Privacy Policy

A legal disclaimer

1. Who we are

Avolve provides Amazon agency services to businesses.

Avolve is the trading name of [full legal company name or sole trader’s full name]. In this policy, “Avolve”, “we”, “us” and “our” refer to that business.

We are the controller of personal information collected for the website, enquiries and business relationship activities described in this policy. This means we decide why and how that information is used.

Our contact details are:

• Email: Kyle@avolve.uk

• Website: avolve.uk

• Data protection officer: Kyle Daniel

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2. Personal information we collect

Depending on your relationship with us, we collect:

• Contact information: your name, business email address, telephone number, job title and business address.

• Enquiry information: information you provide through forms, emails, meetings or other communications, including your business needs and service enquiries.

• Client and supplier information: contact details, correspondence, contracts, invoices and payment records needed to manage our business relationship.

• Technical information: your IP address, browser and device information, and website security logs.

• Website usage information: pages visited and interactions with our website, where collected through the tools described in our cookie information.

• Marketing preferences: your consent records, communication preferences and requests to stop receiving marketing.

Please avoid sending sensitive personal information unless we have specifically explained why it is needed and how we will handle it.

 

3. Where information comes from

We collect information directly from you when you contact us, request a proposal, use our services or interact with our website.

We may also receive your business contact details from your employer or another person arranging services on your behalf.

Technical and usage information is collected through our website and its service providers, subject to your cookie choices where applicable.

 

4. Why we use your information

We use personal information under the UK General Data Protection Regulation and the Data Protection Act 2018, as amended.

PurposeLawful basis

Responding to enquiries and preparing proposalsTaking steps at your request before entering a contract with you; otherwise our legitimate interest in responding to business enquiries.

Providing services where you personally are our client, including as a sole traderPerforming our contract with you.

Communicating with employees and representatives of client or supplier businessesOur legitimate interest in delivering services and managing business relationships.

Managing invoices, payments and accounting recordsPerforming a contract with you where applicable; our legitimate interest in business administration; and legal obligations for required tax and accounting records.

Protecting our website, systems and business against misuse or fraudOur legitimate interest in maintaining security and preventing fraud.

Sending marketing communicationsConsent, or our legitimate interest in promoting relevant services where the law permits marketing without consent, as explained below.

Using optional website analytics or advertising technologiesConsent.

Handling complaints, legal claims and data protection requestsApplicable legal obligations and, where relevant, our legitimate interest in resolving disputes and protecting legal rights.

Where we rely on legitimate interests, we consider whether the processing is necessary and whether your rights and interests outweigh those interests.

If information is necessary to arrange or provide services, we will make this clear when requesting it. Without that information, we may be unable to respond fully, enter into a contract or deliver the relevant service.

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5. Marketing

We may send information about Avolve’s services where permitted by law.

For individuals, sole traders and certain partnerships, we obtain consent for email or text marketing unless the existing-customer exception applies. We only use that exception for our own similar services where we obtained your details during a sale or negotiations and offered an opt-out both when collecting them and in each message.

For contacts at limited companies and other corporate subscribers, we may rely on our legitimate interest in promoting services relevant to their business role.

You can stop marketing at any time using the unsubscribe option in our messages or by emailing Kyle@avolve.uk. You have an absolute right to object to the use of your personal information for direct marketing.

We retain a limited record of opt-outs so that we can respect your preferences.

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6. Cookies and similar technologies

Our website uses cookies and similar technologies as described in our cookie information.

Strictly necessary technologies support essential website functions. Where we use optional analytics, advertising or tracking technologies, we ask for consent before activating them.

You can accept or reject optional technologies.

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7. Who we share information with

We share personal information where necessary with the following categories of recipients:

• Website hosting, maintenance and security providers.

• Email, cloud storage and business software providers.

• Customer relationship management, appointment booking and communication providers.

• Accounting and payment service providers.

• Contractors supporting delivery of our services.

• Analytics and advertising providers, subject to the choices described above.

• Accountants, legal advisers, insurers and other professional advisers.

• Regulators, courts or public authorities where disclosure is legally required.

Providers acting as our processors handle information under appropriate contracts and our instructions. Some recipients, such as professional advisers or payment providers, may act as independent controllers for their own purposes.

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8. International transfers

Personal information is stored in, or accessed from, the UK]

For transfers outside the UK, we rely on the UK International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses.

