Avenor Partners is operated by Varun Gupta and Aarav Jain as an unincorporated venture, based in Sweden. This Policy is written to align with the EU General Data Protection Regulation (GDPR) and should be reviewed once Avenor Partners becomes a registered business entity.
1. Who We Are
Avenor Partners ("Avenor," "we," "us") provides an eight-week educational training programme in M&A and Equity Research. This Privacy Policy explains what personal data we collect from participants and visitors, why we collect it, and how it is handled.
2. What Data We Collect
- Contact details you provide when enrolling or inquiring, such as your name, email address, and, if provided, phone number or LinkedIn profile.
- Enrolment and payment information, such as which cohort you joined and confirmation that payment was made. Payment processing itself is typically handled by a third-party provider, which has its own privacy policy.
- Programme work you submit, including your individual reports, group project contributions, and any worksheets you complete.
- Communications between you and Avenor, such as messages sent via email, WhatsApp, or LinkedIn regarding the Programme.
- Basic website usage data, if our website uses analytics tools. See Section 7.
3. Why We Collect It (Legal Basis)
We process your personal data on the following legal bases under GDPR:
- Performance of a contract: to enrol you in the Programme, deliver course materials, organise group projects, and issue your Certificate of Completion.
- Legitimate interests: to communicate with prospective and enrolled participants, improve the Programme, and, where appropriate, reference anonymised examples of student work for promotional purposes.
- Consent: where we ask separately for your permission, for example to name you and share your project publicly with attribution, or to add you to a mailing list for future cohorts.
- Legal obligation: where we are required to retain certain records, such as payment records, for tax or accounting purposes.
4. How We Use Your Data
- To deliver the Programme, including assigning you to a track and group project team.
- To communicate with you about your enrolment, Programme updates, and, with your consent, future cohorts or opportunities.
- To issue your Certificate of Completion.
- To improve the Programme based on aggregated, anonymised feedback and outcomes.
- To meet legal and accounting obligations.
5. Who We Share Data With
We do not sell your personal data. We may share limited data with:
- Strategic Advisory Board members, solely for the purpose of reviewing your final group project, and subject to their own confidentiality obligations to Avenor.
- Payment processors, to handle your enrolment fee.
- Service providers who help us operate the Programme, for example form or email tools, who are only permitted to use your data to provide that service.
- Authorities, where required by law.
6. How Long We Keep Your Data
We retain your enrolment and contact data for as long as reasonably necessary to administer the Programme and respond to any follow-up questions, and no longer than three years after your cohort ends, unless you ask us to delete it sooner or we are required to retain it longer for legal or accounting reasons. Your submitted Programme work is retained only as long as needed for review and, where agreed, promotional reference.
7. Website Usage Data
If our website uses basic analytics tools to understand visitor traffic, this may involve limited automatically collected data such as browser type, general location, and pages visited. We do not use this data to identify you personally.
8. Your Rights
Under GDPR, you have the right to:
- Access the personal data we hold about you.
- Request correction of inaccurate data.
- Request deletion of your data, subject to any legal retention requirements.
- Object to or restrict certain processing, including withdrawing consent for promotional use of your work at any time.
- Request a copy of your data in a portable format.
- Lodge a complaint with the Swedish Authority for Privacy Protection (IMY) if you believe your data has been mishandled.
9. Data Security
We take reasonable steps to keep your data secure, including limiting access to enrolment and Programme data to those who need it to operate the Programme. As Avenor is currently a small, early-stage venture, please be aware that formal enterprise-grade security infrastructure is still being developed.
10. Children's Privacy
The Programme is intended for university-age students and adults. We do not knowingly collect personal data from children under 16.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated to enrolled participants and reflected in the Last updated date above.
12. Contact
Questions or requests regarding this Privacy Policy can be directed to partners.avenor@gmail.com.