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 Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: 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, Marketing, Access to third-party accounts, Information collection, Managing landing and invitation pages and Connecting Data.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

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

• Access to third-party accounts

  This type of service allows AVOXI, Inc. Websites, Apps, and Services to access Data from your account on a third-party service and perform actions with it.
  These services are not activated automatically, but require explicit authorization by the User.

  ZipWhip SMS

  Privacy Policy
  
  Revised and Effective: December 9, 2017
  
  Version 2.3
  
  Zipwhip, Inc. (“Company“) appreciates your trust and is committed to protecting your privacy. We have prepared this Privacy Policy to describe to you what data we collect, why we do so, and what we do with it. It applies to the personal information we collect from users of our website located at https://www.zipwhip.com(the “Site“), our Application Program Interfaces (collectively the “API“), our downloadable software applications (to include mobile applications) (each, an “Application“), and online services available therein (the “Services“).
  
  Questions; Contacting Company; Reporting Violations. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at the following address or phone number:
  Zipwhip, Inc.
  
  1501 1st Ave South
  Suite 500
  Seattle, WA 98134
  
  1-855-ZIPWHIP (947-9447)
  
  Types of Data We Collect.
  (a) We collect personal information from users or prospective customers during their use of the website, use of our products, or communication with our employees. This includes: (1) basic data passed during text message transmission (including, but not limited to, message content, photos, files, and message count/volume), (2) information entered in website forms or when creating or using accounts, (3) mobile device information including mobile devise identification, service provider, and location, (4) payment information, and (5) information or feedback provided through e-mail, voice, letter, or online posting. We also collect data (including phone number, transmission, and message data) from general text messaging users who send messages to users of Company Services.
  
  (b) We also collect information using technology. We gather (1) clicking, browsing, and use data/patterns (including, but not limited to, information gathered through “cookies” and “pixel tags” as well as information about your IP address, browser, internet service provider, pages, operating system, date/time stamps, and clickstream data), (2) information about your mobile device, use of our app, or app performance and (3) information (via “pixel tags”) about how emails we have sent have been accessed. Third-party advertisers or data analytics providers also gather similar information and/or match this information to that from other sources.
  
  Use of Your Information
  (a) General Use. In general, personal information you submit to us is used to provide the Services, for our direct marketing purposes, to respond to requests that you make, or to aid us in serving you better. We will also use the information to contact you via e-mail or phone call for (1) phone number verification, (2) marketing/promotional purposes, (3) enrollment/activation activities, (5) response to your request/inquiry, (6) encouraging or enabling your use of the Services including, but not limited to, specific features, (7) billing inquiries, (8) to address possible inappropriate use, or at our Company”s discretion, (9) to provide users material updates related to the Services.
  
  (b) User Feedback. If you provide us with feedback, we may post it on the Site or our blog from time to time. (We love to share positive customer experiences!) If we desire to post your full first and full last name along with the feedback, we will ensure that we obtain your consent prior to posting.
  
  (c) Creation of Anonymous Data. We may create anonymous data records from personal information by excluding information that makes the data personally identifiable to you or your business. We reserve the right to use anonymous data for any purpose and disclose anonymous data to third parties in our sole discretion.
  
  Disclosure of Your Personal Information. We disclose your personal information as described below and as described elsewhere in this Privacy Policy.
  (a) Third Parties Designated by You. When you use the Services, the personal information you provide will be shared with the third parties that You designate to receive it (for example, the person you are texting).
  
  (b) Third Party Service Providers. We may share your personal information with third party service providers: (1) to provide you with the Services that we offer you through our Site, (2) to enable message transmission, (3) to conduct quality assurance testing or audits, (4) for our own marketing purposes, (5) to facilitate enrollment and creation of accounts, (6) to provide technical support, (7) to facilitate data storage, (8) for billing, (9) to manage sales accounts, and/or (10) to provide other services to our Company. These third-party service providers are required to not use your personal information other than to provide the services requested by our Company.
  
  (c) Public Profile. Profile information, such as your profile photo, name, and telephone number, may be shared between users of Zipwhip Services when communicating via text-enabled landlines.
  
  (d) Corporate Restructuring. We may share some or all of your personal information in connection with or during negotiation of any merger or change in ownership of all or a portion of our business or assets.
  
