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Privacy Policy

Last updated June 19, 2023

This privacy notice for Avantgarde Finance Ltd (doing business as Avantgarde) ('Avantgarde', 'we', 'us', or 'our'), describes how and why we might collect, store, use, and/or share ('process') your information when you use our services ('Services'), such as when you:

  • Visit our website at https://avantgarde.finance, or any website of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at dpo@avantgarde.finance.

SUMMARY OF KEY POINTS


This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.


What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Avantgarde and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.


Do we process any sensitive personal information? We do not process sensitive personal information.


Do we receive any information from third parties? We do not receive any information from third parties.


How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.


In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.


How do we keep your information safe? We have organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.


What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.


How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.


Want to learn more about what Avantgarde does with any information we collect? Review the privacy notice in full.


TABLE OF CONTENTS


1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?  

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW LONG DO WE KEEP YOUR INFORMATION?

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

8. DO WE COLLECT INFORMATION FROM MINORS?

9. WHAT ARE YOUR PRIVACY RIGHTS?

10. CONTROLS FOR DO-NOT-TRACK FEATURES

11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

13. DO WE MAKE UPDATES TO THIS NOTICE?

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?


Personal information you disclose to us


In Short: We collect personal information that you provide to us.


We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.


Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • email addresses
  • job titles
  • your company

Sensitive Information. We do not process sensitive information.


All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.


Information automatically collected


In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.


We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.


Like many businesses, we also collect information through cookies and similar technologies.


The information we collect includes:

  • Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).

2. HOW DO WE PROCESS YOUR INFORMATION?


In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.


We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see 'WHAT ARE YOUR PRIVACY RIGHTS?' below.
  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.


3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?


In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.


If you are located in the EU or UK, this section applies to you.


The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
  • Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on our products and services
  • Support our marketing activities
  • Understand how our users use our products and services so we can improve user experience
  • Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.


We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.


In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes
  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?


In Short: We may share information in specific situations described in this section and/or with the following third parties.


We may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.


5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?


In Short: We may use cookies and other tracking technologies to collect and store your information.


We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.


6. HOW LONG DO WE KEEP YOUR INFORMATION?


In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.


We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).


When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?


In Short: We aim to protect your personal information through a system of organisational and technical security measures.


We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.


8. DO WE COLLECT INFORMATION FROM MINORS?


In Short: We do not knowingly collect data from or market to children under 18 years of age.


We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at dpo@avantgarde.finance.


9. WHAT ARE YOUR PRIVACY RIGHTS?


In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.


In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.


We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.


If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.


Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.


However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.


Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.


Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.


If you have questions or comments about your privacy rights, you may email us at dpo@avantgarde.finance.

10. CONTROLS FOR DO-NOT-TRACK FEATURES


Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.


11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?


In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.


California Civil Code Section 1798.83, also known as the 'Shine The Light' law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.


If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).


CCPA Privacy Notice


The California Code of Regulations defines a 'resident' as:


(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose


All other individuals are defined as 'non-residents'.


If this definition of 'resident' applies to you, we must adhere to certain rights and obligations regarding your personal information.


What categories of personal information do we collect?


We have collected the following categories of personal information in the past twelve (12) months:

Categories of personal information

Category

Examples

Collected

A. Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES
B. Personal information categories listed in the California Customer Records statute
Name, contact information, education, employment, employment history, and financial information
YES
C. Protected classification characteristics under California or federal law
Gender and date of birth
NO
D. Commercial information
Transaction information, purchase history, financial details, and payment information
YES
E. Biometric information
Fingerprints and voiceprints
NO
F. Internet or other similar network activity
Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements
NO
G. Geolocation data
Device location
NO
H. Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video or call recordings created in connection with our business activities
NO
I. Professional or employment-related information
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us
YES
J. Education Information
Student records and directory information
NO
K. Inferences drawn from other personal information
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics
NO
L. Sensitive
Personal Information
NO

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - Until the user requests removal
  • Category B - Until the user requests removal
  • Category D - Until the user requests removal
  • Category I - Until the user requests removal

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?


More information about our data collection and sharing practices can be found in this privacy notice.


