AVECTAS LIMITED – PRIVACY POLICY

WHO WE ARE

We are Avectas Limited, incorporated and registered in Ireland with company number 506660, whose registered office is at Maynooth Works, Eolas Building, Maynooth University, Co. Kildare, Ireland (hereinafter referred to as we, us or our) and which terms shall also include our Affiliates. Affiliates means any entity that directly or indirectly controls, is controlled by, or is under common control with us. Control, means direct or indirect ownership or control of more than 50% of the voting interests of the subject entity). We are a life sciences bio-technology company based in Ireland that develops cell engineering technology (the Business).

Your privacy is of paramount importance to us. This privacy and cookies policy (the Policy) applies to the Business, our avectas.com website (the Website) and services related thereto (the Service). This Policy is designed to protect you, our users, by informing you what Personal Data is collected, how we will use Your Personal Data, with whom we share it, how long we keep it, your rights in respect of Your Personal Data and how to contact us if you have any queries or concerns about our use of Your Personal Data. Your use of the Website is subject to your agreement with this Policy.

In this Policy, the term Personal Data means data relating to a living individual who is or can be identified either from the data or from the data in conjunction with other information that is in, or is likely to come into, our possession, and includes Personal Data as described in Data Protection Laws (as defined below).

Any Personal Data that we collect from you for the below purposes is referred to in this Policy as Your Personal Data

Please read the following carefully. Use of our Website or otherwise accepting the terms of this Policy indicates that you have reviewed this Policy and have agreed to be bound by it. If you do not agree to these terms you must leave our Website immediately. If you no longer consent to our processing of Your Personal Data, you may request that we cease such processing by contacting us. See ‘How to Contact Us’ below.

We will handle Your Personal Data in accordance with Data Protection Laws. Data Protection Laws means the Data Protection Acts 1988 to 2018, the General Data Protection Regulation (EU) 2016/679 (GDPR), and any other applicable law or regulation relating to the processing of Personal Data and to privacy, including the E-Privacy Directive 2002/58/EC and the European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011, as such legislation shall be supplemented, amended, revised or replaced from time to time and all guidance and codes of practice issued by a relevant supervisory authority, from time to time and which are applicable to us.

We are a controller (as defined in Data Protection Laws) in relation to any Personal Data which we collect from you through your or any other user’s use of the Service. This Policy sets out the basis on which any such Personal Data will be processed by us.

You may be a data subject (as defined in Data Protection Laws) or you may be a controller. When you are a controller in respect of the Personal Data of other data subjects, then you must comply with all of your controller obligations under Data Protection Laws. When you are a controller, we and you act as independent controllers, unless agreed otherwise.

INFORMATION WE GATHER FROM YOU

We fully respect your right to privacy in relation to your interactions with the Service and endeavour to be transparent in our dealings with you as to what Personal Data we will collect and how we will use Your Personal Data. We only collect and use Personal Data where we are legally entitled to do so. Information in relation to Personal Data collected by Irish entities is available on www.dataprotection.ie, the website of the Irish Data Protection Commission (DPC).

We may collect Personal Data from you in the course of your use of the Service. This may be through email, use of the Website or online forms. The information that we process includes the following:

Basic Information	such as your first and last name (including prefix or title);
Contact Information	such as your billing, home and/or business postal address, email address and phone number(s);
Financial Information	including your VAT number, bank account or card details and bank account details for payment processing purposes;
Newsletter Information	which is information provided by you when you opt-in to receive our newsletter;
Technical Information	such as information from your visits to our Website (including internet protocol (IP) address and login data, browser or client application information, language preference, operating system and application version, device type and ID, and device model and manufacturer, and other technology on the devices you use to access the Website) or in relation to materials and communications we send to you electronically;
Employment Data	employment applications including your personal information, education and training information, your photograph, medical or health-related information i.e. sick leave absence; or
Any Other Information	relating to you which you may provide to us in the course of the provision of the Service or otherwise.

We endeavour to keep Your Personal Data accurate and up-to-date. As such, you must tell us about any changes to such information that you are aware of as soon as possible.

If you are aged under 18, please get your parent/guardian’s permission before you provide Your Personal Data to us/use the Service. We do not knowingly collect Personal Data from people under the age of 18. If we become aware we have inadvertently received Personal Data from a person under the age of 18, we will delete such information from our records.

WHY WE COLLECT/HAVE ACCESS TO YOUR INFORMATION

We may collect information from you as necessary in the course of providing our Service. We may collect Your Personal Data while monitoring our technology tools and services, including our Website and email communications sent to and from us. We gather information about you when you provide it to us, or interact with us directly.

We may use Your Personal Data on any one or more of the following legal bases: (i) to perform a contract with you; (ii) for our legitimate business purposes in providing the Service to you (in which case, our legitimate interests will not override your fundamental privacy rights); and/or (iii) in limited circumstances, where you have given us your express consent. We may also use or disclose Your Personal Data to comply with a legal obligation to which we are subject.

