Cookies Policy & Privacy Policy

This document contains two policies: our Cookies Policy (Part A) and our Privacy Policy (Part B). Both policies apply to all visitors to avarismedia.com and to all clients and prospective clients who engage with Avaris Media Limited.

These policies were last updated in 2025 and comply with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations 2003 (PECR).

PART A — COOKIES POLICY

A1. What Are Cookies?

Cookies are small text files that are placed on your device (computer, tablet or mobile phone) when you visit a website. They are widely used to make websites work efficiently, to improve the user experience, and to provide information to website owners.

Cookies do not typically contain information that personally identifies you, but personal data that we store about you may be linked to information stored in or obtained from cookies.

A2. How We Use Cookies

Avaris Media Limited uses cookies on our website avarismedia.com for the following purposes:

  • To ensure the website functions correctly and securely
  • To remember your preferences and settings
  • To analyse how visitors use our website so we can improve it
  • To support our marketing and advertising activities
  • To measure the effectiveness of our campaigns

A3. Types of Cookies We Use

A3.1  Strictly Necessary Cookies

These cookies are essential for our website to function and cannot be disabled. They are usually set in response to actions you take, such as filling in a form or setting your privacy preferences. Without these cookies, the website cannot function properly.

A3.2  Performance and Analytics Cookies

These cookies help us understand how visitors interact with our website by collecting anonymous information. We use this information to improve our website and the experience we offer.

A3.3  Functional Cookies

These cookies allow the website to remember choices you make, such as your language preference or region, to provide a more personalised experience.

A3.4  Marketing and Targeting Cookies

These cookies are used to track visitors across websites. They are set to display advertisements that are relevant and engaging to individual users. They may also be used to measure the effectiveness of our advertising campaigns.

A3.5  Third-Party Cookies

Some cookies on our website are set by third-party services that appear on our pages. We do not control these cookies. The relevant third parties are responsible for their own cookie policies.

A4. Specific Cookies Used

The following table sets out the key cookies used on our website. Please note this list may not be exhaustive as third-party services may set additional cookies.

Cookie Name

Type

Purpose

Duration

_ga

Analytics

Google Analytics — distinguishes users and tracks sessions

2 years

_ga_XXXXXX

Analytics

Google Analytics — persists session state

2 years

_gid

Analytics

Google Analytics — distinguishes users

24 hours

_gat

Analytics

Google Analytics — throttles request rate

1 minute

_gcl_au

Marketing

Google Ads conversion tracking

90 days

_fbp

Marketing

Meta Pixel — tracks visits across Meta products

90 days

hubspotutk

Functional

HubSpot — tracks visitor identity for forms

13 months

__hstc

Analytics

HubSpot — tracks returning visitors

13 months

__hssc

Analytics

HubSpot — tracks session activity

30 minutes

__hssrc

Analytics

HubSpot — detects new sessions/browsers

Session

cookielawinfo-*

Necessary

Stores your cookie consent preferences

1 year

PHPSESSID

Necessary

Maintains your session while browsing

Session

GTM-*

Marketing

Google Tag Manager — manages tracking tags

Varies

This list is reviewed and updated periodically. For the most current information on cookies used by third-party services, please refer to their own cookie policies.

A5. Managing Your Cookie Preferences

When you first visit our website, you will be shown a cookie consent banner. You can choose which categories of non-essential cookies you accept. You can change your preferences at any time by:

  • Clicking the cookie settings link in the footer of our website
  • Adjusting your browser settings to block or delete cookies
  • Using a browser extension to manage cookies

Please be aware that disabling certain cookies may affect the functionality of our website and some features may not work as intended.

A5.1  Browser Settings

Most web browsers allow you to control cookies through their settings. You can find information on how to manage cookies in the most popular browsers at:

  • Google Chrome: support.google.com/chrome/answer/95647
  • Mozilla Firefox: support.mozilla.org/en-US/kb/cookies
  • Safari: support.apple.com/en-gb/guide/safari
  • Microsoft Edge: support.microsoft.com/en-us/microsoft-edge

A5.2  Opting Out of Analytics

You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout.

A5.3  Advertising Cookies

To opt out of interest-based advertising across participating websites, you can visit youronlinechoices.eu (EU) or aboutads.info/choices (US).

A6. Changes to This Cookies Policy

We may update this Cookies Policy from time to time to reflect changes in the cookies we use or for legal, technical or operational reasons. We will notify you of any material changes by updating the date at the top of this policy. We encourage you to review this policy periodically.

A7. Contact Us — Cookies

If you have any questions about our use of cookies, please contact us at:

Email: info@avarismedia.com

Post: Avaris Media Limited, 4th Floor, Silverstream House, 45 Fitzroy Street, London, W1T 6EB

PART B — PRIVACY POLICY

B1. Who We Are

Avaris Media Limited is a specialist digital marketing agency working exclusively with aesthetic, cosmetic and private healthcare clinics. We are the data controller for the personal data we collect through our website and in the course of our business.

