Effective Date: 04/24/2020
Aviata participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework and to the rights of both EU and Swiss Individuals. We are committed to subjecting all personal data received from European Union (EU) and Swiss member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List, https://www.privacyshield.gov/list.
Aviata is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Swiss, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Aviata is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Aviata LLC. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the Privacy Shield Principles, Aviata LLC. commits to resolve complaints about our collection or use of your personal information. EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Aviata LLC. at: firstname.lastname@example.org
Aviata LLC has further committed to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and to comply with the advice given by such authorities with regard to data transferred from the EU and Switzerland. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs or the Swiss FDPIC for more information or to file a complaint. The services of EU DPAs and Swiss FDPIC are provided at no cost to you.
Under certain conditions, more fully described on the Privacy Shield website, https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Types of Data and Collection Methods
Aviata collects data that its clients and customers actively submit “Actively Submitted Data” (registrations and surveys) as well as data collected from outer sources, “Passively Tracked Data.” These are described as follows:
- Actively Submitted Data: data collected via registration and survey completion, or otherwise manually entered on our servers, such as name, physical address, and email address.
- Passively Tracked Data: data collected about your computer, device, connected peripherals, and internet connection when you access and respond to Aviata content, the dates and times of access, the internet address of web sites from which you link to or arrive at the site, the computer technology you’re using and your movements and preferences on our site and for our registration, messaging, and survey software. Unless you actively submit personal information such as your name and address in connection with Passively Tracked Data, Passively Tracked Data does not typically allow us to identify you personally. To the extent permitted by applicable law, we reserve the right to combine Passively Tracked Data or data available via a third party with personal data that you choose to actively submit.
Collection Purposes and Data Usage
- We collect Actively Submitted Data firstly for the purpose our customers originally sent it, e.g. for registrations, product and experience feedback, and to ensure they receive requested information, materials, service, and correspondence. Secondly, we use these data to inform customers about our products and services subject to user communication preferences.
Cookies and Other Tracking Technologies
Cookies and other similar technologies are used by Aviata and our partners, affiliates, or analytics or service providers. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site, and to gather demographic information about our user base as a whole.
You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory (ex, http://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored). To manage Flash cookies, please click here: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.
Disclosures of Personal Information
Aviata won’t sell, rent, or share customer and client data to 3rd parties except in the following cases:
- Sharing information with an affiliated company for reward redemption and incentive management. If you do not want us to share your personal information with these companies, contact us at email@example.com.
- Engaging agents and service providers (i.e. data append, validation providers, marketing services) so they have access to data, but only to process such data on our behalf for purposes under confidentiality agreements.
- Sharing information as required by law or in the interest of protecting or exercising our or others’ legal rights, such as a request from law enforcement and in connection with court proceedings like a subpoena or for protecting your safety or the safety of others
- In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- Transferring information in connection with a prospective or actual sale, merger, transfer, other reorganization of all or parts of our business, or bankruptcy. You will be notified via email and/or a prominent notice on our web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information
- Using and disclosing data that is not personally identifiable or has been masked or anonymized.
Please Note: we do not control how our clients use the data we collect on their behalf.
Third Party Data Collection through Our Site
In connection with promotions or other projects, Aviata may offer customers the opportunity to opt-out of certain types or methods of communication, including email. If you have previously subscribed to receive marketing / promotional emails from us, you can opt-out by clicking on the “unsubscribe” link included in our emails. Aviata will respect customer wishes in accordance with all legal statutes.
Access to Information
Upon request Aviata will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. If the personal information we have on file about you changes, or if you no longer desire our service, you may correct, update or amend your preferences by emailing our Customer Support at firstname.lastname@example.org. We will respond to your request to access and modify your personal information within 30 days and allow you to specify changes via phone, email, or mail.
Aviata will retain customer and partner data for as long as accounts are active or as these data are otherwise needed for the delivery of services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will, however, remove specific data upon request. You may request inaccurate information to be removed or deleted by emailing us at email@example.com or by contacting us through any of our contact
details below. We will respond to your request within 30 days.
Access and Data Retention of Data Controlled by our Clients
Aviata has no direct relationship with the individuals whose personal data it processes. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to Aviata’s client, the data controller. If the client requests Aviata to remove the data, we will respond to their request within 30 days. We will retain personal data we process on behalf of our clients for as long as needed to provide services to our client. Aviata will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
The security of your personal data and the data we process on behalf of our clients is important to us. We follow generally accepted standards, such as secure socket layer (SSL) to protect the personal data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our web site, you can contact us at firstname.lastname@example.org.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at email@example.com.
Links to Other Web Sites
Changes to this Policy