Privacy Policy

LAST UPDATED: Aug 8, 2023

1. What this Policy covers

Your privacy is important to us, as well as being transparent about how we collect, process, use, and share information about you.

This Privacy Policy covers what information we collect about you when you use our websites, products, apps, software, unless a different policy is displayed.  Avora Holdings LTD offers a wide range of products and in this Policy we refer to all of these products, along with our other services, apps, and websites as “Services”.

Revenue Grid acts as the data controller with regard to Personal Information when we collect and determine the purposes and means of the processing of such Personal Information we collect. For example, we act as the data controller when we collect information on our websites, other channels for marketing purposes.

When we process Personal Information on behalf of our customers in connection with Revenue Grid products and services, Revenue Grid acts as the data processor.

Product-specific privacy terms are described in the respective section of this Policy. This section describes how we process customer data in connection with our specific product or service.

2. What information we collect about you

We collect information about you when you provide it to us directly or via our partners, after you give your consent while using our Services or when other sources (Data Controllers) provide it to us.

Information you provide to us

We collect/process information about you when you enter it into the Services or otherwise provide it directly to us.

Account and Profile Information: We collect and store information about you when you register an account on products sign up, set your product preferences, or make purchases through the Services. For example, the contact information you provided.

The content you provide through our websites: The Services include the websites owned or operated by us. We collect content that you submit on these websites. For example, you provide content to us when you share your Services use feedback or when you get engaged with any interactive features, download marketing materials, take part in surveys, promotions, or online events.

Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with the Service. Whether you identify yourself as a technical contact, open a support ticket, speak to one of our representatives directly, or otherwise engage with our support and CSM teams, you will be asked to provide your contact information, a summary of the problem you are experiencing, and any other relevant documentation, screenshots or other details helpful for resolving the issue.

Information we collect automatically when you use the Services

We collect information about you when you use our Services, that includes browsing our websites and performing certain actions within the Services.

Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use and how you interact with others using the Services.

Device and connection information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and the settings applied when you install, access, update, or use our Services. We also collect information from your device about your operating system, browser type, URLs of the referring/exit pages, device identifiers, and crash data, if relevant. We use your IP address and/or region preference in order to approximate your location to provide you with a better Service experience. The scope of collected information depends on the type and settings of the device you use to access the Services.

Cookies and other tracking technologies: Our website and Services may use cookies and other tracking technologies to provide their essential functionality or to recognize you across different Services and devices. Please, see our Cookie Policy for more information.

Information we receive from other sources

We receive information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.

Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned by your CRM administrator when submitting an issue to our technical support. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator may provide your contact information when they designate you as the billing contact for your company’s account.

Other services you link to your account: We receive information about you when you or your administrator integrate or link a third-party service with our Services. For example, if you create an account or log into the Services using your credentials, we receive your name and email address as permitted by your System profile settings in order to authenticate you. You or your administrator may also integrate our Services with other services you use, to allow you to access, store, share and edit certain content from a third party through our Services. Or you may authorize our Services to connect with a third-party calendaring service so that your meetings and connections are available to you through the Services. The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service.

Our Partners: Some of our partners help us to market and promote our products, generate leads for us, and resell our products. We sometimes receive contact information, company name, what Our products you have purchased or may be interested in, evaluation information you have provided, what events you have attended, and what country you are in.

Other partners: We receive information about you and your activities on the Services from third-party partners, that provide us with information about your interest in and engagement with our Services.

Our Services are responsible for transferring data between systems using API technologies.

3. How we use information we collect

How we use information we collect depends on what Services you use, how you use them, and on any preferences you may have communicated to us. Below are listed specific purposes of using information about you.

To provide the Services and personalize your experience: We use information about you to provide the Services to you; this includes: transactions processing, users authentication, customer support, and Services operation and maintenance. Our Services also include tailored features that personalize your experience and enhance your productivity with them.
For research and development: We constantly look for ways to make our Services smarter, faster, and more secure, integrated, useful to you. We use collective anonymized findings about how people use our Services as well as the feedback provided directly to us to troubleshoot issues and to identify Services usage trends, activity patterns, and the areas for Services integration enhancing and general improvement. In some cases we apply these findings across our different Services to improve and develop similar features or to better integrate them with other Services you use.
To communicate with you about the Services: We use your contact information to communicate with you via email and within the Services to confirm your purchases, send reminders about subscription expiration date, respond to your questions and requests, provide customer support, send out technical notices, updates, security alerts, administrative messages, and so on. We also provide tailored communications based on your activity and interactions with us. We also send you communications as you on-board to a particular Service to help you become more proficient in using that Service.
To market, promote, and drive engagement with the Services: We may use your contact information and the information about how you use the Services to send relevant promotional communication that may be of specific interest to you; that includes promotion email and by displaying Our ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications include information about new features, survey requests, newsletters, and events that we think may be of interest to you and are aimed at driving engagement and maximizing the Services’ value for you. We also communicate with you about new product offers, promotions, and contests. You can always opt out from our email newsletters.   For the avoidance of doubt, this applies to the cases where we act as the data controller in relation to registered users of the Services. This subsection does not apply to the processing of customer data processed and synchronized by the Service.
Customer support: We use your information to resolve technical issues you may encounter with the Services, to respond to your assistance requests, to analyze crash information, and to repair and improve the Services.

