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      Privacy Policy

      Dated: March 18th, 2024          

      PLEASE READ THIS POLICY CAREFULLY BEFORE USING AVANTRA’S WEBSITE

      This privacy policy applies to Syslink Xandria Ltd (company no 10864553 and whose registered office is at Parkshot House, 5 Kew Road, Richmond, London, United Kingdom, TW9 2PR) and each member of its Group (“Avantra”, “us”, “our” or “we”). Protecting your data, privacy and personal information is very important to us.  It is vitally important to us that our customers feel secure when using:  https://www.avantra.com (the “Website”) and/or our support services.

      This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by Avantra. Please read this privacy policy carefully to understand the types of information we collect from you, how we use that information, the circumstances under which we will share it with third parties, and your rights in relation to the personal data you provide to us.

      Our Website contains links to third party websites. If you follow a link to any of those third party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Please check these policies before you submit any personal information to such third party websites.

      Information we may collect

      We may collect and process the following data about you:

      • Information that you provide to us. You will be asked to provide us with your information when you:
        • fill in forms on our Website, or correspond with us by phone, email or otherwise;
        • report a problem with the Website; or
        • complete any surveys we ask you to fill in that we use for research purposes (although you do not have to respond to these if you do not want to).

      The information you will be asked to provide to us for these purposes may include your name, email address, mobile number, landline number, company name, address, time zone or further information required to verify your identity.

      With regard to each of your visits to our Website we may automatically collect the following information; however, this information cannot be used to identify you:

      • device-specific information, such as your hardware model, operating system version, unique device identifiers, and mobile network information;
      • details of your visits to our Website, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website (including date and time), length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs).

      If you are using our Website on behalf of a third party, you must have obtained clear permission from the individuals whose data you provide us with before sharing that data with us.

      For the avoidance of any doubt, any reference in this privacy policy to your data shall include data about other individuals that you have provided us with.

      How we use your information and justification of use.

      Use of personal information under UK and EU data protection laws must be justified under one of a number of legal “grounds” and we are required to set out the ground in respect of each use of your personal data in this policy. These are the principal grounds that justify our use of your information:

      • Consent: where you have consented to our use of your information (you are providing explicit, informed, freely given consent, in relation to any such use and may withdraw your consent in the circumstance detailed below by notifying us);
      • Contract performance: where your information is necessary to enter into or perform our contract with you; 
      • Legal obligation: where we need to use your information to comply with our legal obligations; 
      • Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights; and 
      • Legal claims: where your information if necessary for us to defend, prosecute or make a claim against you or a third party.

       We use information held about you (and information about others that you have provided us with) in the following ways: 

      Types of Information Collected

      Uses of that Information

      Use Justification

      Name, email address, job role, company sector and name, mobile number, landline number, fax number, address, time zone, user id, IP address

      To register you as a new customer and/or for a free demo and provide you with the services

      Contract performance; Legitimate interest (provision of demo).

      Name, email address, mobile number, company, landline number, fax number, address, time zone, IP address

      For marketing products and services that we believe will be of interest to you.

      Legitimate interest (for marketing our own similar products and services and any re-engagement campaigns).

      Consent (for marketing unrelated products or services or products or services of third parties).

      Address, time zone, IP address

      To identify more appropriate products and services to market to you.

      Legitimate interests (to administer and improve our Website).

      Name, email address, IP country, IP address

      To administer the Website and for internal operations, including research, data analysis and data statistics, and to create derived, anonymised and aggregated data to improve our Website.

      Legitimate interests (to administer and improve our Website).

      Email address

      To notify you about changes to our Website.

      Legitimate interests (to update our Website from time to time).

      Name, email address, phone, job title

      To provide support services for customers and to permit individual users to raise support tickets.

      Contract performance (to provide the requested support services).

      Name, email address

      To raise invoices for services rendered.

      Contract performance (to issue invoices).

        

      Whilst we will share personal data with other members of our Group, will not sell your personal data (or any other data you provide us with) to third parties, however, we reserve the right to share any data, provided always that it has been anonymised and/or aggregated.  You acknowledge and accept that we own all right, title and interest in and to any derived data or aggregated and/or anonymised data collected or created by us.

      Where we store your personal information

      Personal data may be processed by organisations operating outside of the UK or EEA as applicable who work for us or for one of our business partners or service providers. A full list of our third party processors and details of their privacy policies can be provided upon request.

      Countries outside the UK or EEA as applicable may not provide the same level of adequate protection for the rights and freedoms of data subjects in relation to the processing of personal data. In countries which do not provide appropriate safeguards, we shall transfer your data subject only to your consent except for transfers to and from: (i) any country with a valid adequacy decision from the UK Government or European Commission as applicable; or (ii) any organisation which ensures an adequate level of protection in accordance with applicable data protection laws, including by contractual means approved by the UK ICO or other relevant supervisory authorities. Transfers of personal data from Switzerland will only ever be to the UK or US. 

      It is your responsibility to keep your password secure. Unfortunately, the transmission of information via the internet is not completely secure. Although Avantra will do its best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website, any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent any unauthorised access.

      Please contact us if you would like further details on the specific safeguards applied to the export of your personal information outside the UK or EEA.

