If you reside in the European Union (“EU”) or the European Economic Area (“EEA”), the European Union General Data Protection Regulation (“GDPR”) will apply to how we collect and process your personal information. If you reside in the United Kingdom (UK), the United Kingdom General Data Protection Regulation (“UK GDPR”) will apply to how we collect and process your personal information. Under the GDPR and UK GDPR, EU, EEA, and UK residents have certain rights with respect to their personal information. You can make the following choices regarding your personal information:
AVENEW SOLUTIONS, LLC AS DATA CONTROLLER
PERSONAL DATA WE PROCESS
“Personal Data” refers to any information that relates to you directly or indirectly or any other “personal data” as defined in Article 4 point 1 of Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”). We process the following categories of Personal Data:
Contact information, such as your name, home or business address, email address, and phone number, social media handles, and business contact information;
Customer information, which includes information provided or made available to us by or on behalf of our customers and information generated by us in the course of providing services to our customers;
Technical information, such as data collected about your interaction with our websites, mobile applications, and email communications;
Financial information, such as payment card, debit card and personal information for customer onboarding, account processing, and when providing any of our Services;
Identification or background information provided by you or collected by us or third parties as part of our customer engagements, business analysis, customer onboarding, regulatory compliance checks, and related processes; and
Any other information that you provide us that can be used to identify you.
PERSONAL DATA WE COLLECT
Direct interactions, such as when you inquire about our Services, provide us your contact details, register for an event with us, provide us with information in connection with our Services, participate in surveys or questionnaires, subscribe to newsletter and blog updates, post comments on our blogs, or in any way engage with us or our personnel;
Cookies and automated technologies, such as when you interact with our website, mobile applications or click on links on our emails;
Mobile applications, such as when you use mobile applications that we may offer as part of our Services;
Private third party sources, such as when third parties provide information to us;
Through social media, such as if you link to social media platforms or use social media plug-ins, we may (depending on your user privacy settings on that social media platform) automatically receive information about you from that social media platform;
Public sources, such as Personal Data from publicly available sources including, government and law enforcement agencies, companies, and land registries; and
Security systems, such as when you visit our offices, we may obtain closed circuit television (“CCTV”) footage and other information through electronic means such as security/swipe card records.
HOW WE USE YOUR PERSONAL DATA
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 personal information to request feedback and to contact you about your use of our Services.
To enable user-to-user communications. We may use your personal information in order to enable user-to-user communications with each user's consent.
To manage user accounts. We may use your personal information for the purposes of managing your 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 personal 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. We may use your personal information 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 personal information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
Administer prize draws, and rewards programs. We may use your personal information to administer prize draws, and rewards programs when you elect to participate.
To deliver and facilitate delivery of services to the user. We may use your personal information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may use your personal 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 personal 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.
SOCIAL MEDIA LOGINS
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.
Special Categories of Personal Data includes information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, and data concerning health, sex life, and sexual orientation.
We only process Special Categories of Personal Data if you give us your explicit consent, the processing is necessary to meet a legal or regulatory obligation, the processing is in connection with the establishment, exercise, or defense of our or our customer’s legal claims or is otherwise expressly permitted by the GDPR.
If we need to collect Personal Data by law or under the terms of an engagement or contract we have with you and you fail to provide us with the information when requested, subject to our regulatory ethics, we may not be able to continue the engagement or perform the contract we have, or are trying to enter into, with you. We will inform you of any mandatory Personal Data we require from you and the consequences if you fail to provide it.
HOW WE SHARE YOUR PERSONAL DATA
We will share your Personal Data within our company or affiliates, with data processors, employees, distributors, licensees, and other staff members for accounting, tax, and other administrative purposes. We may disclose your Personal Information to such professional consultants as accountants, lawyers, and financial advisors.
We engage other AveNew Solutions LLC Entities as well as third-party service providers for the provision of services that help us in processing Personal Data and providing services to our customers. These will process your personal data as data processors (Article 28 GDPR) solely on our behalf. The categories of such recipients include:
service providers for information technology and telecommunications (such as data centers, hosting providers, email service providers);
marketing service providers;
accounting service providers;
forensic service providers;
corporate services and litigation support providers;
trustee and nominee service providers;
incorporation service providers;
cyber security providers; and
business process outsourcing providers.