You may contact us by email at dpo@avantgarde.finance, or by referring to the contact details at the bottom of this document.


If you are using an authorised agent to exercise your right to opt out we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.


Will your information be shared with anyone else?


We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.


We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.


Avantgarde Finance Ltd has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Avantgarde Finance Ltd will not sell or share personal information in the future belonging to website visitors, users, and other consumers.


Your rights with respect to your personal data


Right to request deletion of the data — Request to delete


You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.


Right to be informed — Request to know


Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell or share personal information to third parties;
  • the categories of personal information that we sold, shared, or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
  • the business or commercial purpose for collecting, selling, or sharing personal information; and
  • the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.


Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights


We will not discriminate against you if you exercise your privacy rights.


Right to Limit Use and Disclosure of Sensitive Personal Information


We do not process consumer's sensitive personal information.


Verification process


Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.


We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.


Other privacy rights

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
  • You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorised agent that does not submit proof that they have been validly authorised to act on your behalf in accordance with the CCPA.
  • You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by email at dpo@avantgarde.finance, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.


12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?


In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.


Virginia CDPA Privacy Notice


Under the Virginia Consumer Data Protection Act (CDPA):


'Consumer' means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.


'Personal data' means any information that is linked or reasonably linkable to an identified or identifiable natural person. 'Personal data' does not include de-identified data or publicly available information.


'Sale of personal data' means the exchange of personal data for monetary consideration.


If this definition 'consumer' applies to you, we must adhere to certain rights and obligations regarding your personal data.


The information we collect, use, and disclose about you will vary depending on how you interact with Avantgarde Finance Ltd and our Services. To find out more, please visit the following links:

  • Personal data we collect
  • How we use your personal data
  • When and with whom we share your personal data

Your rights with respect to your personal data

  • Right to be informed whether or not we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of the personal data you previously shared with us
  • Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')

Avantgarde Finance Ltd has not sold any personal data to third parties for business or commercial purposes. Avantgarde Finance Ltd will not sell personal data in the future belonging to website visitors, users, and other consumers.


Exercise your rights provided under the Virginia CDPA


More information about our data collection and sharing practices can be found in this privacy notice.


You may contact us by email at dpo@avantgarde.finance, by submitting a data subject access request, or by referring to the contact details at the bottom of this document.


If you are using an authorised agent to exercise your rights, we may deny a request if the authorised agent does not submit proof that they have been validly authorised to act on your behalf.


Verification process


We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request.


Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.


Right to appeal


If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at dpo@avantgarde.finance. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.


13. DO WE MAKE UPDATES TO THIS NOTICE?


In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.


We may update this privacy notice from time to time. The updated version will be indicated by an updated 'Revised' date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.


14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?


If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) , Chris Taylor, by email at dpo@avantgarde.finance, or contact us by post at:


Avantgarde Finance Ltd

Chris Taylor

12 New Fetter Lane

London, 12 New Fetter Lane EC4A 1JP

United Kingdom


15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?


You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.


Privacy Notice

Thank you for choosing to be part of our community at Enzyme (“Company,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice or our practices with regard to your personal information, please contact us at council@enzyme.finance.

This privacy notice describes how we might use your information if you:

    Visit our website at
    https://enzyme.finance
    Engage with us in other related ways ― including any sales, marketing, or events

In this privacy notice, if we refer to:

    “Website,” we are referring to any website of ours that references or links to this policy“Services,” we are referring to our Website, and other related services, including any sales, marketing, or events

The purpose of this privacy notice is to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

💡Please read this privacy notice carefully, as it will help you understand what we do with the information that we collect.

What information do we collect?

Personal information you disclose to us

In Short:  We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You.

We collect names, email addresses, usernames, passwords, contact preferences, and other similar information.

Social Media Login Data.

We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the information described in the section called “How do we handle your social logins?” below.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

How do we use your information?

In Short:  We process your information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Website for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

In legal terms, we are generally the “data controller” under European data protection laws since we determine the means and/or purposes of the data processing we perform. However, if you are a business customer with whom we have entered into a data processing agreement for the provision of corporate services to you, then you would be the “data controller” and we would be the “data processor” under European data protection laws since we would be processing data on your behalf in accordance with your instructions.

