Welcome to Aver
At Aver we are committed to protecting and respecting your privacy. The following policy outlines the how the Company will use the data you provide and the rights you are entitled to. For information on our Terms & Conditions or Returns Policy, please visit the appropriate page.
For the purpose of the UK Data Protection Act 2018 and the General Data Protection Regulation 2016 (the Law), the data controllers for any personal information we hold about you are Glaisher & Ames Ltd T/A Aver, 5 Warfield Road, London, NW10 5LA.
This policy will comprise of 18 sections:
1. Who is the data controller?
a. The data controller is responsible for ensuring that your data is held securely and that you comply with the regulations about how personal data is used and the rights afforded to the consumer. www.averlondon.com is owned and run but the UK base entity Glaisher & Ames Ltd T/A Aver.
b. For the purpose of the UK Data Protection Act 2018 and the General Data Protection Regulation 2016 (the Law), the data controllers for any personal information we hold about you are Glaisher & Ames Ltd T/A Aver, 5 Warfield Road, London, NW10 5LA.
2. What personal data do we collect?
a. We only collect data that we required to fully encompass the service we are providing to you. Data will be collected as you browse and shop on our website.
b. Your personal data is required to process and complete your order, dispatch your Product(s) and fulfil the transfer of ownership. To complete this transactional process, we require your name; the billing address; the delivery address; payment details; contact details including email address and phone number. Your email address is required to send confirmation of your order and in conjunction with your telephone will allow us to contact you in the event of any issues with your order.
c. We retain your email address should you have subscribed to our newsletter.
d. We collect data as you browse certain parts of the site. This allows us to personalise your shopping experience should you have granted us consent to do so.
e. Should you have registered for “The Avery” and provided information for the creation of your personal account we will collect data in raltion to your preferences to personalise your shopping experience.
f. If you provide us with someone else’s data – for example, if you purchase a product to be delivered to a friend or as a gift – we will collect and process the personal data required to complete the transaction such as the name, delivery address and other contact details for your friend. If you are receiving an item as a gift, we will process your data only to fulfil the gift request and our contractual obligations.
3. How do we use your personal data?
a. When you have purchased Product(s) from www.averlondon.com we require a certain amount of personal information to be able to fulfil the contract we have entered into (please refer to our Terms and Conditions). This information includes any payment related information; information required for anti-fraud checks should you have chosen to pay by debit/credit card as well as any information required for the billing/shipping of said Product(s).
b. Upon visiting our website, we will collect the minimum required information to fulfil the service of the website.
c. Upon visiting the site, we will use some of the data about how you use the website to improve the content, service and infrastructure of the Site going forward. We will also use the data to aid the promotion of the Site. This will include gaining an understanding of how you came to the Site, the date and time of your visit; products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
e. When you register for an account and to become part of “The Avery” and have provided information to the fact for the creation of your personal account we will collect data in relation to your preferences to personalise your shopping experience.
f. When you sign up for our marketing communications, we will ask you for your email address. If you would prefer not to receive these emails, you can unsubscribe at any time using the link on the bottom of the email, or by contacting email@example.com.
g. If you have purchased from the Site, we will use the personal data we hold about you, including your purchase history, to contact you regarding products and services that may be of interest to you. This contact will normally be via email, but in certain circumstances we may contact you via other methods e.g. we may call you if an item we know you have been eager to purchase comes back into stock. If you would prefer not to be contacted in this way, you can unsubscribe from emails at any time using the link on the bottom of the email, or update your contact preferences by emailing firstname.lastname@example.org.
h. We analyse contact data, purchase history, web browsing data and lifestyle data to tailor our marketing communications, web site presentation and internet advertising to meet your preferences.
4. What is our legal basis for processing your personal data?
a. Under UK law any data we collate, store and use must be done so for a valid reason.
i. The primary function of collating, storing and using your personal data is to fulfil the contract in which we engaged with you at the point of purchase. The information enables us to complete our obligations to you.
ii. In certain circumstances we may ask for your permission or consent to use your personal data e.g. if we were looking to send you marketing information on items that may be of interest to you and/or our newsletter.
iii. We may also have a legitimate interest in using your personal data e.g. to ensure that the content of our website is presented to you and your device as effectively as possible, or to ensure that our marketing communications are relevant to your interests. If this is our reason for using your data, we must make sure that our interests do not override yours and you are entitled to object to this use of your data.
iv. Lastly, we may be required to use your data to meet a legal obligation or to protect your interests e.g. we may exchange data with other specialist organisations for the purposes of fraud detection and credit risk reduction and we will retain financial data long term to meet our statutory obligations. These legal obligations include.
a) When you have purchased Product(s) from www.averlondon.com we require a certain amount of personal information to be able to fulfil the contract we have entered into (please refer to our Terms and Conditions). This information includes any payment related information; information required for anti-fraud checks should you have chosen to pay by debit/credit card as well as any information required for the billing/shipping of said Product(s).
b) The provision of your personal data for these activities is a contractual obligation. You are free to communicate your data or not, but in the absence of the requested data it will not be possible to finalise or execute the contract and your requests. This means that while you will continue to be able to browse the Site, we are not able to fulfil the full services of the website and you will not be able to purchase products.
c) At the point of purchase we are obligated to perform anti-fraud checks to ensure sufficient payment security on the Site.
d) You are free to choose not to purchase from us however, when you make a purchase at www.averlondon.com we are required to process your personal data to meet our legal obligations in accordance with the tax provisions and other statutory rules which apply.
e) Our use of your data is necessary for our legitimate interest in ensuring that the service we provide to you is managed correctly.
h) Upon registering on the Site, we will collect sufficient data to recognise you on return visits to maximise your customer experience. Should you wish to be excluded from this, please email email@example.com.
i) Should you sign up for our direct marketing communications, we will ask you for your email address to facilitate this. You are able to unsubscribe from this at any time.
j) Our use of your data is necessary for our legitimate interest in ensuring that you receive information about goods and services that may be of interest to you.
k) We analyse contact data, purchase histories and web browsing data to tailor our marketing communications, web site presentation and internet advertising to meet your preferences.