In addition, we may share your Personal Data with:
Any party for whom your consent has been provided or other legal basis obtained, including companies we introduce you to or companies with whom you ask us to share your Personal Data;
Third parties that provide services necessary to accomplish the processing activities set forth above;
Third parties, if necessary, in relation to a merger, sale, acquisition, divesture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control (whether in whole or in part); and
INTERNATIONAL TRANSFER OF PERSONAL DATA
COOKIES AND OTHER DATA COLLECTION TECHNOLOGY
A “Cookie” is a small text file that is sent to or accessed from your web browser or your computer’s hard drive. A Cookie typically contains the name of the domain (internet location) from which the Cookie originated, the “lifetime” of the Cookie (when it expires), and a randomly generated unique number or other similar identifier. A Cookie may also contain information about your computer, such as user settings, browsing history and activities conducted while using our online Services.
A “Web Beacon” (also called a “pixel tag” or “clear GIF”) is a piece of computer code that enables us to monitor user activity and website traffic.
We refer to Cookies, web beacons (also known as pixel tags and clear GIFs) and other similar technology as “Data Collection Technology.” To learn more about cookies and web beacons, visit www.allaboutcookies.org.
Data Collection Technology helps us improve your experience on our online Services. For example, we use Google Analytics, a web-based analytics tool that tracks and reports on the manner in which the website is used to help us to improve it. Google Analytics does this by placing Cookies on your device. The information that the Cookies collect, such as the number of visitors to the website, the pages visited and the length of time spent on the website, is aggregated. We also may use Data Collection Technology to collect information from the computer or device that you use to access our online Services, such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your computer or device is located.
YOUR CONTROL OF COOKIES
Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject Cookies or alert you when a Cookies is placed on your device. You may also be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through our online Services.
Although you are not required to accept cookies, web trackers or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.
You may disable the use of advertising cookies and other tracking technologies. Please click here for Cookie and Privacy Settings. You must complete this step on each of our websites from each browser and on each device that you use. These steps are necessary so that we can place a first-party cookie signaling that you have opted out on each browser and each device you use. Please note:
If you block cookies, we will be unable to comply with your request to opt out with respect to device data that we automatically collect and disclose to third parties online using cookies, pixels, and other tracking technologies.
If you clear cookies, you will need to disable the use of all advertising cookies and tracking technologies in the preference center again on each browser on each device where you have cleared cookies.
Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. The choices available, and the mechanism used, will vary from browser to browser. Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or alert you when a cookie is placed on your computer or device.
You may also be able to reject mobile device identifiers by adjusting the appropriate setting on your mobile device. Such browser settings are typically found in the “options,” “tools” or “preferences” menu of your browser. You may also consult your browser’s “help” menu.
OUR POLICY ON DO NOT TRACK SIGNALS
Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. We follow the DNT signals we receive from your browsers.
LINKS TO THIRD PARTY WEBSITES AND SERVICES
We implement appropriate technical and organizational measures designed to ensure your Personal Data in protected from unauthorized access, use, disclosure, alteration, or destruction, in accordance with applicable laws and regulations. For example:
Limiting access of your Personal Data to authorized parties;
Limiting our collection and use of your Personal Data to the extent necessary to provide you with our Services;
If we outsource processing of Personal Data to third parties, basing our selection on said third parties having adequate safeguards in place that meet our data protection and security standards.
Having systems in place designed to ensure that we can restore the availability and access to Personal Data in the event of a physical or technical incident;
Periodically inspecting, assessing, and evaluating the effectiveness of our technical and organizational measures designed to ensure the security of our processing; and
Regularly training our personnel on data protection and cybersecurity.
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.
RETENTION OF PERSONAL DATA
We will keep your Personal Data for as long as necessary to fulfill the purposes we collected it for, including any legal, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, whether we can achieve those purposes through other means, and all applicable legal requirements.
Our online content and Services are not directed to or intended for use by minors. Consistent with the requirements of the US Children’s Online Privacy Protection Act, the GDPR, and all other applicable laws and regulations, if we learn that we have received information directly from a child under age 16 without his or her parent or legal guardian’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use our Services. Subsequently, we will delete such information.
OUR SERVICES NOT INTENDED FOR MINORS UNDER 18 YEARS OF AGE
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.
YOUR PRIVACY RIGHTS
Objections/Restriction to your personal information. You have the right to object to how personal data is processed in relation to public interest/official authority and our legitimate interests as well as direct marketing purposes – including profiling under both. You also have the right to request that processing of your personal information be restricted where its accuracy or lawfulness is contested, you need it in response to legal claims or in relation to verification as to whether legitimate interests for processing exist.
Move, copy, or export personal data. This is known as the Right of Portability. You have the right to request that your personal data be forwarded to a third party.
Please note that if you decide to exercise some of your rights, we may be unable to perform the actions necessary to achieve the purposes set out above or you may not be able to use or take full advantage of the services and products we offer.
AveNew Technologies, Inc.
5256 S. Mission Rd. Ste 703, #335
Bonsall, CA 92003