  (e) Marketing. Personal information will not be used for third party marketing purposes with the following exceptions: (1) Third party analytics companies or advertisers on our website may collect and use information via their own technical tools such as cookies. This policy does not apply to, and we are not responsible for, cookies used by analytics companies or in third party ads. We encourage you to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technologies. If you would like more information about this practice and to know your choices about not having this information used by these companies, click here: http://www.networkadvertising.org. And, (2) third parties may track and record user clicking/browsing data as related to retargeting display adds.
  
  (f) Other Disclosures. Regardless of any choices you make regarding your personal information (as described below), our Company may disclose your personal information if it believes in good faith that such disclosure is necessary (i) in connection with any legal investigation; (ii) to comply with relevant laws or to respond to subpoenas or warrants served on Company; (iii) to protect or defend the rights or property of Company or users of the Application or Services; and/or (iv) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Use.
  
  Your Choices Regarding Your Information. You have several choices regarding use of information on our Services:
  (a) Email Communications. You may indicate a preference to stop receiving further marketing e-mail from us and may “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Despite your indicated e-mail preferences, we may send you service related communications.
  
  (b) Changing Your Personal Information. You may change certain elements of personal information in your Account by logging into the Site. You may requested deletion of your personal information by us, and at our discretion, we may use commercially reasonable efforts to honor your request; but, please note that we may be required to keep such information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives. We may also retain your information for fraud prevention or similar purposes.
  
  Security of Your Personal information. Your security matters to us. We use a variety of security technologies and procedures designed to help protect your personal information from unauthorized access, use, or disclosure.
  Information from Children. From time to time as part of a special Zipwhip promotion, such as “texting to Santa,” we may request information from children under 13 years of age. We will take all necessary steps to protect the privacy and safety of any child participating in these activities in accordance with the Children’s Online Privacy Protection Act (COPPA).
  Obtaining Verifiable Parental Consent. We will use reasonable effort to obtain verifiable parental consent prior to the collection and use of personally identifiable information from children under 13. The method of parental consent verification may vary according to the event in which the child wishes to participate. Means of obtaining such consent may include, but are not limited to, offline consent such as printing and submitting a permission form by mail or fax or online consent that contains information that enables Zipwhip to verify the identity of the parent.
  Parental Review. Zipwhip will allow parents to review any personal information collected from their children, based on verifying the identity of the consenting parent. Parents may revoke their consent and delete information collected from their children at their discretion. In such event, Zipwhip will then stop collecting, using, or disclosing information from that child, and will end that child’s participation in that event.
  When Parental Consent is not Required. We do not require parental consent in order to collect and use information texted to Zipwhip to:
  Respond more than once directly to a specific request from a child and not used to re-contact the child beyond the scope of the child’s request (e.g. a response to a child’s text to Santa);
  Request the name or online contact information of a parent for the sole purpose of obtaining a verifiable parental consent or providing parental notification; or
  Respond directly to a child’s request on a one-time basis to a specific request where the information is not used for purposes other than the event (e.g. Santa’s response to a child’s text request).
  Texts received from children under the age of 13 will not be used for any purpose unrelated to a particular event; each will only be stored long enough to complete the event and will be promptly deleted thereafter from Zipwhip databases.
  
  Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision. When changes are made, the Company will make a new copy of the Privacy Policy available at the Site. Any changes to this Privacy Policy will be effective upon thirty (30) calendar days following our posting of the changes on our Site. These changes will be effective immediately for new users of our Service. If you do not wish to permit changes in our use of your personal information, you must notify us prior to the effective date of the changes that you wish to deactivate your Account with us. Continued use of our Site, Application or Service, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: Cookies; Usage Data.

  Category of personal data collected according to CCPA: internet information.

  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 processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Wordpress Stats (Automattic Inc.)

  Wordpress Stats is an analytics service provided by Automattic Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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/

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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

  Matomo is an analytics software used by AVOXI, Inc. Websites, Apps, and Services to analyze data directly without the help of third parties.

  Personal Data processed: Cookies; Usage Data.

  Category of personal data collected according to CCPA: internet information.

• 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 processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

• Connecting Data

  This type of service allows the Owner to connect Data with third-party services disclosed within this privacy policy.
  This results in Data flowing through these services, potentially causing the retention of this Data.

  Zapier (Zapier, Inc.)

  Zapier is a workflow automation service provided by Zapier, Inc. that automates the movement of Data between (third-party) services.

  Personal Data processed: company name.

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

  Category of personal data collected according to CCPA: commercial information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: address; city; company name; email address; first name; last name; phone number; state.

  Category of personal data collected according to CCPA: identifiers; commercial information.

  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 processed: phone number.

