Privacy Policy

Introduction

Avania is committed to privacy compliance and to earning our users’ (“you”, “your”, “me”, “my”) trust.

This privacy notice explains how Avania controls and processes your personal information including what we collect, why we collect it, how it is used and your choices regarding your personal information.

Who is Avania?

Avania is responsible for making decisions about how your personal information is processed on all Avania websites (the “controller”).

Who does this Privacy Notice apply to?

This Privacy Notice applies to all websites, apps and services operated by Avania (our “Services”). This includes:

1. General users including (potential) clients; and
2. Job applicants.

PART 1: General users, including (potential) clients

If you are an Avania website user or have entered into a contract or have contacted us with the intention to enter into a contract, Avania will control your data. This will be independent of your location or which of the subsidiary entities you from Avania you contacted.

What Personal information are we processing and/or controlling?

We collect and process personal information about you when you interact with us, if you visit our website and when you purchase services from us. The personal information concerns:

• your name;
• your home or work address, email address and/or phone number;
• your job title and the company you work for;
• information related to the browser or device you use to access our website;
• internet browser and operating system; and
• and/or any other information you provide.

How do we use this information?

We process the personal information listed above for the following purposes:

• Processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of the data subject prior to entering into a contract.
• We require to process this data in order to establish contact with you and are unable to do so without it;
• Enter into an agreement to provide or receive services;
• Contacting us via the website contact form;
• Contact us via e-mail or by any other contact methods such as phone calls;
• To monitor use of our websites and online services;
• To comply with applicable law and regulation;
• In accordance with our legitimate interests in protecting Avania’s legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes; and
• To send you informative newsletters relating to our expertise and services. Newsletters will be sent where you have given your consent to receive it, or where this is allowed under soft-opt in. You will be given an opportunity to opt-out at each Newsletter. You will only receive newsletters from Avania or one of our subsidiary companies.

With whom and where will we share your personal information?

We may share your personal information with our subsidiaries companies to process it for the purposes of inter-group administration and to provide services or products where elements of these are provided by companies other than those with which you have directly contracted. We may also share your personal information with third parties. This may include:

• Our professional advisors;
• Our suppliers, business partners and sub-contractors;
• Customer relationship management system;
• Web analytics (depending on your choice for cookie placement);
• Marketing and communications agencies; (depending on your choice for cookie placement);
• Government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws; and
• In the event that our business or any part of it is integrated or sold with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.

PART 2: Privacy Information specific to Job applicants

What information do we collect and process?

We collect and process personal information about you when you apply for a vacancy with us. This includes:

• your name, home address, email address and/or phone numbers;
• If permissible, your date of birth,
• your educational and employment history;
• other information contained within your CV or other documents or information you submit to us; and
• information from the selection process, if any.

For the fulfillment of certain positions within our company, we will ask your permission during the application process to process additional data relevant for a particular position. This may concern:

• References and assessments relating to your work for previous employers; if this is the case, we will inform you upfront and inform you about the outcome;
• Health information (where you provide this to us);
• financial information i.e. bank details (where you provide this to us);
• information to confirm your identity and right to work, such as a copy of your passport; if this will be the case, we will specifically request this from you; and
• information relating to your feedback on our organization.

If there is reason to believe that you have any unspent criminal convictions; we will remain the right to request further information if required under the applicable laws or, if applicable, our legitimate interest.  If in the interest of our company and when deemed necessary, we will perform a background check.  However, depending on the jurisdiction, these background checks are not part of our standard routines.

What is the source of this information?

We obtain this information directly from you, our personnel, through our systems and equipment, as well as from third parties such as recruitment agencies, background checking companies or former employers. We may also obtain it from your public profiles available online.

How do we use this information and what is the legal basis for this use?

We process the personal information listed above for the following purposes only in accordance with our legitimate interests and to comply with our legal obligations:

• to perform an adequate selection process and to select the right person for each job vacancy;
• to prevent and detect fraud and other wrongdoing; and
• to establish, exercise our legal rights.

Part 3: General information

How long will you store my personal information?

We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where is my personal information stored?

The personal information we collect is stored on US and EU servers. Since we are an organization that operates globally, your personal information may be transferred to and stored outside the European Economic Area (“EEA”) if needed. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers.

How does Avania send personal information outside of my country?

When we send your personal information outside of your country we have in place adequate safeguards to do so. This includes our intra group agreement, EU standard contract clauses approved by the European Commission or other suitable safeguards to permit personal information transfers from the European Economic Area (“EEA”) to other countries.

What are my rights in relation to my personal information?

In certain circumstances (for example, if you are an EEA resident), you may exercise the rights available to you under the applicable data protection laws as follows:

•  If you wish to access, correct, update or request deletion of your personal information.
• You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
• If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. This may mean your access to certain services is restricted or denied as a result. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Who do I contact if I have questions or if I need more information?

If you need more information or have any questions, please contact our Data Protection Officer via: Dataprivacy@avaniaclinical.com

Which entities are part of Avania?

At the time of the last review of this Privacy notice, the entities are as follows.

Please note that these may be updated from time to time, please contact us for more information.

