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Privacy Policy

Effective as of May 25, 2018

 

AVA Information Systems GmbH Torstraße 149, 10119 Berlin, Germany (hereinafter: “AVA Information Systems”, “AVA”, “we” or “us”), as a data controller, collects and processes personal data in relation to interactions on the Website and the use of our Service.

 

AVA Information Systems is highly aware and understands that privacy is of great importance to you, so we take personal data protection very seriously.

Therefore, as a data controller and by creating this Privacy Policy, we make the processing of your personal data transparent and understandable. In this Privacy Policy, we explain how we collect, share, and use your personal data, as well as how you can exercise the rights you have as a data subject.

 

This Privacy Policy applies to all individuals who access our website at https://ava.info/ (hereinafter: “Website”), send us inquiries via the Website, engage our professional services (hereinafter: “Services”), or apply for a working position in AVA Information Systems.

This Privacy Policy, along with our Terms and Conditions and Cookie Policy, constitutes an agreement that applies to you. Therefore, we suggest you read it carefully in order to find out all the necessary information regarding the protection of your personal data.

Every term that is capitalized but undefined in this Privacy Policy shall have a meaning given to it in our Terms and Conditions.

In case you have any questions regarding this Privacy Policy, please contact us at privacy@ava.info.

Definitions

Personal data” or “data” is any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Therefore, data about a company or any legal entity is not considered to be personal data but registering on behalf of a legal entity may include sharing personal data. For example, the information in relation to one-person companies may constitute personal data where it allows the identification of a natural person. The rules also apply to all personal data relating to natural persons in the course of professional activity, such as the employees of a company or organisation, business e-mail addresses like “firstname.surname@company.com”. This Privacy Policy does not apply to information from which no individual can reasonably be identified (anonymized information).

 

You” or “Data subject” is any natural person who shares their personal data with us.

 

Cookies” are small pieces of data stored on your device (computer or mobile device). This information is used to track your use of the Website and to compile statistical reports on website activity. For further information about how we use cookies and how you can manage them, please read our Cookie Policy.

 

Website” is the website located at https://ava.info/.

 

Service” means making available any content by us on the Website. The Service does not include services that AVA Information Systems otherwise provides without the use of the Website.

 

Data Processor” is any natural or legal person who processes the data on behalf of the Data Controller. In order to process your data more effectively, AVA Information Systems may use the services of various Service Providers.

 

Processing” is any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 

Consent” is your explicit consent to the processing of personal data. Persons who are 15 years of age or older may give free consent to the processing of their personal data.

Personal data we collect

Information about you may be collected and received in several ways:

  • Personal data that we collect from you, including
    • Data you share with us voluntarily,
    • Data we collect automatically when you use our Website, and
  • Personal data we collect about you from third parties.

 

A. Personal data you share with us voluntarily

 

Include information such as:

  • Your name and contact information

When you choose to contact us via the Contact page on our Website or otherwise, we will ask you to leave your name and your e-mail address.

  • Additional information

If you contact us via the Contact page on our Website or otherwise (including, but not limited to inquiries regarding custom project requests, Beta Ambassadors Program, Application Programming Interfaces, and other requests about our products), we may receive additional information about you, such as a business address, your profession, content of the messages or attachments you may send us, or any other information you decide to share with us.

 

In case you decide to submit an application for a working position at AVA Information Systems, via the Careers page, we will ask you to send your Cover letter and CV to our e-mail address. During the application process for any of the opened working positions at AVA Information Systems, we may require additional information regarding your professional life, which can be relevant for your future working position.

 

When you choose to acquire our Products and Services, we may request some information necessary for us to provide you with the chosen Product or Service, such as the name of your organisation, your city, region or country, as well as, for example, the information on the brand and type of your Smartphone, in case you are applying for our Beta Ambassadors Program.

 

All personal information that you provide to us needs to be true, complete, and accurate, and you are obliged to notify us of any changes to such personal information.

 

 

B. Personal data we collect automatically when you use our Website

 

Include information such as:

  • Your IP address,
  • Device type,
  • Unique device identification number,
  • Browser-type,
  • Broad geographic location (e.g. country or city-level location).

 

We may also collect information about how your device has interacted with our Website, which includes the pages accessed and links clicked.

 

Collecting this information enables us to better understand the visitors who visit our Website, where they come from, and what content on our Website is of interest to them.