Avaris Media Limited

Company Number: 13841542

4th Floor, Silverstream House, 45 Fitzroy Street, London, W1T 6EB

info@avarismedia.com   |   03335679858   |   avarismedia.com

We are committed to protecting your privacy and handling your personal data responsibly, transparently and in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

B2. What Personal Data We Collect

B2.1  Data You Provide to Us

We collect personal data that you voluntarily provide to us, including when you:

  • Complete a contact form or enquiry form on our website
  • Book a discovery call or consultation
  • Enter into a contract with us for services
  • Email, call or message us directly
  • Subscribe to our newsletter or marketing communications
  • Respond to a survey or provide feedback

The personal data collected in these circumstances may include: your name, job title, clinic or business name, email address, telephone number, postal address and any information you choose to include in your message.

B2.2  Data We Collect Automatically

When you visit our website, we automatically collect certain technical information, including:

  • IP address and approximate location
  • Browser type and version
  • Operating system
  • Pages visited and time spent on each page
  • Referring website or search term
  • Device type and screen resolution

This information is collected via cookies and analytics tools (see Part A — Cookies Policy) and is used to improve our website and understand how visitors use it.

B2.3  Data We Collect in the Course of Providing Services

Where we provide digital marketing services to a client, we may process personal data on their behalf in the course of delivering those services. This may include:

  • Data captured via website contact forms or live chat tools
  • Patient enquiry data flowing through our AI Conversion System
  • Call tracking data
  • Google Analytics and advertising platform data relating to website visitors

In these circumstances, we act as a data processor on behalf of the client, who is the data controller. Clients are responsible for ensuring they have appropriate lawful bases for the processing of their patients’ personal data.

B3. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

B3.1  To Respond to Enquiries and Provide Services

Lawful basis: Performance of a contract / Legitimate interests

We use your contact information to respond to enquiries, book discovery calls, and provide the services you have engaged us for.

B3.2  To Manage Our Client Relationships

Lawful basis: Performance of a contract / Legitimate interests

We use your data to manage our contractual relationship with you, including invoicing, reporting, communications and account management.

B3.3  To Improve Our Website and Services

Lawful basis: Legitimate interests

We analyse website usage data to understand how our site is performing and how we can improve it. This data is used in aggregated and anonymised form where possible.

B3.4  To Send Marketing Communications

Lawful basis: Consent / Legitimate interests

With your consent, or where we have a legitimate interest to do so (such as marketing similar services to existing clients), we may send you information about our services, case studies, industry insights and relevant updates. You can unsubscribe at any time by clicking the unsubscribe link in any email or by contacting us directly.

B3.5  To Comply With Legal Obligations

Lawful basis: Legal obligation

We may need to process your data to comply with our legal and regulatory obligations, including tax, accounting and financial reporting requirements.

B3.6  To Protect Our Legitimate Business Interests

Lawful basis: Legitimate interests

We may use your data to protect our business interests, enforce our contracts, and defend or bring legal claims where necessary.

B4. Marketing Communications

We will only send you direct marketing communications where we have your consent or a legitimate interest to do so.

If you are an existing client, we may send you relevant updates and information about our services without your prior consent, on the basis of our legitimate interest in maintaining our business relationship with you. You may opt out of receiving these communications at any time.

If you are not an existing client, we will only send you marketing communications with your explicit consent.

You can withdraw your consent or opt out of marketing communications at any time by:

  • Clicking the unsubscribe link in any marketing email
  • Emailing info@avarismedia.com with the subject line ‘Unsubscribe’
  • Calling us on 03335679858

Opting out of marketing communications will not affect the processing of your data for other purposes.

B5. Who We Share Your Data With

We do not sell your personal data. We may share your data with trusted third parties in the following limited circumstances:

B5.1  Service Providers and Technology Partners

We work with a range of third-party service providers to operate our business and deliver our services. These may include:

  • CRM and email marketing platforms (such as HubSpot)
  • Cloud hosting and storage providers
  • Accounting and invoicing software
  • Project management and communication tools
  • Google (Analytics, Ads, Business Profile, Search Console)
  • AI technology providers underpinning our AI Conversion System
  • Call tracking providers

All third-party service providers are required to handle your data securely and in accordance with applicable data protection law. We ensure that appropriate data processing agreements are in place where required.

B5.2  Legal and Regulatory Requirements

We may disclose your personal data to regulatory authorities, law enforcement agencies or courts where we are required to do so by law, or where we believe disclosure is necessary to protect our legal rights or the safety of others.

