Privacy Policy

We are Avrasons Ltd with registered number 5039944 and registered address Avrasons Ltd, 18-18A, Brixton Road. Our Data Protection Lead can be contacted at richard@avrasons.co.uk. We have produced this privacy notice in order to keep you informed of how we handle your personal data. All handling of your personal data is done in compliance with the General Data Protection Regulation (EU) 2016/679 (“Data Protection Legislation”).

What are your rights?

When reading this notice, it might be helpful to understand that your rights arising under Data Protection Legislation include:

• The right to be informed of how your Personal Data is used (through this notice);
• The right to access any personal data held about you;
• The right to withdraw consent at any time, by emailing richard@avrasons.co.uk;
• The right to rectify any inaccurate or incomplete personal data held about you;
• The right to erasure where it cannot be justified that the information held satisfies any of the criteria outlined in this policy, or where you have withdrawn consent;
• The right to prevent processing for direct marketing purposes, scientific/historical research or in any such way that is likely to cause substantial damage to you or another, including through profile building; and
• The right to object to processing that results in decisions being made about you by automated processes and prevent those decisions being enacted.

Who is the Data Controller?

• If we have collected your personal data directly from you for our own purposes, we are the Data Controller.
• If we have purchased your personal data from a third-party for our own purposes, we are the Data Controller. Where we have purchased your personal data, we will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
• If we have been passed your personal data from a third-party for our own purposes, we are the Data Controller. We will contact you to let you know before we first start to use it, or, at the latest, within one month of acquiring it.
• If we have been passed your personal data from a third-party for a joint purpose that we both influence, we are the joint Data Controller. We will contact you to let you know before we first start to use your data, or, at the latest, within one month of acquiring it.
• If your data has been passed to us by a third party for processing under their instruction, that third party is the Data Controller. They should have notified you that they would be passing your personal data to us, Avrasons Ltd, at the time they collected your data and within their own privacy notices/standards. For a list of Data Controllers that we process personal data for, the section below ‘Third Party Interests’.
• If we have received your personal data as part of a business to business relationship, the Data Controller is your employer.

What are the Lawful Basis for Processing Personal Data?

Under Data Protection Legislation, there must be a ‘lawful basis’ for the use of personal data. The lawful bases are outlined in Article 6, Section 1 of the GDPR. They are sub-sections:

a) ‘your consent’;
b) ‘performance of a contract’;
c) ‘compliance with a legal obligation’;
d) ‘protection of your, or another’s vital interests’;
e) ‘public interest/official authority’; and
f) ‘our legitimate interests’.

About our Processing of Your Data

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 which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

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 this website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

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.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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.

Reference	What categories of information about you do we process?	Why are we processing your data?	Where did we get your personal data from?
B2B Marketing	Identity Data Contact Data	Direct marketing to former, current and prospective clients. This processing is conducted lawfully on the basis of ‘our legitimate interests’.	Directly obtained or by referral from existing clients/partners/suppliers.
Analytics	Technical Data Usage Data	To understand how you use our website, how you reached us and how long you spend on our website, in order to analyse our performance and improve our service. This processing is conducted lawfully on the basis of ‘our legitimate interests’.	Directly obtained or indirectly obtained through a client’s website (notice given at the point of collection).
Fraud Prevention	Identity Data Transaction Data	To combat fraud, we share information of clients who instruct the payment issuer to cancel payments to us without first informing us of why and/or allowing us the opportunity to issue a refund with credit reference agencies. This processing is conducted lawfully on the basis of ‘protection of your, or another’s vital interests’.	Directly obtained or indirectly obtained through a client’s website (notice given at the point of collection).
Contact Submission	Identity Data Contact Data	When you send us information about you by posting on a forum or blog, we will store this information in order to make it available for viewing on the website. You consent is obtained at the time of posting and via reference to this notice. This processing is conducted lawfully on the basis of ‘your consent’.	Directly obtained or indirectly obtained through a client’s website (notice given at the point of collection).
Online Payment Processing	Identity Data Contact Data Transaction Data	We require certain information about you in order to instruct our payments processor to take payment from you and transfer it to us. To ensure security, we do not ever process your payment information and will transfer you to the payment service’s website at the time of payment. None of our staff or contractors ever have access to this information. This processing is conducted lawfully on the basis of ‘performance of a contract’.	Directly obtained.
Phone Calls	Identity Data Contact Data	We might record calls for training and/or auditing purposes. We also collect Calling Line Identification information. This is used to help improve the efficiency and accountability of our customer services. This processing is conducted lawfully on the basis of ‘our legitimate interests’.	Directly obtained.
Email and Web Contact	Identity Data Contact Data	If you contact us through our website or by email, we will use the information you send in order to respond to your enquiry or complaint. This information will be kept in order to improve our service to you overall. This processing is conducted lawfully on the basis of ‘our legitimate interests’.	Directly obtained or indirectly obtained through a client’s website (notice given at the point of collection).
Consumer Marketing	Identity Data Contact Data Transactional Data Marketing and Communications Data	If you make a purchase with us, we will add your contact information to our marketing list and send you information we think you might be interested in. This processing is conducted lawfully on the basis of ‘our legitimate interests’.	Directly obtained.

