Privacy Policy

AVERio respects your privacy and is committed to protecting your Data. This privacy policy will inform you as to how we look after your Data and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR DATA COLLECTED?
4. HOW WE USE YOUR DATA
5. DISCLOSURES OF YOUR DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY
11. Important information and who we are

Purpose of this privacy policy

This privacy policy applies between you, the User of our Website (www.averio.co.uk) and/or the service, hardware and software products provided to you and Smart Sense Solution Ltd trading as AVERio, the owner and provider of this Website and associated products. For the avoidance of doubt, it also applies when you or a User downloads, installs or uses a mobile application that we make available to you and the User, or you use a web application that we make available to you for the purpose of allowing Users to monitor residents and other automated functions locally or remotely.

This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website and associated products.

It also explains your rights in relation to your Data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain Data about you.  When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).  We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to products and services we offer to individuals [and our wider operations] in the European Economic Area (EEA)]

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

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

Controller

Smart Sense Solutions Ltd trading as AVERio is the controller and responsible for processing your Data (collectively referred to as “we”, “us”, or “our” in this privacy notice). We will let you know which entity will be the controller for your data when you purchase a product or service with us.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Full name of legal entity: Smart Sense Solutions Ltd

Email address: [email protected]

Postal address: Initial Business Centre, Wilson Business Park, Manchester, United Kingdom, M40 8WN

Telephone number: 0161 552 4224

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator 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 policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on [31 March 2023]. [Historic versions can be obtained by contacting us].

It is important that the Data we hold about you is accurate and current. Please keep us informed if your Data changes during your relationship with us.

Third-party links and Third Parties

This 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.

Additionally, third parties may be providers of software in connection with devices or equipment that we sell.  These third parties will collect Data directly from you in accordance with their own privacy statements.  We are not responsible for how those third parties collect or process your data.

2. The data we collect about you

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 Data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, job title, organisation name, username or similar identifier and login credentials to our services, marital status, title, date of birth and gender [date of birth].
• Contact Data includes billing address, shipping/delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details, fraud check details.
• Order Details such as reference numbers or words that you have added to your order that may refer to personal 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 our own websites. It also includes the type of mobile device you use, a unique device identifier, your mobile operating system and time zone setting.
• Profile Data includes your username and [encrypted] password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our websites, mobile application, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Vat relief details which include your (or the person you are claiming VAT relief on behalf of’s (name, address, declaration of chronic illness or disability and signature.
• Email content, postal content and telephone content data which includes information that you have provided or that we have requested from you by email, post or telephone.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Data but is not considered 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 Data so that it can directly or indirectly identify you, we treat the combined data as Data which will be used in accordance with this privacy policy.

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

We will only collect information about your health when you submit a VAT relief form to us, and by completing and signing the VAR relief form you are providing us with permission to collect and process this special category of Data.

If you fail to provide Data

Where we need to collect Data by law, or under the terms of a contract we have with you, and you fail to provide that Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your Data collected?

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

• Direct interactions. You may give us your Identity, Contact, Financial, Profile, Vat relief and Email Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Data you provide when you:
• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• sign up to our newsletters;
• request marketing information or literature to be sent to you;
• request a quotation;
• complete and send us a VAT relief form;
• enter a competition, promotion or survey; or
• give us feedback or contact us by email, telephone, post [or fax].
• Automated technologies or interactions. As you interact with our website, mobile application and use our services we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Data by using cookies, server logs and other similar technologies. [We may also receive Technical Data about you if you visit other websites employing our cookies.] Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive Data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

• analytics providers such as Google based outside the [UK] [EU];
• advertising networks based inside the UK; and
• search information providers such as Google based inside the UK

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside the UK.
• Identity and Contact Data from data brokers or aggregators based inside the UK.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.
• Fraud risk data from providers of payment support such as STRIPE based in the UK
• Payment and address data from [Paypal] based outside the UK;

4. How we use your Data

We will only use your Data when the law allows us to. Most commonly, we will use your 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 Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing and promotional emails at any time by contacting us.

