Privacy Policy

Published On 1st December 2018 by Alex Wiley

ONE AVENUE GROUP:

GDPR Privacy Policy

This website is owned and operated by One Avenue Group Limited (“we”, “us”, “our”, “ourselves” and “One Avenue Group”). For the purposes of the Data Protection Act 1998 (Act), the data controller is One Avenue Group Limited.

One Avenue Group is committed to protecting the confidentiality and safety of your personal data. This Privacy Policy describes how we gather, use and look after your personal data when you visit our website (irrespective of where you visit it from), together with when you purchase a product or services or sign up to our newsletter. It also tells you about your rights and how the law protects you.

  1. Important information
    1. This website is not meant for children – we therefore do not actively collect any data related to children.
    2. This Privacy Policy complements the other notices on this website (including our terms of use (Terms)) and is not intended to supersede them in any way.
    3. One Avenue Group is the controller and responsible for your personal data (we, us or our).
    4. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us either:
    5. You have the legal right to raise a grievance at any time to the ICO (www.ico.org.uk). One Avenue Group would like the opportunity to deal with your grievance before you approach the ICO so please contact us in the first instance.
    6. Informing us of changes – it is critical that the information we store about you is accurate and up to date, please keep us in the know in relation to any changes to your personal data.
    7. Third-party links – our website may include links to third-party websites, plug-ins and applications. By following or allowing a connection to these links, you may be allowing third parties to gather or share your personal data. We have no control of these third-party websites, plug in or applications and are not responsible for their privacy policies, therefore you should also read their privacy policies to understand what personal data they collect about you and how they use it.

 

 

  1. The data we collect about you
    1. Part 1 of Schedule 1 lists the types of data we may use, store and collect.
    2. We also collect, use and share aggregated data. If any aggregated data can directly or indirectly identify you, we will consider and treat this as your personal data.
    3. Special categories of data are not collected by One Avenue Group.
    4. If One Avenue Group is required by law, or under the terms of an agreement in place with you, to collect your personal data and you fail to provide it, we may not be able to enter into perform the contract with you and, we may have to terminate services or products. You will be notified of this at the relevant time.

 

  1. How personal data is collected
    1. We collect personal data in the following ways:

 

  • Direct interactions you may provide personal data when you complete online forms, request products/services, subscribe to our services, create a user account, join our mailing lists or otherwise or correspond with us (by post, phone or email)
  • Automated technology we automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, and other similar technologies. We may also receive technical data about you if you visit other websites which use our cookies. Please see our cookie policy here for further details
  • Publicly available sources we may collect personal data from publicly availably sources such as Companies House and the Electoral Register and credit reference agencies, based inside the EU
  • Third parties we may receive personal data from: (a) analytics providers based outside the EU (such as Google); (b) advertising networks inside the EU; (c) search information providers inside the EU; and (d) our suppliers such as payment providers, delivery services, website support and maintenance providers

 

  1. How we use your personal data
    1. We shall only use your personal data when there is a legal basis to do so. Ordinarily, we will use your personal data:
      • to perform a contract
      • to ensure we comply with a legal obligation; and
      • where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.

  1. Generally, we only rely on consent as a legal basis for processing your personal data to send email and other forms of marketing communications and you have the right to remove your consent at any time by getting in touch with us. We may process your personal data for more than one legal basis, this is dependent on the specific purpose for which we are using your information.
  2. You will only receive marketing communications from us, in the following situations; if you consent to marketing at the point in which we collected your personal data, if you have requested information or purchased products from us, if you have not subsequently opted out of receiving marketing communications or if we have another legal basis for sending you the marketing communications e.g. legitimate interest.
  3. Before sharing any of your personal information with third parties for marketing purposes, we will make sure to get your explicit opt in. We do not accept advertising, sell email lists, or generate any third-party revenue from data gathered on this website.
  4. To opt out of email marketing, please contact us to withdraw your consent. You can also unsubscribe by selecting the ‘unsubscribe’ option within the marketing communications. Opting out of receiving marketing doesn’t mean we cannot use your personal data for other purposes, as long as we have a legal basis to do so.
  5. Your personal data will only be used for the purpose we originally gathered it for – unless we need to use it for another purpose which is reasonable and well-matched with the original purpose. You will be notified if we need to use your personal data for an unrelated purpose.
  6. Where this is required or permitted by law, we may process your personal data (without your knowledge or consent).

 

  1. Disclosure of your personal data
    1. Part 4 of Schedule 1 sets out instances in which we may have to share your personal data with third parties. We require all third parties to show the upmost confidentiality and treat your personal data in accordance with legal requirements. Third party service providers are not allowed to use your personal data for their own purposes – they can only process your personal data for the specified purposes and in accordance with our instructions.

 

  1. Data Security
    1. The security of your personal data is important to us – we have internal data security guidelines which have been designed to protect the personal information submitted to us, both during transmission and once we receive it. However, no security system is guaranteed to be fully secure – whilst we strive to protect your personal data, One Avenue Group cannot guarantee the security of our servers, nor can we guarantee the data you supply through our website will not be intercepted whilst being transmitted over the internet.
    2. We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know and they can only process your personal data on our instructions and will be subject to a duty of confidentiality. We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

  1. Data retention
    1. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
    2. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us. However, we are legally required to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers, for tax purposes.
    3. We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. We can use anonymised information indefinitely without further notice to you.

 

  1. Your legal rights
    1. You have certain rights in certain circumstances under data protection law. If you wish to exercise any of your rights, please contact our DPM.
    2. You will not have to pay a fee to exercise any of your rights. However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee for this information or refuse to comply with your request.
    3. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

  1. Changes to this Privacy Policy
    1. One Avenue Group Limited reserves the right to change this Privacy Policy when required by law or at any time we deem necessary. We will post a notification of any alternations on the Website but we encourage you to periodically refer to this policy to remain up to date – upon your first visit to the Website following any changes, you are deemed to have accepted the terms of the Policy.