In case you have special accessibility needs to access the content of this statement, we recommend that you or someone on your behalf, consults our Accessibility Statement and recommendations.

This privacy statement is effective as of November 1, 2023.

Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal information or any changes in applicable laws. If you are not a California resident, this privacy statement does not apply to you. Please visit the Avanade Privacy Statement for more information.

This Avanade Privacy Statement for California Residents applies to California residents whose personal information is processed by Avanade Inc and/or its affiliates, subsidiaries and newly acquired companies ("Avanade"; "we") pursuant to the California Consumer Privacy Act (“CCPA”), including how we protect the personal information we process and control relating to you (“your personal information”; "your information") and which rights you have in relation to the processing of your personal information.

Any Avanade entity located outside the European Union will for the purposes of compliance with data privacy laws be represented by Accenture Global Holdings Limited.

Below, we first give a general description of how Avanade protects your personal information. Further below, we also include specific information on the following:

• How do we use personal data when you visit Avanade’s website?
• How do we use cookies (and other tracking technologies)?
• How do we use personal data when you visit our offices?
• How do we use personal data for marketing purposes?
• How do we use personal data when using AI supported capabilities in our communications? < />

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.

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.

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 and vendors. 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.

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 PLC 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 and vendors (including third party data providers).
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, contact Avanade’s Data Privacy Officer. In addition, you can call +1 833-226-2351 during the standard Pacific Standard Time (PST) office hours (only available in English). 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).

Contact us to exercise any of your rights.

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.

2. How do we use personal information when you visit Avanade’s website?

In addition to the information set out above, the following sections describe how we use personal information when you visit Avanade’s website:

• Which personal information do we gather?
• Do we include (links to) websites and programs of third parties?
• How do we use personal information that we collect from our websites?

Which personal information do we gather?
Avanade collects personal information at its websites in two ways: (1) directly (for example, when you provide personal information to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website's technology).

We may collect and process the following personal information:

• Personal information that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of personal information may provide further information as to why your personal information is needed and how it will be used. It is completely up to you whether you want to provide it.
• If you contact us, we may keep a record of that correspondence.
• We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
• Any postings, comments or other content that you upload or post to an Avanade website.
• Our website or mobile applications can collect personal information about your computer or mobile device, including (where available) your IP address, operating system, type of device, device identification number, mobile operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
• Details of your visits to our website, the pages you view and resources you access or download, including but not limited to, traffic data, (geo) location data, weblogs and other communication data. Please see the Cookies section below for more information.

Do we include (links to) websites and programs of third parties?
Our websites may include:

• Links to and from the sites of our partner networks, advertisers and affiliates.
• Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal information collected through such programs for their own purposes.

We do not accept any responsibility or liability for such third parties’ sites or programs. Please check such third parties’ terms of use and privacy statements before using and providing any information to such third parties’ sites and programs.

How do we use personal information that we collect from our websites?
We use personal information for the purposes described in the section “For which purposes and on which legal basis do we use your personal information?” above, as well as to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected. For example:

• Links to and from the sites of our partner networks, advertisers and affiliates.
• Certain programs (widgets and apps) of third parties. Where this is the case, note that such third parties may process your personal information collected through such programs for their own purposes.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section below for more information.

3. How do we use cookies (and other tracking technologies)?

In addition to the information set out above, this section describes how we use cookies and other tracking technologies.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.

Please see our Cookies policy for more details, including for information about your choices with respect to Advertising and Social Media Cookies and for access to our cookie consent manager. By using our website, you agree that we and third parties can place cookies and other similar technologies on your device as explained in our Cookies policy.

5. How do we use personal information for marketing purposes?

In addition to the information set out above, the following sections describe how we use personal information for marketing purposes:

• What are the sources of marketing data?
• Do we send targeted e-mails?
• Do we maintain Customer Relationship Management (CRM) databases?
• Do we combine and analyze personal information?
• Do we share personal information with third parties?
• What are your rights regarding marketing communications?

What are the sources of marketing data?
The bulk of the personal information we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.

Do we send targeted e-mails?
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Avanade, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from Avanade may include additional data privacy information, as required by applicable laws.

You may adapt your contact, content and data preferences in the Avanade Preference Center at any time.

Do we send push notifications?

If you use our mobile applications, you may receive notifications such as notifications of industry topics you selected to follow within the mobile app or live events information. With your consent provided through the app permissions/settings, we may send push notifications or alerts to your mobile device even when you are not logged in. At any time, you can manage your push notification preferences or deactivate these notifications by turning off the notification settings in the mobile app or in the device settings/app permissions of your mobile device.

Do we maintain Customer Relationship Management (CRM) databases?
Like most companies, Avanade uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal information belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal information used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purposes), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Avanade professionals based on their personal interactions with you.

Do we combine and analyze personal information?
We may combine data from publicly available sources, and from our different e-mail, website, and personal interactions with you (this includes information collected across our different websites such as our careers and corporate sites and information collected when you sign-up or log on to our sites or connect to our sites using your social media credentials (such as LinkedIn and Xing)). We combine this data to better assess your experience with Avanade and to perform the other activities described throughout our privacy statement.

You may adapt your contact, content and data preferences in the Avanade Preference Center at any time.

Do we share personal information with third parties?
In addition to the third parties mentioned in the section “Will we share your personal information with third parties?” above, we may share your personal information with marketing agencies.

What are your rights regarding marketing communications?
You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal information, or by utilizing opt-out mechanisms in e-mails we send to you. In such cases, we will retain minimum personal information to note that you opted out in order to avoid contacting you again.

7. Content creation / production activities

In addition to the information set out above and to the extent you would be involved in our content creation/production activities, the following sections describe how we process your personal information in connection with any content creation / production purposes. Below, we provide you with further details about how we process your personal data in connection with any content creation / production purposes.

Content creation / production activities
Some Avanade entities are in the business of content production. We may process your personal information for these TV, film, marketing, advertising or other related content creation, production and distribution activities.

What personal information do we process in connection with production activities?

• The personal information that we process for production purposes include images and footage of you and may include your location at the time of filming.
• If you are a member of the public, we will diligently attempt to make you aware of our location and filming activities in advance and will give you an opportunity not to enter the location where filming is taking place and participate in them.
• If you are a focus of our filming activities (i.e. a contributor or talent such as an interviewee, extra or actor, as opposed to a member of the public) we will also collect and process your name, contact information and any other information provided in any pre-filming questionnaires and/or release forms, such as next of kin details.
• We may also collect and process special categories of data a such as health or disability information to the extent that this is necessary to enable us to make any necessary adjustments to our filming arrangements to assist or support you.

If you have any questions on data privacy or any aspects of our production activities, please contact us.

8. Contact us

Please click here if:

• You have a general question about how Avanade protects your personal information.
• You wish to exercise your rights in relation to your personal information rights (as set out in the sections “Which rights do you have with respect to the processing of your personal information?” and “What are your rights regarding marketing communications?”). Alternatively, you may want to use this link to exercise these rights.
• You wish to make a complaint about Avanade’s use of your personal information.
• You would like a copy of the full version of our BCR.

You can also contact Avanade as data controller of your personal information via our Data Privacy Officer (preferably electronically) or via letter, clearly marked for the attention of the Data Privacy Officer, via this address: Accenture Limited Dublin, 1 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. In addition, to exercise your rights mentioned above, you can call 1-833-226-2351 during the standard Pacific Standard Time (PST) office hours (only available in English).