Effective Date April 1 2020.
Avochato is a cloud messaging platform that provides businesses with the tools necessary to communicate with their stakeholders through various messaging channels.
We understand that when you use Avochato’s platform you are placing your trust in us to handle your data appropriately, including the personal information of you and your stakeholders. That is why data protection is a top priority at Avochato.
In this document you’ll find information about how we process personal information in connection with your use of our products and services, including our website. We want to enable you to make informed decisions about your personal information when using Avochato. We also want to provide you with relevant information to help you make informed decisions with regards to the personal data of the people you are messaging.
If you’ve read everything here and you’ve checked out our product-specific docs, but you still have more questions or concerns about how we’re processing personal information, or you would like to know more about how to exercise your rights, contact our Privacy Team in the Office of the Data Protection Officer by either emailing us at firstname.lastname@example.org or by writing to us at our San Franscisco Headquarters located at: 203 Flamingo Road, Suite 501, Mill Valley, California, 94941.
Table Of Contents
Let's Get Oriented
Avochato processes two broad categories of personal information when you use our products and services:
Your personal information as a customer (or potential customer) of Avochato’s services — information that we refer to as Customer Account Data, and
The personal information of your end users who use or interact with your Avochato account — this category contains both your Customer Usage Data (e.g., communications metadata) and your Customer Content (e.g., the contents of communications).
Avochato processes these categories of personal information differently because the direct relationship we have with you, our customer, is different than the indirect relationship we have with your end users.
How Avochato Processes your Personal Information
Data protection laws and privacy laws in certain jurisdictions, like the European Economic Area (EEA), differentiate between “controllers” and “processors” of personal information. A controller decides why and how to process personal information.
A processor processes personal information on behalf of a controller based on the controller’s instructions. When Avochato processes your Customer Account Data, the Avochato entity with whom you are contracting is acting as a controller.
Broadly speaking, we use Customer Account Data to further our legitimate interests to:
- understand who our customers and potential customers are and their interests in Avochato’s product and services
- manage our relationship with you and other customers
- carry out core business operations such as accounting, filing taxes, and fulfilling regulatory obligations
- help detect, prevent, or investigate security incidents, fraud and other abuse and/or misuse of our products and services
What personal information Avochato collects
While we’re on the subject of Customer Account Data and Customer Usage Data, we’d like to give you a brief summary of the categories of personal information that might be found in the Customer Account Data and Customer Usage Data that we collect from our customers and their end users, so you can know at a glance what we’re talking about.
We collect and process your personal information:
- When you visit an Avochato public-facing website like www.avochato.com, sign up for an Avochato event, or make a request to receive information about Avochato or our products, like an Avochato whitepaper or a newsletter;
- When you contact our Sales Team or Customer Support Team; and
- When you sign up for Avochato and use our products and services.
We call this personal information Customer Account Data. We also collect Customer Usage Data from you when you send or receive communications through your use of our services. This data might take different forms, and we might use it for different purposes.
What Customer Account Data Avochato Processes When You Visit Our Website, Sign Up for an Avochato Event, or Make a Request for Information About Avochato and Why
When you visit our website, sign up for an Avochato event or request more information about Avochato, we collect information automatically using tracking technologies, like cookies, and through web forms where you type in your information. We collect this information to provide you with what you request through the web form, to learn more about who is interested in our products and services, and to improve navigation experience on our pages.
What Customer Account Data Avochato Processes When You Communicate with Our Sales or Customer Support Teams and Why
You may share personal information, like your contact information, with a member of our Sales or Customer Support Team when you communicate with them. We keep a record of this interaction.
What Customer Account Data Avochato Processes When You Sign Up for and Log Into an Avochato Account and Why
When you sign up for an account with us, we ask for certain information like your contact details and billing information so we can communicate with you and so you can pay for our products and services. We also collect some information automatically, like your IP address, or when you log in to your account. We use this to understand who is using our services and how, and to detect, prevent and investigate fraud, abuse, or security incidents.
Other Customer Account Data We Collect and Why
We may collect information about you, as our customer, from publicly-available sources so we can understand our customer base better.
How Long We Store Your Customer Account Data
Avochato will store your Customer Account Data as long as needed to provide you with our services and to operate our business. If you ask Avochato to delete specific personal information from your Customer Account Data (see ‘How To Make Choices About Your Customer Account Data’ below), we will honor this request unless deleting that information prevents us from carrying out necessary business functions, like billing for our services, calculating taxes, or conducting required audits.
