Privacy Policy

This Privacy Policy was last updated on 06/08/2021.

We are committed to protecting and respecting your privacy. This Privacy Policy explains what personal data we collect, how we use it and who you can contact in case of any questions. Please read through this Privacy Policy carefully so that you are fully aware of how and why we are using your data.

This Privacy Policy applies to you if you are an individual visiting our website at www.avara.com (the “website”) for any purpose, including to send us an enquiry (including about career opportunities) or otherwise engage with us (via our website, email/web form enquiries, social media platforms like our Linkedin page, phone or otherwise).

About Us

Avara Pharma Services Limited (“we”, “us”, “our”) collects, uses and keeps information in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the Privacy and Electronic Communications (EC Directive) Regulations 2003, the UK Data Protection Act 2018 and all relevant regulations. For the purposes of the above data protection laws, we are the data controller. This means that we are the primary entity who decides the purposes and means for dealing with your personal data.

We are a registered company in England and Wales under company number 10022553 and have our registered office at 9a Burroughs Gardens, London, NW4 4AU. We are a UK privately held company with over 700 employees worldwide, with the following entities within the group: Avara Holdings Ltd., Avara International Holdings Ltd., Avara International Ltd., AIAC International Pharma LLC, Avara Liscate Pharmaceutical Services S.p.A., Avara US Holdings LLC, Avara Aiken Pharmaceutical Services Inc., Avara Pharmaceutical Services Inc., and Avara Pharmaceutical Technologies Inc (together, the “Avara Group”, “Avara”). We are the primary data controller for the wider Avara Group.

The Data We Collect About You

Personal data, or personal information, 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 will need to ask you for certain personal information to give you the best possible experience when you visit our website or engage our services.

We do not generally require you to provide us with any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual origination, political opinions, trade union membership, information about your health, genetic biometric data, and criminal convictions). If you choose to provide us with any special categories of data, you give us your consent to process it and we rely on consent as a legal basis for processing such data. The exception to this may be where you are enquiring about career opportunities with Avara (see below), in which case some limited criminal conviction or health data may need to be processed as part of our HR/recruitment screening activities to comply with our legal obligations, deal with the application you have made to us or ensure your suitability for the role.

We use different methods to collect data from and about you including through:

Direct Interactions. We may collect the following personal data from you directly:

• For all visitors to our website: Any personal data you provide when you (i) get in touch by phone, email, LinkedIn, or otherwise; (ii) fill out our web form on the “Contact Us” page; or (iii) enquiring about career opportunities with the Avara Group (see below). Personal data collected is likely to include your name, email address, telephone number, the details of the organisation that you work, as well as any other personal information you may voluntarily choose to provide us in the course of your enquiry.
• If you are enquiring about career opportunities with Avara: Any personal data you provide in connection with applying for a job with us, including your contact information (e.g. name, email address, telephone number) and any information contained in your resume (e.g. current occupation and title, current and past employers, qualifications, social media handles, languages spoken, location and personal description).If you progress further into the job application process, we may also receive further information from previous employer references you have requested be sent to us, necessary ID verification documents (e.g. proof of address and passport) or certain health/criminal conviction data as necessary for our HR/recruitment screening activities.

For more information about the cookies we use and the purposes for which we use them please see our Cookie Policy.

Third parties or publicly available sources. We may receive the following information about you from various third parties or publicly available sources:

• Our third party service providers assisting with the operation of the website and services we provide you (e.g. our customer relationship management platform Hubspot)
• Personal data provided through public resources such as LinkedIn and your company website (e.g. name, title, profile photo, any comments posted through your profile)

How We Use Your Personal Data

We will use your personal data for the following purposes and legal bases:

Performance of a contract

• To provide you with the information and services that you request from us.
• To deal with any enquiries or requests you make of us.
• To manage our relationship with you.

Our legitimate interests

• To send you important service updates regarding our website, our services and this Privacy Policy.
• To confirm your identity and authenticate the information you provide for security purposes.
• For our own reporting and analytical purposes to enable us to improve our website, services, marketing and our customer relationships and experiences.
• For our own record-keeping and general administrative purposes regarding our handling of your personal data and other operational activities.
• To provide you with our support and resolve any complaints.
• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
• To improve our website to ensure that content is presented in the most effective manner for you and for your computer.
• To effectively handle any legal claims or regulatory enforcement actions taken against us, or take appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us.
• To assist with our internal training purposes.

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

To comply with our legal obligations

• To comply with our legal and regulatory obligations (including under applicable data protection laws).
• For preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies.
• To fulfil our duties to you, to other visitors to our websites, colleagues and other stakeholders.