Where required, we assess the protection provided by the transfer arrangements and apply additional safeguards.

You can contact Kyle@avolve.uk for further information or a copy of relevant safeguards, subject to necessary redactions.

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9. How long we keep information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including applicable legal, accounting and recordkeeping requirements.

Our usual retention periods are set out below. We delete information earlier where it is no longer needed and there is no legal requirement or other valid reason to retain it.

Type of informationUsual retention period

Enquiries and proposals that do not result in a client relationshipUp to 12 months after our last meaningful contact, to handle follow-up enquiries and proposals. Separately authorised marketing records follow the period below.

Client and supplier contracts, key correspondence and records needed to establish the services providedFor the relationship’s duration and up to 6 years after it ends, where needed to deal with contractual questions or legal claims. This does not mean we retain every working file or all customer data for six years.

Invoices, payment records and accounting information6 years from the end of the financial year to which they relate, or longer where tax or accounting law requires it.

Routine website security and server logsUp to 90 days after collection. Relevant extracts may be retained longer where needed to investigate a specific incident or deal with a legal claim.

Personal information held in website analytics tools, where usedUp to 14 months after collection, to understand website performance and usage over time.

Contact details used for direct marketing until you unsubscribe, withdraw consent or object, or after 24 months without meaningful engagement, whichever happens first. Meaningful engagement includes an enquiry, purchase, reply or renewed subscription; merely sending you a message does not restart this period.

Evidence of marketing consent and relevant permission recordsWhile we rely on the permission and for up to 3 years after we last rely on it, where needed to demonstrate compliance or resolve a complaint. These records are not used to continue marketing after an opt-out.

Complaints and data protection rights requestsUp to 3 years after final resolution, to record our response and demonstrate how we handled the matter.

Marketing suppression recordsWe retain only the minimum information needed to honour your opt-out for as long as we conduct marketing that could otherwise result in you being contacted again. We review whether these records remain necessary at least annually.

Information processed on behalf of clients

Personal information that we handle solely on a client’s behalf, including customer information accessed through Amazon accounts, follows the client’s documented instructions and the agreed data processing terms. It is returned or deleted when no longer required for the service, in accordance with those terms and any applicable legal or Amazon requirements.

The six-year period for our own contracts and accounting records does not automatically apply to this information.

Longer retention and deletion

If particular information is needed for an ongoing dispute, investigation or legal obligation, we retain only the relevant information for the period necessary and review that need regularly.

When information is no longer required, we securely delete it or anonymise it so that individuals can no longer be identified. Backup copies are protected from ordinary use and removed through the applicable backup deletion cycle.

Cookie lifetimes are explained separately in our cookie information and may differ from the retention periods for information collected through those cookies.

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10. Information handled for our clients

When delivering Amazon agency services, we may handle personal information on a client’s behalf, such as customer information accessible through an account we manage.

Where we act as a processor, we handle that information under the client’s documented instructions and our data processing agreement. The client’s privacy notice explains its purposes and lawful bases.

If your request concerns information we handle solely for a client, we will help direct it to the appropriate controller and assist that controller as required.

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11. Security

We use appropriate technical and organisational measures to protect personal information against unauthorised access, loss, alteration or disclosure. Access is limited to people who need it for their work.

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12. Your rights

Depending on the circumstances, you may have the right to:

• Obtain a copy of your personal information.

• Have inaccurate or incomplete information corrected.

• Request deletion of your information.

• Restrict how we use your information.

• Receive certain information in a portable format.

• Object to processing based on legitimate interests.

• Object to direct marketing at any time.

• Withdraw consent where processing relies on it.

Withdrawing consent does not affect the lawfulness of processing before withdrawal.

To exercise your rights, email Kyle@avolve.uk or write to the address in section 1.

We normally respond within one month and do not charge a fee. We may need to verify your identity. If a lawful extension or exception applies, we will explain it.

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13. Complaints

If you have concerns about our use of your personal information, please contact Kyle Daniel at Kyle@avolve.uk, or write to the postal address in section 1.

We will acknowledge your complaint within 30 days, investigate appropriately, keep you informed and communicate the outcome without undue delay.

You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator. Information about raising a complaint is available at ico.org.uk/make-a-complaint.

14. Changes to this policy

We review this policy and update it when our practices or legal requirements change.

The latest version will appear on our website with its revision date. Where required, we will notify you of material changes before using your information for a new purpose.