Purposes for which we will use your Data

We have set out below, in a table format, a description of all the ways we plan to use your 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 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 Data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain Data uses, particularly around marketing and advertising. We have established the following Data control mechanisms:

Promotional offers from us

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 (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing, if you provided us with details by subscribing to our newsletters, if you provided us with details when you entered a competition or registered for a promotion, and in in each case,  you have not opted out of receiving that marketing or promotional content.

Third-party marketing

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

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to Data provided to us as a result of a service purchase, service experience or other transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Change of purpose

We will only use your 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 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 Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

In some circumstances you can ask us to delete your data: see section 9. headed Your Legal Rights.

In some circumstances we mat anonymise your 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.

5. Disclosures of your Data

We may share your Data with the parties set out below for the purposes set out in the table Purposes for which we will use your Data above.

• Internal Third Parties as set out in the [Glossary].
• External Third Parties as set out in the [Glossary].
• Specific third parties listed in the table Purposes for which we will use your Data above.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Data in the same way as set out in this privacy policy.

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

6. International transfers

 We do not transfer your Data outside the UK.

7. Data security

We have put in place appropriate security measures to prevent your Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Data on our instructions and they are subject to a duty of confidentiality.

We continually test our systems to ensure we are kep up to date in relation to the latest known security threats.

Access to your account is controlled by a password and user name that is unique to you.

Payment details are encrypted using SSL technology.

We have put in place procedures to deal with any suspected 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 Data for?

We will only retain your 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 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 Data, we consider the amount, nature and sensitivity of the Data, the potential risk of harm from unauthorised use or disclosure of your Data, the purposes for which we process your Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

[Details of retention periods for different aspects of your Data are [available in our retention policy which you can request from us by contacting us OR set out in the table [Purposes for which we will use your Data] above].

9. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your Data. Please click on the links below to find out more about these rights:

• Request access to your Data.
• Request correction of your Data.
• Request erasure of your Data.
• Object to processing of your Data.
• Request restriction of processing your Data.
• Request transfer of your Data.
• Right to withdraw 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 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 Data (or to exercise any of your other rights). This is a security measure to ensure that 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.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Data for our legitimate interests. We do not use your Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data 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.

Comply with a legal obligation means processing your Data where it is necessary for compliance with a legal obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the AVERio Group acting as joint controllers or processors and who are based [in the UK] and provide [IT and system administration services and undertake leadership reporting].

External Third Parties

• Service providers [acting as processors] based in the UK who provide [IT and system administration services].
• Professional advisers [acting as processors or joint controllers] including lawyers, bankers, auditors and insurers based in the UK who provide [consultancy, banking, legal, insurance and accounting services].
• HM Revenue & Customs, regulators and other authorities [acting as processors or joint controllers] based [in the United Kingdom] [who require reporting of processing activities in certain circumstances].
• Third party suppliers or subcontractors based in the UK that may dispatch goods or provide services directly to you in pursuance of an order placed with us. In this instance we may provide your name, address, email address and telephone number to a supplier in order for that third party supplier or subcontractor to deliver a product and service directly to you.  As part of this delivery of product or service, your details may also be passed to a postal or courier service to effect delivery.
• Third party delivery providers based in the UK. In this instance we may pass your details including name,  address, email address and telephone number to the postal service or courier service to enable delivery of your product or service and in order to communicate delivery  confirmations and/or estimated delivery times.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.  If this happens to our business, then the new owners may use your Data in the same way as set out in this privacy notice.

Data means collectively all information that you submit to Averio via the Website, over the phone, via the hardware and software (including for the avoidance of doubt mobile or web application) provided or any other method of contact that you choose. This definition incorporates, where applicable, the definitions provided in data protection laws. When providing the data of a third party (i.e. a friend or family member) you must ensure you have their permission to share their Data with us for all the purposes detailed in the Section ‘Purposes for which we will use your Data’.

User or you means any third party that accesses the Website and associated products and is not either (i) employed by AVERio and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Averio and accessing the Website and associated products in connection with the provision of such services.

Website means www.averio.co.uk, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

YOUR LEGAL RIGHTS

You have the right to:

Request access to your Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Data we hold about you and to check that we are lawfully processing it.

Request correction of the 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 Data. This enables you to ask us to delete or remove 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 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 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 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 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 Data. This enables you to ask us to suspend the processing of your 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 Data to you or to a third party. We will provide to you, or a third party you have chosen, your 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 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.