Privacy Policy
Information about Avelios Alternative Assets Limited
References to Avelios in this Website are to Avelios Alternative Assets Limited, a UK private limited company with registration number 12178036 at Companies House.
You can contact Avelios by email at [email protected] or by mail at Berkeley Square House, Berkeley Square, London, W1J 6DB.
Data Protection Section
We (Avelios Alternative Assets Ltd.), as data controllers, are dedicated to ensuring the protection of your personal data you entrust us with. In the context of the enforcement of the new regulation on the protection of personal data (General Data Protection Regulation, “GDPR”) on 25th May 2018, we are committed to ensuring that personal data collected online is appropriately processed and protected.
This notice, designed as a proof of transparency, is a practical summary of how we use, share and protect the personal data collected on our website.
What data do we collect?
Information you give us
We obtain personal information about you if you choose to provide it—for example, to contact us via mail or social networks. This includes information such as your name, address, email address, phone number and any information you give us by filling in forms on our site or by corresponding with us by phone, e-mail or otherwise.
It may also include employment details if you send us a CV, resumé or other details of your employment history in connection with an advertised job vacancy or a general enquiry regarding employment opportunities with us.
Information we collect from other sources
If you choose to register or login to our social network profile using a third party service that authenticates and connects you to with us (e.g., LinkedIn or Twitter), we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social network provider, so please review the privacy statement or policy of the applicable service.
Information we collect about you from your use of our site
We will automatically collect information from you each time you visit our site. This includes:
• Technical information such as (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• Information about your visit such as full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number or social media handle used to connect with our customer service team.
When we collect your personal data, we will process it mainly to permit and facilitate our business relationship with you as prescribed by a contractual agreement. Other purposes are described in the section below (“How we use your information and on what legal basis”). Your personal data will not be used for other purposes, unless we obtain your consent, or unless required or permitted by law.
We value the protection of children’s data, especially in the online context. Our websites are not designed for or directed at children under the age of 18. We never knowingly collect or process data from anyone under the age of 18, except as part of an agreement to provide relevant services and in this case only with the appropriate consent from his/her legal guardians, where necessary.
Automatic collection of personal information
We (and our service providers) use cookies and tracking tools to automatically collect certain types of data when you visit us online. Collecting this data allows us to customize your online experience, improve the performance, usability and effectiveness of our websites, and to measure the effectiveness of our marketing activities.
What is a cookie?
A cookie is a small text file that is placed on your computer by websites that you visit. Cookies are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site.
Some cookies expire upon the termination of each session and other cookies may be stored on your computer’s hard drive for longer periods, depending on their purpose and providers.
Tracking cookies
These allow Avelios to monitor its website’s visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage.
Your choices with regards to cookies’ usage
Avelios uses the cookiebot (https://www.cookiebot.com/) platform to ensure full GDPR and ICO Cookie Policy compliance. The platform provides an up to date catalogue of cookies deployed on the Avelios website and records visitor consent for those by category. Cookie consent for all categories is recorded via a control panel on the first visit to the website. To read more about our cookies and to modify your stored consent you may visit our cookie policy page by clicking here.
How we use your information and on what legal basis
We generally collect only the personal information necessary to fulfil the aforementioned purposes. Where further, optional information is required/needed, you will be notified of this at the point of collection.
EU and Luxembourg data protection law allows us to process personal information, as long as we have a legal basis to do so. It also requires us to inform you of those legal bases. We set out how we use your personal data and the lawful bases that we rely on for the processing below:
Information you give to us:
We will use this information to:
• Comply with our legal obligations: this is when we are required to process your personal data in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency.
• Perform a contract: We use the information that you give to us to take any steps in order to enter into a contract or to carry out our obligations arising from a contract, including administering your account with us and notifying you about any changes to our service.
• Pursue our legitimate interests: this is when we process your personal data to ensure that we keep running a lawful, reliable and sustainable business. This is done as long as it doesn’t outweigh your interests and includes sending you information about our services.
• On the basis of your consent: this is when for specific activities, your permission is required for further processing. In that case, you could revoke that consent freely at any time by contacting us at [email protected]. For example, you might provide your name and email address and opt-in for particular services or communications, such as an e-newsletter. You will then be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove you from the communication list promptly.
Information we receive from other sources:
We may combine this information with information you give to us and information we collect about you in our legitimate interests (where we have considered that these are not overridden by your rights). We will use this information and the combined information for the purposes set out above and below (depending on the types of information we receive).
Information that we collect from you and about your use of the website to:
Ensure in our legitimate interests (as long these are not overridden by your privacy rights) that we:
- Provide you with sound information and/or services.
- Administer our site.
- Keep our site secure.
- Provide you with a tailored experience.
- Monitor and improve the performance of our websites based on usage patterns.
Who we share your information with
We share your personal data with other member firms of Avelios Alternative Assets Ltd. as part of international engagements, and where required or desirable to meet our legal and regulatory obligations. We also share your personal data with organisations that process your personal data on our behalf and in accordance with our instructions and the Data Protection Law. This includes those that support the services we offer through our website, for example, hosting our websites, performing Anti-Money Laundering checks and otherwise as required in order to continue to run our business as well as third party software-as-a-service providers including our CRM system.
We will also disclose your personal information to third parties:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this privacy policy.
• If Avelios or a substantial amount of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of supply terms and other agreements with you; or to protect the rights, property, or safety of Avelios, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.
Transfers to third parties outside the EEA
We will only transfer personal data to countries outside of the UK, EU or the EEA (so-called third countries) if it is protected by an appropriate safeguard. This includes relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy. If you would like more information on whether your personal data is transferred outside the EEA and if so, the appropriate safeguard used, please contact [email protected].
How long do we keep your information for?
We retain personal data for as long as you have an account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
Your rights with regards to your data
You benefit from the following rights in relation to your personal data which we process in certain circumstances:
- Access your data considering that you provide us with proof of your identity,
• Request its rectification,
• Request its erasure where applicable,
• Restrict or object to their processing,
• Request that your data be transferred to a third party,
• Lodge a complaint with the relevant supervisory authority (the Commission Nationale pour la Protection des Données (“CNPD”) in Luxemburg, or the Information Commissioner’s Office (“ICO”) in the UK)
• To withdraw your consent (where we are relying on this as the lawful basis).
Berkeley Square House, Berkeley Square, W1J 6DB, London
We will take all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
Data security and conservation
We take reasonable security measures to protect your data from unauthorized access, alteration or loss. However and despite our best efforts, we cannot ensure absolute security, therefore we recommend that you take the necessary steps to ensure secure browsing.
We also make reasonable efforts to retain personal information only for so long as necessary to comply with our contractual, legal, regulatory requirements, or you request that your data be deleted. The period for which data is retained will depend on the specific nature, circumstance and purpose for which the data was collected.
Our promotional updates and communications
Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional update communications about our products and services.
You can object to further marketing at any time selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you, or by sending us an email to [email protected]
Changes to this notice
We might modify this notice from time to time to reflect our most current data protection practices. In such cases, any changes affecting you will be communicated to you on our websites in a timely manner.
Policy questions and enforcement
We are committed to protecting your online privacy when using our websites. If you have questions or comments with regards to this notice or other data protection specific questions, please contact us at [email protected].
