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.
“You” or “Data subject” is any natural person who shares their personal data with us.
“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.
Information about you may be collected and received in several ways:
A. Personal data you share with us voluntarily
Include information such as:
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.
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:
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.
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:
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.
|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 email@example.com, 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:
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 firstname.lastname@example.org.
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.
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 email@example.com, we will erase your personal data within a year after your application has been received unless you become one of our team members.
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):
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:
AVA Information Systems doo
Providing software design and development services, data analysis, project management and other related services
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:
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:
However, this right does not apply where, for example, the processing is necessary:
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 firstname.lastname@example.org 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 email@example.com.
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 firstname.lastname@example.org.
Any changes shall enter into force upon being published on our Website.