Awespira Privacy Policy

PRIVACY NOTICE

Updated: May 26, 2022

 

Thank you for choosing to be part of our community at AveNew Solutions, LLC (“Company,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at Awespira@AveNew.org.

 

When you visit our website https://www.AveNew.org (the "Website"), use our mobile application, as the case may be (the "App"), and more generally, use any of our services (the "Services,” which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please discontinue use of our Services immediately.

 

This privacy notice applies to all information collected through our Services (which, as described above, includes our Website and App), as well as any related services, sales, texts, marketing, or events.

It does not apply to information collected by us offline or through any other means, including on any other website operated by the Company (or any third party). It does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or through the Services.

 

Please read this privacy notice carefully as it will help you understand what we do with the information that we collect. 

 

1. INFORMATION WE COLLECT.

 

(A)       Personal Information You Disclose To Us

 

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services (such as by posting messages in our online forums or entering competitions, contests, or giveaways) or otherwise when you contact us.

 

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

 

(i)         Personal Information Provided by You. We collect names; phone numbers; email addresses; mailing addresses; contact preferences; contact or authentication data; and other similar information.

 

(ii)        Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called “SOCIAL MEDIA LOGINS" below.

 

(B)       All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

 

(C)       The app does use third party services that may collect information used to identify you.

 

·    Privacy policy of Google Play Store.

·    Privacy policy of Apple App Store.

·    Privacy policy of Facebook.

·    Privacy policy of Twitter.

·    Privacy policy of Google.

 

 

(D)       Information Automatically Collected

 

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

 

We collect information automatically through cookies and similar technologies. The information we collect includes:

 

(i)         Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).

(ii)        We may use three types of cookies in providing the Services: required, analytics/performance, and advertising. Required cookies are essential to provide necessary security, enable you to browse around our Website and App, and use the features. Performance cookies collect information about how you use our Website and App. Advertising cookies allow us to provide you with meaningful content related to your interests and browsing history. Our cookies may change as our Website, App, and business needs change; however, the following is a list of some of the cookies we use and what they do:

 

Cookie: 1P_JAR

Type: Advertising

Purpose: Used to provide ad delivery or retargeting.

 

Cookie: hs

Type: Required

Purpose: Security cookie.

 

Cookie: SvSession 

Type: Required

Purpose: Used in connection with user login.

 

Cookie: XSRF-TOKEN 

Type: Required

Purpose: Prevents cross-site request forgery.

 

(E)        Information Collected Through Our App.

 

When you use our App, we also collect the following information:

 

(i)         Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings. The information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

 

(ii)        Personal Information. In addition to your name, email, company name and phone number, which you voluntarily provide us, we automatically collect browsing history and interests.

 

(F)        Information Collected From Other Sources

 

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.

 

Our App may rely on Tribe to provide a platform for a discussion forum. Your comments may be publicly available. Tribe’s privacy policy may be found here: https://tribe.so/privacy-policy.

 

2. HOW WE USE YOUR INFORMATION.

 

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

 

We do NOT sell user personal information.

 

We use the information we collect or receive:

 

To facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. See the section below headed "SOCIAL MEDIA LOGINS" for further information.

 

To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the consent of the testimonial. If you wish to update, or delete your testimonial, please contact us at Awespira@AveNew.org and be sure to include your name, testimonial location, and contact information.

 

Request feedback. We may use your information to request feedback and to contact you about your use of our Services.

 

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

 

To send administrative information to you. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.

 

To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).

 

To enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

 

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

 

Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

 

Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

 

To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

 

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

 

To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. For example, when expressing an interest in obtaining information about us or our Services, subscribing to marketing or otherwise contacting us, we will collect personal information from you. You can opt-out of our marketing emails at any time (see "YOUR PRIVACY RIGHTS" below).

 

Deliver targeted advertising to you. We may use your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

 

3. OUR INFORMATION SHARING POLICY.

 

A.         We may process or share your data that we hold based on the following legal basis:

 

(i)         Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

 

(ii)        Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests. Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

 

(iii)       Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

 

(iv)       Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

 

B.         More specifically, we may need to process your data or share your personal information in the following situations:

 

(i)         Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

 

(iii)       Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

 

(iv)       Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

 

(v)        Offer Wall. Our App may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our App and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our App. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please note that we do not control third- party websites and have no responsibility in relation to the content of such websites. The inclusion of any link towards a third-party website does not imply an endorsement by us of such website. Accordingly, we do not make any warranty regarding such third-party websites, and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy notice and terms of service relating to the use of those websites.

 

4.         COOKIES AND OTHER TRACKING TECHNOLOGIES.

 

We use cookies and similar automatic tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in this section.

 

A.         About cookies. A cookie is a small computer file that can be placed on your device. It is sent to your Web browser and stored on your computer or mobile device. Cookies are used to “remember” you, to provide you with content relevant to your interests, for security reasons, and to help us understand how our Website and App are being used.

 

B.         Types of Cookies We Use. We may use three types of cookies in providing the Servcies: required, analytics/performance, and advertising. Required cookies are essential to provide necessary security, enable you to browse around our Website and App, and use the features. Performance cookies collect information about how you use our Website and App. Advertising cookies allow us to provide you with meaningful content related to your interests and browsing history. 

 

C.         Our Website and App may also contain cookies set by third parties. Some of our Website’s pages rely on cookies from third parties such as Stripe to facilitate online purchases. We use cookies from Google to perform analysis on our Website and the App to help us understand how our products are being used. Third party cookies may also be used to deliver content of interest to you when you navigate away from our Website or the App.

