GENERAL

Thank you for visiting the Avanade website (“the website” or “site”). This online privacy policy explains how Avanade, Inc. (“Avanade”; “we”) protects your personal data, what your rights are in relation to your personal data, and how we will collect and use information from our website so that you can make informed decisions about using this site. You will also find additional information on this page about how website data, marketing data and personal data are processed by Avanade.

This section (“General”) provides an overview of how Avanade protects the privacy of users and visitors to the site. Following the General section we have provided additional, more specific detail around how the Avanade website is used to collect data. If you have any questions concerning data privacy, please see our contact information at, "Contact Us", below.

Avanade’s data privacy practices

This section summarises Avanade’s data privacy policies.

• Information We Collect
• Use of Personal Data
• Purposes of Processing Personal Data
• Information Sharing
• Sensitive Personal Data
• Protecting your personal data
• Your safe use of our Site
• Processing of Personal Data
• Retention of Personal Data
• Your Rights
• Privacy Questions and Concerns

Data We Collect

We collect personal data of our workers, job candidates, suppliers, business contacts, shareholders and website users. We will always try to give individuals appropriate notice of what data will be collected and how it will be used. Whatever happens, we will only process that data if we consider it fair and lawful to do so. Except for certain information that we are required to collect by law, your decision to provide any personal data to us is voluntary. However, please note that if you do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this privacy statement. The data we collect may include information about you or your experiences with Avanade. For example, name and contact information; relationship with Avanade; and device data.

The personal data we process has been obtained from you or from certain third parties. Such third parties may include our affiliates, public authorities, public websites and social media, suppliers and vendors.

If you provide us with personal data of another person (for instance, a potential employee/referral), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with Avanade.

The above-mentioned categories of personal data have been obtained either directly from you (for example, when you provide information to sign up for a newsletter or register to comment on a forum website) or indirectly from certain third parties (for example, through our website’s technology). These third parties may include our affiliates, public authorities, public websites and social media, suppliers and vendors.

Use and Purposes of Processing Personal Data

Avanade uses your personal data only where required for specific purposes. Below is a list of the purposes for which Avanade uses your personal data and an overview of the legal basis for each purpose.

Purpose	Legal Basis
Managing our contractual and/or employment relationship with you.	Necessary for the performance of a contract to which you are a party.
Recruitment.	Justified on the basis of our legitimate interests for ensuring that we recruit the appropriate employees.
Facilitating communication with you (including in case of emergencies, and to provide you with requested information).	Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organisation.
Operating and managing our business operations.	Justified on the basis of our legitimate interests for ensuring the proper functioning of our business operations.
Complying with legal requirements.	Necessary for the compliance with a legal obligation to which we are subject.
Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use).	Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Improving the security and functioning of our website, networks and information.	Justified on the basis of our legitimate interests for ensuring that you receive an excellent user experience and our networks and information are secure.
Undertaking data analytics, i.e. applying analytics to business operations and data to describe, predict and improve business performance within Avanade and/or to provide a better user experience. More details on how we run analytics on our website can be found in our cookies policy.	Justified on the basis of our legitimate interests, such as conducting and increasing our business.
Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing?” below).	Justified on the basis of our legitimate interests, such as conducting and increasing our business.

Where the above table states that we rely on our legitimate interests for a given purpose, we believe that our legitimate interests are not overridden by your interests, rights or freedoms, given (i) the transparency we provide on the processing activity, (ii) our privacy by design approach, (iii) our regular privacy reviews and (iv) the rights you have in relation to the processing activity. Please contact us if you wish to obtain further information on this balancing test approach.

We will process your personal data for the purposes mentioned above based on your prior consent, to the extent such consent is mandatory under applicable laws.

