Privacy Policy
This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use the Service and explains your privacy rights and how the law protects you.
We use your Personal Data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.
Interpretation and Definitions
Interpretation
Words with initial capital letters have meanings defined below. The following definitions have the same meaning whether they appear in singular or plural.
Definitions
For the purposes of this Privacy Policy:
- Account means a unique account created for you to access our Service or parts of our Service.
- Business (for the CCPA) refers to the Company as the legal entity that collects consumers’ personal information and determines the purposes and means of processing.
- Company (referred to as “Ava,” “we,” “us,” or “our”) means Astro Virtual Agents Inc. d/b/a Ava. Registered in Delaware.
- For the GDPR, the Company is the Data Controller unless stated otherwise in a Data Processing Addendum for enterprise customers.
- Consumer (for the CCPA) means a natural person who is a California resident.
- Cookies are small files placed on your device that store certain information about your session.
- Country refers to the United States.
- Data Controller has the meaning in the GDPR.
- Data Processor / Service Provider means an entity that processes Personal Data on behalf of the Data Controller.
- Device means any device that can access the Service such as a computer, cellphone, or tablet.
- Do Not Track (DNT) is a preference you can set in your browser to inform websites that you do not want to be tracked.
- Personal Data means any information that relates to an identified or identifiable individual.
- GDPR: identifiers such as name, ID number, location data, online identifier, or identity factors.
- CCPA: information that identifies, relates to, describes, or could reasonably be linked with you.
- Sale and Share have the meanings under the CCPA.
- Service refers to the Website, mobile apps, Slack/chat-based assistants, voice agents, APIs, and related AI-enabled services provided by Ava.
- Third-party Social Media Service refers to any social network through which a user can log in or connect to the Service.
- Usage Data refers to data collected automatically by use of the Service or its infrastructure.
- Website refers to Ava’s sites, including https://avaassist.ai and any subdomains.
- You means the individual accessing or using the Service, or the company/legal entity on behalf of which such individual is accessing/using the Service.
- Under GDPR, you may be referred to as the Data Subject or User.
Collecting and Using Your Personal Data
Types of Data Collected
Personal Data You Provide
We may ask you to provide personally identifiable information such as:
- Contact details: email, first and last name, phone number, mailing address
- Professional details: company, role, license numbers (for real estate professionals), team rosters
- Billing details: billing address, transaction identifiers (card data handled by PCI-DSS compliant processors)
- Identity verification: date of birth or government ID metadata (where required by law)
- Content you submit: messages, files, tasks, calendar items, CRM records, call transcripts, prompts
Usage Data
Collected automatically, may include:
- IP address, browser type, device identifiers
- Pages visited, date/time, time spent, logs, performance metrics
- For mobile: OS, device type, app version
Data from Integrations and Third Parties
If you connect services (Google, Microsoft, Slack, CRM, telephony, calendar, social media), we may receive information such as messages, contacts, calendar events, files, and metadata.
Tracking Technologies and Cookies
We use Cookies, pixels, and similar technologies to:
- Operate the Service
- Remember preferences
- Measure performance
- Improve features
Types:
- Necessary Cookies (core functionality)
- Preference Cookies (settings)
- Performance/Analytics Cookies (usage, testing)
- Advertising Cookies (opt-in only)
You can control Cookies in browser settings; disabling may affect functionality.
How We Use Your Information
We use Personal Data to:
- Provide, operate, and maintain the Service
- Manage Accounts, authenticate users, secure access
- Process transactions and subscriptions
- Deliver human-in-the-loop support
- Enable and maintain integrations
- Communicate updates and security alerts
- Provide support and respond to inquiries
- Analyze, improve, and develop the Service
- Detect/prevent fraud and abuse
- Comply with legal obligations
AI Model Use and Safeguards
- Model operations: Ava uses third-party and proprietary AI models.
- Training: No identifiable customer content is used to train public models. De-identified/aggregated data may be used. Enterprise customers may disable training.
- Human review: Limited review may occur for safety and support under strict confidentiality.
Legal Bases for Processing (GDPR)
- Contract (to provide the Service)
- Legitimate interests (improvements, security, fraud prevention)
- Consent (Cookies, marketing, integrations)
- Legal obligations (tax, compliance)
Sharing Your Information
We may share with:
- Service Providers (under confidentiality obligations)
- Integration partners (chosen by you)
- Professional advisors (auditors, law firms)
- Affiliates (under common control)
- Authorities (where required by law)
- Transferees (mergers/acquisitions)
We do not sell Personal Data. We only “share” for advertising if you opt in.
Retention
We retain data as long as necessary to provide the Service, meet legal obligations, or resolve disputes. Some data may be anonymized and retained for analytics.
International Transfers
We operate in the U.S. and may transfer data to other countries with safeguards (e.g., Standard Contractual Clauses).
Security
We use encryption, access controls, audit logging, and vulnerability management. No system is fully secure; safeguards are continuously improved.
Your Rights
Under GDPR
- Access, rectify, erase, restrict, or object to processing
- Data portability
- Withdraw consent
- File complaint with supervisory authority
Under CCPA (California)
- Know categories and pieces of Personal Information collected
- Request deletion (with exceptions)
- Correct inaccuracies
- Opt out of Sale/Share of Personal Information
- Limit use/disclosure of Sensitive Personal Information
- Non-discrimination for exercising rights
Requests can be made via the Contact section; identity will be verified.
“Do Not Sell or Share My Personal Information” & Cookie Choices
California residents can opt out via the link in our footer or by contacting us. Cookie/ad preferences can be managed via the Cookie banner or browser.
Payments
We use third-party processors (Stripe, PayPal). We do not store full card numbers. Their policies apply.
Third-Party Links
Our Service may contain links to third-party sites. We are not responsible for their practices.
Children’s Privacy
Not directed to children under 13. We do not knowingly collect their data. If we become aware, we will delete it.
Do Not Track
Our Service does not respond to DNT signals. You can manage tracking via browser and Cookie choices.
State Disclosures (CCPA Categories)
Collected in the last 12 months:
- Identifiers (name, email, IP)
- Customer records (billing address, transactions)
- Commercial information (services purchased)
- Internet/network activity (site/app usage)
- Professional information (job title, team)
We do not collect sensitive categories (biometric, health, precise location) except when submitted by a customer through an integration.
Enterprise Customers and Data Processing Addendum
Enterprise customers may sign a DPA with SCCs and training controls. If conflicts arise, the DPA governs.
Changes to This Policy
We may update this Policy and post with a new “Last updated” date. Material changes will include additional notice. Continued use constitutes acceptance.
Contact Us
If you have questions or requests, contact:
Email: info@avaassist.ai