Overview

Your Rights

You have the right to request information and access to the personal data we have collected from and of you. You also have the right to request that we replenish, rectify, anonymize or delete any incomplete, incorrect, unnecessary or outdated personal data we hold on you. However, we cannot delete such personal data that is necessary for compliance with binding legal obligations or if the personal data must be retained according to applicable laws. You have the right to request and receive the personal data we have collected on you in a commonly used and machine-readable form. In case you consider your personal data collected by us to be inaccurate, you do not wish your personal data to be deleted where the processing of your personal data has been deemed unlawful or the personal data is no longer necessary, or you have objected to the processing and the existence of legitimate grounds for processing is still under consideration, you may request restriction of processing of your personal data.

You may also at any time object to your personal data being processed for direct marketing purposes, sending promotional materials, profiling, or for the performance of market research. Further, where your personal data is processed based on your consent, you have the right to withdraw your consent for such processing at any time.

In case you wish to make use of your rights mentioned above, you may, as appropriate and in accordance with applicable laws, exercise such rights by contacting us through the contact points referred in the marketing materials or below in this policy. In some cases, especially if you wish us to delete or cease the processing of your personal data, this may also mean that we may not be able to continue to provide the services to you. We encourage you to use available profile management tools for the above purposes as such tools often provide you with direct access to your personal data and allow you to effectively manage it.

If you believe there has been a violation of your privacy rights, please contact us as set forth in the “contact us” section below. You also have a right to lodge a complaint with your local data protection authorities.

For big decisions that may impact you, you have “the right not to be subject to automatic decision-making, including profiling,” but we will always explain to you when we might do this, why it’s happening and the effect.

Please note that AVA may need to identify you and to ask for additional information in order to be able to fulfill your above requests. Please also note that applicable law may contain restrictions and other provisions that relate to your above rights.

Complaint To the Supervisory Authority

In the event you consider AVA’s processing activities of your personal data to be inconsistent with the applicable data protection laws or that AVA has not sufficiently ensured the realization of your rights, you may lodge a complaint with the local supervisory authority responsible for data protection matters.

Subject To Changes

AVA may from time-to-time update and change this privacy policy. If the changes include new purposes of processing, AVA will give you prior notice of such changes and, where necessary, request your consent.

California Rights

California residents. This section fully incorporates all of the above stated privacy policy terms as if fully set forth below and your rights under the California Consumer Privacy Act (CCPA) are intended to supplement the rights set forth above.

Right to know/ access

California residents have the right, (upon a verifiable request) to request the following:

• the categories and/or the specific pieces of personal information about you that we collect, use, disclose, and may sell.

• the categories of sources from which personal information is collected.

• the business or commercial purpose for collecting or selling personal information.

• the categories of third parties with whom we share personal information.

• the specific pieces of personal information we have collected about you.

You may request this information up to two (2) times each year, and we will respond within forty-five (45) days without charging you.

Additionally, you may request and obtain from us one (1) time per year, free of charge, information about our disclosure of personal information to third parties or affiliated companies for their direct marketing purposes.

Please note that AVA may need to identify you and to ask for additional information in order to fulfill your request. You can make your request through the online webform listed below. You may be required to provide your email address on file with us among other information. We will acknowledge your request within ten (10) days. Upon verification of your identity, we will fulfill your request. However, we will not provide any information that we reasonably believe may be subject to fraudulent action.

Right to non-discrimination for the exercise of your california rights. You have the right not be discriminated against because you exercised any of your rights under california law.

Right To Request Deletion Of Personal Information

Subject to certain expectations, california residents have the right to request deletion of their personal information collected or maintained by AVA.

Please note that AVA may need to identify you and to ask for additional information in order to be able to fulfill your request. You can make your request at the toll-free number or through the online webform listed below. In both instances, you may be required to provide your email address on file with us among other information. We will acknowledge your request within ten (10) days. Upon verification of your identity, we will fulfill your request. However, we will not provide any information that we reasonably believe may be subject to fraudulent action.

To submit a request through our online form (link AVA’ website form)

– please select type of request “personal data management” and data request type “right to deletion” prior to filling following fields when making your request. Please also indicate in the “comments” field “right to deletion”.

Please note, to ensure that your personal information is permanently deleted, you should delete your cookies from your browser (refer to our link AVA’s cookie policy) and decline giving your consent via our cookies preference center (link AVA’s website form).

