AVC Wise | Privacy Policy

Your employer (referred to in this privacy policy as ‘your employer’, ‘we’, ‘us’ or ‘our’) has appointed AVC Wise Limited to run and administer an employment benefit scheme on our behalf. We respect your privacy and are committed to protecting your personal data. This privacy statement will tell you how we look after the personal data that you provide to us when you register for an employment benefit scheme. It will also tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy statement

This statement aims to give you information on how we collect and process your personal data.

It is important that you read this privacy statement, together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy statement supplements other notices and privacy policies and is not intended to override them.

Controller/Processor

As the Data Controller, we will remain responsible for the collection and processing of your personal data by us, and done on our behalf by AVC Wise Ltd (as Data Processor), and will oversee questions in relation to this privacy statement.

With respect to personal data processed in respect of an employee benefit scheme, the following provisions will apply:

With respect to personal data processed for our internal business management and financial purposes, such personal data is processed by us as a Data Controller.
With respect to personal data processed for the purpose of running and administering an employment benefit scheme on our behalf, such personal data is processed by us as Data Controller and by AVC Wise Ltd as Data Processor.

If you have any questions about this privacy statement, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

If you have any questions about this privacy statement or our privacy practices, please contact us.

Alternatively, you can contact AVC Wise Ltd (our Data Processor) in the following ways:

Email address: [email protected]

Postal address: 5 Margaret Road, Romford, Essex. RM2 5SH.

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

Changes to the privacy statement and your duty to inform us of changes

We keep our privacy statement under regular review.

This version was last updated on 18/05/2023.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

2. The data we collect about you

A piece of information constitutes personal data if it relates to an individual, directly or indirectly. In other words, personal data is any information relating to an identified or identifiable living person; such a person is called a data subject.

We, or AVC Wise Ltd on our behalf, may collect, use, store and transfer different types of personal data about you, which we have grouped together in the following ways:

Identity Data includes first name, last name, username or similar identifier, Employee Number, NI Number, date of birth, salary and any existing AVC Plan information.

Contact Data includes address, email address and telephone numbers.

Transaction Data includes details about products and services you have selected.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access the AVC Wise Platform at www.avcwise.co.uk

Profile Data includes your username and password, feedback and survey responses.

Usage Data includes information about how you use the AVC Wise Platform and services.

Communications Data includes your communication preferences.

We also collect, use and share with third parties Aggregated Data such as statistical or demographic data. 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 Site 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 statement.

Neither we, nor AVC Wise Ltd on our behalf, collect any Special Categories of Personal Data about you (such as 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, or AVC Wise Ltd on our behalf, collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we, or AVC Wise Ltd on our behalf, need to collect your personal data by law, or for the performance of a contract to which you are party, if you fail to provide that personal data, those lawful purposes for collecting and processing it cannot be met.

Consequently, for example, you may have your request for services rejected.

3. How is your personal data collected?

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

Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make an application for products or services;
- create an account;
- subscribe to publications;
- enter a competition, promotion or survey; or
- give us feedback or contact us.

Automated technologies or interactions. As you interact with the Site, 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. Please see our cookie policy for further details.

Third parties or publicly available sources. We will receive personal data about you from analytics providers such as Google.

4. How we use your personal data

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

Where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. This also means the services we are providing to you through your Contract of Employment.

Where it is necessary for compliance with a legal obligation that we are subject to.

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.

Purpose/Activity	Type of data	Lawful basis for processing
To register you for an employment benefit scheme;	Identity Contact	Performance of a contract with you
To process and deliver your request for services, including: Manage payments, fees and charges Collect and recover money owed to us	Identity Contact Transaction Communications	Performance of a contract with you
To manage our relationship with you, which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey	Identity Contact Profile Communications	Performance of a contract with you Necessary to comply with a legal obligation
To enable you to partake in a prize draw, competition or complete a survey	Identity Contact Profile Usage Communications	Performance of a contract with you
To administer and protect our organisation and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Identity Contact Technical	Performance of a contract with you
To deliver relevant website content to you and measure or understand the effectiveness of the communications	Identity Contact Profile Usage Communications Technical	Performance of a contract with you
To use data analytics to improve our website, products/services, communications, customer relationships and experiences	Technical Usage	Performance of a contract with you
To make relevant suggestions and recommendations to you about goods or services that may be of interest to you	Identity Contact Technical Usage Profile Communications	Performance of a contract with you

Promotional offers from us

You will receive communications from us and/or AVC Wise Ltd if you have registered on the AVC Wise Platform.

Third-party communications

Communications sent by AVC Wise Ltd on behalf of your employer are not third party communications.

Opting out

You can ask us to stop sending you communications at any time by contacting AVC Wise Ltd or clicking the unsubscribe link in a message.

Where you opt out of receiving communications, this will not apply to messages as a result of the fulfilment of services, or when we want to notify you regarding other important developments.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. For more information about the cookies used, please see AVC Wise | Cookie Notice

Change of purpose

We will only use your personal data for the purposes for which it is collected, 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 in Section 4 above.

Internal Third Parties related to your Employer acting as joint controllers or processors.

External Third Parties such as:

Service providers acting as processors who, for example, provide administration services or payroll services.

Professional advisers acting as processors or joint controllers including lawyers, tax advisors and auditors.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.

Other parties to whom we may choose to sell, transfer or merge parts of our organisation or our assets. Alternatively, we may seek to acquire other organisations or merge with them. If a change happens to our organisation, then the new owners may use your personal data in the same way as set out in this privacy statement.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We do not transfer your personal data outside the European Economic Area (EEA)..

7. 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.

8. 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.

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.

9. Your legal rights

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

You have the right to:

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 processing it lawfully.
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. 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.

Alternatively, you can contact AVC Wise Ltd (our Data Processor) by email at [email protected] - who will then make us aware of your data right request.

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 ‘manifestly unfounded or excessive’. Alternatively, we could refuse to comply with your request in those 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

Normally, we will respond to all legitimate requests within one month. In exceptional cases, it could take us longer than a month if your request is particularly complex or you have made a number of requests. In such a case, we will notify you and keep you updated.