 

This information is collected primarily by using cookies and similar tracking technology, as explained further in our Cookie Policy.

 

 

C. Personal data we collect about you from third parties

 

In some cases, we may obtain your personal data without you giving us such data directly.

 

If you apply for a working position at AVA Information Systems, we may obtain information about you:

  • from recruitment agencies – (e.g. when a recruitment agency contacts us to identify you as a potential candidate);
  • through publicly available sources online – (e.g. on your current employer’s website, or on a professional networking site such as LinkedIn); and
  • by reference or word of mouth – for example, through a referral from a former employee/employer or from a referee you have identified.

 

If you are our client, we will process identification and background information as part of our business acceptance, as well as to fulfil any other legal or regulatory requirements to which we may be subject.

Why do we collect your personal data?
PURPOSE DATA WE COLLECT LEGAL BASIS

Providing and improving our Products & Services, responding to your inquiries

 

We collect your personal data in order to respond to the inquiries you sent us via the Contact page on our Website, as well as to respond to you regarding the rest of your requests addressed to us and to provide and improve Services to you.

Your name and e-mail.

Processing is necessary for the performance of the Agreement or to enter into such an Agreement with you.

Sending personalized offers and monitoring of your behaviour

 

When sending us an inquiry, you may agree to the monitoring of your behaviour patterns by AVA and sending you personalized offers on products and services based on the behaviour patterns observed by AVA. This means that you may give us your consent to process data about your past inquiries and/or interaction on our Website, and send you information about other products we believe you might be interested in based on that information.

 

Your name and e-mail address.

 

 

Processing is based on your consent. You have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on consent prior to such withdrawal. You may unsubscribe from receiving personalized offers and monitoring of your behaviour. If you wish to do so, simply follow the instructions found at the end of each e-mail. We may use your email for this purpose until you unsubscribe.

Processing your application for opened working positions

 

After you send us your application, which you submit by sending an inquiry at careers@ava.info, we will need to examine it in order to determine whether you fulfil our requirement as a candidate.

Your name, email address, and any additional personal data contained in your Cover letter and CV. Processing is based on your consent and is necessary for the examination of your application. In case we do not accept your job application, your data will be erased within the time period described in section 6.

 

We do not process data outside the specified purposes, and, especially, we do not:

  • Sell any kind of personal data,
  • Disclose this information to other marketers,
  • Provide your personal information to any third-party individual, government agency, or company at any time unless strictly compelled to do so by law.
Data subjects under the age of 15

Our Website is not intended for children, and we do not knowingly collect data relating to children. If you are under the age of 15, please do not provide any personal information about yourself to us. If we detect that we have collected personal information from a person under the age of 15, such information will be deleted promptly. If you believe we have collected personal information regarding a child under the age of 15, please contact us at privacy@ava.info.

Usage of your personal data

None of your personal data will be used by AVA Information Systems, unless we have your consent or if some other legally permitted reason applies.

 

Your personal data will be used only for purposes we collected it for, and only when we have a reasonable and lawful reason to do so.

 

In order to achieve the highest level of personal data security, our staff is legally bound by the professional secret. Furthermore, we use all legal, technical, and organizational measures to prevent any disclosed information is revealed outside the legal purpose for which was collected.

How long do we keep your personal data?

AVA Information Systems does not keep your personal data longer than the time necessary to fulfil the purpose for which the data is collected, or no longer than the time for which we have your consent. In determining data retention periods, we take into consideration local laws, contractual obligations, and the expectations and requirements of our customers and suppliers. When we no longer need personal information, or when you request us to delete your information, where this is legal, we will securely delete or destroy it.

 

In case you have applied for a working position in our company by sending your Cover letter and CV via careers@ava.info, we will erase your personal data within a year after your application has been received unless you become one of our team members.

Who do we share your personal data with?

The performance of certain processing activities requires the engagement of external processors.  AVA Information Systems uses information audits to identify, categorize and make records of all personal data that is processed outside of the company – that way, all the information, processing activity, processor, and legal basis are recorded, reviewed, and easily accessible.

 

Such external processing includes (but is not limited to):

  • IT Systems and Services,
  • Legal Services,
  • Financial Services
  • Human Resources,
  • Direct Marketing Services.

