Privacy Policy of AVOXI, Inc. Websites, Apps, and Services

Owner and Data Controller

AVOXI, Inc.
1000 Circle 75 Parkway, Suite 500
Atlanta, GA 30339 USA
Policy Effective Date: 25 MAY 2018

Owner contact email: privacy@avoxi.com

Types of Data collected

Among the types of Personal Data that AVOXI, Inc. Websites, Apps, and Services collects, by itself or through third parties, there are: Cookies; Usage Data; first name; last name; phone number; company name; address; state; email address; city; various types of Data; geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using AVOXI, Inc. Websites, Apps, and Services.
Unless specified otherwise, all Data requested by AVOXI, Inc. Websites, Apps, and Services is mandatory and failure to provide this Data may make it impossible for AVOXI, Inc. Websites, Apps, and Services to provide its services. In cases where AVOXI, Inc. Websites, Apps, and Services specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by AVOXI, Inc. Websites, Apps, and Services or by the owners of third-party services used by AVOXI, Inc. Websites, Apps, and Services serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through AVOXI, Inc. Websites, Apps, and Services and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of AVOXI, Inc. Websites, Apps, and Services (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Remarketing and behavioral targeting, Backup saving and management, Contacting the User, Displaying content from external platforms, Tag Management, User database management, Interaction with live chat platforms, Interaction with external social networks and platforms, Platform services and hosting, Content performance and features testing (A/B testing), Analytics, Handling payments, Data transfer outside the EU, Location-based interactions, Hosting and backend infrastructure, Registration and authentication and Marketing.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Analytics collected directly (AVOXI, Inc. Websites, Apps, and Services)

  AVOXI, Inc. Websites, Apps, and Services uses an internal analytics system that does not involve third parties.

  Personal Data collected: Cookies; Usage Data.

  Google Ads conversion tracking (Google Inc.)

  Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on AVOXI, Inc. Websites, Apps, and Services.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Google Analytics (Google Inc.)

  Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of AVOXI, Inc. Websites, Apps, and Services, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

  Wordpress Stats (Automattic Inc.)

  Wordpress Stats is an analytics service provided by Automattic Inc.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Fullstory

  Anonymous Data – Analytics
  Google Analytics: Company uses Google Analytics as a web analytics tool to track user behavior on its marketing Site. Google Analytics collects anonymized information in accordance with its Privacy Policy. However, if you do not want Google Analytics to track your behavior on the Platform, you may opt-out by installing Google Analytics Opt-out Browser Add-on.
  
  FullStory: Company utilizes FullStory for tracking user-driven events in the web application. FullStory collects information in accordance with its FullStory Privacy Policy. You can opt-out of FullStory automatic retention of data collected by clicking here: FullStory Opt Out. If you get a new computer, install a new browser, erase or otherwise alter your browser's cookie file (including upgrading certain browsers) you may also clear the FullStory opt-out cookie.
  
  https://www.fullstory.com/optout/

• Backup saving and management

  This type of service allows the Owner to save and manage backups of AVOXI, Inc. Websites, Apps, and Services on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to AVOXI, Inc. Websites, Apps, and Services.

  Backup on Google Drive (Google Inc.)

  Google Drive is a service to save and manage backups provided by Google Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

• Contacting the User

  Contact form (AVOXI, Inc. Websites, Apps, and Services)

  By filling in the contact form with their Data, the User authorizes AVOXI, Inc. Websites, Apps, and Services to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data collected: address; city; company name; email address; first name; last name; phone number; state.

  Phone contact (AVOXI, Inc. Websites, Apps, and Services)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to AVOXI, Inc. Websites, Apps, and Services, as well as for fulfilling support requests.

  Personal Data collected: phone number.

• Content performance and features testing (A/B testing)

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of AVOXI, Inc. Websites, Apps, and Services.

  Visual Website Optimizer (Wingify)

  Visual Website Optimizer is an A/B testing service provided by Wingify Inc.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on standard contractual clauses (AVOXI, Inc. Websites, Apps, and Services)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
  This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.

  Personal Data collected: various types of Data.

  Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (AVOXI, Inc. Websites, Apps, and Services)

  If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
  In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
  Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.

  Personal Data collected: various types of Data.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of AVOXI, Inc. Websites, Apps, and Services and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Site Search (Google Inc.)

  Google Site Search is a search engine embedding service provided by Google Inc. that allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of this kind on its pages.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Google Maps widget (Google Inc.)

  Google Maps is a maps visualization service provided by Google Inc. that allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of this kind on its pages.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Google Fonts (Google Inc.)

  Google Fonts is a typeface visualization service provided by Google Inc. that allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of this kind on its pages.

  Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Instagram widget (Instagram, Inc.)

  Instagram is an image visualization service provided by Instagram, Inc. that allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of this kind on its pages.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  YouTube video widget (Google Inc.)

  YouTube is a video content visualization service provided by Google Inc. that allows AVOXI, Inc. Websites, Apps, and Services to incorporate content of this kind on its pages.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Handling payments

  Payment processing services enable AVOXI, Inc. Websites, Apps, and Services to process payments by credit card, bank transfer or other means. To ensure greater security, AVOXI, Inc. Websites, Apps, and Services shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  Authorize.Net (Authorize.Net)

  Authorize.Net is a payment service provided by Authorize.Net.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable AVOXI, Inc. Websites, Apps, and Services to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of AVOXI, Inc. Websites, Apps, and Services. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Google Cloud Storage (Google Inc.)

