Last Updated: February 27th, 2019
Our Commitment to Your Privacy
We have set ourselves a key principle that also appears in our contracts: Ava does not sell the data collected as part of the services offered for advertising purposes. We make our living by creating better communication services for you, not by advertising.
- take into account, with respect to its tools, products, applications or services, the principles of protection of data from the design and protection of data by default (Privacy By Design);
- keep in writing a register of all categories of processing activities carried out as part of the performance of its duties.
Information We Collect And Why
Marketing or promotional purposes Email Communications. We may use your Personal Information to provide you with marketing or other promotional communications via email. If, at any time, you would like to stop receiving these promotional e-mails, you may follow the opt-out instructions contained in any such e-mail. Please note that by opting out, you may prohibit Ava from informing you of offerings that may be of interest to you. It may take up to ten business days for us to process opt-out requests. If you opt-out of receiving emails or promotions from us, we still may send you e-mails about your Account or any products or services you have requested or received from us, or for other customer service purposes.
Information from Third Parties
When do we disclose the Personal Information we collect?
Ava only grants access to your Personal Information on a need-to-know basis, and such access will be limited to the personal data that is necessary to perform the purpose for which such access is granted. To the extent needed to provide our services, Ava may grant access to the part of your personal data that is strictly necessary to authorized personnel, affiliates, vendors or suppliers. To the extent needed to meet our legal obligations, your data can also be sent to public institutions, court officers, departmental officers and agencies responsible for collecting debts. Ava may use a sub-contractor to conduct specific processing activities on behalf of Ava and as per Ava’s instructions. In this case, Ava ensures that the subcontractor is required to respect the obligations of this Agreement. Ava also ensures that the subcontractor provides sufficient safeguards for the implementation of appropriate technical and organizational measures to ensure that the treatment meets the requirements of the GDPR. When using subcontractors located outside of the EU, Ava ensures that they are GDPR compliant. Except as provided herein, Ava will not sell, rent or otherwise disclose Personal Information about you to third parties.
Third party providers. We may share your Personal Information with unaffiliated third parties that provide certain services to us, including, but not limited to data analysis, payment processing. These third parties may have access to Personal Information or non-Personal Information in order to perform their functions on our behalf. However, these third parties are only permitted to use your Personal Information for the purpose for which it has been provided or to administer, service or process transactions that you have authorized, and may not disclose it to any other third party except at our express direction and in accordance with this Policy. We do not share your Personal Information with: (1) affiliated companies for their everyday business purposes; or (2) any third parties so that they can market to you. Employer partners. If your employer is subsidizing your subscription to Ava Pro, we may share limited Personal Information with that employer, including your name, employee email, place of employment, along with non-Personal Information, such as your accessibility needs, to facilitate processing of the employer’s subsidy, for joint marketing purposes, or to enhance your use of Ava’s service. Your employer may not disclose this information to any other third party except at our express direction, and in accordance with this Policy and all applicable law. We will not disclose to your employer Personal Information concerning your use of Ava’s services. Business transfers. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or our assets, or assets related to the Services, Personal Information, information about how the Services are accessed and used, and any other information that we have collected about the users of the Services may be disclosed to such entity as one of the transferred assets. Also if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties. Your Data Protection Rights Ava is the Data Controller, and we’ve appointed a EU Digital Privacy Officer, the person in charge of the protection of your Personal Information, and have declared them to the French Data Protection Authority (CNIL) in accordance with applicable law. If you’re a EU citizen, you are granted rights under the General Data Privacy Regulation (GDPR). Due to the organization of the Services, you send your Personal Information directly to Ava, which is located in the USA, for the purpose of using the Services to which you have subscribed. Ava also protects your data in accordance with the GDPR requirements. If you wish to view, edit, delete, transfer, or otherwise restrict our use of your Personal Information, you may edit your Account information or contact us at firstname.lastname@example.org. Please note that you may update your personal data and activate or deactivate the recording of conversations directly from your Account. If you are facing any problems while managing your Personal Information through your user Account or if you wish to exercise any rights mentioned above, please contact us using the information provided under Contacting Ava section below. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Services. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons.