 

We may be legally required to share certain information, including your personal data, with e.g. public authorities or governmental bodies; in such cases, we will not require your further consent in order to share your personal data in such circumstances.

 

This is the list of processors and sub-processors with whom we share your personal data:

 

PROCESSOR

ROLE

SEAT

Google, Inc.

Analytics

USA

AVA Information Systems doo

Providing software design and development services, data analysis, project management and other related services

Serbia

 

We may transfer your personal data to countries other than the one you reside in. In these cases, we will transfer your personal data only:

  1. To the countries within the EEA;
  2. To the countries which do not form the EEA but are considered to ensure an adequate level of protection;
  3. To the countries which do not belong to those specified under item 1. and 2, but only by applying the appropriate safeguard measure in accordance with the GDPR (for example, applying standard contractual clauses).
Data subject’s rights

As a Data Subject in the EEA, whose personal information we hold, you have certain rights under the GDPR. This part of the Privacy Policy aims to give you a general understanding of these rights. In relation to each of the rights noted below, we provided a reference to the specific provision of the GDPR from which that right arises.

 

 

Right to access (Article 15 GDPR)

 

You can send us a request for a copy of the personal data we hold about you.

 

We have ensured that appropriate measures have been taken to provide such in a concise, transparent, intelligible and easily accessible form, using clear and plain language. Such information is provided in writing free of charge. It may be provided by other means when authorized by the Data Subject and with prior verification as to the subject’s identity.

 

Information is provided to the Data Subject at the earliest convenience, but at a maximum of 30 days from the date the request was received. Where the retrieval or provision of information is particularly complex or is subject to a valid delay, the period may be extended by two further months where necessary.

 

 

Right to Correction of Your Personal Data (Article 16 GDPR)

 

If the personal data we have about you is incorrect, you have the right to request that we correct those data. Where notified of inaccurate data by the Data Subject, we will rectify the error within 30 days and inform any third party of the rectification if we have disclosed the personal data in question to them.

 

 

Right to Withdraw the Consent (Article 13(2)c) GDPR)

 

If you have provided your consent to the collection, processing and transfer of your personal data, you have the right to fully or partly withdraw your consent. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) to which you originally consented unless there is another legal ground for the processing.

 

 

Right to be forgotten (Article 17 GDPR)

 

You have the right to request from us that your personal data is deleted in certain circumstances including:

  • The personal data are no longer needed for the purpose for which they were collected;
  • You withdraw your consent (where the processing was based on consent);
  • You object to the processing and no overriding legitimate grounds are justifying us processing the personal data;
  • The personal data have been unlawfully processed; or
  • To comply with a legal obligation.

However, this right does not apply where, for example, the processing is necessary:

  • To comply with a legal obligation; or
  • For the establishment, exercise or defense of legal claims.

 

 

Right to the restriction of processing (Article 18 GDPR)

 

If the accuracy of the personal data is contested, you consider the processing is unlawful but you do not want it erased, we no longer need the personal data but you require it for the establishment, exercise or defense of legal claims or you have objected to the processing and verification, you can exercise your right to the restriction of processing.

 

 

Right to Lodge a Complaint

 

If you have any concerns or requests in relation to your personal data, please contact us at privacy@ava.info and we will respond within 30 days.

 

If you are unsatisfied with how we process your data, you may contact the competent supervisory authority.

 

In case you believe that we are processing your personal data in violation of the GDPR, you have the right to lodge a complaint with the supervisory authority located in the EEA where you reside or work or where the alleged infringement took place.

 

To exercise these rights, please contact us at privacy@ava.info.

Keeping your personal data secure

AVA Information Systems uses appropriate technical and organizational measures to protect the personal data that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.

 

However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security or confidentiality. If you have any questions about security on the Website or Service, you can contact us at privacy@ava.info.

Changes to our Privacy Policy

AVA Information Systems reserves the right to change this Privacy Policy from time to time at our sole discretion.

 

If you provide us with your e-mail address, we will send you the notice of all the changes. However, a notice on each change will be published on our Website. Therefore, please review our Privacy Policy periodically in order to be updated in a timely manner.

 

Any changes shall enter into force upon being published on our Website.

 

If you do not agree to our Privacy Policy, please stop using our Website immediately.

Get in touch

Should you wish to exercise any of the rights you have as a data subject, or you have a question for us regarding this Privacy Policy, please contact us at privacy@ava.info.