With your consent: We use information about you when you have given us your consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.

Legal basis for processing (for EU and EEA users):

If you are an individual in the European Economic Area (EEA), we collect and process information about you only when we have legal basis for doing so under applicable EU laws. The legal basis depends on the Services you use and how you use them. This means we collect and use your information only when we rely on one or more of the following grounds:

We need such information to provide the Services to you, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
You give us consent to do so for a specific purpose; or
We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. When we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use. However, in some cases, this may mean that you will no longer use the Services.

4. How we share information we collect

We do not sell or trade your information with any third parties.

This section describes how we may share data collected by us for the defined purposes and in accordance with a legal basis for processing, as specified in this Privacy Policy.

Sharing with third parties 

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our services.

Service providers: We engage our contracted service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services for us, which may require them to access or use information about you. If a service provider needs to access some information about you to perform relevant services on our behalf, they do so under strict instruction from us, including a set of Policies and Procedures implemented to protect your information.

Third-party apps: You, your administrator, or other Services users may choose to add new functionality or change the behavior of the Services by installing third-party apps within the Services. Doing so may give these third-party apps access to your account and information about you, like your name and email address, and any content you choose to use in connection with those apps. We encourage you to review privacy policies of any third parties before connecting to or using their applications or services, to learn more about their privacy and information handling practices. If you object to information about you being shared with these third parties, please uninstall the app.

Links to third-party sites: The Services may include links that direct you to other websites or services whose privacy practices may differ from ours. If you submit information to any of those third-party sites, your information is governed by privacy policies of these third-party sites, and not by the present Policy. We encourage you to carefully read the privacy policy of any website you visit.

With your consent: We may share information about you with third parties if you have given us your consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name by a testimonial.

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our Agreements, Policies and Terms of Service, (c) protect the security and integrity of our products and services, (d) protect Us, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

How we store and secure information we collect

Security and storage of information

We use data hosting service providers located in the United States and Europe to host the information we collect and process, and we use industry standard technical measures to secure your data.

We have taken steps to implement appropriate security, technical, and administrative measures to prevent unauthorized disclosure, use, or access to the information.

How long we keep information

We will keep the Personal information we collect about you only for as long as we need it for the purposes it was collected, or for the period of time as may be required by law.

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

Account information: We retain your account information for as long as your account is active and for a reasonable period thereafter, in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services.

When we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain.

Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or stopped using your account at Our Services. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

With regard to Personal Information we process on behalf of our customers in connection with Revenue Grid specific products and services, please, see Product-Specific Policy Terms below for more information.

5. International transfer of information

Your Personal Information may be processed by us in the United States, by our affiliates, and by our service providers located in other countries, as disclosed in the respective section “How we share information we collect” and “Product-Specific Privacy terms” herein.

If we transfer Personal Information to other countries, we ensure that the recipient provides the necessary adequate level of protection. If your Personal Information is transferred outside the EEA to any countries that are not subject to an adequacy decision by the European Commission, we apply and enter into standard contractual clauses approved by the European Commission, or use other appropriate legal mechanisms to safeguard the transfer.

Data Privacy Framework (DPF)

We comply with the EU-U.S. DPF, UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, as set forth by the U.S. Department of Commerce (the “Data Privacy Framework”) regarding the collection, use and retention of personal information transferred from the European Union (EU), United Kingdom (UK) and Switzerland to the United States. We have certified to the Department of Commerce that we adhere to the Data Privacy Framework Principles. To learn more about the Data Privacy Framework program, and to view our certification, please visit https://www.dataprivacyframework.gov/ and https://www.dataprivacyframework.gov/s/participant-search/participant-detail?id=a2zt0000000CjKUAA0&status=Active.

