1. How does Avanade protect your personal information?

Avanade attaches great importance to your right to privacy and the protection of your personal information. We want you to feel secure that when you deal with Avanade, your personal information is in good hands.

Avanade protects your personal information in accordance with applicable laws and our data privacy policies. In addition, Avanade maintains the appropriate technical and organizational measures to protect your personal information against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure or access, or accidental or unlawful destruction of or damage thereto.

The following sections provide further details as to how Avanade processes your personal information:

Which categories of personal information do we collect and how do we process such personal information?
For which purposes and on which legal basis do we use your personal information?
Will we share your personal information with third parties?
What about sensitive data?
What about data security?
Where will your personal information be processed?
How long will your personal information be retained by us?
Which rights do you have with respect to the processing of your personal information?

Which categories of personal information do we collect and how do we process such personal information?
We collect personal information of our employees, potential employees, clients and their current/former/prospective employees/directors, suppliers, business contacts, shareholders and website users. If the information we collect is not listed in this privacy statement, we will give individuals (when required by law) appropriate notice of which other information will be collected and how it will be used.

Specifically, the personal information we collect includes the categories of personal information described in the sections “How do we use personal information when you visit Avanade’s website?”,"How do we use cookies (and other tracking technologies)?", “How do we use personal information when you visit our offices?” and “How do we use personal information for marketing purposes?” and How do we use personal data when using AI supported capabilities in our communications?”, as well as any other categories of personal data referred to in this privacy statement or in other statements you have received.

The below table provides an overview of the categories of personal information that Avanade processes or may process in the context of the processing activities described in this privacy statement.

Category of personal information	Types of personal information captured by category
Personal details, contact details, and identifiers.	Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address) and occasionally, when necessary for specific purposes, gender, date of birth, age, place of birth.
Commercial information.	History and records of the products and services you have obtained from Avanade. Correspondence between you and us when it is sent to a dedicated mailbox or via other electronic communication means (including communication channels supported by AI that – for example – generates content to assist our personnel when interacting with you), for the purpose of processing account receivable payments and commercial follow-up.
Marketing and research information	1. Identifiers – the IP address, social media handle or other online identifiers of a person, e-mail address/mobile number if used for direct marketing, and name and address 2. Demographic data - (e.g. income, family status, age bracket, gender, interests, pets, home ownership, health, current service providers) 3. Browser/web history data and preferences expressed through selection/viewing/purchase of goods, services and content, information about your mobile device including (where available) type of device, device identification number, mobile operating system. 4. Social media content – blogs, posts and anything posted by an individual online or which mentioned/references an individual 5. Analytics and profiles of the individuals based on the data collected on them. 6. Voice-enabled services (Speech-to-Text engines for search requests) without being recorded or stored by the mobile device.
Sensitive data and biometric information.	Avanade may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status/access requirements and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication.
Audiovisual materials, including transcriptions.	Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security/monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions), voice search functionality to enable a voice command feature that allows you to ask a question and see results (functionality enabled for mobile applications only), and/or audio video recording and transcription during meetings.
Position and professional or employment-related information.	Professional or employment-related information, such as description of current position, job title, employer, location, and Avanade contact(s).
System and application access data and Internet and electronic network activity information.	Where you are provided with access to Avanade’s systems, Avanade may collect information required to access such Avanade systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using Avanade systems.
Cookies and geolocation data	As described below, we also may collect geolocation data in some circumstances. Please see our Cookies policy for more details regarding our use of cookies.
Avanade alumni related information	Information you provide us when you register as an Avanade alumnus/alumna or update your profile including your name and email address. If you were previously a user of another Avanade alumni website, additional data that you provided to that site may be automatically added to your profile at the Alumni Site. In addition, your user profile offers you the opportunity to provide a wide range of additional data, including postal address, current occupation, industry, education, and personal and business interests. Correspondence between you and us in relation to the Alumni Site. Data you post on the Alumni Site, such as on the chat pages. Responses to online surveys that we use for research and quality control purposes. Details on (former) compensation and payroll. Details on (former) position. Birth year when necessary for specific purposes Personal information we already have in our Avanade systems such as (former) Enterprise ID, (former) office location, telephone number, home address and education or training – this to verify your identity when registering on our Alumni Site.

