A measured and transparent approach to personal data.

1. Scope

This Privacy Policy applies to personal data processed through this website, including information submitted through contact forms or other direct website interactions, communications initiated through the website and related website administration, security, performance and compliance activities.

It does not automatically apply to offline interactions, employment matters, vendor onboarding, contractual due diligence, investor materials, customer-specific services or any third-party website, platform or application that may be linked from this site unless a separate notice expressly states otherwise.

2. Who We Are

3. Personal Data We May Collect

Depending on the context, we may collect or receive the following categories of personal data:

• Identity and contact data, such as name, company name, title, email address, telephone number, country or other details voluntarily provided by you.
• Communication data, such as the contents of messages, enquiries, form submissions, attachments and related correspondence.
• Technical and device data, such as IP address, browser type, operating system, device identifiers, language settings, referral data and approximate technical diagnostics.
• Usage data, such as pages viewed, navigation paths, timestamps, interaction patterns and performance or error logs associated with website use.
• Security and anti-abuse data, such as signals used to protect the website, forms, infrastructure and users from spam, bot activity, fraud, malicious behaviour or misuse.
• Preference or consent data, where relevant, such as cookie preferences, communication preferences or records of consent or withdrawal.

4. How We Collect Personal Data

• Directly from you, when you complete a contact form, send an enquiry, request information, communicate with us or otherwise provide information voluntarily.
• Automatically, through website operations, server logs, security tools, cookies or similar technologies, subject to the settings and notices applicable on the website.
• From third parties, where appropriate, such as service providers, publicly available sources, business counterparties, professional advisers, analytics providers or security providers, provided that such collection is lawful and relevant.

5. Why We Process Personal Data

We may process personal data for one or more of the following purposes, as relevant to the interaction:

• to operate, administer, maintain and improve this website and related digital infrastructure;
• to respond to enquiries, business communications and requests submitted through the website or otherwise connected to it;
• to assess, manage and document potential business relationships, partnerships, projects or professional communications;
• to secure the website, forms, systems and users against spam, unauthorised access, malicious conduct, misuse or other harmful activity;
• to troubleshoot issues, monitor performance, maintain reliability and conduct internal analytics or reporting;
• to comply with legal, regulatory, contractual, governance or record-keeping obligations;
• to establish, exercise or defend legal rights and claims; and
• to support corporate transactions, reorganisations or business continuity processes where reasonably necessary.

6. Legal Bases for Processing

Where a legal basis is required under applicable law, we may rely on one or more of the following, depending on the context:

• legitimate interests, including website administration, security, business communications, corporate organisation, service improvement and the protection of our legal and commercial interests;
• steps prior to entering into a contract or performance of a contract, where your request or relationship requires it;
• legal obligation, where processing is necessary to comply with applicable law, regulation, governmental request or compliance requirements;
• consent, where required and obtained, including in relation to certain optional technologies or communications; and
• legal claims and rights protection, where recognised under applicable law.

A single processing activity may be supported by more than one legal basis. Where consent is used, it may generally be withdrawn prospectively, subject to the lawfulness of prior processing.

7. Cookies and Similar Technologies

Our website may use cookies, pixels, local storage, security tokens, server-side identifiers or similar technologies for functions including website operation, security, abuse prevention, user preference management, performance measurement and analytics.

Some technologies may be strictly necessary for the operation, stability or security of the website. Others may be optional and subject to applicable consent requirements or browser/device controls.

Where a separate cookie notice, preference mechanism or consent interface is made available on the website, that notice or interface should be read together with this Privacy Policy and may supplement it.

8. Disclosure of Personal Data

We may disclose personal data, where appropriate and lawful, to:

• hosting, infrastructure, security, anti-abuse, analytics, website management, communications or IT support providers;
• professional advisers, auditors, insurers, consultants or compliance support providers;
• affiliated entities within the Avingler organisational structure where reasonably necessary for internal administration, oversight or business continuity;
• regulators, public authorities, courts, law enforcement or other third parties where required or permitted by law; and
• actual or prospective purchasers, investors, lenders or transaction participants in connection with a merger, reorganisation, restructuring, asset transfer, financing or similar corporate event, subject to appropriate safeguards where required.

We do not disclose personal data more broadly than is reasonably necessary for the relevant purpose, legal requirement or legitimate organisational need.

9. International Data Transfers

Depending on the location of our operations, service providers, infrastructure or counterparties, personal data may be processed in jurisdictions other than the one in which it was originally collected.

Where applicable law imposes conditions on international transfers, we will seek to implement an appropriate transfer mechanism or safeguard, which may include adequacy decisions, contractual safeguards, internal arrangements or other lawful means recognised by the relevant legal framework.

10. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including for legitimate business administration, communications management, security, legal compliance, record keeping, dispute handling and the protection or exercise of rights.

Retention periods may vary depending on the type of data, the context of collection, whether an ongoing business relationship exists, the sensitivity of the information, the presence of legal or regulatory obligations and the operational need to preserve records or evidence.

When data is no longer required, we may delete, anonymise, aggregate or otherwise render it non-identifiable, subject to technical feasibility and applicable law.

11. Security

We use administrative, technical and organisational measures intended to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access or misuse.

However, no website, transmission method, storage environment or security control can guarantee absolute security. Accordingly, while we seek to apply appropriate safeguards, we do not warrant that personal data will always remain secure under all circumstances.

12. Your Rights and Choices

Depending on the laws that apply to you and to the relevant processing activity, you may have rights including:

• the right to request access to personal data;
• the right to request correction or updating of inaccurate or incomplete data;
• the right to request deletion or restriction of processing in certain circumstances;
• the right to object to certain processing, including certain processing based on legitimate interests;
• the right to request portability of certain data where available under law;
• the right to withdraw consent where processing relies on consent; and
• the right to lodge a complaint with a competent supervisory or regulatory authority where applicable.

These rights are not absolute and may be limited, declined or managed in accordance with applicable law. We may also request information necessary to verify your identity, authority and the scope of your request before taking action.

13. Marketing and Business Communications

If we send communications to you in a business or professional context, we will seek to do so in accordance with applicable law, the nature of the relationship and the communication preferences or choices available to you.

You may request that we discontinue non-essential communications by using the relevant opt-out mechanism, replying accordingly where appropriate or contacting us through the contact route identified in this Privacy Policy.

14. Third-Party Sites and Services

This website may contain links to third-party websites, platforms or resources. Those external destinations operate under their own terms, notices and privacy practices. We are not responsible for the privacy, security, availability, content or data handling practices of third-party sites or services that we do not control.

15. Children’s Privacy

This website is not directed to children and is intended for business, corporate or professional use. We do not knowingly seek to collect personal data from children through this website in circumstances where such collection would require a specific legal basis, authorisation or parental involvement under applicable law.

16. Changes to This Privacy Policy

We may amend, update or restate this Privacy Policy from time to time in order to reflect legal, regulatory, technical, operational or organisational changes. The revised version will become effective when posted, unless another date is stated.

Your continued use of the website after an update does not by itself waive any rights or create new contractual rights, but it may indicate awareness of the updated notice to the extent permitted by law.

17. Contact

For privacy-related questions, data rights requests or formal communications concerning this Privacy Policy, please use our designated contact route. We intentionally do not publish a plaintext email address on this page in order to reduce automated harvesting, abuse and spam against operational communication channels.

Please visit: /contact-us