We will retain your Personal Information for a period of time that does not exceed the time necessary for the purposes for which the data were collected: If you use our Site, Ava retains your Personal Information: - for the duration required to process your request; - as long as you have not withdrawn your consent to receive newsletters and information about Ava and its Services.
If you or your interlocutors are using our Services, Ava retains your Personal Information: - as long as your Account has not been deactivated, in a maximum limit of 5 years, or as needed to provide you services, comply with our legal obligations, resolve disputes, or enforce our agreements. An Account will be considered “deactivated” if you affirmatively request that we deactivate your account by emailing us at email@example.com. We will deactivate a user Account by erasing it from our database within 30 days of receiving your written request. - for a 1-year period for statistics and monitoring about your use of our Services; - as long as you have not withdrawn your consent to receive newsletters and information about Services different to those for which you have subscribed;
Security of your Personal Information
Ava takes all necessary precautions, organizational and technical measures to preserve the security, the integrity and the confidentiality of your Personal Information and in particular, to prevent that they are deformed, damaged or that unauthorized third parties have access to it. We may or may also use secure payment systems that comply with the state of the art and applicable regulations. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information that you transmit to us. You use the Services and provide us with your Personal Information at your own risk. Your Account is authenticated, among other means, using SMS Device verification for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by implementing and protecting your Device password appropriately and limiting access to your Device. We also recommend that you change your Device password periodically. You are responsible for maintaining the security of your Account username and password. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your Account has been compromised), you must immediately notify us of the problem by contacting us and change your password immediately via the Services. Ava will notify any violation of Personal Information within a maximum of five (5) days after becoming aware of it. This notification shall be accompanied by all relevant documentation in order to allow you, if necessary, to notify that breach to the competent local privacy authority.
Ava uses “cookies” to help personalize your use of our site, including for storing user preferences, such as your language preference. Information About Cookies. A cookie is a text file stored on your computer. Cookies store bits of information that we use to help make our site work. They can’t run any code and don’t contain viruses. No one can read our cookies except us.
Your Choices Regarding Cookies. You can choose to have your computer warn you each time a cookie is being set, or you can choose to turn off all cookies. You do this through your browser settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies. If you clear your cookies, you will need to opt out again. If you use a different computer or browser, your choices will not be carried over. Ava adheres to the Self-Regulatory Principles for Online Behavioral Advertising from the Digital Advertising Alliance. You can opt out of targeted advertising by third parties by setting your browser to decline third party cookies. You can also delete the advertiser’s cookie each time. Many of the third parties are members of the Network Advertising Initiative. You can opt-out of targeted advertising by all NAI members by visiting the NAI site. The cookies and other information stored in your terminal will not be kept beyond 13 months after your last expression of consent. Personal Information collected through the cookies will not be kept beyond 13 months as from their collection.
Children Under 18 and Under 13
If you are under 18 or otherwise would be required to have parent or guardian consent to share information with Ava, you should not send any information about yourself to us. The Services are not directed to children under 13 years of age and we do not knowingly collect Personal Information from children under 13. If we become aware that a child under 13 has provided us with Personal Information, we will make reasonable efforts to delete such information from our files. If you believe we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
Your California Privacy Rights
California law provides California residents the right to request from Ava: (i) a list of the categories of Personal Information that we have disclosed to third parties for direct marketing purposes; and (ii) the names and addresses of all such third parties. If you would like to request this information, please email your request to email@example.com. In your request, please specify that you want a “Your Ava California Privacy Rights Notice”. Please allow 30 days for a response.
California Do Not Track Disclosures
Changes to this Policy
Our goal is to respect your privacy. If you have any questions or concerns about this Policy, please contact us by email at firstname.lastname@example.org Attn: Data Privacy Officer or by mail to:
Attn: Data Privacy Officer
1355 Market Street, Ste 488
San Francisco, CA
Updated : February 2019