In addition, for recruitment/employment purposes and to provide assessment and HR consultancy services to our clients, Avanade may process the personal information set out in the below table.

Additional personal details, contact details and identifiers/demographics.	In addition to the personal details listed above, Avanade may collect additional personal details for recruitment/employment purposes, such as national identification number, social security number, insurance information, marital/civil partnership status, domestic partners, dependents, emergency contact information, and military history; professional/personal calendar availability/scheduling information for meeting/communication purposes.
Education information and professional or employment-related information.	Avanade may collect information about your education and professional or employment-related information, such as your employment history.
Sensitive data for recruitment purposes or for providing assessment/HR consultancy services.	Avanade may collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status), trade union membership information, religion, race or ethnicity, minority flag, and information on criminal convictions and offences. Avanade collects this information for specific purposes, such as health/medical information in order to accommodate a disability or illness (subject to legal limits on the timing of collection of such information and other applicable limitations) and to provide benefits; background checks and diversity-related personal information (such as race or ethnicity) in order to comply with legal obligations and internal policies relating to diversity and anti-discrimination.
Documentation required under immigration laws.	Avanade may collect data on citizenship, passport data, and details of residency or work permit (a physical copy and/or an electronic copy).
Financial information for payroll/benefits purposes	Your banking and other relevant financial details we need for payroll/benefits purposes.
Talent management information.	Information necessary to complete a background check, details on performance decisions and outcomes, performance feedback and warnings, e-learning/training programs, performance and development reviews (including information you provide when asking for/providing feedback, creating priorities, updating your input in relevant tools), driver’s license and car ownership information, and information used to populate biographies.
Requested recruitment information	Information requested to provide during the recruitment process, to the extent allowed by applicable law.
Recruitment information you submit	Information that you submit in résumés / CVs, letters, writing samples, or other written materials (including photographs).
Information generated by us during recruitment or during assessments	Information generated by interviewers and recruiters related to you, based on their interactions with you or basic Internet searches where allowed under applicable law.
Recruitment information received from third parties	Information related to you provided by third-party placement firms, recruiters, or job-search websites, clients where applicable.
Audiovisual and transcript information processed during recruitment	Photograph, and images/audio/footage captured on CCTV or other video systems when visiting our office or captured in the course of recruitment events, audio video recording and/or transcript during interviews and assessments.
Recommendations	Recommendations related information provided on your behalf by others.
Immigration	Documentation and related information required under immigration laws.
Employment history and background checks	Information about your prior employment, education, and where applicable and allowed by applicable law, credit history, criminal records or other information revealed during background screenings.
Diversity related information	Information about race, ethnicity, religion, disability, gender (legal and identity) and/or sexual orientation, for purposes of government reporting where required by law, as well as to understand the diversity characteristics of the candidate pool and workforce, subject to legal limits and consent where applicable.
Assessment information	Information generated by your participation in psychological, technical or behavioral assessments. You will receive more information about the nature of such assessments before your participation in any of them.

We also may derive inferences about you based on the information described above and also collect other information about you as described in this privacy statement. If you provide us with personal information 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). Such third parties include our affiliates, public authorities, public websites and social media, suppliers, clients, vendors (including third party data providers) and target entities or assets (in the framework of mergers and acquisitions). Except where certain information is required by law or by Avanade policies (including management of an employment relationship with Avanade), your decision to provide any personal data to us is voluntary. 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, and you may not be able to use certain tools and systems which require the use of such personal data.

For which purposes and on which legal basis do we use your personal information?

Avanade uses your personal information only where required for specific purposes. Please view the table below for (i) a list of the business purposes for which Avanade uses your personal information and (ii) an overview of the legal basis for each such business purpose.