California minors only: see data concerning minors above. A business shall not sell the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer, in the case of consumers at least 13 years of age and less than 16 years of age, or the consumer’s parent or guardian, in the case of consumers who are less than 13 years of age, has affirmatively authorized the sale of the consumer’s personal information. This is the right to opt-in. If you are between 13 and 16 years of age, you may opt-in simply by consenting to cookies via our cookies preference center (here). If you are under 13 years of age, we do not seek to engage with you in any transaction, tracking by cookies or otherwise.

Authorized agent

You have the right to designate an authorized agent to make any ccpa request on your behalf. AVA reserves the right to ask for proof that such agent is in fact authorized by you. Please direct your agent reach out by email at [email protected]. Authorized agents must submit proof of the consumer’s signed authorization to make a request. We may require you to verify your identity directly with us prior to fulfilling your authorized agent’s request.

If you exercise any of the foregoing rights, we will not discriminate against you, including by denying access to our products or services or restricting your access to products or services of a certain quality or price level.

CCPA Disclosures

Pursuant to the ccpa, and in addition to the disclosures elsewhere in this privacy policy, this section describes the types of personal information that we collected, disclosed for business purposes, or sold to third parties in the last twelve (12) months.

personal information collected: biographical information / identifiers, characteristics of protected classifications under california or federal law (i.e., gender, age), commercial information, payment card information, internet or other electronic network activity information, geolocation information, visual information, and inferences drawn from the above. For more information about the information that we collect, please see the above privacy policy terms. The sources of the information are the consumer, our business customers and partners, analytics providers, advertising partners, social networks, and service providers.

• disclosure of personal information: in the last twelve (12) months, AVA has disclosed the following categories of personal information to its service providers, contractors, and vendors for business purposes: biographical information / identifiers, characteristics of protected classifications under california or federal law (i.e., gender, age), commercial information, financial and payment number, internet or other electronic network activity information, geolocation information, education information, visual information, and inferences drawn from the above. To learn more, please see the above privacy policy terms.

• “sale” of personal information: in the last twelve (12) months, AVA has “sold” (as defined in the ccpa) the following categories of personal information: biographical information / identifiers, commercial information, internet or other electronic network activity information, and inferences drawn from the above. Each category of personal information was sold to advertising partners, data analytics providers, and social networks, for the purposes described above. We do not have actual knowledge that we sell personal information of consumers under 16 years of age. To learn more, please see the above privacy policy terms.

Eea and uk residents

We respect your privacy rights and provide you with reasonable access and rights to the personal data that you may have provided through your use of the products and services. If you live in the european economic area (“eea”) or united kingdom (“uk”) and wish to access, amend, delete, or transfer any personal data we hold about you, you may contact us as at [email protected]. In some cases, you may also update your registration information or preferences by accessing your account settings page on our websites.

At any time, you may object to the processing of your personal data in our legitimate interests, except if otherwise permitted by applicable law. If you believe there has been a violation of your privacy rights, please contact us as at [email protected]. You also have a right to lodge a complaint with your local data protection authorities.

You may decline to share certain personal data with us, in which case we may not be able to provide to you some of the features and functionality of the products and services.

We will retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for analytics purposes, in which case we may use this information indefinitely without further notice to you.

Please be advised that the following below terms shall apply to eea and uk residents to the extent they vary from the terms listed above.

Eea and uk minors only: see data concerning minors above. A business shall not sell the personal information of consumers if the business has actual knowledge that the consumer is less than 16 years of age, unless the consumer’s parent or guardian has affirmatively authorized the sale of the consumer’s personal information. This is the right to opt-in. If you are under 13 years of age, we do not seek to engage with you in any transaction, tracking by cookies or otherwise.

To the extent AVA is required to respond to questions about data it collects, stores and sells, AVA shall endeavor to respond within thirty (30) days of the request being made.

To the extent AVA has any of your personal data, it shall promptly respond to requests regarding:

• why AVA has the data;

• what categories of personal data AVA has;

• who in AVA’s organization or third-parties accessed the personal data;

• how long AVA plans on keeping the personal data;

• having data deleted or fixed as requested; and

• source of where the personal data was obtained.

You have the right to lodge a complaint with the eu commission if you are displeased with any of AVA’s responses. AVA shall endeavor to provide requested information electronically.

If you believe that any personal data that AVA has regarding you is inaccurate, please contact us as at [email protected] and inform us as to what you believe is inaccurate.

If you want to have any of your personal data that AVA has regarding you deleted, please contact us as at [email protected] and AVA with endeavor to delete the information unless AVA is legally required to retain such information.

If you want to have any of your personal data that AVA has regarding you kept, but not used by AVA, please contact us as at [email protected] and AVA with endeavor to cease using such information.