      Disclosure of your information

      We may also disclose your personal information to third parties in the following circumstances:

      Purpose of disclosure and third party(s) to which disclosure might be made

      Use Justification

      We may disclose your personal information to our system service providers and business partners, including contractors, agents, third party software providers (to assist us in performing any contract we enter into with them or you, including providing our Website it enables), analytics providers,  (to assist us in the improvement and optimisation of the Website) and/or a member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.

      Contract performance, legitimate interest, (to allow our Service providers to provide the necessary services).

       

      If we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets

      Legitimate interest (to sell our business or assets); Consent (for sensitive personal data)

      If Avantra or substantially all of its assets are acquired by a third party, personal information about our customers will be one of the transferred assets

      Legitimate interest (to sell our Company or assets), Consent (for sensitive personal data)

      If we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property, or safety of Avantra, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection

      Legal obligation

      Fraud Prevention and other checks. We and other organisations may also access and use your personal information to conduct credit checks and checks to prevent fraud. If false or accurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies.

      Legitimate interest (to assist with the prevention of fraud and to assess your risk profile)

      We may disclose your personal information to third parties, the court service and/or regulators or law enforcement agencies in connection with proceedings or investigations anywhere in the world where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.

      Legal obligation (to cooperate with law enforcement and regulatory authorities)

       

      How long we retain your personal data

      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.

      We will hold the above information as long as is necessary in order to deal with request including those received via the Website, deal with any specific issues that may arise, or otherwise as is required by law or any relevant regulatory body.

      If information is used for two purposes, we will retain it until the purpose with the latest period expires but we will stop using it for the purpose with a shorter period when that period expires.

      We restrict access to your personal information to those persons who need to use it for the relevant purpose(s). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymized (and the anonymized information may be retained) or securely destroyed.

      Your rights

      Under the UK Data Protection 2018 and the UK implementation of the General Data Protection Regulation (EU) 2017/676, you have various rights in relation to your personal data. All of these rights can be exercised by contacting us at legal@avantra.com.  

      In certain circumstances you have the following rights in relation to your personal data:

      Rights

      Details

      Right of Access

      You have the right to obtain from us information as to whether your personal data is being processed, and, where that is the case, access to such personal data.

      Right to Rectification

      We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to the personal information that you have provided to us by sending us a request to rectify your personal data where you believe the personal data we have is inaccurate or incomplete.

      Right of Access

      The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, a copy of the personal data undergoing processing.

      Right to erasure / ‘Right to be forgotten’

      Asking us to delete all of your personal data will result in Avantra deleting your personal data without undue delay (unless there is a legitimate and legal reason why Avantra is unable to delete certain of your personal data, in which case we will inform you of this in writing).

      Right to restriction of processing

      You have the right to ask us to stop processing your personal data at any time.

      Right to data portability

      You have the right to request that Avantra provides you with a copy of all of your personal data and to transmit your personal data to another data controller in a structured, commonly used and machine-readable format, where it is technically feasible for us to do so.

      Right to complain

      You have the right to lodge a complaint to a supervisory authority such as the Information Commissioner’s Office in the UK (see www.ico.org.uk) or another applicable supervisory authority. Although we encourage our customers to engage with us in the event they have any concerns or complaints.

       

      Please note that asking us to stop processing your personal data or deleting your personal data will likely mean that you are no longer able to use Avantra’s Website, or at least those aspects of our Website which require the processing of the types of personal data you have asked us to delete, which may result in you no longer being able to use our Website.

      Avantra will not ordinarily charge you in respect of any requests we receive to exercise any of your rights detailed above; however, if you make excessive, repetitive or manifestly unfounded requests, we may charge you an administration fee in order to process such requests or refuse to act on such requests. Where we are required to provide a copy of the personal data undergoing processing this will be free of charge; however, any further copies requested may be subject to reasonable fees based on administrative costs. 

      Where you request Avantra to rectify or erase your personal data or restrict any processing of such personal data, Syslink may notify third parties to whom such personal data has been disclosed of such request.

      Changes to this policy

      Any changes we make to our privacy policy in the future will be posted on this page, and where appropriate, notified to you by email or notifications via the Website.  We therefore encourage you to review it from time to time to stay informed of how we are processing your information. 

      Contact

      The entity ultimately responsible for the processing of your personal data, as data controller, will depend on which Syslink Xandria Ltd group company you are interacting with and for what purpose. Syslink Xandria Ltd  acts as the primary point of contact on behalf of each of the Group companies in respect of the personal data which is processed about you in relation to marketing and sales activity. Syslink Software AG acts as the primary point of contact on behalf of each of the Group companies in respect of the personal data which is processed about you in relation to support services.

      All questions, comments and requests regarding this privacy policy are welcome and should be addressed to legal@avantra.com.

      For the purpose of the relevant data protection legislation, the data controller is Syslink Xandria Ltd (company no. 10864553) with registered office address 5 Kew Road, Richmond, Greater London, United Kingdom. 

      Cookies

      Avantra uses cookies to distinguish you from other users. This helps us provide you with a good experience when you use our Website. Please note that it is possible to disable cookies being stored on your computer by changing your browser settings. However, our Website may not perform properly or some features may not be available to you if you disable cookies.

      For detailed information on the cookies we use and the purposes for which we use them see our Cookies Policy.

       

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