Privacy Shield

Avania complies with the EU-U.S. Privacy Framework and Swiss-U.S. Privacy Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.  Avania has certified to the U.S. Department of Commerce that it adheres to the Privacy Framework Principles.  If there is any conflict between the terms in this privacy policy and the Privacy Framework Principles, the Privacy Framework Principles shall govern.  To learn more about the Privacy Framework program, and to view our certification, please visit www.privacyFramework.gov.

Avania is subject to the Federal Trade Commission (FTC) investigatory and enforcement powers ensuring Avania’s compliance with the Privacy Framework framework. In compliance with the Privacy Framework Principles, Avania commits to resolve complaints about our collection or use of personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Framework policy should first contact Avania’s Data Protection Officer at: dataprivacy@avaniaclinical.com or by mail at 100 Crowley Drive, Marlborough, MA 01752. Avania agrees to respond to the complaint within 30 days of receipt. Avania has further committed to refer unresolved Privacy Framework complaints to JAMS, an alternative dispute resolution provided located in the United States. If you do not receive timely acknowledgement of your complaint from us, or we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-Framework for more information or to file a complaint. The services of JAMS are provided at no cost to you. In addition, Avania commits to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel and the Commissioner with regard to data transferred from the EU. The DPAs can be found here: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm, The FTC has committed to reviewing on a priority basis referrals alleging non-compliance with the Principles of the Privacy Framework framework. If the complaint is not resolved using the independent recourse mechanism, as a last resort, the Privacy Framework framework provides for binding arbitration from a Privacy Framework Panel, made up of three neutral arbitrators. EU and Swiss citizens who pursue resolution of a data protection dispute will not be charged any costs by Avania associated with resolution of the dispute. However, in pursuing the final option of binding arbitration, each party will bear its own legal fees. Avania commits to cooperate with EU data protection authorities (DPAs)and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.

For specific privacy related questions, please contact the Data Protection Officer via: Dataprivacy@avaniaclinical.com

Our procedures related to the data handling are developed in line with the requirements set forth in the General Data Protection Regulation REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 and will be periodically assessed for compliancy.

PART 4: Cookie notice

Cookie Settings

What are cookies?

This site uses cookies – small text files that are placed on your machine to help the site provide a better user experience.  As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others.

Cookies are files containing small amounts of information which are downloaded to your device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes that cookie. Cookies are useful because they allow a website to recognize a user’s device. We suggest consulting the Help section of your browser which offers guidance for all modern browsers – see also links at the end of this privacy policy.

What happens if I disable all cookies?

The Avania website runs most efficiently with cookies enabled. However, you can decide to only select certain cookies.

Who can drop cookies?

First-party cookies

First-party cookies are placed on your device directly by Avania. For example, Avania uses first-party cookies to adapt our website to your browser’s language preferences and to better understand your use of our website.

Third- Party Cookies

Third-party cookies are placed on your device by our partners and service providers. For example, Avania uses third-party cookies to measure user numbers on our website.

How long does a cookie stay on my device?

Session cookies

There are session cookies and persistent cookies. Session cookies only last until you close your browser. We use session cookies for a variety of reasons, including to learn more about your use of our website during one single browser session and to help you to use our website more efficiently.

Persistent cookies

Persistent cookies have a longer lifespan and aren’t automatically deleted when you close your browser. These types of cookies are primarily used to help you quickly sign-in to our website again and for analytical purposes.

Do you use other tracking technologies?

Other technologies (which Avania also call cookies) such as web beacons (also called pixel tags or clear gifs), tracking URLs or software development kits (SDKs) can also be used. Web beacons are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our service or opened an e-mail that Avania have sent them.  Tracking URLs are custom generated links that help us understand where the traffic to our webpages comes from.  SDKs are small pieces of code included in apps, which function like cookies and web beacons.

What does Avania use cookies (and other tracking technologies) for?

Cookie type	What does it do?	Legal basis
Strictly necessary cookies	These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like e-shop, cannot be provided.	Legitimate interest
Performance cookies	These cookies collect information about how our visitors use our website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how our Avania website works.	Consent
Functionality or Session Cookies	These cookies allow our Avania website to remember choices you make (such as your username, language or the region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to the text size, fonts and other parts of the web pages that you can customize. The information these cookies collect are anonymized and they cannot track your browsing activity on other websites. These cookies will be removed once you closed your browser.	Consent
Targeting/advertising and tracking Cookies	These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers. Targeting or advertising cookies will be linked to site functionality provided by the other organization.  All details about the cookies can be reviewed here. This also provides a list of companies that jointly control the data processed by means of the Privacy Sensitive cookies (Analytical + Marketing). A tracking cookie is a special type of web cookie, which enables identification of an internet user in multiple websites. Based on the visit history, general information about the visitor will be collected. Avania will ask you for your consent prior to the placement of such cookies. You may at all times withdraw your consent for the placement of marketing cookies.	Consent

How do I disable cookies?

The Avania website is designed to function optimally with cookies enabled. However, if you wish to select only certain cookies, this can be controlled in the cookies Privacy Preference Center or in your browser setting.

Please note that if you do deactivate cookies it may mean some of the website features become disabled. Even with all cookies disabled, a tiny amount of information will continue to be retrieved from your web browser. This information is necessary for the basic functioning of our website.

For instructions on changing your cookie setting, select your browser:

• Chrome
• Firefox
• Internet Explorer
• Opera
• Safari

Cookie Settings