The DPF Principles set forth our accountability for EU/UK/Switzerland Personal Data that we receive under the DPF and subsequently transfer to a third party. As described in this Privacy Policy, we may use third parties to process data on our behalf. We remain liable if they do so in a manner inconsistent with the DPF Principles.

Should you have any DPF-related complaints about our collection or use of your personal information or any inquiries, please, contact Avora Holdings LTD at: [email protected]. We will respond within 45 days.

If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, you may contact your relevant Data Protection Authority using the information provided at https://ec.europa.eu/info/law/law-topic/data-protection_en and/or the Swiss Federal Data Protection and Information Commissioner (FDPIC). Avora Holdings LTD commits to cooperate with the panel established by the EU, UK DPAs and/or the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by the panel established by the EU, UK DPAs and/or FDPIC with regard to unresolved DPF complaints concerning data transferred from the EU, UK and/or Switzerland.

Under certain conditions, more fully described on the DPF website, you may be entitled to invoke binding arbitration through the DPF Panel if neither we nor the panel established by the DPAs/FDPIC resolves your DPF complaint.

We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

We may be required to disclose personal information in response to lawful requests by public authorities, including to meet the national security or law enforcement requirements.

Representation for data subjects in the EU/UK

We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.
Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/17757937

6. How to access and control your information

There are several choices available to you for accessing and controlling your information that we collected. Below is a summary of these choices, the ways to exercise them, and limitations that might apply.

Your Choices:

You have the right to

Obtain from us a confirmation as to whether or not the Personal information about you is being processed by us, and to request a copy of your information that we hold about you;
To object to our use and processing of your information (including for marketing purposes);
To request erasure, deletion, or restriction of your information;
To request your information to be presented to you in a structured electronic format;
You also have the right to request the erasure or deletion of your Personal information and the right to restrict the processing of your information in certain cases;
To request your information to be presented to you in a structured, commonly used and machine-readable format and the right to transmit those data to another controller to the extent possible (the right to data portability);
Withdraw your consent in the cases when processing of your Personal Information is based on your consent;
The right to request rectification/correction of your Personal Information in cases where the processed Personal Information is inaccurate or out of date;
To file a complaint with the appropriate data protection authority if you consider your rights have been violated.

Below, we describe the tools and processes for making these requests.

In case the Services are administered for you by an administrator from your organization, you may first need to contact your administrator to assist with your requests. In other occasions, you may contact us as provided in the Contact Us section below.

Your requests and choices may have some limitations in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. If you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country you reside, work, or where you feel your rights were infringed.

Request to deactivate your account: If you wish to stop using our Services, please contact our Support team.

A Request to stop using your information: In some cases, you may ask us to stop accessing, storing, using, and otherwise processing your information where you believe we don’t have the appropriate rights to do so. In case you gave us the consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt out of our using of your information for marketing purposes by contacting us. If you make such request, we may need some time to investigate and facilitate it. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.

A Request to opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link included in each email. Not that after you opt out from receiving promotional messages from us, you will continue receiving transaction messages from us regarding our Services. You can also opt out of some notification messages via your Service account settings.

You may exercise your rights by contacting us using the information in the “Contact Us” section below.

7. Product-specific Privacy Terms

This section provides information with regard to processing of data in connection with the use of our certain Services/Products by the customers/users. Hereinafter, “User Data” means data, including personal information, that is processed by the Services as specified below in the respective subsections.

The servers we use to host and run our Services’ infrastructure are located in secure data centers. Specifically, industry standard Microsoft Azure cloud hosting servers are used.

In order to provide technical support for our Services (exclusively for troubleshooting and incident resolution), we may provide access to telemetry and service logs data to our employees/contractors. All such individuals strictly adhere to our Privacy and Security policies and any such access is restricted to such specially trained individuals.

Revenue Inbox 

Our solution Revenue Inbox performs synchronization of business communication and CRM data between user’s CRM account and user’s mailbox. Revenue Inbox for Salesforce can synchronize data of the following types: Calendar items, Tasks, Contacts, Email messages, and Attachments of the authorized User. Using the solution’s Dashboard, the authorized User can define which record types to synchronize via the Service.

