Privacy Notice

Last update: 11/09/18
Thank you for visiting Avitar Site!

Your privacy and security of your personal data is and will always be incredibly important and valuable for us. That is why, we want to transparently explain how and why we collect, store, share and use your personal data – as well as tell you about choices and rights which you have under this Notice.

Please take your time to read our Notice. In case you don’t agree with the way we treat your personal data please stop using the Site.

1. Introduction

This Privacy Notice (“Notice”) together with the Terms of Use form the entire legal Agreement (“Agreement”) between Avitar Group (“Avitar”, “Company”, “we”, “us” or “our”) and you as a user (“you”, “user”). The Agreement applies to our website (“Site”) located at https://avitar.group/

The aim of this Notice is to:

  • Ensure, that you understand what personal data we collect, the reasons why we collect and use it, and with whom we share it;
  • Explain the way we use the personal data that you give us;
  • Explain your rights and choices in relation to the personal data , and how we will protect your privacy.

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2. What personal data we collect?

Our Site is designed so that you may generally browse it without providing any Personal Information (defined below). Certain areas of the our Site, however, may require or allow the voluntarily submission of certain information (for example, leaving request on our Site).

Personal data or personal information is any information about an individual from which a person can be identified. However, such data does not include anonymous data (data where the identity has been removed).

We may collect, use, retain different kinds of personal data about you, for example:

  • Identity data such as name, last name;
  • Contact data such as email address and telephone number;
  • Technical data such as internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
  • Usage data such as information about how you use our Site;

Also we may collect and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

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3. How we collect your personal data?

Generally our collection of your personal data may be divided into two categories

  • Direct interactions
  • Automated technologies or interactions

3.1. Direct interactions
You may choose to give us your Identity and Contact data by filling in forms or providing other information via our Site. This may include personal data you provide when you:

  • Request our services;
  • Contact us via our Site;
  • Provide us with feedback.

Note: We include information that you may provide in feedback in this section, because it is your decision to provide us with feedback. Moreover, you may knowingly or unknowingly provide us with your personal information that we don’t need to provide our service. Therefore, we kindly ask you not to disclose any information that you don’t want to disclose in your feedback. You are responsible for information that you provide in feedback.

3.2. Automated technologies or interactions
When you interact with our Site we may automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies and other similar technologies. Find out more about our use of cookies further in this Privacy Notice.

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4. How do we use information we collect?

We only use your personal data when we have legal grounds to do so. Our usage of information that we collect may divided into following categories:

  • Performance of the contract;
  • Pursuance of legitimate interest;
  • Compliance with legal obligations.

We have set out in the table below the reasons why we process your personal data, the associated legal bases we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 2) used for these purposes:

Description of why Avitar processes your personal data (“processing purpose”) Legal basis for the processing purpose Categories of personal data used by Avitar for the processing purpose
To provide, personalize and improve your experience. Example by providing customized, personalized service which will fit your needs.
  • Performance of a Contract
  • Legitimate interest
  • Identity data
  • Contact data
  • Technical data
To understand how you access and use our Site to ensure technical functionality. To develop new products and services, and analyze your use of the Site, conducting researches to improve content and general administration of our Site.
  • Performance of a Contract
  • Legitimate interest
  • Technical data
  • Usage data
To communicate with you.
  • Performance of a Contract
  • Legitimate interest
  • Identity data
  • Contact data
To comply with our legal obligations.
  • Performance of a Contract
  • Legitimate interest
  • Compliance with legal obligations
  • Identity data
  • Contact data
  • Technical data

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5. Do we share and disclose your information?

If you provide us with your personal identifiable information, we may share and disclose information that we collect for following reasons:

  • With your consent;
  • Safety, legal purposes, and law enforcement;
  • Business transfers;
  • Aggregated data;
  • Service providers.
  1. 5.1. With your consent

    In cases where you have provided your explicit consent, we may share your personal data , as described at the time of consent.

  2. 5.2. Safety, Legal purposes, and Law enforcement

    We will disclose your personal data (a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an ongoing investigation of a governmental authority, (b) to enforce the Avitar’s Site Terms of Use or user agreements or to protect our rights.

  3. 5.3. Business transfers

    We will not sell your personal data to any company or organization, but we may transfer your personal data to a successor entity upon a merger, consolidation or other corporate reorganization in which Avitar Group participates or to a purchaser or acquirer of all or substantially all of Avitar Group ‘s assets to which this Site relates. In such event we will notify you before your personal data is transferred and becomes subject to a different privacy Notice.

  4. 5.4. Aggregated data

    Through the third party analytic providers and directly through our Site, we may track information that will be maintained, used and disclosed in aggregate form only and which will not contain your personal data . For example, without limitation, the total number of visitors of our Site, the browser type. We may analyze this data for trends and statistics in the aggregate, and we may use such aggregate information to administer the Site, and gather broad demographic information for aggregate use.

  5. 5.5. Service providers

    We may provide your personal data and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our services to you for their use solely to provide us with such assistance.

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6. Other important information

In this section we will describe other important information that our users need to know. Such information includes:

  • Children’s privacy;
  • Cookies;
  • Third-party websites;

6.1. Children’s privacy
Avitar Group recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Our Site is not directed to children under the age of 13. Avitar Group does not target its Site to children under 13. Avitar Group does not knowingly collect personal data from children under the age of 13. If we learn that a child under the age of 13 provided us with personal data , we will delete that information. If your child has provided personal data , please contact us so we can delete it. If you are under the age of 13, please do not provide us with any personal data.