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 legal basis, depending on the specific purpose(s) for which we are using Your Personal Data. Please contact us if you need details about the specific legal basis we are relying on to process Your Personal Data where more than one ground has been set out in the table below. See ‘How to Contact Us’ below.

Where we process any special category data, such as health data, we will ensure that we have a legal basis for processing, that a data protection impact assessment is carried out, where required and that additional safeguards are put in place to protect the data, where required.

Purpose

Categories of data

Legal basis for processing and, where necessary, the basis of legitimate interest

To respond to an enquiry from you/provide customer support.

basic information, and

contact information.

Necessary to take steps at your request prior to entering into a contract with you.

To register you as a customer.

basic information,

contact information,

profile information, and

financial information.

Performance of a contract with you or to take steps at your request before entering into a contract.

Necessary for our legitimate interests (in protecting our business from insolvent customers and fraud/to develop our products/services and grow our business.

To make suggestions and recommendations to you about products, services, events or promotions that may be of interest to you/personalise the products and services we offer you through marketing communications.

basic information,

contact information, and

newsletter information.

Consent

To provide you with relevant materials and resources, when you sign-up to download resources from our Website.

basic information, and

contact information.

Consent

To enable you to attend online webinars that may be of interest to you.

basic information, and

contact information.

Consent

To recruit new employees (where we have advertised a position and you have applied for it) and to conduct interviews and carry out an assessment of your suitability for the role.

basic information,

contact information, and

employment information.

Necessary for our legitimate interest (to develop our business and employ staff where required).

Consent (for health-related data).

To administer and protect our business and improve our Website and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

basic information,

contact information,

newsletter information, and

technical information.

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

To provide and improve our Website, including auditing and monitoring its use, providing and improving our Service to you and managing and administering our relationship with you.

basic information,

contact information,

technical information, and

location data.

Necessary for our legitimate interests to provide and improve our Website, including auditing and monitoring its use; providing and improving our Service to you; or managing and administering our relationship with you;

Necessary to fulfil our legal, regulatory and risk management obligations.

AVECTAS PRIVACY STATEMENT

Avectas is committed to protecting and respecting your privacy. For the purposes of the Data Protection Acts 1988 and 2013 (As amended) (“the Act”), Avectas has nominated a Data Protection Officer.

It is the intention of this privacy statement (“Privacy Statement”) to explain to you the information practices of Avectas and its related business units i.e. Spraybase®, in relation to the information we collect.

Please review this statement carefully as it sets out the basis on which any personal data we collect from you or that you provide to Avectas will be processed.

Note when we refer to “Avectas” in this statement we are referring to both Avectas Ltd. and business unit Spraybase®.

COLLECTION AND USE OF INFORMATION

Avectas collects personal data about you as a customer and data relating to your interactions such as completing a Contact Us Form on our Websites or by correspondence via phone, email or otherwise. Avectas asks you to disclose as much information as is necessary to provide you with information requested by you. When you access our website, your computers’ browser provides us with information such as your IP address, browser type and access time, which is collected and used to compile statistical data on the use of our website. In most cases the data we collect will be anonymous and it will simply tell us what pages have received the most activity and are of particular interest to our customers in general. We use Google Analytics to assist this process, we do not make, and do not allow Google to make, any attempt to find out the identities of those visiting our website. This information is used only to improve our website and the services we offer.

Avectas, will only use personal information for the stated purpose. Purposes arelimited to, but not restricted to the following:
Marketing and administration purposes, such as information detailing events,publications, promotions and product information.

For analysis, ensuring that content from our website is presented in the most effective manner.

We use a third-party provider, Constant Contact, to deliver our newsletter. We gather statistics around email opening and clicks using industry standard technologies to help us monitor and improve our e-newsletter. For more information, please see Constant Contact Privacy Statement. You can unsubscribe to general mailings at any time by clicking the unsubscribe link at the bottom of any of our emails.

Avectas does not sell or rent to any third party any personally identifiable information about you.

Avectas will retain personal information indefinitely unless you, the individual, requests otherwise.

YOUR RIGHT OF ACCESS

Under the Data Protection Acts you have the right to see the personal information Avectas holds on you. If you would like to review the information we have collected, please contact Avectas. If your information changes or if you believe we have information which is inaccurate, please let Avectas know so this can be updated.

SECURITY

Avectas, endeavours to employ industry standard security measures to protect and prevent the loss or misuse of information. Avectas and associated Websites and Customer Relationship Manager platforms use encryption to prevent unauthorised access. Avectas will ensure that such information is secure as possible.

AMENDMENTS OF THIS PRIVACY STATEMENT

Avectas, reserves the right to amend this privacy statement at any time, any changes to this statement will be posted on the website and will be effective once posted. You should regularly check this Privacy Statement for any changes, as this is a live document under regular review.

GOVERNING LAW & JURISDICTION

This Privacy Statement is governed exclusively by Irish Law and subject to exclusive jurisdiction of the Irish Courts.

CONTACT

At Avectas, your privacy is important to us. If you have any comments or questions regarding this Statement, please contact the Avectas Data Protection Officer.