Purpose	Legal basis
Managing our contractual and/or employment relationship with you.	Necessary for 1) the performance of a contract or similar arrangement to which you are a party or 2) managing your employment relationship with Avanade.
Facilitating communication with you, which may include AI-powered support capabilities (involving facilitating meetings, meeting recaps and insights, email suggested content, communication in case of emergencies, and to provide you with requested information). Find further details at “ 6. How do we use personal data when using AI in our communications?”.	Justified on the basis of our legitimate interests for ensuring proper communication and emergency handling within the organization.
Operating and managing our business operations including or being part of the provision of our services to our clients and their employees/contractors and their customers, for example in collecting their data as part of surveys/assessments/psychometrics, data analytics, Marketing research or other purposes.	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 (involving monitoring the use of our website and any apps and tools you use), which may include AI powered support capabilities.	Justified on the basis of our legitimate interests of avoiding non-compliance and protecting our reputation.
Research in general and market research.	Justified on our legitimate interest to gain market insights and insights in business and society in general or, where required, the consent of the relevant subjects.
Social listening (Identifying and assessing what is being said about Avanade and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements or other interactions on social media channels.)	Justified on the basis of our legitimate interest of protecting our assets and our brand on social media
Ethnographic videography – this is video recording of the activity of individuals in their natural environment, in order to experience, interpret and understand behavior. This may be part of a campaign or project.	Justified on the consent of the relevant subjects.
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 , including the use of AI (e.g. machine learning). This includes marketing analytics and analytics related to the organization of events/meetings. (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 for ensuring the proper functioning of our business operations.
Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal information for marketing purposes?” below).	Justified on the basis of our legitimate interests for ensuring that we can conduct and increase our business.
Audio, video and transcription captured during live/recorded events and meetings (including virtual events/webinars) to inform interested stakeholders about the content of such events/meetings (including online publication of recordings for marketing purposes).	Based on your informed consent obtained prior to the event.
Specific Recruitment / Employment Purposes	Legal basis
Assess your suitability for employment for the role for which you are applying, as well as future roles that may become available.	Justified on the basis of Avanade’s legitimate interests of ensuring that it recruits the appropriate employees.
Manage your application.	Justified on the basis of Avanade’s legitimate interests of ensuring that it recruits the appropriate employees.
Facilitate communication with you.	Justified on the basis of Avanade’s legitimate interests of ensuring proper communication within the organization and with you.
Perform administrative functions (e.g. reimburse you for interview-related expenses).	Justified on the basis of Avanade’s legitimate interests of ensuring that it recruits the appropriate employees.
Perform data analytics, including analysis of our applicant pool in order to better understand who is applying to positions at Avanade and how to attract and keep top talent.	Justified on the basis of Avanade’s legitimate interests of ensuring that it continually improves its recruitment processes.
In some cases, take photos, record and/or transcribe your online interview and assessment (which may include AI-powered support capabilities) for review by additional recruiters and hiring managers.	Justified on the basis of Avanade’s legitimate interests of ensuring that it recruits the appropriate employees.
If you register on our Careers website, we will enter you into a database to receive future mailings about Avanade positions and events. You may also receive personalized job recommendations while browsing our Careers website.	Justified on the basis of Avanade’s legitimate interests of ensuring that it recruits the appropriate employees.
Transfer your contact information, education data, employment data, application information and the CV, all as supplied by you in our recruitment system, to the Avanade Applicant Tracking System —a site that we maintain to notify you about new positions that may be of interest to you.	Justified on the basis of Avanade’s legitimate interests of ensuring that it recruits the appropriate employees.
Administration of employee benefits	Justified on the basis of Avanade’s legitimate interests of ensuring that our employees receive the applicable benefits.
Perform any legally-required reporting and respond to legal process.	Compliance with a legal obligation.
Specific alumni information related purposes	Legal basis
To enable alumni to search for and locate you via the directory if you are registered as an Avanade alumnus/alumna.	Justified on the basis of our legitimate interests of offering users the possibility to use the Alumni Site to contact other alumni.
Provide users of the Alumni Site with a customized experience on the Alumni Site, including personalization services such as News and Events and interactive communications.	Justified on the basis of our legitimate interests of providing our users with a customized experience.
To research and analyze our alumni demographics, interests and behavior in an aggregated form.	Justified on the basis of our legitimate interests to better understand and serve our users and improve the Alumni Site and its offerings.
To contact alumni periodically with communications about events, publications or employment opportunities with Avanade, which we feel might interest you, unless you ask not to be contacted. You will have an opportunity to opt out of receiving further messages.	Justified on the basis of our legitimate interest for ensuring proper communication with, and sending marketing to, our alumni.
To share alumni information with other internal Avanade systems, specifically our internal sales tools, to contact you with industry relevant information.	Justified on the basis of our legitimate interest for ensuring proper communication with, and sending marketing to, our alumni.

