” where a) we host a joint partner webinar and it will be made clear on the relevant web page if this is a Partner webinar and b) we host a roadshow where we specify your details will be passed to the partners exhibiting at that roadshow. The only other time we would share your data with a third party is when a telemarketing firm may do telephone follow-up on our behalf.

Visitors / Others:

• When you report bad practices as a whistle-blower;
• When you visit our premises or websites;
• You are a supplier or prospective supplier.

COOKIES:

We may also use Cookies in order to collect information about you. Cookies are small files which are sent to your browser and stored on your computer’s hard disk.

All Cookies used by and on Our Site are used in accordance with current UK and EU Cookie Law. Before Cookies are placed on your computer or device you will be shown a pop-up message requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

THE LAWFUL BASES WE RELY ON

Under the GDPR there are six lawful bases under which organisations can collect, use and store (called “processing”) personal data. We have identified four which we rely upon for our business activities: Consent, Contractual, Legitimate Interests and Legal Obligation.

Contractual: in many circumstances we rely on the lawful basis of “performance of a contract”. This enables us to process your personal data to provide the services you buy from us (or in preparation for the contract).

Consent: in some circumstances we rely on your specific consent, whereby you actively agree and “opt-in”. We will always make it clear how you can withdraw your consent, which you can do at any time.

Legal Obligation: there will be circumstances under which we are legally obliged to hold your personal data or are required to disclose it to a third party by law. This will apply for certain tax or other regulatory purposes.

Legitimate Interests: for some of our activities we rely on our legitimate business interests to collect and use your personal data. In such cases, we have been very careful to balance our interests with yours. We are confident that these activities will not have any negative impact on your privacy rights and freedoms.

We specifically rely on Legitimate Interests to:

• send you marketing communications about our newsletters, offers, webinars and our products and services where we believe you will be interested in hearing about them
• personalise the marketing content we provide you
• undertake business sales and advertising activities
• research publicly available business contact details
• customise the content you see on our websites
• share your contact details where you register on any Partner Webinars

You can always object to our marketing messages by opting out, either by contacting our Data Protection Manager or by clicking the subscription preferences link in the footer of every email we send.

If you wish to object to our reliance on Legitimate Interests for any other purpose please contact the Data Protection Manager at [email protected].

MARKETING

We may contact you to tell you about our products, services and offerings (or updates to them) using information that you have provided to us, or that we have collected through third parties (e.g. external marketing companies).

We will only send you direct marketing communications:

• When you have provided your consent (typically by clicking a “button” to submit a form)
• Where we believe we can demonstrate a legitimate business interest and have balanced this with your interests and privacy

You can stop receiving direct marketing communications from us at any time. We provide a clear and easy way for you to do this for by including a subscription preferences link in the footer of every email we send.

For electronic marketing communications we adhere to the rules of the Privacy and Electronic Communications Regulations (PECR).

The data we collect is only used for internal review and to contact you for marketing purposes. It is not shared with other organisations for commercial purposes.

WHY AND HOW WE USE YOUR PERSONAL DATA

Your personal data may be processed in any of the following ways:

• Information that you provide by filling in forms on any of our sites or sub domains (including information provided at the time of registering to use our site, subscribing to our Services, posting material, any inquiry through the “Contact Us” section of our site, an online employment application or requesting further Services)
• Establishing and manage AvantEdge accounts;
• Communicating changes to our Services;
• Providing customer support, trouble-shooting, manage subscriptions and respond to requests, questions and comments;
• Ensuring that the content of our site is presented in the most effective manner for you and your computer;
• Communicating about and administering participation in special events, surveys, contests, webinars, and other offers and promotions;
• Analysing users’ behaviour when using our Services to customise preferences, and develop new products, services and advertising;
• Enabling posting on our blog and other communication channels (such as Social Media);
• Complying with and enforcing applicable legal requirements, agreements, and policies; and
• Any other activity consistent with this Privacy Notice.

You have the right to OPT-OUT at any time by contacting us at [email protected].

SPECIFIC EXAMPLES OF WHY AND HOW WE PROCESS YOUR PERSONAL DATA:

IP addresses

We may collect information about your computer (or other device) that does not, by itself, identify you by name. This may include (where available) your IP address, operating system and browser type. This helps with our system administration and allows us to report aggregate information – statistical data about our users’ browsing actions and patterns. The purpose of the data is to improve effectiveness of the site, to help diagnose problems and to administer the sites.

