Privacy Policy

1. Introduction

Avalla Limited (“we” “our” or “us”) is committed to protecting and respecting your personal data. This privacy policy (together with any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

The website www.avalla.com is owned and operated by Avalla Ltd.

Our website is not intended for children and we do not knowingly collect data relating to children.

The 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 every website you visit.

 

2. Information we may 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 may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes: first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes: billing address, delivery address, email address and telephone numbers.
• Financial Data includes: bank account and payment card details.
• Transaction Data includes: details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes: your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes: information about how you use our website, products and services.
• Marketing and Communications Data includes: your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

 

3. How is your personal data collected?

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

3.1 Direct interactions: You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise.

For customers and prospective customers: this includes personal data you provide when you:

• make contact with us to request a quotation or other information about our products and services;
• place an order with us for yourself or on behalf of someone else;
• create an account on our website;
• subscribe to our newsletter;
• request marketing to be sent to you;
• subscribe to our ‘stay in touch’ sign up option;
• enter a competition, promotion or survey; or
• give us feedback or contact us.

3.2 Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Cookies are small text files placed on your computer by websites that you visit. They are widely used in order to make websites work, for improved efficiency and to provide information to the owners of the site. Cookies are not shared with any third parties. Not allowing the use of cookies may prevent you from using some websites.

A majority of web browsers allow some control of cookies through their settings. If you wish to find out more information about cookies, including how to see what cookies have been set and how to manage them, please visit www.allaboutcookies.org.

3.3 Via third parties or publicly available sources:

• Third party online marketplaces provide us with Identity and Contact details.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services.
• Identity and Contact Data from publicly available sources such as the Electoral Register based inside the UK.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct [third party] marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer	(a) Identity (b) Contact	(a) Performance of a contract with you (b) Necessary for our legitimate interests
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To utilise your consented information, including your email and telephone number, for communicating marketing promotions.	(a) Identity (b) Contact (c) Marketing and Communications	(a) Consent: the individual has given clear consent to us to process their personal data for a specific purpose.

 

Marketing

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, warranty registration, product experience or other transactions.

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.

5. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

Where a courier is based outside the UK, their processing of your personal data will involve a transfer of data outside the UK. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

8. Data security

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 limit 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 have put in place procedures 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.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Subject to the above, we have made the decision to keep personal data for 3 years.

In some circumstances you can ask us to delete your data: see your rights below 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.

10. Your rights:

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

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. 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.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
• If you want us to establish the data's accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time Limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could 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.

11. Changes to this privacy policy

This privacy policy was last updated on [05.11.2022]. If we make important changes to this policy then we will draw them to your attention. We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

12. Job Applicant Privacy Notice

The Draper Tools Group has a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from job applicants allows us to manage the recruitment process, assess and confirm a candidate’s suitability for employment and assist with deciding who to offer a position to. We may also need to process data from job applicants to respond to and defend against legal claims.

Your information may be shared internally within the Draper Group for the purposes of the recruitment exercise. This includes members of the HR department, interviewers involved in the recruitment process, Managers in the business area or company with a vacancy and IT staff if access to data is necessary for the performance of their roles. Your data will not be shared with any third parties unless there is a requirement to do so during the recruitment process; we will obtain further consent from you if that is the case.  The Draper Group currently consists of Draper Tools Limited and Avalla Limited.

If your application is unsuccessful, the Draper Tools Group may keep your personal data on file in case there are future employment opportunities for you which you may be suited. We will securely hold your data on file for six months after the end of the relevant recruitment process. At the end of that period, or once you withdraw your consent, your data will be deleted and confidentially destroyed.

If your application is successful, personal data gathered during the recruitment process will be transferred to your Human Resources file (electronic and paper based) and retained during your employment. The periods for which your data will be held will be provided to you in a new privacy notice.

Your Rights

As a data subject, you have several rights. You can:

• Access and obtain a copy of your data on request
• Require the organisation to change incorrect or incomplete data
• Require the organisation to delete or stop processing your data

You are under no statutory or contractual obligation to provide data to Draper Tools Limited during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.

If you would like to withdraw your consent or have any questions or concerns, please contact the relevant Data Protection Officer as below:

13. Contact us

Avalla Limited: on data@avalla.com.

Avalla Limited is a company registered in England and Wales with company number 13477899

Questions, comments and requests regarding this privacy policy should be addressed to support@avalla.com.

You also have the right to lodge a complaint with the UK data protection regulator, the Information Commissioner's Office (“ICO”). For further information on your rights and how to complain to the ICO, please refer to the ICO website https://ico.org.uk/concerns.