Legitimate interest means that Avanade has reasonable grounds to process your personal information. Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion 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. If you wish to obtain further information on this balancing test approach, please contact Avanade’s Data Privacy Officer.

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.

To the extent you are asked to click on/check “I accept”, “I agree” or similar buttons /checkboxes /functionalities in relation to a privacy statement, doing so will be considered as providing your consent to process your personal data, only in the countries where such consent is required by mandatory law. In all other countries, such action will be considered as a mere acknowledgement and the legal basis of the processing of your personal data will not be your consent but any other applicable legal basis. 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 authorized by law, or it is in your own vital interest (e.g. in case of a medical emergency) to do so.

Where we maintain or use deidentified information, we will continue to maintain and use that information only in a deidentified form and will not attempt to reidentify the information.

Will we share your personal information with third parties and service providers?
We may transfer personal information to our service providers and professional advisors, public and governmental authorities, Accenture companies/affiliates or third parties in connection with Avanade’s operation of its business, including any (potential) corporate or commercial transaction and including clients if the data has been processed to provide client services. Such third parties may be located in other countries. Before we do so, we shall take the necessary steps to ensure that your personal information will be given adequate protection as required by relevant data privacy laws and Avanade’s internal policies. Avanade may transfer your personal information to any of its global affiliates/partners in furtherance of any visits to our Avanade locations. If you would like more information on the categories of personal information we may share please read the section titled “Which categories of personal information do we collect and how do we process such personal information?”

For example, we may disclose personal information to third parties for other business purposes as follows:

We share your information with third-party service providers that provide services to us, including billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing;
To protect and defend the legal rights, safety, and security of Avanade, our affiliates, users, or the public, including to protect against fraud and malicious activity; and
For other business purposes described in this privacy statement or for any other purpose disclosed to you at the time we collect the information or pursuant to your consent.

We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.

Unless you are otherwise notified, any transfers of your personal information from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses (a copy of which can be obtained through the contact information included below). Any other non-EEA related transfers of your personal information will take place in accordance with the appropriate international data transfer mechanisms and standards.

What about sensitive data?
We do not generally seek to collect sensitive data as defined in the second paragraph below (also known as special categories within the EEA) through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.

The term "sensitive data" refers to the various categories of personal information identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union, physical or mental health information, biometric or genetic data, sexual life or orientation, finances, geolocation, the contents of private communications, sensitive data related to a consumer’s government I.D. (i.e. social security number or driver’s license number), or criminal convictions and offences (including information about suspected criminal activities).

What about data security?
We maintain organizational, physical and technical security arrangements for all the personal information we hold. We have protocols, controls and relevant policies, procedures and guidance to maintain these arrangements taking into account the risks associated with the categories of personal information and the processing we undertake.

We adopt market leading security measures to protect your personal information. This includes (without being limitative):

We hold an ISO 27001 certification, which indicates that we adhere to strict information security standards. This is a security standard awarded by DEKRA that serves as international certification that Avanade adheres to the highest and strictest standards. This certification is the only auditable international standard that defines the requirements for an Information Security Management System (“ISMS”), and confirms that Avanade’s processes and security controls provide an effective framework for protecting our clients’ and our own information.
We have a global Client Data Protection (“CDP”) program in place which governs the stewardship of client information and systems entrusted to us.
We have regular penetration testing performed by a third-party provider, which continues to show the strength of our technical defenses.

Where will your personal data be processed?
As a global organization with offices and operations throughout the world, personal data we collect may be transferred or be accessible internationally throughout Avanade's global business and between its entities and affiliates.