5. Who will process your data?
a. Your data will be handled and processed by the employees of Glaisher and Ames Ltd T/A Aver. This data may also be transmitted to subsidiaries of Glaisher & Ames Ltd T/A Aver. We may also transmit data to third party service providers. Significant due diligence has been undertaken on any third-party provider we are associated with, all of whom comply with the legislation of personal data processing. These parties have been designated as data processors and carry out their activities according to the instructions given by Glaisher & Ames Ltd T/A Aver and under our control.
b. Such companies include; banks, e-commerce providers, third party marketing providers, market research consultants, data processors, publishers, couriers and distributors.
c. We may be obligated to transmit your data in accordance with the law to the police, judicial or administrative authorities, for the investigation and prosecution of crimes, the prevention of and protection from threats to public security, to allow Glaisher & Ames Ltd T/A Aver to understand, defend and exercise their rights in court, as well as other reasons related to the protection of the rights of others.
6. Do we transfer your personal data outside of the EU?
a. There may be instances where some third parties engaged for and in accordance with the purposes outlined above are based outside of the EU. We ensure that they nevertheless offer adequate levels of data protection as established by specific decisions of the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).
b. Transmission of data to companies based in non-EU countries who explicitly do not have the sufficient levels of data protection legislation as determined by the European Commission will only occur if:
i. There has been the completion of specific safeguards and guarantees on the protection of your personal data. These are the “standard contractual clauses” as outlined by the European Commission.
ii. The transfer is a necessary condition for the completion of and execution of the contract between you the customer and Glaisher & Ames Ltd T/A Aver.
iii. It is a requirement to manage your requests.
7. How long do we keep your personal data?
a. Outside of the minimum requirements as determined by UK law, we will not retain your personal data for longer than is necessary to fulfil the purposes for which you provided it. The retention period varies depending on the purpose of the processing.
i. The data collected during your purchase of goods on www.averlondon.com are retained in accordance with local tax law (seven years in the UK).
ii. The data collected when you opt-in for Aver to send you our marketing communications is retained indefinitely/until you terminate your subscription. When you give us your consent to send you marketing communications, you can withdraw your consent at any time.
iii. When we use your personal data and browsing history to analyse your behaviour in order to customise the website and to show you personalised sales offers, we will keep the data for analytical purposes until you ask us to delete it;
iv. When we use personal data for market research, we will keep the data until you ask us to stop.
8. Your rights
a. Under the Law, you have the right to:
i. Request information as to how we came into possession of your data, in what format and what it is used for;
ii. Request that your data is updated or corrected;
iii. Withdraw consent for processing for a specified purpose;
iv. Request your data to be erased from our systems in all matters where we are not required to hold it by law.
v. Limit or oppose our processing of your data;
vi. Request a download of the personal data we hold on you in an easily readable electronic format or via electronic transfer.
vii. At any time object to our legitimate reasons for processing your data. Please do so by emailing firstname.lastname@example.org to express your reasoning and we will consider your request before responding.
b. You can exercise these rights at any time at any time by emailing email@example.com. To ensure that the data of our users are not subject to breaches or illegitimate use by third parties, we will ask you to confirm your identity before carrying out your request.
9. Security measures
a. We have implemented technical and organisational security measures aimed at preventing your personal data from being used illegitimately or fraudulently.
b. Specifically we have taken measures to encrypt your data as well as implement robust systems for processing and handling of your data. Glaisher & Ames Ltd T/A Aver will continually assess the effectivity of our data protection services to assure that our data control is sufficient.
a. Any complaints or queries about the processing of your data should be first directed to firstname.lastname@example.org.
b. If you believe that the processing of your personal data has been carried out unlawfully, you can file a complaint with the supervisory authority responsible for compliance with the rules on personal data protection in your jurisdiction. In the UK, the complaint should be presented to the Information Commissioner’s Office (https://ico.org.uk/).
11. Changes to this notice
12. Legislative reference and useful links
a. The processing of your personal data is carried out by Glaisher & Ames Ltd T/A Aver in compliance with the Regulation (EU) 2016/679 general regulation on data protection, UK Data Protection Act 2018 and rules on the processing of personal data (https://ico.org.uk/).
13. Cookies and how we use them?
a. We collect data about your use of our online services in conjunction with our business partners. Cookies are tiny files that your device transmits to us that we can access when you visit our site at a later date. They help us identify who you are and some of the personal data about your time spent on the site. This allows us to personalise your shopping experience and best facilitate the service to you the customer.
14. Testimonials & Reviews:
a. We value your feedback and may choose to implement some of your suggestions to improve our services. We reserve our right to publish your comments but will ensure that they remain anonymous without prior consent from you. We may also similarly publish your reviews. Again your personal information will remain anonymous unless we have obtained prior written consent.
15. Social networks:
16. Marketing Opt-In/Opt-Out:
a. One of the primary sources of contact for us at Aver and the customer is our newsletter. We offer you the opportunity to opt into our communications at a number of points on our website and during the sale process. This is designed to bring value to you and best enable us to meet the service defined. We, or our third party business partners, may also ask you if you want to receive marketing if you enter a promotion or attend an event thrown or sponsored by us. Other companies in our Group may also pass your personal information to us for marketing use. You have the option to opt out of these communications at any time. Please contact email@example.com to do so.
17. Customer surveys:
In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.