Revenue Inbox may store the following categories of User Data:

Email and full name of the authorized user of the Service
Identifiers and Last modified dates of synchronized records
Revenue Inbox sync engine temporarily keeps the names of records that it encounters issues with, solely to display these details to the users in sync error logs and notifications
Revenue Inbox Meeting Scheduler (the “Book me” and “Time slots”) feature temporarily keeps selected meeting slots and invitees’ names and email addresses in order to build interactive selection tables and send out the invites
Diagnostics logs temporarily keep non-Personal Data, such as email or meeting identifiers, Sent/Received dates, etc. solely for customer support and troubleshooting purposes. The logs are transferred and kept securely, and all diagnostic data is automatically purged after 90 days

With regard to the Email Opens (“Magic Pixel”) and Link Clicks Tracking feature, please refer to the respective subsection below

Revenue Engage

Our Revenue Engage solution is intended for outbound mailing and replies processing automation within sales and other kinds of email campaigns. Revenue Engage also bi-directionally synchronizes Lead statuses within Salesforce.

Revenue Engage processes and stores the following categories of User Data, including Personal Data:

User Details: First name, Last name, title, phone, and email of Revenue Engage user to provide the possibility to send email to business contacts imported from Salesforce by the user’s request and the IP address
User Contacts’ details: business contacts may be imported from Salesforce or other sources. Contacts access is restricted according to defined User roles and visibility settings. Based on the data available in the data source, Revenue Engage may process and store the following contact details: First name, Last name, Email, Phone number, Company name, Title, Country, Address details

Related emails (correspondence): emails sent from Revenue Engage, replies, and other correspondence, including Sent date, Subject, Recipients list, Email body
Email Templates and Attachments: templates imported from Salesforce and files attached to business correspondence, for communication processing

Revenue Engage User data is stored throughout the Service subscription term and then for three calendar months after the end or expiration of the subscription. Three calendar months after the end/expiry of the subscription, all the User Data gets permanently deleted from our servers.

The User may permanently delete the persisted data including Personal data of Revenue Engage emails recipients, using one of the following methods:

Manually: one recipient at a time or in a bulk manner. In this case Revenue Engage will purge the recipients’ details and all related data used in the system.
By request sent to our Customer support. In this case all recipients’ details and related data will be purged irrecoverably from our servers

Revenue Engage Service logs and telemetry data may be stored for three calendar months.

With regard to the Email Opens (“Magic Pixel”) and Link Clicks Tracking feature please refer to the respective subsection below.

Revenue Guide

Revenue Guide consists of a range of solutions for the customer-facing teams. It includes business pipeline and team analytics, a system of playbook-based signals as well as automation means which recommend the best following steps to take or perform required actions automatically.

Revenue Guide processes and stores the following categories of User Data, including Personal Data:

Salesforce: Salesforce objects IDs
Inbox Email Details: Sent date, Subject, Sender and Recipients list, Contact full names, Contact signatures, Contact emails, Read/unread by User state, Attachments list: attached files’ names, attached files’ sizes, attached files’ extensions
Calendar Meeting Details: Creation date, Start date, End date, Subject, Attendees list, Contact full names, Contact emails, Attendees statuses (accepted/declined), Attachments list: Attached files’ names, Attached files’ sizes, Attached files’ extensions

Revenue Guide may also store additional data points per the customer’s demand, according to requested custom patterns.

Revenue Guide User data is stored throughout the Service subscription term and then for three calendar months after the end or expiration of the subscription. Three calendar months after the end/expiry of the subscription, all the User Data gets permanently deleted from our servers.

The User may delete the User data including Personal data of Revenue Guide emails recipients in the following way:

By request sent to our Customer support. In this case all recipients’ details and related data will be purged irrecoverably from our servers. Revenue Engage Service logs and telemetry data may be stored for three calendar months.

Email Opens And Link Clicks Tracking Feature

Our products Revenue Inbox and Revenue Engage include the Email Opens (“Magic Pixel”) and Link Clicks Tracking feature that allows users to track sent emails’ status (opened/not opened by a recipient) and clicking of links contained in emails’ bodies.

The user can disable or enable this feature in product Customization settings. If this feature is enabled, the following data categories get processed and stored by the Service:

Public IP Addresses of the recipients who opened the email or clicked the links
Country/state (from the Public IP)
City (from the Public IP)
Browser name / UserAgent
Email Subject
Recipients’ email addresses

The User may delete the User Data stored by the Services by submitting a respective request to our Customer Support.

Please note that when using the Email Opens and Link Clicks Tracking feature, the user (being the data Controller) needs to comply with the requirements of data protection laws, and some laws may require that the recipients have opted-in to the collection of the tracking data.

SAP Cloud for Customer Server-Side Integration for Groupware

Our Services performs synchronization of business communication and CRM data between user’s CRM account and user’s mailbox over API technologies, including Google APIs, as specified below.

