Data Privacy Policy

INTRODUCTION
1. Important information and who we areWelcome to Avasam Ltd’s Privacy and Data Protection Policy (“Privacy Policy”).At Avasam Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the DPA 2018 and all other mandatory laws and regulations of the United Kingdom.This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data. The individuals from which we may gather and use data can include:
  - Customers
  - Suppliers
  - Business contacts
  - Employees/Staff Members
  - Third parties connected to your customers
  - Any other people that the organisation has a relationship with or may need to contact.
  This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.
2. Who is Your Data ControllerAvasam Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us on email at [email protected] or sent in a letter to 9 Oliver Business Park, Oliver Road, London, NW10 7JB, United Kingdom.You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. Processing Data on Behalf of a Controller and Processors’ responsibility to youIn discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:
  - Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
  - Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
  - Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
  - Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
  - Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
  - Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
  - Maintain a record of all categories of processing activities carried out on behalf of a Controller;
  - Cooperate, on request, with the supervisory authority in the performance of its tasks;
  - Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
  - Notify the Controller without undue delay after becoming aware of a Personal Data Breach.
LEGAL BASIS FOR DATA COLLECTION
1. Types of Data / Privacy Policy Scope“Personal Data” 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 below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
  - Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
  - Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
  - Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
  - Financial Data: These are your banking details e.g. your account number and sort code.
  - Transactional Data: This is information of details and records of all payments you have made for our services or products.
  - Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
  - Customer Support Data: This includes feedback and survey responses.
  - Usage Data: information about how you use our website, products and services.
  We also collect, use and share Aggregated Data such as the proportion of overall sales being made by product category or sales channel over time. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. 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 Policy.We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.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.
2. The Legal Basis for Collecting That DataThere are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
  - “Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
  - “Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
  - “Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
  - “Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

HOW WE USE YOUR PERSONAL DATA

Our UsesWe will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below. Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