Cookies and information gathering tools

Our websites (and subdomains) use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our websites and helps us to improve them.

AvantEdge may also collect information during your visit to our websites through automated tools, which include Web beacons, embedded web links and any other commonly used information gathering tools. A web beacon is an object that is embedded in a web page or email and is usually invisible to the user but allows checking that a user has viewed the page or email. AvantEdge may use the web beacons for the purpose of email tracking and page tagging for Web analytics. In addition we might use web beacons implemented through an embedded image include tracking pixel, pixel tag, 1×1 gif, and clear gif that may be implemented by using JavaScript.

You can learn more about Cookies and how they are used here:

• www.youronlinechoices.eu
• www.allaboutcookies.org

AVANTEDGE INNOVATION EMPLOYEES

WHAT KINDS OF PERSONAL DATA DO WE COLLECT?

• name and contact details;
• previous experience, education, referees and answers to questions relevant to the role;
• equal opportunities information (non-mandatory)
• health data
• next of kin
• criminal records (you will be advised if this is necessary for the role)

HOW IS THE DATA COLLECTED?

AvantEdge may collect data (which may include personal data about you) in a variety of ways:

• When you apply for a job (application forms, CV, recruitment agencies etc),
• During the course of your employment as an employee

THE LAWFUL BASES WE RELY ON

Contractual: in many circumstances we rely on the lawful basis of “performance of a contract” – it is necessary for us to process your information to fulfil the requirements of your employment contract.

Consent: in some circumstances we rely on your specific consent, whereby you actively agree and “opt-in”. We will always make it clear how you can withdraw your consent at any time.

Legal Obligation: there will be circumstances under which we are legally obliged to hold your personal data or required to disclose it to a third party by law. This will apply to many aspects of the data we may process if you are an employee of AvantEdge.

Legitimate Interests: for some of our activities we rely on our legitimate business interests to collect and use your personal data. In such cases, we have balanced our interests with yours and do not believe these activities will have an overriding negative impact on your privacy rights and freedoms.

GENERAL

DATA TRANSFERS

AvantEdge is headquartered in the United Kingdom. The data that we collect may be processed, transferred to, and stored at our various service (including home working) and data centre locations. Where possible we ensure this processing is conducted within the European Economic Area (‘EEA’), but on occasion processing may happen outside of the EEA. Where this is the case, we ensure we have suitable legal and contractual protection in place in our data transfer/processing agreements.

AvantEdge will take all reasonable steps necessary to ensure that your data is treated securely, with appropriate technical and organisational measures, and in accordance with this privacy notice.

YOUR RIGHTS AND CHOICES

If you would prefer us not to:

• contact you (via phone, email, SMS or any other way)
• use your data in the way described in this Privacy Notice
• pass your details on to third parties

then please contact us at: [email protected].

Under data protection law, you have rights we need to make you aware of. The rights available to you depend on our reason for processing your information.

a) Your right of access
You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

b) Your right to rectification
You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

c) Your right to erasure
You have the right to ask us to erase your personal information in certain circumstances.

d) Your right to restriction of processing
You have the right to ask us to restrict the processing of your information in certain circumstances.

e) Your right to object to processing
You have the right to object to processing if we are processing your information under the legitimate interests lawful basis.

f) Your right to data portability
This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent, or under/in talks about entering into a contract and the processing is automated.

You are not required to pay any charge for exercising your rights. We have one month to respond to you.

Please contact us at [email protected] if you wish to make a request.

YOUR RIGHT TO COMPLAIN

If you have queries or concerns, please contact us at [email protected] and we’ll respond.

If we fail to address your concerns, you can make a complaint about the way we process your personal information to the Information Commissioner’s Office (the ICO) as the UK supervisory authority. Please follow this link to see how to do that https://ico.org.uk/make-a-comp….

HOW WE SECURE YOUR PERSONAL DATA

In accordance with AvantEdge policies, we are committed to protect any personal data divulged to us. AvantEdge have implemented appropriate security measures, technologies and procedures in order to protect your personal data from loss, misuse, alteration or destruction. Our management team, employees and partners are required to keep personal data confidential.

Unfortunately, the transmission of information via the internet (by way of an email or other) is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site – any transmission is at your own risk. Once we have received your information, we will use internal procedures and security features in an attempt to prevent unauthorised access.

DATA RETENTION INFORMATION

AvantEdge retains information for legitimate business or legal purposes. We will not hold information for any longer than is reasonably necessary to fulfil the purposes for which it was collected.