SAP Cloud for Customer Server-Side Integration for Groupware (hereinafter for the purposes of this subsection referred as the “Service”) performs specific data processing between SAP Cloud for Customer and the user’s mailbox (“User Data” processing) and provides a sidebar pane for Microsoft Outlook (as an add-in) or Gmail (as a Chrome browser extension) that allows to interactively view and modify CRM context associated with the currently selected email message or calendar item. The Service can access and handle records of the following types: Calendar items, Tasks, Contacts, Email messages, and Attached files from the user’s mailbox, as well as various record types available in the CRM. Using the Service’s settings pages, the authorized CRM user can define which record types to synchronize or access via the Service.

Any User data including Personal data is processed or transferred by the Service solely to provide the Service to the users. User Data is only passed through the Service, temporarily kept in our servers’ memory for performing a specific operation (a records data synchronization session or user-initiated data access or update) and is not written to any persistent storage.

While processing the data including Personal Information in connection with this Service on behalf of our customers, we process such information in the capacity of data processor.

Google API Services User Data Policy Disclosure

Revenue Grid App’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Organization’s administrators

If an end-user registers or accesses the Service(s) using an email address with a domain that is owned by end-user’s employer or organization, and such organization wishes to establish an account on the site, the name of that end-user, email address of that end-user, and dates of past use of end-user account with the Service may become accessible to that organization’s administrators so they would be able to perform their functions as administrators and adjust and/or customize the Service for users.

Sub-Processors

In order to provide our Products and Services to customers and run our platform, we may use and engage sub-processors, including the affiliates of AVORA HOLDINGS LTD.

The list of our Sub-Processors is available on Revenue Grid Sub-Processors Page. 

Notice to End Users  

Many of our products are intended for use by organizations. This implies that the Services are made available to you through an organization (e.g. your employer), and the organization is the administrator of the Services and is responsible for the user accounts and/or Service sites over which it has control.

If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be differ from this Policy.

Administrators are able to:

require you to reset your account password
restrict, suspend, or terminate your access to the Services
access information in and about your account
access or retain information stored as part of your account
install or uninstall third-party apps or other integrations

In some cases, the administrators can also:

restrict, suspend, or terminate your account access
change the email address associated with your account
change your information, including profile information
restrict your ability to edit, restrict, modify, or delete information

Please contact your organization or refer to your administrator’s organizational policies for more information.

8. Our Policy towards children

The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.

9. Changes to our Privacy Policy

We may change this Privacy Policy from time to time. We will post any Privacy Policy changes on this page and, if the changes are significant, we will provide a more prominent notice by adding a notification on the Services home pages and login screens, or by sending you an email notification. We encourage you to review our Privacy Policy whenever you use the Services to stay informed about our information practices and the ways how you can help protect your privacy.

If you disagree with any changes made to this Privacy Policy, you will need to stop using the Services and deactivate your account(s), as outlined above.

10. Additional disclosures to California residents

We have collected the following statutory categories of Personal information over the past twelve months:

Identifiers (name, e-mail, phone number)
Commercial information
Internet or network information
Geolocation data (IP address)
Payment information

The purposes for which we collect this information are described in the respective section of this Policy “How we use information we collect”. We do not trade or sell your personal information to any third parties. We may share or disclose the above information only in the ways that are described in the respective section in this Policy “How we share information we collect”, provided the involved parties have adopted the appropriate security and confidentiality measures.

Your Rights Under California Consumer Privacy Act of 2018

You have the right to request from us what information we have collected, used, and disclosed about you over the past twelve months.

You have the right to learn how we process your Personal Information.

You have the right to request from us the deletion of your Personal Information collected and maintained by us. Please, note that some exceptions may apply to this right.

You have the right not to be discriminated while you exercise one of your privacy rights.

Please kindly note that some exceptions to your rights specified above may apply, as permitted by laws.

You may designate your authorized agent to exercise the above rights on your behalf. We may need to verify your identity by the appropriate method if necessary or verify your authorized agent’s identity.

To exercise your rights, please contact us at the address provided in the section “Contact Us” of this Policy.

11. Contact Us

If you have questions or concerns about how your information is handled, please direct your inquiry to Avora Holdings LTD at:

Avora Holdings LTD. 650 Castro St, Suite 120/385 Mountain View, CA 94041

Company Communications; 13110 NE 177th Place, Suite 135 Woodinville, WA 98072.

E-Mail: [email protected]

Phone number: +1 866 684 9276