This privacy policy sets out how AVRION Pay uses and protects any information that you give AVRION Pay when you use this website. AVRION Pay is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. AVRION Pay may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from [date].

WHAT WE COLLECT

We may collect the following information:

• name and job title
• contact information including email address
• demographic information such as postcode, preferences and interests
• other information relevant to customer surveys and/or offers

WHAT WE DO WITH THE INFORMATION WE GATHER

We require this information to understand your needs and provide you with a better service, and in particular for the following reasons:

• Internal record keeping.
• We may use the information to improve our products and services.
• We may periodically send promotional email about new products, special offers or other information which we think you may find interesting using the email address which you have provided.
• From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail.
• We may use the information to customize the website according to your interests.
• We may provide your information to our third-party partners for marketing or promotional purposes.
• We will never sell your information.

How long do we keep your information?

We will keep customer and account application information for the period when the customer has an account with us, and a further five years, and such further period during which you may bring a claim against us and for us to be able to defend ourselves. Where you apply for an account, but we do not proceed, we will store your information for a reasonable period in case you make a repeat application. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.

We will keep information about visitors to our websites (not being customers) for a reasonable length of time that lets us understand how people use our website and any technical issues they have. This will not exceed 12 months.

We will keep information about individuals who are our point of contact at a business customer and/or supplier for the duration of our relationship with the relevant business. If the individual was to leave the business, we reasonably expect to be informed by the business that employed that individual to keep our records accurate. We may keep our correspondence with these individuals for longer where relevant to our transactions with the business.

Where your information will be held

Your information may be transferred outside the European Economic Area (EEA)

Some of those countries do not have equivalent data protection laws to those applicable in the EEA.

However, to ensure your personal information is properly protected in line with EU, the transfer of this information is, in general, governed by a contract including Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation (GDPR) or (where indicated in Section 5) transferred to a business certified under the US Privacy Shield in accordance with Article 46(2)(e) of the GDPR.

In some limited circumstances, we may also transfer your information outside the EEA if the GDPR (under Article 49) allows this. This includes where it is necessary for the performance of a contract between us and you. This also includes where the transfer is necessary in connection with legal proceedings.

Your Rights

You have certain rights in relation to your information. The availability of these rights and the ways in which you can use them are set out below in more detail.

Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact our Data Protection Officer.

Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you and certain other information about it. We do not have to provide this information if this would adversely affect the rights and freedoms of others.

1. Correction: you are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected.
2. Erasure: you are entitled to ask us to delete or remove personal information in certain circumstances, including where you have withdrawn consent to our using it or we no longer need it in connection with your account or for other legitimate reasons. There are also certain exceptions where we may refuse a request for erasure, for example, where the personal data is required for compliance with law or in connection with claims.
3. Restriction: you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
4. Transfer: you may request the transfer of certain of your personal information to another party. This is we use it based on your consent or on a contract with you personally. To help with that you have a right to ask that we provide your information in an easily readable format to another company.
5. Objection: where we are processing your personal information based on a legitimate interest (or those of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your personal information for direct marketing purposes.
6. Automated decisions: you may contest any automated decision made about you where this has a legal or similar significant effect and ask for it to be reconsidered.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State in the European Union where you are habitually resident where we are based or where an alleged infringement of Data Protection law has taken place.

Links to third party website

Our website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others including our partner networks, advertisers and other group companies and/or social networks as offered to you and supported by your browser.

The personal data that you provide through these websites is not subject to this Privacy Policy and the treatment of your personal data by such websites is not our responsibility. If you follow a link to any of these websites, please note that these websites have their own privacy notices which will set out how your information is collected and processed when visiting those sites. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy notices of entities through which you chose to share.

SECURITY

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

HOW WE USE COOKIES

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

LINKS TO OTHER WEBSITES

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

CONTROLLING YOUR PERSONAL INFORMATION

You may choose to restrict the collection or use of your personal information in the following ways:

• whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes
• if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email address]

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.