How To Make Choices About Your Customer Account Data
You can make various choices about your Customer Account Data through the account portal, such as accessing it, correcting it, deleting it, or updating your choices about how it is used, when you log into your Avochato account. Any other requests about your data you cannot make through these self-service tools, you can request by emailing email@example.com or contacting Customer Support.
California Consumer Access and Deletion Rights
For those customers that would like more information about our use of Customer Account Data or Customer Usage Data, you have the ability to request:
- that we provide details about the categories of personal information that we collect about you, including how we collect and share it;
- that we provide you access to the personal information we collect about you; and
- that we delete the personal information we have about you.
Please be aware that when you ask us for these things, we will take steps to verify that you are authorized to make the request.
How Avochato Processes Your Contacts’ Personal Information
Your contacts’ personal information typically shows up on Avochato’s platform in a few different ways:
- Communications-related personal information about your contacts, like your contacts’ phone numbers for number-based communications and your contacts’ email addresses for email communications show up in our systems when you use or intend to use this information to contact your contacts through use of our products and services.
- Your contacts’ personal information may show up in “friendly names,” which are strings you provide, if you choose to include your contacts’ personal information as part of a string.
- Your contacts’ personal information may also be contained in the content of communications you (or your end users) send or receive using Avochato’s products and services. We call the information in the first two bullets above Customer Usage Data. The information in the third bullet is what we refer to as Customer Content.
As noted above, data protection law (including privacy law) in certain jurisdictions, like the EEA, differentiate between “controllers” and “processors” of personal information. When Avochato processes Customer Content, we generally act as a processor. When we process Customer Usage Data, we act as a processor in many respects, but we may act as a controller in others. For example, we may need to use certain Customer Usage Data for the legitimate interests of billing, reconciling invoices with telecommunications carriers, and in the context of troubleshooting and detecting problems with the network.
What Customer Usage Data and Customer Content Avochato Processes and Why
We use Customer Usage Data and Customer Content to provide services to you and to carry out necessary functions of our business as a communications service provider. We do not sell your contacts’ personal information and we do not share your end users’ information with third parties for those third parties’ own business interests.
How Long Do We Store Customer Usage Data and Customer Content, and Exercising Choices About Contacts Personal Information
Details regarding how long your contacts personal information may be stored on Avochato systems and how to delete, access, or exercise other choices about end user data will depend on which Avochato products and services you are using and how you are using them. For that reason, documentation for each of our products and services is the best place to find more detailed information about managing contact data collected and stored in connection with your use of our products and services.
When and Why We Share Your Personal Information Or Your Contacts’ Personal Information
We do not sell or allow your Customer Account Data to be used by third parties for their own marketing purposes, unless you ask us to do this or give us your consent to do this. Further, we do not sell your contacts’ personal information. We also do not share it with third parties for their own marketing or other purposes, unless you instruct us to do so.
Automated Decision Making
Avochato may use automated decision making using a variety of signals derived from account activity to help identify and suspend accounts sending spam or engaged in other abusive or fraudulent activity. Holders of accounts suspended under these circumstances are notified of the suspension and given an opportunity to request human review of the suspension decision.
Handling disputes relating to our data protection practices
We hope we can resolve any disputes relating to our data protection practices between us. You can raise your concern or dispute by emailing our Privacy Team at firstname.lastname@example.org or by writing to us at:
Avochato Inc. (our worldwide headquarters)
203 Flamingo Road, Suite 501
Mill Valley, CA 94941
For individuals in the EEA, you have additional rights to make a complaint to a competent data protection authority or commence proceedings in a court of competent jurisdiction in accordance with applicable data protection laws.
How We Secure Personal Information
We use appropriate security measures to protect the security of your personal information both online and offline. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security controls in place.
Information from Children
We do not knowingly permit children (under the age of 13 in the US or 16, if you live in the EEA) to sign up for an Avochato account. If we discover someone who is underage has signed up for an Avochato account, we will take reasonable steps to promptly remove that person’s personal information from our records. If you believe a person who is underage has signed up for an Avochato account, please contact us at email@example.com.
Avochato does not currently respond to web browser’s Do-Not-Track signals.
Changes to Our Privacy Notice
We may change our Privacy Notice from time to time. If we make changes, we’ll revise the “Effective” date at the top of this notice, and we may provide additional notice such as on the Avochato website homepage, account portal sign-in page, or via the email address we have on file for you. We will comply with applicable law with respect to any changes we make to this notice and seek your consent to any material changes if this is required by applicable law.
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