Privacy Policy

1. About this Privacy Policy

This Privacy Policy sets out the basis on which we, Avilla Innovations LLC and our affiliates (hereinafter “Avilla”, “we”, “us”, “our”), take care of your privacy. It explains how we collect, use, process, share, disclose and store your Personal Data — as this term is defined below — collected through your interactions with us, including through our website www.AvillaInnovations.com (hereinafter the “Site”), our sales process, marketing activities, our Services (including the AI Email Agent Service), and other means, as further detailed in Section 3. As used in this Privacy Policy, “Personal Data”, “Personal Information” or “information about you” means any data relating to an identified or identifiable individual including but not limited to: your name, last name, company name, email address, phone number, date of birth, card type credit or debit, card number, expiration date, postal code, details of your purchase and payment history, amongst others. The aim of this Privacy Policy is to ensure that you understand the Personal Data we collect from you, the purposes for which we collect it, how we use it, and how we share it. In sum, to explain to you how we protect your privacy, and to explain to you your rights in connection to the Personal Data we collect and process about you.

This Privacy Policy does not apply to our processing of the personal information of our business customers’ end users or customers. We process that end-user or customer information on behalf of our business customers in our capacity as a service provider / processor. Our processing of that information is governed by our agreement with our business customers, including the Data Processing Addendum, and is further described in the “The AI Email Agent Service and Email Content” section below.

Please read this Privacy Policy before using our Services or submitting any personal information to Avilla, and contact us if you have any questions. By using the Services or otherwise providing personal information to us, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Services or otherwise provide personal information.

For further clarifications on this Privacy Policy, questions, or concerns, please do not hesitate to contact us via email: support@avillainnovations.com

2. About Avilla Innovations LLC

Avilla Innovations LLC is a Limited Liability Company headquartered in California. Avilla is the data controller of your Personal Data as described in this Privacy Policy, unless expressly specified otherwise.

3. Personal Data

When do we collect your Personal Information? We may collect data, including your Personal Data, through our interactions with you, and when you:

• Register, or complete or submit information or forms on our website;
• Download content on our website;
• Register for webcasts, seminars, conferences, etc. sponsored by us, or a partner;
• Provide us with feedback and information via phone, email, social media, etc.;
• Answer a survey;
• Subscribe to our newsletters or other content-related material;
• Use Live Chat;
• Use forums or leave comments on our website;
• Purchase or use Avilla products and/or services;
• During in-person meetings or at Avilla’s events, conferences, workshops or gatherings.

Online information about you may also originate from the use of cookies and similar technologies on our Site or sites of third parties. Please note that Avilla does not control the content that you may post to Avilla’s forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit Personal Information to these forums or social networks and whether you wish to make your profile available to other users.

Categories of Personal Information and Specific Pieces of Personal Information we collect from you.

We may have collected within the last twelve (12) months, and may collect in the future, the following categories of Personal Information listed below from consumers, for commercial and/or business purposes under the California Consumer Privacy Act of 2018 (“CCPA”):

1. Identifiers and registration contact information: such as name, e-mail address, postal address, telephone number, account name, online identifier, Internet Protocol (IP) address, or other similar identifiers.
2. Customer records information: such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, bank account number, credit or debit card number, other financial information.
3. Characteristics of protected classifications under California or federal law: such as age, gender.
4. Commercial information: such as delivery information and records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies and transactions made with us.
5. Internet or other electronic network activity information: device information and device identifiers, browsing type and language, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement, and data connection and use, such as information you download.
6. Geolocation data: such as city, state, zip code, etc. related to your IP address.
7. Inferences on your preferences and characteristics.
8. Other information, such as any other information you choose to provide us directly in relation to the use of our services, surveys we send you, etc., customer information such as questions and other messages that you send us directly through online forms, chats, e-mail, phone, or post, summaries or voice recordings of your interactions with customer service.

4. How do we use your Personal Data

Such business purposes may be:

1. Purpose Fulfillment: We use your Personal Information to fulfill the specific purposes for which you provided it to us.
2. Information and Services: We utilize your data to provide you with the information, products, or services you have requested from Avilla.
3. Communication and Response: Your inquiries and requests are addressed through communication, ensuring timely and accurate responses from Avilla.
4. Operational Excellence: We process your data to efficiently operate our business, manage transactions, and process orders.
5. Post-Service Interaction: We follow up with you after delivering products and/or services, using methods like live chat, email, or phone inquiries.
6. Consumer Engagement: We provide email alerts, event registrations, and notices about Avilla’s offerings, events, or relevant news.
7. Site Management: We administer, enhance, and technically manage our website, ensuring content presentation to clients and visitors.
8. Functionality Improvement: Your data aids us in analyzing and enhancing the functionality and performance of our site.
9. Service Enhancement: We modify, enhance, and improve our services and their provision to clients for better value.
10. Rights and Property Protection: We may use your data as required to protect the rights and property of Avilla, our clients, or others.
11. Contractual Obligations: Personal Information supports our obligations under agreements with clients and other contractual entities, including billing and collections.
12. Research and Development: Data is employed for testing, research, analysis, and the development of new products and services.
13. Site Security: We manage the security of our website, safeguarding user information.
14. Legal Compliance: Your data is processed to comply with applicable laws and regulations governing our business.
15. Law Enforcement: We respond to law enforcement requests as mandated by law, court orders, or governmental regulations.
16. Transparency: We use your data as described during data collection or as outlined by the CCPA.

Such commercial purposes (“Commercial Purposes”) may be:

1. To promote our products and/or services, along with related offerings, and to customize our marketing and sales initiatives to align with our clients’ preferences.

We do not collect additional categories of Personal Information, nor process the collected Personal Information for a different purpose than the ones described in this Privacy Policy. The Personal Information we collect allows us to keep you posted on Avilla’s latest product announcements, software updates, and upcoming events; to customize the content and advertising you see on our website, personalizing your experience and allowing us to deliver the type of content and product offerings you are most interested in; and to send periodic emails regarding our products and/or services. If you don’t want to be on our mailing list, you can opt out anytime by emailing us at: support@avillainnovations.com

4.1 Personal Data we collect automatically. Our website automatically collects certain data through automatic data collection tools such as cookies, beacons, among others. These tools automatically collect the following information:

• Technical information including, but not limited to, browser type, operating system, device information, online identifiers including cookie data and Internet Protocol address (IP), domain name, referral URL, time zone setting, and/or time-stamp for your visit, information about your devices.
• Usage information including, but not limited to, geographic location information (such as your country and/or state), date and time you visited our Site, numbers and frequency of visitors to our Site, page views and search queries, clickstream behaviors, amongst others. It may also include details of your use of third-party applications in connection with our service.

4.2 Sources of Personal Information. Personal Information we collect from third parties.

We work closely with various third parties and may receive Personal Data from them. We protect the Personal Data obtained from them in accordance with the practices and policies described herein, plus any additional obligations imposed by the third-party source of your Personal Data. The third-party sources may vary due to context, but may include the following:

• Data brokers from which we purchase data to complement the data we collect;
• Partners: (i) authentication partners: if you register or log in to our services using third-party credentials (e.g. Google) we will import your information from such third-party source to help you create an account on our website; (ii) technical services partners that help us with technology, and may provide us with certain data (e.g. mapping IP address to location data) to help us provide our services; (iii) advertising partners that provide us with services on our website (analytics, marketing, etc.) providing inferences about your preferences and interests to offer you a better service and customized offerings; (iv) payment partners, if you choose to pay for a service and/or product, we may receive data from them to enable us to send you invoices and process your payment; (v) resellers, distributors that deliver the product and/or service you have contracted, and therefore may supply us with data to help us improve our services, amongst others.

During the past twelve (12) months we may have disclosed the categories of Personal Information about you listed above to our affiliates, group companies, and service providers for our business and commercial purposes. We have not, however, sold your Personal Information to third parties and shall not sell your Personal Information to third parties.

5. Legal Basis for processing your Personal Data

We rely on the following legal bases to collect and process your Personal Data under the applicable California Consumer Privacy Act of 2018 (“CCPA”) and, where applicable, other data protection laws:

• Consent: where you have provided your consent for the processing of your Personal Data for a specific purpose.
• Performance of a contract: where processing is necessary for the performance of a contract with you or to take steps prior to entering a contract with you.
• Legal obligation: where we have a legal obligation to process your Personal Data, for example when responding to a public or governmental authority, courts, or regulators, according to a legal obligation under applicable law.
• Legitimate interest: to satisfy a legitimate interest, for example when it is not required by law but it clearly benefits you.
• Service provider / processor role: When we process or receive information from a customer, we act as a “service provider” for purposes of the CCPA and a “data processor” for purposes of the General Data Protection Regulation, to the extent those laws apply. Therefore, any requests about or relating to personal information that we hold for our customers should be directed to those customers.

6. Data Retention

We will retain your Personal Data for a period of time that is consistent with the original purpose of the data collection, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer have a legitimate need to process your information, we may delete or anonymize your information from our data repositories after 90 days.