  Google Cloud Storage is a hosting service provided by Google Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of AVOXI, Inc. Websites, Apps, and Services.
  The interaction and information obtained through AVOXI, Inc. Websites, Apps, and Services are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out from the respective services in order to make sure that the processed data on AVOXI, Inc. Websites, Apps, and Services isn’t being connected back to the User’s profile.

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Facebook Like button and social widgets (Facebook, Inc.)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  Google+ +1 button and social widgets (Google Inc.)

  The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

  LinkedIn button and social widgets (LinkedIn Corporation)

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  YouTube button and social widgets (Google Inc.)

  The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Inc.

  Personal Data collected: Usage Data.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Interaction with live chat platforms

  This type of service allows Users to interact with third-party live chat platforms directly from the pages of AVOXI, Inc. Websites, Apps, and Services, for contacting and being contacted by AVOXI, Inc. Websites, Apps, and Services support service.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

  Snapengage Widget (TimZon, LLC.)

  The Snapengage Widget is a service for interacting with the Snapengage live chat platform provided by TimZon, LLC.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

• Location-based interactions

  Geolocation (AVOXI, Inc. Websites, Apps, and Services)

  AVOXI, Inc. Websites, Apps, and Services may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by AVOXI, Inc. Websites, Apps, and Services.

  Personal Data collected: geographic position.

• Marketing

  Consent to Receive Email Messages

  You consent to receive e-mail messages that are of promotional nature from AVOXI to market, promote, and drive engagement of our products and services. We use data about you to send promotional communications that may be of specific interest to you. Based on the information we collect about you, we may decide whether and how to promote certain of our products or services to you over others. These communications are to drive your engagement and maximize the value of our services to you. To perform the above functions and others described in this Privacy Policy, we may match information collected from you, including personal data and usage information, and use such information in communications. You can opt out of promotional communications at any time by clicking the unsubscribe button.

• Platform services and hosting

  These services have the purpose of hosting and running key components of AVOXI, Inc. Websites, Apps, and Services, therefore allowing the provision of AVOXI, Inc. Websites, Apps, and Services from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  WordPress.com (Automattic Inc.)

  WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host AVOXI, Inc. Websites, Apps, and Services.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: USA – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow AVOXI, Inc. Websites, Apps, and Services to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, AVOXI, Inc. Websites, Apps, and Services will be able to access some Data, stored by these third-party services, for registration or identification purposes.

  Google OAuth (Google Inc.)

  Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy. Privacy Shield participant.

• Remarketing and behavioral targeting

  This type of service allows AVOXI, Inc. Websites, Apps, and Services and its partners to inform, optimize and serve advertising based on past use of AVOXI, Inc. Websites, Apps, and Services by the User.
  This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

  Google Ads Remarketing (Google Inc.)

  Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location AVOXI, Inc. Websites, Apps, and Services is accessed from that connects the activity of AVOXI, Inc. Websites, Apps, and Services with the Google Ads advertising network and the DoubleClick Cookie.

  Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: US – Privacy Policy – Opt Out. Privacy Shield participant.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on AVOXI, Inc. Websites, Apps, and Services in a centralized fashion.
  This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

  Google Tag Manager (Google LLC)

  Google Tag Manager is a tag management service provided by Google LLC.

  Personal Data collected: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

• User database management

  This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to AVOXI, Inc. Websites, Apps, and Services, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving AVOXI, Inc. Websites, Apps, and Services.
  Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on AVOXI, Inc. Websites, Apps, and Services.

  Salesforce Sales Cloud (salesforce.com, inc.)

  Salesforce Sales Cloud is a User database management service provided by salesforce.com, inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Pardot (Salesforce.com, inc.)

  Pardot is a User database management service provided by Salesforce.com, inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

Further information about Personal Data

• DocuSign

  Provider
  DocuSign, Inc.
  
  Purpose
  Handles documents (contracts) for review and signature
  
  Personal Data collected
  Various types of data as specified in the privacy policy of the service
  
  Privacy Policy
  DocuSign is service used to process and store document information on behalf of its clients to allow its clients' customer (or the customer’s Authorized Users) to review and sign such documents (contracts).

• Call Recording and Monitoring

  Purpose
  
  Call recording and monitoring allow service improvement which AVOXI provides to ensure call quality, to manage services and user experience, and to confirm compliance to policies and procedures.
  
  
  Personal Data collected
  
  Various types of data may be collected such as IP address, name, location, account details, and phone number.
  
  
  Privacy Policy
  
  AVOXI has a legitimate reason to process the personal data collected to enable our ability to provide services, administer customer accounts, and operate its business.

• The Service is not directed to children under the age of 13

  Users declare themselves to be adult according to their applicable legislation. Minors may use AVOXI, Inc. Websites, Apps, and Services only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use AVOXI, Inc. Websites, Apps, and Services.

• Privacy Shield participation: data transfers from the EU and Switzerland to the United States

  The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

  If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner’s certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).

  What does this mean for the European User?

  The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.

  This, most importantly, includes the right of individuals to access their personal data processed by the Owner.

  The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.

  With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.

  The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

  Dispute resolution under the Privacy Shield

  In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.

  In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.

  In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.

  Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

AVOXI, Inc. Websites, Apps, and Services uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of AVOXI, Inc. Websites, Apps, and Services or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, AVOXI, Inc. Websites, Apps, and Services may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, AVOXI, Inc. Websites, Apps, and Services and any third-party services may collect files that record interaction with AVOXI, Inc. Websites, Apps, and Services (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

AVOXI, Inc. Websites, Apps, and Services does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within AVOXI, Inc. Websites, Apps, and Services and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.