6.2. Cookies
A cookie is a piece of data stored on the user’s hard drive containing information about the user. Cookies generally do not permit us to personally identify you. We generally use session cookies to save your preferences and such cookies expire when you close your browser. These cookies are likely to be analytical, or performance cookies.

We, along with third-party vendors such as Google use first-party cookies (such as the Google Analytics cookies) you can find out more about this popular website analytics tool here.

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and anonymous. It is only used to improve how a website works. All of this information is anonymized. You can find out more about how it protects your data here.

You can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.

6.3. Third-party websites
The Site may provide links to other Websites or resources over which Avitar does not have control (“External Web Sites”). Such links do not constitute an endorsement by Avitar of those External Web Sites. You acknowledge that Avitaris providing these links to you only as a convenience, and further agree that Avitaris not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

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7. What are your choices and rights?

In case you provide us with your personal data such as email you may use your powers and exercise any of the of the rights described in this section by sending an email to info@avitar.group

7.1. Choices
Under this Privacy Notice you have following choices:

  • Not to provide us with personal data
  • Turn off cookies
  1. 7.1.1. Not to provide us with personal data

    You can choose to not to provide us with personal data. If you choose to do so, you can continue to use the Site and browse its pages, but we will not be able to process any of your requests.

  2. 7.1.2. Turn off cookies

    You can block cookies by activating a setting on your browser allowing you to refuse cookies. You can also delete cookies through your browser settings. If you turn off cookies, you can continue to use the Site and browse its pages.

7.2. Rights
Under this Privacy Notice you have following rights:

  • Right of access;
  • Right to rectification of inaccurate or incomplete information;
  • Right to data portability;
  • Right to be forgotten and data retention;
  • Right to restrict processing and to withdraw consent;
  • Right to object processing;
  • Right to lodge a complaints;
  • Right not to be subject to automated decision-making.
  1. 7.2.1. Right of access

    You have the right to be informed of and request access to the personal data we process about you that you provided directly to us by sending an email to our support at info@avitar.group.

  2. 7.2.2. Right to rectification of inaccurate or incomplete information

    You have the right to ask us to correct inaccurate or incomplete personal data that you have provided directly to us by contacting our support at info@avitar.group.

  3. 7.2.3. Right to data portability

    You have the right to request a copy of your personal data in electronic format and the right to transmit that personal data for use in another party’s service (where technically feasible).

  4. 7.2.4. Right to be forgotten

    You the right to request that we delete your personal data if it is no longer necessary for us to hold the information for purposes of your use of Avitar.

  5. 7.2.5. Right to restrict processing

    You have the the right to request that we temporarily or permanently stop processing all or some of your personal data.

  6. 7.2.6. Right to object processing

    You have the right to, at any time, to object to us processing your personal data on grounds relating to your particular situation. You have the right to object to your personal data being processed for direct marketing purposes;

  7. 7.2.7. Right to lodge a complaints

    You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities.

  8. 7.2.8. Right not to be subject to automated decision-making

    You have a right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

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8. How do we retain and secure data?

In this section we will tell you how we store, retain and secure information.

8.1. Data retention
We generally retain your personal data for as long as is necessary for the provision of our service to you and us and to comply with our legal obligations. If you request, we will delete or anonymise your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:

  • Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law;
  • Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.

8.2. Data Security
We may employ procedural and technological measures that are generally consistent with industry practice. Such measures are reasonably designed to help protect your personal data from loss, unauthorized access, disclosure, alteration or destruction. Avitar Group may use encryption, secure socket layer and password protection to help prevent unauthorized access to your personal data.

Moreover, we are actively monitoring and enforcing the information protection standards during all of our activities, namely:

  • Limitation of the rendered access to information only to those employees who need it for providing services to you;
  • Signature of non-disclosure agreements by employees;
  • Signature by partners and external companies invited for the fulfillment of particular functions of non-disclosure agreements and agreements concerning non-usage of such information for any unauthorized purposes;
  • Storing of the personal data obtained from you in encrypted form, on protected servers secured from unauthorized access.

The security of your information is important to us. Nevertheless, we cannot guarantee absolute protection of your personal data. If you have a reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us in writing at info@avitar.group.

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9. How do we update Privacy Notice?

Avitar Group may need to update this Privacy Notice from time to time. If so, Avitar Group will post our updated Privacy Notice in our Site, along with notice that the Privacy Notice has been changed so you are always aware of what personal data we may collect and how we may use such data. Avitar Group encourages you to review this Privacy Notice regularly for any changes. Your continued use of this Site and/or continued provision of personal data to us will be subject to the terms of the then-current Privacy Notice.

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10. Glossary

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and most secure experience. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of a Contract means processing your data where it is necessary for the performance of a contract to which you are party or to take steps at your request before entering into such a contract.

Compliance with legal obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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11. Contact us

Thank you for reading our Privacy Notice. If you have any questions about this Notice, please contact us by:

Avitar Group, Mendeleeva st. 37,
Kyiv 01103, Ukraine

info@avitar.group

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