1. Introduction

1.1. This Privacy Policy is provided by AVx Global.

1.2. We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your “personal data”).

1.3. It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law.

1.4. We are the controller of personal data obtained via the Services, meaning we are the organization legally responsible for deciding how and for what purposes it is used.

2. What this policy applies to

2.1. This privacy policy relates to your use of the Services only.

2.2. The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

3. Personal data we collect about you

3.1. The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you.

• Identify and account data you input into the Services:

  • -Your first and last name

  • -Your email address

  • -Your mobile or telephone number

  • -Your postal address

  • -Your payment history

  • -Your gender

  • -Your date of birth

  • -The last 4 digits of your debit/credit card

  • -Mode of payment (e.g. MasterCard, Visa, Apple Pay, GooglePay).

• Data collected when you use specific functions in the Services:

  • -Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases we will assume it is and treat it by this policy as if it were).

• Other data the Services collects automatically when you use it:

  • -Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use.

3.2. If you do not provide personal data we ask for where it is required, it may prevent us from providing the Services to you.

3.3.We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

4. Sensitive Data

4.1. Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

4.2. Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals and that you should not submit sensitive data to us.

5. How your personal data is collected

5.1. We collect personal data from you directly when you engage our Services, contact us directly or reach out to us via the Website, social media, make submissions via email, or indirectly, such as your activity while using the Services.

5.2. We collect personal information about you using cookies or similar technologies. Please refer to our cookies policy regarding our use of cookies and similar technologies.

6. How and why we use your personal data

6.1. Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

• where you have given consent

• to comply with our legal and regulatory obligations

• for the performance of a contract with you or to take steps at your request before entering into a contract

• for our legitimate interests or those of a third party

6.2. A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

6.3. The table below explains what we use your personal data for and why.

6.4. -Create and manage your account with us:

• To perform our contract with you or to take steps at your request before entering into a contract

-Providing the Services to you

• To perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means our Website terms and conditions and the Website terms of use which apply to the Services)

-Enforce legal rights or defend or undertake legal proceedings

• to comply with our legal and regulatory obligations

• in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

-Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or other important notices

• to comply with our legal and regulatory obligations

• in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you

-Protect the security of systems and data

• to comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

-Operational reasons, such as improving efficiency, training, and quality control or to provide support to you

• for our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you

-Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, Website and functionalities and offerings or other efficiency measures

• For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our Website

-Updating and enhancing user records

• to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means our Website terms and conditions and the Website terms of use which apply to the Services)

• to comply with our legal and regulatory obligations

• where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new services or functionalities related to the Website and our Services

-To comply with our legal and regulatory obligations

• to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means our Website terms and conditions and the Website terms of use which apply to the Services)

• to comply with our legal and regulatory obligations (where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new services or functionalities related to the Website and our Services)

-To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.

-In such cases information will be anonymized where possible and only shared where necessary

• to comply with our legal and regulatory obligations

• in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

6.5. See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

7. Marketing

7.1. We intend to send you email marketing to inform you of our services such as promotions.

7.2. We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

7.3. You will have the right to opt out of receiving marketing communications at any time by:

• contacting us at yohan.ismael@avxglobal.org

• using the ‘unsubscribe’ link included in all marketing emails you may received from us

7.4. We will always treat your personal data with the utmost respect and never sell or share it with other organizations for marketing purposes.

7.5. For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

8. Who we share your personal data with

8.1. We need to share your personal data with:

• our employees and subcontractors

• external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations

• professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations

8.2. We will not share your personal data with any other third party.

9. How long your personal data will be kept

9.1. We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once your engagement with us is terminated, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need-to-know basis’ have access to such data.

9.2. Following the end of the aforementioned retention period, we will delete or anonymize your personal data.

10. Your rights

10.1. You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

-Access to a copy of your personal data

• The right to be provided with a copy of your personal data

-Correction (also known as rectification)

• The right to require us to correct any mistakes in your personal data

-Erasure (also known as the right to be forgotten)

• The right to require us to delete your personal data—in certain situations

-Restriction of use

• The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

-Data portability

• The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

-To object to use

• at any time to your personal data being used for direct marketing (including profiling)

• in certain other situations to our continued use of your personal data, e.g. where we use you personal data for our legitimate interests

-Not to be subject to decisions without human involvement

• The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects

• We do not make any such decisions based on data collected by the Services

10.2. For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below)..

10.3. If you would like to exercise any of those rights, please complete a request form—available on our website www.avxglobal.org ‘How to contact us’. When contacting us please:

• provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you

• let us know which right(s) you want to exercise and the information to which your request relates

11. Keeping your personal data secure

11.1. We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.

11.2. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

12. How to complain

12.1. Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

13. Changes to this privacy policy

13.1. We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.

13.2. The information you provide will be used to:

• process your request for information;

• register you to receive our newsletters;

• contact you regarding our services and products.

14.How to contact us

14.1. You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

14.2. Our contact details are shown below:

AVx Global, Member of AeroVista FZCO

Dubai Silicon Oasis, DDP, Building A1

Dubai, United Arab Emirates

M: +230 5813 1642 / +971 58 567 5721

W: www.avxglobal.org

E: yohan.ismael@avxglobal.org