Email Content processed through the AI Email Agent Service is retained only for as long as necessary to provide the Service and is deleted or de-identified within twelve (12) months, or sooner upon disconnection of the relevant Email Account or termination of the Service, except where a longer period is required to comply with our legal obligations, resolve disputes, or enforce our agreements.

7. The AI Email Agent Service and Email Content

If you or your organization use our AI Email Agent Service, you connect one or more email accounts to the service, and our automated agent accesses and processes the contents of those accounts in order to review, classify, reply to, forward, move, and organize messages according to the guidelines you provide (“Email Content”). Email Content may include message headers, subject lines, sender and recipient information, message bodies, attachments, contacts, and related metadata.

We process Email Content on behalf of, and under the instructions of, our business customer in our capacity as a service provider under the CCPA and a data processor under the GDPR and other applicable laws. We do not use Email Content for our own purposes, do not sell or share it, and do not use it for advertising or marketing. Requests from individuals regarding Email Content should be directed to the business customer that controls the relevant email accounts.

The AI Email Agent Service is not intended for the transmission, processing, or storage of protected health information (PHI) under HIPAA or other specially regulated categories of data, and customers agree not to use the Service for such data, as described in our Terms of Service.

We retain Email Content only as long as necessary to provide the AI Email Agent Service and as described in our Data Retention section, and we delete or de-identify it when it is no longer needed for that purpose, subject to legal requirements.

8. Artificial Intelligence and Subprocessors

To provide the AI Email Agent Service, we use artificial-intelligence and machine-learning technologies and engage trusted third-party subprocessors, which may include a provider that connects to and accesses email accounts on our behalf, a provider of artificial-intelligence models, cloud hosting providers, and a payment processor. Email Content may be transmitted to and processed by these subprocessors solely to provide the service to you. We require our subprocessors by contract to protect the information consistent with this Privacy Policy, to use it only to provide services to us, and not to use Email Content to train generalized or independent artificial-intelligence models. A list of the categories of our subprocessors, and the specific subprocessors we use, is available on request by emailing support@avillainnovations.com.

9. Use of Google and Microsoft Email Services

When you connect a Google (Gmail) or Microsoft (Outlook) email account to our service, we access your email through those providers’ APIs only with your authorization and only to provide the features you have enabled.

Avilla Innovations’ use and transfer of information received from Google APIs to any other app will adhere to the Google API Services User Data Policy, including the Limited Use requirements. In particular, we use Google user data only to provide and improve the user-facing features of our service, do not transfer or sell it except as necessary to provide the service or as required by law, do not use it for advertising, and do not allow humans to read it except with your consent for specific support or security purposes, to comply with law, or as otherwise permitted under that policy. Our use of data obtained from Microsoft services is likewise limited to providing the service and is governed by the applicable Microsoft and Microsoft 365 terms.

You can review the Google API Services User Data Policy at: https://developers.google.com/terms/api-services-user-data-policy

10. Data Location and International Transfers

We and our subprocessors may process and store data in multiple countries. The provider we use to connect to and access email accounts hosts data on infrastructure located in the European Union, and our artificial-intelligence provider processes data on infrastructure located in the United States. As a result, Email Content and related data may be processed or stored outside your country of residence, including in the European Union and the United States. Where data is transferred internationally, we and our subprocessors rely on appropriate safeguards as required by applicable law. By using the AI Email Agent Service, you acknowledge that data may be processed in the locations described above.

11. Security

We maintain administrative, technical, and physical safeguards designed to protect the information we process, including encryption in transit, access controls, and limits on which personnel and subprocessors may access Email Content. No method of transmission or storage is completely secure, however, and we cannot guarantee absolute security. You are responsible for maintaining the security of your account credentials and connected email accounts and for promptly notifying us of any suspected unauthorized access.

12. Your Privacy Rights

Depending on your jurisdiction, you may have rights regarding your Personal Data, including the right to request access to, correction of, or deletion of your Personal Data; the right to opt out of the sale or sharing of Personal Data (we do not sell or share Personal Data); and the right to non-discrimination for exercising your rights. To exercise any of these rights, please contact us at support@avillainnovations.com. We will respond to verifiable requests as required by applicable law. If you use our AI Email Agent Service and your request concerns Email Content we process on behalf of a business customer, we will direct your request to that customer.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your Personal Data, please contact us at:

• Email: support@avillainnovations.com
• Phone: (562) 606-5071
• Address: PO Box 11171, Whittier, CA 90603

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date above. Your continued use of the Services after changes become effective constitutes acceptance of the updated Privacy Policy.