Activity	Type of data	Justification	Lawful basis for processing data
User visiting our website (www.avasam.com) for the first time	Technical Data	Necessity	We need to understand where you are logging in from so we know whether you can take advantage of the services we provide and what browser you are using so we can diagnose potential service-related issues.
User visiting our website (www.avasam.com) for the first time	Usage Data	Legitimate Interest	We need to understand where you are logging in from in order to keep our records up-to-date and to analyse how customers use our services and the profile of our users in order to keep our website and platform up to date and relevant to the needs of our customers.
When a non-registered user contacts us via our live-chat support, email or telephone	Profile/Identity Data	Consent	We may ask you for your email address or other contact information including telephone number so we can easily get back in touch with you and connect the conversation history to an individual profile. Such information is voluntarily provided by you. We will not extract it from you without your consent.
When a non-registered user contacts us via our live-chat support, email or telephone	Contact Data	Consent	We may ask you for your email address or other contact information including telephone number so we can easily get back in touch with you and connect the conversation history to an individual profile. Such information is voluntarily provided by you. We will not extract it from you without your consent.
When a non-registered user contacts us via our live-chat support, email or telephone	Marketing and Communications Data	Legitimate Interest	If you have expressed an interest in our services, we may wish to contact you using the details you have provided in order to provide you with more information or to update you regarding new services or features. You can unsubscribe at any time by clicking the ‘unsubscribe’ link at the bottom of our digital communications.
A user requesting and attending a live demo of our platform/services or inquiring for more information via a call with members of our support or business development team	Profile/Identity Data	Consent	We will likely ask you to provide or confirm your contact information such as email and telephone number, full name or business name, address, and website address. This is so that we can undertake an informed discussion with you, understand your needs, and contact you again as required depending on the outcome of our conversation.
A user requesting and attending a live demo of our platform/services or inquiring for more information via a call with members of our support or business development team	Contact Data	Consent	We will likely ask you to provide or confirm your contact information such as email and telephone number, full name or business name, address, and website address. This is so that we can undertake an informed discussion with you, understand your needs, and contact you again as required depending on the outcome of our conversation.
A user signing up to our platform and creating an account	Profile/Identity Data	Consent Necessity	In order to set up an account, you will be required to provide contact or personal information such as email and telephone number, full name or business name, address, and website address. This is because as an account holder and user of our services, we need to be able to contact you in relation to important announcements and ongoing operational matters. We also need to be able to identify you whenever you contact us.
A user signing up to our platform and creating an account	Contact Data	Consent Legal Compliance Necessity	We need to store details of our customers during the account opening process for record-keeping purposes. We may also be required to comply with potential requests from regulators and government agencies, for which we will be expected to provide accurate records.
A user signing up to our platform and creating an account	Technical Data	Legal Compliance Legitimate Interest Necessity	We need to understand where you are logging in from so we know whether you can take advantage of the services we provide and what browser you are using so we can diagnose potential service-related issues. Technical data is also stored for the provision of IT and administration services, platform security and fraud prevention.
User signing up to the platform and creating an account	Marketing and Communications Data	Legitimate Interest	If you use our services, we may wish to contact you using the details you have provided in order to update you regarding new services or features and keep you informed about important platform or operational announcements. You can unsubscribe at any time by clicking the ‘unsubscribe’ link at the bottom of our digital communications.
A user making a purchase via our platform	Financial Data	Consent Necessity	In order to make purchases for products on our platform, you will need to provide your payment method details, typically a debit or credit card. Avasam does not store any payment information on our own servers or network. All such information is stored directly by our independent payment gateway provider. You can delete your payment details at any time.
A user making a purchase via our platform	Transactional Data	Consent Necessity	In order to process your orders we need to access certain transactional information including the product being purchased by your end customer (and subsequently purchased by you from our supplier), the price paid, quantity ordered, the tax applied, the chosen shipping service, the end-customer name, the delivery/billing address and any special delivery instructions. Transactional data required to facilitate the order fulfilment will be shared with the relevant product supplier.
A user making a purchase via our platform	Usage Data	Legitimate Interest	In order to provide our services and optimise them over time, such as product recommendations, we need to be able to monitor individual and aggregate usage and transaction statistics.
Registered user seeking support for specific products or services we offer	Profile/Identity Data	Consent Necessity	We will likely ask you to provide or confirm your contact information such as email and telephone number, full name or business name, address, and website address. This is so that we can undertake an informed discussion with you, understand your needs, and contact you again as required depending on the outcome of your support request.
Registered user seeking support for specific products or services we offer	Contact Data	Consent Necessity	We will likely ask you to provide or confirm your contact information such as email and telephone number, full name or business name, address, and website address. This is so that we can undertake an informed discussion with you, understand your needs, and contact you again as required depending on the outcome of your support request.
Registered user seeking support for specific products or services we offer	Transactional Data	Consent Legitimate Interest Necessity	We will retain records of the transactions you have made with us and what services you have used on our platform so that we can quickly identify your account details whenever you contact us for support. Accessing your user history is important to help us understand the context of your support requirements and to follow-up with any ongoing matters.
Sharing Personal Information with third parties	Transactional Data	Necessity	In order to process your orders, core transactional data (as explained above) will be shared with the product supplier in order to facilitate the order fulfilment. More information on this is available in our Terms and Conditions.
When a user integrates/connects their online sales channel (webstore or marketplace) to our platform	Technical Data	Consent Legal Compliance Legitimate Interest Necessity	We need to understand where you are logging in from and what browser you are using so we can diagnose potential service-related issues. Technical data is also stored for the provision of IT and administration services, platform security and fraud prevention.
When a user integrates/connects their online sales channel (webstore or marketplace) to our platform and when we synchronise inventory/orders to facilitate order fulfilment	Transactional Data	Consent Contractual Obligations Legitimate Interest Necessity	Upon integrating your online sales channel with Avasam, certain APIs are authorised. These are primarily the Order API, Product Details API and Inventory API. Under an API it is not possible to selectively pull data. Therefore our system pulls all data in your sales channel related to the given API and does this every time it synchronises your orders and inventory levels. Avasam does not use information obtained via such APIs for any purpose other than to process orders specifically related to your Avasam account or in accordance with this Data Privacy Policy. Any data pulled that is not directly linked to your Avasam orders is permanently deleted within 5 calendar days. Any Personally Identifiable Information pulled via API (such as your end customer name and the delivery/billing address) and required for processing your Avasam orders is obfuscated and removed from our live servers after 30 days.
When a new supplier partner opens and maintains a live account with us	Financial Data	Consent	We are required to store your bank details on our secure servers in order to process payouts owing to you as a result of transacting with sellers on our platform. Any such information will be deleted within 5 days of an account being closed.

