01.01.2023:
Introduction
This is the privacy notice (the “Notice”) for avellum.com (the “Website”).
This Notice describes how AVELLUM LLC (“AVELLUM”, “we” or “us”) processes your personal data – any information that enables you to be identified, directly or indirectly (the “Personal Data”) – when you visit and use our Website, including any services available on the Website, in particular when you:
- contact us through the Website or otherwise;
- apply for any positions at AVELLUM;
- subscribe for our newsletter; or
- register and/or attend our events, including those published on the Website (the “Events”),
(together the “Services”).
Sometimes, our Website may contain links to third-party websites and services. Those websites and services have their own policies how they handle your Personal Data. If you follow a link to any third-party website or services, you should read the relevant policies shown on their website or services.
Data controller
AVELLUM is a data controller in relation to your Personal Data, meaning that we determine the purposes and means of how we process the Personal Data.
If you have any questions about this Notice, including any requests as to how you can exercise your rights, please contact us using the following contact details:
AVELLUM LLC
32/2 Kniaziv Ostrozkykh St., BC Senator, 12th floor, 01010, Kyiv, Ukraine
Email: info@avellum.com
Phone: +380 (44) 591 33 55
Personal Data we collect
Below, we have grouped together the following categories of Personal Data to explain how we use this type of information. These terms are used throughout this Notice:
| Identity Data: | your full name; your email; and your phone number. |
| Professional Information: | your job title and other professional information provided to us; your email; and your phone number. |
| Contact Data: | your full name; your email; and your phone number. |
| Marketing and Communications Data: | information regarding marketing communications you receive from us; information on the Events you attend; and marketing and communication preferences. |
When you visit our Website, we may automatically collect cookies. We made available Cookie Notice that describes the cookies and other web technologies used on the Website and provides information on how users can accept or reject them. To view the Notice, please follow this link.
How and why do we use Personal Data?
| Activity and purpose | Type of data | Legal basis |
| Use of AVELLUM Website: To manage and protect our Website (improving data security, troubleshooting data and systems, system maintenance and testing, data hosting and reporting);To deliver the relevant Website content to you;To measure or understand the effectiveness of the content we serve to you; andTo use data analytics to improve our Website, our services, marketing, customer relationships and experiences. | Identity DataContact Data Cookies | Your consent;Our legitimate interests, including by ensuring the Website’s efficient and secure operation, providing relevant content and identifying opportunities to expand our business and reviewing how clients use and perceive our Website, improving our Website, and identifying; andLegal obligation (in exceptional cases). |
| Contact us through the Website or otherwise To provide our legal services you request;To comply with our internal Know Your Customer (KYC) or other similar procedures;To conduct our internal procedures, including record keeping, accounting and billing;To deliver information you request; andTo otherwise process your Personal Data in connection with any of the following purposes. | Contact Data | Your consent;Our legitimate interests, including by providing relevant content and identifying opportunities to expand our business, ensuring that you receive the best client and visitor services we can provide and ensuring that we (and all other parties involved) are aware of any conflict of interest that may arise in a matter; andLegal obligation. |
| Apply for any positions at AVELLUM To contact you about the vacant position you are applying for or any similar position we may have from time to time;To conduct our internal HR procedures, including record keeping; andTo otherwise process your Personal Data in connection with any of the following purposes. | Identity DataContact Data | Your consent;Our legitimate interests of recruiting highly skilled employees and maintain a network of potential candidates;To the extent applicable, the entry into an employment or other similar agreement with you; andLegal obligation. |
| Newsletter emails: To deliver the relevant content to you; andTo send you news, materials, and press releases. | Identity DataContact Data | Your consent; andOur legitimate interests, including by ensuring that you receive the best client and visitor services we can provide. |
| Registration and/or attendance our Events: To promote and deliver our Events (both online and offline), host these Events and manage your registration and participation in them; andTo ask you for feedback about our Events and to manage, review and act on the feedback we are getting. | Identity DataContact Data | Your consent; andOur legitimate interests of ensuring that you receive the best client and visitor services we can provide and providing the relevant content and identifying opportunities to expand our business. |
We will only use your Personal Data for the purposes, for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
If you wish to receive an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info@avellum.com.
How do we disclose Personal Data?
We may share your Personal Data with the entities, companies and individuals set out below for the purposes for which we collected the Personal Data, as detailed in the section “How and why do we use Personal Data?”.
According to our professional obligations and any terms of business which we may enter into with you, if required, we will disclose your personal data to:
- any person who requires or requires us to make such disclosure by any court of competent jurisdiction or by any governmental, tax or other regulatory authority, law enforcement agency or similar authority;
- our professional advisers, who provide us with consulting, banking or other services; and
- service providers who provide us with information technology and systems management services.
We require any person, to whom we disclose the Personal Data, to respect the confidentiality and security of your Personal Data and to treat it in line with the requirements under applicable laws and regulations. We do not allow such recipients of your Personal Data to use it for their purposes, and we only permit them to process your Personal Data for specified purposes and subject to our instructions.
In certain cases, we may transfer your Personal Data outside the territory of Ukraine. In doing so, we will comply with the terms of this Notice and all applicable laws.
How long do we store Personal Data?
We will only use your Personal Data as long as necessary to fulfil the purposes for which it was collected and processed.
To determine an appropriate retention period, we consider the volume, nature, and sensitivity of the Personal Data we collect, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process the Personal Data and whether we can otherwise achieve those purposes and applicable legal and regulatory requirements.
After the applicable retention period expires, we will securely destroy, to the fullest extent possible, the Personal Data collected. Still, in certain cases, AVELLUM may retain copies of certain information, including the Personal Data, necessary to protect our legitimate interests or those of third parties, comply with official orders, resolve disputes, rectify problems, or enforce agreements you have entered into.
Technical and organisational measures
We provide different measures to protect the Personal Data we collect. In particular, we:
- maintain records of our employees having access to the Personal Data and define such employees’ level of access to the Personal Data; and
- obtain a written obligation of each of the above employees not to disclose the Personal Data.
Your rights
You have all rights afforded under Law of Ukraine “On Protection of Personal Data” No. 2297-VI, namely to:
- receive the information on the Personal Data location, the purpose of its processing, the location or residency of a data controller or a data processor;
- receive the information on the conditions upon which third parties may be granted access to the Personal Data as well as information about such third parties;
- access your Personal Data;
- submit an objection to the processing of the Personal Data;
- submit a request to change or destroy the Personal Data if the Personal Data is processed illegally or is inaccurate;
- the protection of the Personal Data from unlawful processing or unintentional loss, destruction or damage;
- make reservations to the restrictions on processing of the Personal Data;
- revoke consent to processing of the Personal Data; and
- protection from automated decisions which entail legal implications.
If you do not want to receive any offered marketing communications, newsletter and related services, please use the button “unsubscribe” or contact us. In order to exercise any other rights in relation to the Personal Data, please contact us using the details contained in this Notice.
Please note
Even after you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by law, in exercising and defending our legal rights or meeting our legal obligations.
