Privacy Policy

Last updated 8th January 2024


1.  Introduction

Aveni Ltd. (“Aveni” referred to as “We, “Our” or “Us”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, (“Our Site”) and/or uses Aveni Detect, and Aveni Assist (“Our Services”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under data protection legislation.

Data protection legislation means the UK GDPR and other applicable laws including (but not limited to) the EU GDPR 2016 and the Privacy Electronic Communication Regulation (“PECR”) 2011. This also includes any replacement legislation which may come into effect from time to time.

Aveni is both a data controller and a data processor and this notice sets out how we act as both roles. Where we have an agreement in place with a customer who is asking you to use our Services (for example your employer), we obtain and process your Personal Information on behalf of and at the instructions of that customer. In that context, such customers are the data controllers and their privacy policies will apply to the processing of your Information and Information of others which you provide. We encourage you to read and uphold their privacy policies. You can see an example of the Data Processing Agreement we put in place with our customers here

Please do not use or access the Services or Website if you do not agree to this privacy policy. 

As we are based and headquartered in the United Kingdom (UK), we are registered with the Information Commissioners Office (the ICO) with registration number ZA925667.

You contact our head office using the following details:



58 Morrison Street

Edinburgh, Scotland



Phone: +44 (0)3330 165 242

We have also appointed an external data protection officer (DPO) and their details are as follows:

Evalian Limited

West Lodge

Leylands Business Park

Colden Common


SO21 1TH

United Kingdom


Phone: +44 (0)333 050 0111



2. Lawful Basis for Data Processing

Data protection legislation requires Aveni to identify an appropriate lawful bases to process personal data. The lawful basis we rely on as a data controller are detailed below with brief examples for when they may apply:


For opting into marketing communications, newsletters, competitions etc

Contractual Obligation

To take steps into entering and concluding contracts of employment

Legal Obligation

Where needed for tax reasons such as HMRC purposes

Legitimate Interests

To help answer any questions or concerns that may be sent to us from individuals who we may have no prior existing relationship with

There may be instances of where we may need to process certain categories of data referred to as Special Category Personal Data. These may include personal data related to health, race and ethnicity as examples, but where identified and needed, we will ensure the relevant special conditions are applied and documented where needed.

As a data processor we process personal data in line with the lawful basis determined by the data controller. For the purposes of our software platform and AI services, this would be legitimate interests.

3. Personal Data Collected

Due to the nature of our business and data processing activities we would collect and process various categories of personal data from various data subjects. Examples of data subjects whose data we process as a data controller can include job applicants, employees, visitors/guests to our premises and those who send us enquiries through our website.

As a data controller we would normally collect the following categories of personal data:

  • Names
  • Job details (company and job function)
  • Contact information
  • Recruitment data (CVs and cover letters)
  • Technical data (e.g. IP Addresses)

The above list is representative and non-exhaustive.

As a data processor, we may process and store the following categories of personal data, which can include (but is not limited to):

  • Audio call recordings
  • Meta data of call recordings
  • Quality reviews

We collect personal data through several means. Examples can include:

  • When you complete an online form on our website
  • Contact by phone, email or other communications (e.g. LinkedIn)
  • Applying to any of recruitment vacancies
  • When you use any of our services
  • From third-party sources, professional contacts or third parties who send us your details as prospective clients, candidates, associates or business partners

The above list is representative and non-exhaustive.


4. How We Use Personal Data

We may use personal data for various activities which can include the following activities:

  • To contract with you as a new client or supplier
  • To provide services to you and carry out your instructions in connection with our services
  • To manage queries relating to services we have provided to you historically
  • To manage our relationship with you as a client, supplier or professional contact
  • To process job applications
  • Action any data subject right requests
  • Communicate with relevant data controllers any communications received from a data subject including (but not limited to) data subject right requests
  • Process an order for a product or other service
  • Seek your views or comments on the services we provide
  • Notify you of changes to our services
  • Handle an enquiry or complaint you have made
  • Sending marketing communications and other company updates

The above list is non-exhaustive and representative. For more information to how we use personal data for specific activities you can contact us as detailed above.


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