Marketing and Content UpdatesYou will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
Change of PurposeWe 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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 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, in compliance with the above rules, where this is required or permitted by law.

YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US
1. What Control Do I Have Over Avasam Ltd’s Use Of My Personal Data?You may delete your account at any time – this will remove your account page from our systems and our related software.We guarantee this will delete all stored data.Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.You can access information associated with your account by logging into your account you created with us.Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to [email protected].
2. How Does Avasam Ltd Protect Customers’ Personal Data? We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including encryption of data, secure cloud-based servers, firewalls, removal of personal information from our live servers 30 days after orders are processed, secure account passwords, restricted login failure attempts, and defined incident response planning and reporting. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession.However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Avasam Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
3. Opting Out Of Marketing PromotionsYou can ask us to stop sending you marketing messages at any time by clicking on the unsubscribe button or link attached to our marketing communications. You can also request for Personal Data to be obfuscated via the settings menu in the platform and clicking on GDPR maintenance.Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
4. How to Request your Data and the Process for Obtaining itYou will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
YOUR DATA AND THIRD PARTIES
1. Will We Share Your Data With Third Parties?We may share non-Personal Data with third parties. We may share your Personal Data with subcontractors (only when necessary and with your consent) or affiliates (subject to confidentiality obligations to use it only for the purposes for which we disclose it to them and pursuant to our instructions).We may also share Personal Data with interested parties in the event that Avasam Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.If Avasam Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
2. Third-Party LinksThis Site may include links to third-party websites, plug-ins and 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 Site, we encourage you to read the privacy policy of every website you visit.
HOW LONG WILL WE RETAIN YOUR DATA FOR?We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
AGE LIMIT FOR OUR USERS You must not use Avasam Ltd unless you are aged 18 or older. If you are under 18 and you access Avasam Ltd by lying about your age, you must immediately stop using Avasam Ltd.This website is not intended for children and we do not knowingly collect data relating to children.
INTERNATIONAL TRANSFER OF DATAYour information may be stored and processed in the US or other countries or jurisdictions outside the US where Avasam Ltd has facilities. We are currently storing data in the EU and so, by using Avasam Ltd, you are permitting and consenting to the transfer of information, including Personal Data, outside of the US.
NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICYWe keep our Privacy Policy under review and will place any updates on this webpage. This version is dated 1 October 2019. By using Avasam Ltd, you consent to the collection and use of data by us as set out in this Privacy Policy. Continued access or use of Avasam Ltd will constitute your express acceptance of any modifications to this Privacy Policy.
INTERPRETATIONAll uses of the word “including” mean “including but not limited to” and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. As a matter of common sense, you are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website etc.).Our staff are not authorised to contract on behalf of Avasam Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a Avasam Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any Avasam Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the Avasam Ltd legal department.
TERMS OF USEPlease also see our Terms of Use (https://www.avasam.com/terms-and-conditions/) which set out the terms, disclaimers, and limitations of liability governing your use of Avasam Ltd.