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.
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:
Third parties or publicly available sources. We may receive the following information about you from various third parties or publicly available sources:
We will use your personal data for the following purposes and legal bases:
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).
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.
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.
We may disclose your personal data to the following third parties:
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You can request to:
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:
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).
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.
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.
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 email@example.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.
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.
Avara Pharmaceutical Services, Inc.
3300 Marshall Avenue
Norman, OK 73072
© 2020 Avara Pharmaceutical Services, Inc.
All Rights Reserved