We use the information we collect or receive:

    To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed “How do we handle your social logins?” for further information.To post testimonials. We post testimonials on our Website that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at
    dpo@avantgarde.finance
    and be sure to include your name, testimonial location, and contact information.Request feedback. We may use your information to request feedback and to contact you about your use of our Website.To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Website.Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Website, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time below).Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Website, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.

Will your information be shared with anyone?

In Short:  We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

    Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

More specifically, we may need to process your data or share your personal information in the following situations:

    Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.Vendors, Consultants and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.

Who will your information be shared with?

In Short:  We only share information with the following categories of third parties.

We only share and disclose your information with the following categories of third parties. If we have processed your data based on your consent and you wish to revoke your consent, please contact us using the contact details provided in the section below titled “How can you contact us about this notice?”.

    Ad NetworksCloud Computing ServicesData Storage Service ProvidersCommunication & Collaboration ToolsFinance & Accounting ToolsSales & Marketing ToolsTesting ToolsProduct Engineering & Design ToolsUser Account Registration & Authentication ServicesWebsite Hosting Service Providers

Do we use cookies and other tracking technologies?

In Short:  We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

How do we handle your social logins?

In Short:  If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Website offers you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Website. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

How long do we keep your information?

In Short:  We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than six (6) months past the termination of the user’s account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How do we keep your information safe?

In Short:  We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

Do we collect information from minors?

In Short:  We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at dpo@avantgarde.finance.

What are your privacy rights?

In Short:  In some regions, such as the European Economic Area (EEA) and United Kingdom (UK), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA and UK), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you are a resident in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

If you have questions or comments about your privacy rights, you may email us at dpo@avantgarde.finance.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

    Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

Cookies and similar technologies

Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.

Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list — however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may:

    Access your account settings and update your preferences.Contact us using the contact information provided.

Controls for do-not-track features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

Do California residents have specific privacy rights?

In Short:  Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

    every individual who is in the State of California for other than a temporary or transitory purpose and
    every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months:

    Category A — Identifiers: Such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.Category B — Personal information: As defined in the California Customer Records law, such as your name, contact information, education, employment, employment history and financial information.Category D — Commercial information: Such as transaction information, purchase history, financial details and payment information.Category I — Professional or employment-related information: Such as business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

    Receiving help through our customer support channels;Participation in customer surveys or contests; andFacilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Enzyme collects and shares your personal information through:

    Targeting cookies/Marketing cookiesBeacons/Pixels/Tags

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at dpo@avantgarde.finance, or by referring to the contact details at the bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal data.

Enzyme has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

    Category A — Identifiers: Such as contact details, like your real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name.Category B — Personal information: As defined in the California Customer Records law, such as your name, contact information, education, employment, employment history and financial information.Category D — Commercial information: Such as transaction information, purchase history, financial details and payment information.Category I — Professional or employment-related information: Such as business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us.

Enzyme has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. Enzyme will not sell personal information in the future belonging to website visitors, users and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data - Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed - Request to know

Depending on the circumstances, you have a right to know:

    whether we collect and use your personal information;the categories of personal information that we collect;the purposes for which the collected personal information is used;whether we sell your personal information to third parties;the categories of personal information that we sold or disclosed for a business purpose;the categories of third parties to whom the personal information was sold or disclosed for a business purpose; andthe business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

    you may object to the processing of your personal data.you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data.you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us by email at dpo@avantgarde.finance, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Do we make updates to this notice?

In Short:  Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

How can you contact us about this notice?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), by email at dpo@avantgarde.finance, or by post to:

Data Protection Officer Avantgarde Finance 12 New Fetter Lane London EC4A 1JP United Kingdom

If you are a resident in the United Kingdom, the “data controller” of your personal information is Enzyme. Enzyme has appointed Avantgarde Finance Ltd to be its representative in the UK. You can contact them directly regarding the processing of your information by Enzyme, by email at dpo@avantgarde.finance, by visiting https://enzyme.finance, or by post to:

Data Protection Officer Avantgarde Finance 12 New Fetter Lane London EC4A 1JP United Kingdom

How can you review, update or delete the data we collect from you?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by clicking here.