Cookie Policy

A cookie is a small amount of data, which often includes an anonymous unique identifier that is sent to your browser from a website’s computer and stored on your computer’s hard drive. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Many sites do this whenever a user visits their website in order to track online traffic flows and record information about your online preferences.

What Cookies do we use and what for?
Our site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by us. We use Cookies to facilitate and improve your experience of our site and to provide and improve our services.

Cookies are uniquely assigned to you, and can only be read by a Web server in the domain that issued the cookie to you.

We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

By using our site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. We use third-party cookies on our site for analytics, advertising, social media interaction and logged administrative purposes. For more details, please refer to the above table. These Cookies are not integral to the functioning of our site.

All Cookies used by and on our site, are used in accordance with current UK and EU Cookie Law.

See the table below for the list of Cookies used by our site:

Cookie	Name	Purpose	Further information
Google Analytics and Google+	_utma _utmb _utmc _utmz	These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.	Click here for an overview of privacy at Google
Facebook	Renamed frequently	Facebook use cookies to recognise you when you log in, for security, advertising, localisation and analytics.	Click here for an overview of privacy at Facebook
Twitter	_twitter_sess	To remember your logged in Twitter session.	Click here for an overview of privacy at Twitter
Content Management System	wordpress_ [hash]	A functional cookie used by our content management system for administrative sessions.

* If you choose to decline cookies, you may not be able to fully experience the interactive features of our Service or Website. Our company keeps track of the pages you visit on our website, in order to determine what portion of our Website or Service is the most popular or most used. This data is used to deliver customised content and promotions within our Website and Service to customers whose behaviour indicates that they are interested in a particular subject area.

Types of Cookies Used

Analytics
We use ‘analytical’ cookies which, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our website and which parts of the website are most popular. This helps us gather feedback so that we can improve our website. Our analytics cookies include Google Analytics. To opt-out of Google Analytics, click here or to find out more information about Google Analytics security and privacy click here.

Targeting
We may use Remarketing with Google Analytics to advertise online and make ads more relevant. Remarketing cookies will be used by third parties (including Google) to show our ads on websites other than our own.

Both us and third parties (including Google) will also use Remarketing cookies – both first-party (such as Google Analytics) and third-party – to serve more relevant ads to users based on past visits to our website, whether those users are on our website or on other websites. To opt-out of Remarketing or to control your ad preferences, click here. Remarketing cookies expire 90 days from the time that the cookie is set or updated (whichever the later).

Social Media
In order to enhance your internet experience and to make the sharing of content easier, some pages on our website contain tools or applications that are linked to third party social media providers such as Facebook, Twitter or LinkedIn. Through these tools or applications, the social media service provider may set its own cookies on your device. We do not control these cookies and you should check the social media service provider’s website for further details about how they use them.

How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided below.

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

In addition, most advertising networks offer you a way to opt-out of targeted advertising.  If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. You may opt-out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.

Changes to Our Privacy Policy
We may change this Privacy Policy as we may deem necessary from time to time, or as may be required by law. Any changes will be posted on this page.