Any such transfers throughout Avanade’s global business take place in accordance with the applicable data privacy laws and in accordance with our Binding Corporate Rules (“BCR”). Our BCR reflect the standards contained in European data privacy laws (including the General Data Protection Regulation). Having our BCR means that all our group entities which have signed up to our BCR have to comply with the same internal rules. It also means that your rights (see “Which rights do you have with respect to the processing of your personal information?”) stay the same no matter where your data are processed by Avanade.

Download a copy of Avanade's BCR.

What are the sources we get your personal information from?
If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (registers or the internet), Avanade employees, contractors, (prospective) members of board of directors, shareholders, Avanade’s affiliates, subsidiaries and newly acquired businesses, employers of our contractors, our clients, public authorities, public websites and social media, previous employers, educational institutions, suppliers, vendors (including third party data providers) and target entities or assets (in the framework of mergers and acquisitions).
In section 5, you can find more information on the sources of your personal information for marketing purposes.

How long will your personal information be retained by us?
We will retain your personal data only for as long as is necessary. We maintain specific records management and retention policies and procedures, so that personal data are deleted after a reasonable time according to the following retention criteria:

We retain your data as long as we have an ongoing relationship with you (in particular, if you have an account with us).
We will only keep the data while your account is active or for as long as needed to provide services to you.
We retain your data for as long as needed in order to comply with our global legal and contractual obligations.

Which rights do you have with respect to the processing of your personal information?

You may be entitled, where provided for under applicable law, to:

Request access to the personal information we process about you: this right entitles you to know whether we hold personal information about you and, if we do, to obtain information on and a copy of the specific pieces and categories of personal information.
Request a rectification of your personal information: this right entitles you to have your personal information corrected if it is inaccurate or incomplete.
Object to the processing of your personal information: this right entitles you to request that Avanade no longer processes your personal information.
Request the erasure or deletion of your personal information: this right entitles you to request the erasure or deletion of your personal information, including where such personal information would no longer be necessary to achieve the purposes.
Request the restriction of the processing of your personal information: this right entitles you to request that Avanade only processes your personal information in limited circumstances, including with your consent.
Request portability of your personal information: this right entitles you to receive a copy (in a portable and, if technically feasible, readily usable format) of your personal information, or request Avanade to transmit such personal information to another data controller.

California law provides California residents with the right to receive a privacy notice with information about what we have collected, disclosed for business purposes, and sold during the preceding 12 months. This Avanade Privacy Statement for California Residents provides information about the categories of information that we have collected, the sources of that information, the purposes for which we have used the information, and the categories of third parties to whom we have disclosed the information for business purposes.

California law also affords California residents a right to opt out of the “sale” of your personal information. This right is applicable to the extent that Avanade is engaging in a “sale” of your personal information as that term is defined under applicable law. While Avanade generally is not in the business of selling information, there are limited circumstances where we share personal information with our clients, third-party partners, or others that we treat as a sale for which California residents have the right to opt out. We do not sell the personal information of minors under 16 years of age without affirmative authorization.

If you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your personal information or otherwise permitted by law. Please click here to opt out of the “sale” of your personal information. If at any time you would like to opt back in and allow Avanade to sell your personal information, please click here.

To exercise any other rights available to you under California law, please contact us. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. Where necessary, this may include asking you for a copy of your valid government-issued identification, such as your valid passport or driver’s license (with the allowance of the redaction of your driver’s license number or social security number). If you would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf that we can confirm directly with the requestor. We reserve the right to deny requests from authorized agents in certain circumstances, such as where we have a reasonable belief that the request is fraudulent. For this reporting period, Avanade does not qualify for the CCPA 11 CCR § 999.317(g) reporting requirement.

Avanade may offer certain financial incentives for the collection, sale, or deletion of personal information. Where we would do so, we will provide California residents additional information where required by California law.

To the extent that the processing of your personal information is based on your consent, you have the right to withdraw such consent at any time by contacting Avanade’s Data Privacy Officer. Please note that this will not affect Avanade’s right to process personal information 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.

If, despite our commitment and efforts to protect your personal information, you believe that your data privacy rights have been violated, we encourage and welcome individuals 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/State where you live, the country where you work or the country where you deem that data privacy law has been infringed).

If you would like to exercise your erasure, rectification, or access rights in reference to your data as a job applicant, you may also click here. Any other rights can be exercised by contacting us.