Consent

Generally we do not rely on consent as a legal basis for processing your personal data. Where this is necessary for occasional specific situations, you will always be informed beforehand to obtain your consent and you have the right to withdraw your consent to these activities at any time, which will mean (unless another lawful basis applies to your data) that we will cease to process the affected data after consent is withdrawn.

We will always seek your consent before sending third party direct marketing communications to you or if we intend to disclose your information to any third party for such purposes before we collect any personal data for this purpose. You have the right to withdraw consent to marketing at any time by contacting us or following the opt-out links on any marketing emails sent to you.

Change of purpose

We 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.

Who We Share Your Data With

We may disclose your personal data to the following third parties:

• Analytics and search engine providers that assist us in the improvement and optimisation of our website, such as our marketing service provider That’s Nice.
• Other offices in the Avara Group as appropriate to deal with the query or service you have requested from us.
• Our third party providers of operational and business services, who are authorised to process your personal data on our behalf and pursuant to our instructions as necessary to run our business and provide you with the services you request from us, including our IT providers such as Hubspot.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
• Any third parties with whom we are required to share your personal data in order to comply with our legal obligations, to enforce our terms and conditions and policies, or to protect the rights, property, or safety of our website, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection, professional advice and security.

Your Rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You can request to:

• Access a copy of the personal data we hold about you.
• Rectify any incorrect or incomplete data we hold about you. It is both in our interest and yours that any personal data we hold about you is accurate, complete and current. If the data we hold about you is inaccurate in any way, please contact us to have your personal data
• Delete, restrict or remove the data we hold about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Transfer your personal data that we hold to you or to a third
• Object to any further processing of your data, if we are processing your personal data on the basis of our legitimate interests, or for direct marketing. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Withdraw your consent to any processing where consent is a legal basis on which we rely to process your data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact Us using the details below.

We will endeavour to respond to your requests within one month and free of charge. Please note that in respect of all these rights, we reserve the right to:

• Refuse your request based on the exemptions set out in the applicable data protection laws.
• Request proof of your ID to process the request or request further information.
• Charge you a reasonable administrative fee for any repetitive, manifestly unfounded or excessive requests.
• Request more time to respond to you if your request if particularly complex of you have made a number of requests.

If we refuse your request to exercise these rights, we will give reasons for our refusal and allow you to challenge our decision. If we have shared your personal data with others, we will tell them about your request to rectify, erase, restrict or object to the processing where possible.

If you have any concerns about how we handle your data, please Contact Us. If you are not satisfied after we’ve tried to resolve your issue, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO).

Where We Share Your Personal Data

The Avara Group has offices across the world including in the US, Puerto Rico and Italy. Depending on the nature of your query or service you request from us, we may need to share your personal data with these other offices in order to process your request. Additionally, our website server platforms are located in both the EU and the US.

If you are based in the UK or EU and we need to transfer your personal data in the future to any countries outside the European Economic Area, additional regulations may apply under applicable data protection laws to ensure a similar degree of protection is afforded to your personal data. At the date of this policy the position in respect of transfers of data between the UK and EU is constantly changing, but we will ensure that such transfers are made subject to appropriate safeguards as may be required by any applicable data protection laws from time to time. These will include ensuring that the data is only located in a country deemed to hold adequacy status or through the use of approved standard contractual clauses.

For more details on the safeguards in place for transfers of your personal data abroad, including how to obtain copies of these where relevant, please contact us using the details below.

How We Keep Your Personal Data Secure

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we restrict access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

How Long We Keep Your Personal Data For

We keep your data for as long as it’s necessary to meet the relevant purposes for which we’ve collected your data, including for the purpose of satisfying any legal, accounting or reporting requirements.

To determine the appropriate length of time for holding your data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm, from unauthorized use or disclosure of your personal data, the purpose for which we process your data and whether we can achieve those purposes through other means, along with the applicable legal requirements. For example, enquiries received through our info@avara.com mailbox is reviewed frequently and any emails deleted once the query is resolved.

In some circumstances you can ask us to delete your data: see Your Rights above for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Changes To This Privacy Policy

We may need to update this Privacy Policy to reflect changes to our practices, technology and legal requirements. We will post any changes we make to this Privacy Policy on our website from time to time and, where appropriate, notify you by e-mail.

All personal data held by us will be governed by the most recent Privacy Policy posted on our website, so please regularly check back to see any updates or changes.

Third Parties

This Privacy Policy only addresses our use and disclosure of your personal data.

Our website 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 website, we encourage you to read the privacy policy of any website you visit before you submit any personal data to them.

Contact Us

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please contact us at info@avara.com.