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Avosec Distribution Limited — Privacy Notice (Offline Business)

Important Information

Avosec Distribution Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law. This notice relates to all our offline business and all personal information either provided by an individual or company or information provided on their behalf by a third party, eg our resellers.

This notice applies to our Head office in the UK and our affiliate sales office in Sofia, Bulgaria.

  1. Information About Us

    Avosec Distribution Limited

    Limited Company registered in Bulgaria under registration number 202891074.

    Registered address: 8 Bunaya Str. Floor 2, apt 5, Sofia, Bulgaria

    Contact details:
    E-mail address: [email protected]
    Postal Address: 8 Bunaya Str. Floor 2, apt 5, Sofia, Bulgaria

  2. What Does This Policy Cover?

    This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

  3. What is Personal Data?

    Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

    Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

    The personal data that we use is set out in Part 5, below.

  4. What Are My Rights?

    Under the GDPR, you have the following rights, which we will always work to uphold:

    • The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.
    • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.
    • The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.
    • The right to restrict (i.e. prevent) the processing of your personal data.
    • The right to object to us using your personal data for a particular purpose or purposes.
    • The right to data portability. This means that you can ask us for a copy of your personal data held by us to re-use with another service or business in many cases.
    • Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
    • For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

    Further information about your rights can also be obtained from the Commission For Personal Data Protection or your local Citizens Advice Bureau.

    If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

  5. What Data Do We Collect?

    We may collect some or all of the following personal data (this may vary according to your relationship with us:

    • Name;
    • Address;
    • Business/company name;
    • Tax ID;
    • VAT number;
    • Job title;
    • Contact information such as email addresses, telephone and fax numbers;

    Your personal data can also be obtained from the following third parties

    • Our Reseller Partners;
    • Our Vendors;

  6. How Do You Use My Personal Data?

    All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.

    Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:

    • Providing and managing your Account;
    • Process orders and applications submitted by you;
    • Providing and managing your access to Our Sites;
    • Personalising and tailoring your experience;
    • Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
    • To contact you if you requested communication from us;
    • Personalising and tailoring Our products and services for you;
    • Replying to emails from you;
    • Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by disabling your subscription from your profile page, by following the Unsubscribe link in the footer of the newsletter e-mail or by sending us an e-mail to [email protected];
    • Market research;
    • Analysing your use of our services and gathering feedback to enable Us to continually improve our services and your user experience;

    With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email or telephone with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR. If you do not wish to receive these details please e-mail us at [email protected]

  7. How Long Will You Keep My Personal Data?

    We will only store your personal data in the UK and European Union. This means that it will be fully protected under the GDPR.

    • Personal data provided in connection to your software subscription will be retained for 6 full calendar months after the day on which your subscription is due to expire.
    • Personal data provided in connection with direct marketing or newsletter subscriptions will be retained as long as your subscription remains active and your consent is considered to be valid.

  8. How and Where Do You Store or Transfer My Personal Data?

    We will only store your personal data in the UK and European Union. This means that it will be fully protected under the GDPR.

    We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.

    Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected.

    Steps We take to secure and protect your data include:

    We are totally committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure we have put into place suitable physical, electronic and managerial procedure to safeguard and secure the personal data we collect against loss, theft, misuse, unauthorised access, disclosure, alteration and destruction. Access to your personal information is restricted to authorised personnel only.

  9. Do You Share My Personal Data?

    We may share your personal data with other companies within our group. We also contract with Third parties to supply products to you on our behalf. These may include software vendors and payment processing companies. In some cases, those third parties may require access to some or all of your personal data that we hold.Please see list below of the third parties with whom your data may be disclosed:

    Avast, Google and Paypal.

    If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law.

    We contract with third parties (as described above), and those third parties are located in the UK or EU member states. We may sometimes contract with third parties (as described above) that are located outside of the European Economic Area (the “EEA” consists of all EU member states, plus Norway, Iceland, and Liechtenstein). If any personal data is transferred to a third party outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the GDPR.

    In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

  10. How Can I Access My Personal Data?

    If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

    All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

    There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

    We will respond to your subject access request within not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of progress.

  11. How Do I Contact You?

    To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details for the attention of James Norris:

    Contact details:
    E-mail address: [email protected]
    Postal Address: 8 Bunaya Str. Floor 2, apt 5, Sofia, Bulgaria.

  12. Changes to this Privacy Notice

    We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

    Any changes will be made available

Last Updated: 24th May 2018