  Category of personal data collected according to CCPA: identifiers.

  FormSite

  Formsite does not access, view, sell, share, rent, or trade any information collected by customer forms for any purposes aside from naturally occurring exposure as a result of customer support, fraud prevention, or other maintenance activities, or as may be required by law.
  
  Privacy Statement | Formsite
  https://www.formsite.com/privacy/#:~:text=required%20by%20law.-,Form%20visitors,may%20be%20required%20by%20law.

• 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 processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google Optimize (Google LLC)

  Google Optimize is an A/B testing service provided by Google LLC ("Google").

  Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: various types of Data.

  Category of personal data collected according to CCPA: internet information.

  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 processed: various types of Data.

  Category of personal data collected according to CCPA: internet information.

• 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 processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: 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.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Wistia widget (Wistia, Inc.)

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

  Personal Data processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  3BMeteo widget (Meteosolutions srl)

  3BMeteo widget is a content visualization service provided by 3BMeteo and Meteosolutions srl.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: Italy – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  PayPal (PayPal Inc.)

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

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

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

  Category of personal data collected according to CCPA: internet information.

• 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 processed: various types of Data as specified in the privacy policy of the service.

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

  Category of personal data collected according to CCPA: internet information.

• Information collection

  Privacy Shield

  In compliance with the Privacy Shield Principles, Avoxi, Inc. commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Avoxi, Inc. at:
  
  Privacy@avoxi.com and/or Weston.Edmunds@avoxi.com or call +1.678.348.5042
  
  Avoxi, Inc. has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  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 processed: Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: Cookies; Usage Data.

  Place of processing: US – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: geographic position.

  Category of personal data collected according to CCPA: geolocation data.

• Managing landing and invitation pages

  This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
  Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.

  Unbounce (Unbounce Marketing Solutions Inc.)

  Unbounce is a landing page management service provided by Unbounce Marketing Solutions Inc., that allows AVOXI, Inc. Websites, Apps, and Services to collect the email addresses of Users interested in its service.
  Unbounce allows 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 the created landing pages.

  Personal Data processed: Cookies; email address; Usage Data.

  Place of processing: Canada – Privacy Policy.

  Category of personal data collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Clearbit

  Clearbit is a B2B marketing data engine that helps businesses sell to other businesses. They enable them to better understand the businesses they sell to, identify future prospects, and personalize their marketing and sales interactions. Our proprietary indexing systems ("Clearbit Indexers") collect information from a variety of sources in order to compile "Attribute Data" about corporations, non-profits, and similar entities ("Companies") and the professionals that work for them ("Professionals"). A complete list of Attribute Data we make available to users of the Site and Services (defined below) can be found at www.clearbit.com/attributes. Learn more here https://clearbit.com/privacy

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: USA – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: various types of Data as specified in the privacy policy of the service.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
  Some services offer a remarketing option based on email address lists.
  In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.

  Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

  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 processed: Cookies; Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 or by Google Ireland Limited, depending on the location AVOXI, Inc. Websites, Apps, and Services is accessed from.

  Personal Data processed: Usage Data.

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

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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 processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Pardot (Salesforce.com, inc.)

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

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

  Place of processing: United States – Privacy Policy.

  Category of personal data collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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).

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• 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.

• CCPA: Collection of personal information about consumers aged 13 to 16

  We collect personal information of consumers between the age of 13 and 16 and won't sell their data unless those consumers have opted-in.

  
  
  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• CCPA: Collection of personal information about minors

  We do not knowingly collect personal information of consumers who are below the age of 16.

  
  
  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• CCPA: Collection of personal information about consumers below the age of 13

  We collect personal information of consumers below the age of 13 and won't sell their data unless their parents or guardians have opted-in on behalf of those minors.

  
  
  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

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 Trackers. To learn more, 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 notifying 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.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running AVOXI, Inc. Websites, Apps, and Services and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, commercial information, internet information and geolocation data.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use AVOXI, Inc. Websites, Apps, and Services.

For example, you directly provide your personal information when you submit requests via any forms on AVOXI, Inc. Websites, Apps, and Services. You also provide personal information indirectly when you navigate AVOXI, Inc. Websites, Apps, and Services, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of AVOXI, Inc. Websites, Apps, and Services and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by AVOXI, Inc. Websites, Apps, and Services, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of AVOXI, Inc. Websites, Apps, and Services and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

• the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • for sales, the personal information categories purchased by each category of recipient; and
  • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on AVOXI, Inc. Websites, Apps, and Services, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.