 

D.         Examples of Cookies that We Use. Our cookies may change as our Website, App, and business needs change; however, the following is a list of some of the cookies we use and what they do:

 

Cookie: 1P_JAR

Type: Advertising

Purpose: Used to provide ad delivery or retargeting.

 

Cookie: hs

Type: Required

Purpose: Security cookie.

 

5.         SOCIAL MEDIA LOGINS.

 

In the future, we may offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.

 

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

 

6.         DATA RETENTION POLICY.

 

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

 

7.         DATA SECURITY POLICY.

 

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

 

8.         MINORS UNDER THE AGE OF 18.

 

Our Services are not directed to, nor are they intended for minors under 18 years of age. We do not knowingly solicit data from or market to minors under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from a minor less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from minors under age 18, please contact us at Awespira@AveNew.org.

 

9.         YOUR PRIVACY RIGHTS.

 

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data- protection/bodies/authorities/index_en.htm.

 

If you are resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

 

If you have questions or comments about your privacy rights, you may email us at Awespira@AveNew.org.

 

A.         Account Information. If you would at any time like to review or change the information in your account or terminate your account, you can: Log in to your account settings and update your user account. Contact us using the contact information provided.

 

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

 

B.         Cookies and similar technologies. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

 

C.         Opting out of email marketing. You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. To otherwise opt-out, you may access your account settings and update your preferences. Contact us using the contact information provided.

 

10.       CONTROLS FOR DO-NOT-TRACK FEATURES.

 

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

 

11.       NOTICE TO CALIFORNIA CONSUMERS.

 

This supplemental Notice to California Consumers only applies to our processing of personal information that is subject to the “Shine the Light” law and the California Consumer Privacy Act of 2018 (“CCPA”). 

 

A.         Shine The Light. California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

 

B.         CCPA Privacy Notice.


The California Code of Regulations defines a "resident" as:

 

Every individual who is in the State of California for other than a temporary or transitory purpose; and


Every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as "non-residents."

 

If this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.

 

C.         Categories of Information We Collect.

 

We may have collected the following categories of personal information in the past twelve (12) months: 

 

i. Identifiers 

Example: Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name 

Collected? YES 

 

ii. Personal information categories listed in the California Customer Records statute 

Example: Social Security number, passport number, driver’s license or state identification card number, insurance policy number, employment, employment history, financial information, medical information, or health insurance information

Collected? NO 

 

iii. Protected classification characteristics under California or federal law 

Example: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected? NO 

 

iv. Commercial information 

Example: Transaction information, purchase history, financial details, and payment information

Collected? NO 

 

v. Biometric information 

Example: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected? NO 

 

vi. Internet or other similar network activity 

Example: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements 

Collected? YES 

 

vii. Geolocation data 

Example: Device location 

Collected? YES

 

viii. Audio, electronic, visual, thermal, olfactory, or similar information 

Example: Images and audio, video or call recordings created in connection with our business activities 

Collected? NO 

 

ix. Professional or employment-related information 

Example: Business contact details in order to provide you our services at a business level or job title, work history, and professional qualifications if you apply for a job with us 

Collected? NO 

 

x. Non-public Education Information 

Example: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student id codes, student financial information, or student disciplinary records. 

Collected? NO 

 

xi. Inferences drawn from other personal information 

Example: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s taste, color, or purchasing preferences and characteristics

Collected? YES 

 

We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

 

Receiving help through our customer support channels;

 

Participation in customer surveys or contests; and

 

Facilitation in the delivery of our Services and to respond to your inquiries.

 

D.         Use of Your Personal Information.

 

We use your information according to the terms of this privacy policy. 

 

You may contact us by email at Awespira@AveNew.org, or by referring to the contact details at the bottom of this document.


We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

 

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

 

AveNew Technologies, Inc., has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. AveNew Technologies, Inc., will not sell personal information in the future belonging to website visitors, users, and other consumers.

 

F.         Your Rights with Respect to Your Personal Information.

 

(i)         Right to request deletion of the data - Request to delete

 

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

 

(ii)        Right to be informed - Request to know

 

Depending on the circumstances, you have a right to know:

 

Whether we collect and use your personal information;

 

The categories of personal information that we collect;

 

The purposes for which the collected personal information is used;

 

Whether we sell your personal information to third parties;

 

The categories of personal information that we sold or disclosed for a business purpose;

 

The categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

 

The business or commercial purpose for collecting or selling personal information. In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

 

(iii)       Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights We will not discriminate against you if you exercise your privacy rights.

 

(iv)       Right to Correction; Restrict Processing. You may object to the processing of your personal data you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data, you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

 

(v)        Right to Opt-Out. You may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission. To exercise these rights, you can contact us by email at Awespira@AveNew.org, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

 

(vi)       If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

 

G.        Verification Process

 

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

 

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

 

12.       REVIEWING, UPDATING OR DELETING YOUR DATA.

 

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please email Awespira@AveNew.org. We will respond to your request within 30 days.

 

13.       UPDATES TO THIS NOTICE.

 

We reserve the right to update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

14.       CONTACT INFORMATION.

 

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO), CLO, by email at Awespira@AveNew.org, by phone at 213-387-0780, or by mail to:

 

AveNew Technologies, Inc.

5256 S. Mission Rd. Ste 703, #335 

Bonsall, CA  92003