B5.3  Business Transfers

If Avaris Media Limited is acquired by or merged with another business, your personal data may be transferred to the new owners as part of that transaction. We will notify you of any such change and your rights in relation to your data.

B6. International Data Transfers

Some of our third-party service providers may be based outside the United Kingdom. Where we transfer personal data outside the UK, we ensure that appropriate safeguards are in place, such as UK adequacy regulations, Standard Contractual Clauses approved by the Information Commissioner’s Office (ICO), or other legally recognised transfer mechanisms.

For further information on the safeguards in place, please contact us at info@avarismedia.com.

B7. How Long We Keep Your Data

We retain personal data only for as long as is necessary for the purposes for which it was collected, or as required by law. Our standard retention periods are as follows:

  • Client and contract data: 7 years from the end of the contract (for accounting and legal purposes)
  • Enquiry and contact form data: 2 years from the date of last contact
  • Marketing contact data: Until you unsubscribe or withdraw consent
  • Website analytics data: As determined by the relevant platform settings (typically 26 months for Google Analytics)
  • Call tracking and AI system data: As agreed with the relevant client, subject to a maximum of 2 years

At the end of the applicable retention period, personal data is securely deleted or anonymised.

B8. Your Rights

Under the UK GDPR, you have the following rights in relation to your personal data:

B8.1  Right of Access

You have the right to request a copy of the personal data we hold about you (a ‘Subject Access Request’). We will respond within one calendar month.

B8.2  Right to Rectification

You have the right to ask us to correct any inaccurate or incomplete personal data we hold about you.

B8.3  Right to Erasure

You have the right to ask us to delete your personal data in certain circumstances, such as where the data is no longer necessary for the purpose for which it was collected, or where you withdraw your consent.

B8.4  Right to Restrict Processing

You have the right to ask us to restrict the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to our processing.

B8.5  Right to Data Portability

Where we process your data by automated means on the basis of your consent or a contract, you have the right to receive your data in a structured, commonly used and machine-readable format.

B8.6  Right to Object

You have the right to object to our processing of your personal data where we rely on legitimate interests as our lawful basis. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

B8.7  Rights Related to Automated Decision-Making

We do not make significant automated decisions about individuals without human involvement. If this changes, we will update this policy accordingly.

B8.8  How to Exercise Your Rights

To exercise any of your rights, please contact us at:

Email: info@avarismedia.com

Post: Avaris Media Limited, 4th Floor, Silverstream House, 45 Fitzroy Street, London, W1T 6EB

We will respond to all legitimate requests within one calendar month. We may need to verify your identity before processing your request. There is no charge for exercising your rights, except in cases of manifestly unfounded or excessive requests.

B9. How We Protect Your Data

We take the security of your personal data seriously and have appropriate technical and organisational measures in place to protect it against unauthorised access, loss, destruction or disclosure. These measures include:

  • Encryption of data in transit and at rest
  • Access controls and password policies
  • Regular security reviews and staff training
  • Use of reputable, security-certified third-party platforms
  • Confidentiality obligations on all staff and contractors

Despite these measures, no data transmission over the internet is completely secure. We cannot guarantee the security of data you transmit to us, and you do so at your own risk. Once we receive your data, we take all reasonable steps to secure it.

B10. Children’s Privacy

Our website and services are not directed at children under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected data from a child, please contact us immediately at info@avarismedia.com and we will take steps to delete that data.

B11. Third-Party Websites

Our website may contain links to third-party websites, social media platforms and other online services. This Privacy Policy applies only to our website and our services. We are not responsible for the privacy practices of any third-party websites and we encourage you to read their privacy policies before providing any personal data to them.

B12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements or other factors. We will notify you of any material changes by updating the ‘last updated’ date at the top of this policy and, where appropriate, by sending you a notification directly.

We encourage you to review this policy periodically to stay informed about how we are protecting your data.

B13. How to Make a Complaint

If you have a concern about how we have handled your personal data, we would like the opportunity to resolve it. Please contact us in the first instance at info@avarismedia.com.

If you are not satisfied with our response, or if you believe we are processing your personal data unlawfully, you have the right to lodge a complaint with the UK’s supervisory authority:

Information Commissioner’s Office (ICO)

Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Telephone: 0303 123 1113

Website: ico.org.uk

B14. Contact Us — Privacy

If you have any questions, concerns or requests regarding this Privacy Policy or our data practices, please contact us:

Avaris Media Limited

Data Controller

4th Floor, Silverstream House, 45 Fitzroy Street, London, W1T 6EB

Email: info@avarismedia.com

Telephone: 03335679858

Website: avarismedia.com

These policies were prepared for Avaris Media Limited and are intended to reflect our current practices as of 2025. They should be reviewed annually or whenever significant changes occur to our data processing activities.