We will not use your personal data for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorised by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Information Sharing

We may transfer personal data to our service providers, professional advisors, public and governmental authorities or third parties in connection with a (potential) corporate or commercial transaction. Such outside parties may be located in other countries. Before we do so, we take steps to ensure that your personal data will be given adequate protection as required by relevant data protection laws and Avanade’s internal policies. If you are located in the European Union (“E.U.”) or European Economic Area (“EEA”), unless you are otherwise notified, any transfer of your personal data to third parties outside the EEA or EU will be based on an adequacy decision or are governed by the standard contractual clauses. Any other non-EEA related transfers of your personal data, will take place in accordance with the appropriate international data transfer mechanisms and standards.

Sensitive Personal Data

We do not generally seek to collect sensitive personal data (also known as special categories) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with local data privacy law requirements. If you choose to provide us with unsolicited sensitive personal data, you consent to our using the data, subject to applicable law as described in this privacy policy.

The term "sensitive personal data" refers to the various categories of personal data identified by European and other data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent. These categories may include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).

Protecting your personal data

Avanade protects your personal data in accordance with applicable laws and through its contractual commitments and privacy policies and procedures. Avanade has a global data privacy and data security policy which sets out the safeguards that apply across Avanade regardless of where we process your data. Avanade also has data privacy procedures describing how we should handle access requests or inquiries. Together, these ensure that appropriate data privacy safeguards are in place across our organisation.

Your safe use of our Site

We take appropriate steps to maintain the security of personal data collected. Regarding your use of our websites, you should understand that the open nature of the Internet is such that information and personal data may flow over networks connecting you to our systems without security measures, and your data may be accessed and used by people other than those for whom the data is intended.

From time to time, our site may contain links to and from the sites of our partner networks, advertisers and affiliates. If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies or sites. Please check these policies before you submit any personal data to these sites.

Processing of your Personal Data

As a global organisation with distributed IT systems, personal data we collect may be routed, stored, or transferred internationally throughout Avanade's worldwide organisation in accordance with our privacy policies and procedures, and in accordance with data privacy laws.

Retention of your Personal Data

We will retain your personal data only for as long as is necessary. Criteria we use to determine the retention periods include:

• Retention of your data for as long as we have an ongoing or legitimate interest relationship with you.
• Retention of your data for as long as needed for us to comply with our global legal and contractual obligations.

Your rights concerning your personal data

Please contact AvanadeDPO@avanade.com if you have any questions or concerns about how Avanade processes your personal data.

If you want to exercise any of your rights in relation to your personal data please contact SubjectAccessRequest@avanade.com.

You have the right (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law to:

• Request access to the personal data Avanade processes about you: this right entitles you to know whether Avanade holds personal data of you and, if so, obtain information on and a copy of those personal data.
• Request rectification of your personal data: this right entitles you to have your personal data be corrected if it is inaccurate or incomplete.
• Object to the processing of your personal data: this right entitles you to request that Avanade no longer processes your personal data.
• Request the erasure of your personal data: this right entitles you to request the erasure of your personal data, including where such personal data would no longer be necessary to achieve the purposes.
• Request the restriction of the processing of your personal data: this right entitles you to request that Avanade only processes your personal data in limited circumstances, including with your consent.
• Request portability of your personal data: this right entitles you to receive a copy (in a structured, commonly used and machine-readable format) of personal data that you have provided to Avanade, or request Avanade to transmit such personal data to another data controller.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by contacting SubjectAccessRequest@avanade.com.

Please note that this will not affect Avanade’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent. Please note, however, that certain personal data may be exempt from the above-mentioned rights pursuant to applicable data privacy or other laws and regulations.

If, despite Avanade’s commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, Avanade encourages and welcomes you to come to Avanade first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against Avanade with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).

Questions and Concerns

You can find additional information about how we process your personal data in relation to websites, cookies, marketing and personnel below.

If you can’t find what you’re looking for in this statement, or have a concern about our use of your personal data, you may contact our Data Protection Officer (DPO) via e-mail at: AvanadeDPO@avanade.com.