Privacy Policy

Avow GmbH

Version: APP201002

Last updated: 15 05 2021

 

Avow GmbH (“Avow”, “us” or “we”) is delighted that you have shown interest in our company. We respect your privacy and are committed to protecting your privacy through our compliance with this Privacy Policy (“Policy”).

This Privacy Policy applies to your use of our website www.avow.tech (“Site”) and to your use of the services provided by Avow (“Services”).

This Policy describes the types of information we may collect from you or that you may provide us when you visit our Site or use our Services, and describes our practices for collecting, using, maintaining, protecting and disclosing that information.

The terms used in the below data privacy policy will have the following meanings:

“CCPA” refers to the California Consumer Privacy Act of 2018.

“Customer” refers to app owners, developers, marketers, or agencies making use of Avow Services, or having signed up for the Avow Services.

“Media Partner(s)” are registered publishers, OEMs and additional sources of inventory run by Avow and forming Avow’s Media Partner Program.

“Advertiser(s)” means any client of Avow GmbH which has entered into one or multiple Insertion Orders, contracts or agreeement with Avow.

“Applicable Law” means (i) any and all laws, statutes, regulations, by-laws, orders, ordinances and court decrees that apply to the performance and supply of the Services or the Processing of Personal Data, and (ii) the terms and conditions of any applicable approvals, consents, exemptions, filings, licences, authorities, permits, registrations or waivers issued or granted by, or any binding requirement, instruction, direction or order of, any applicable government department.

“Service provider” has the meaning as given in the CCPA.

“Sub Processor” means any person appointed by or on behalf of Processor to Process Personal Data on behalf of the Controller in connection with the Principal Agreement.

“Standard Contractual Clauses” shall have the meaning set out in the Commission Decision of 5 February 2010 (C (2010) 593).

“User” or “Users” are individuals that access and use mobile applications that are connected to or use the Services.

The terms “Controller”“Data Subject”Recipient”Member State“Personal Data”“Consent”“Processor”“Third party”“Processing” and “Profiling”, and other words and expressions used in this Agreement but not defined herein shall have the same meaning as given to such words and expressions in the EU Directive 95/46/EC or, from 25 May 2018, the General Data Protection Regulation (2016/679) (“GDPR”).

 

A. The Avow Site Privacy Policy

The Avow Site is a marketing website aimed to provide information and content, created by Avow, about Avow and its Services. You can visit the Avow Site without any registration.

Please note that you are not required by law to provide us Personal Data.

The Site is not directed to children under 16 years of age and Avow does not intentionally or knowingly collect Personal Data on such users.

This Policy does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by any third party;
  • Any third party, including through any application, product, service or content (including

advertising) that may link to or be accessible from the Site

 

  1. The Personal Data that You provide voluntarily through the Site

We receive Personal Data that you provide and submit through the forms and sign-on tabs available  on our Site, such as the Contact Form, the “Request a Demo” form, the tabs or pop-ups through which you register for our Newsletter or other communications (eg. Blog post subscription). Avow will process any Personal Data that you provide Avow such as your name, your company’s name, city, country, email address, telephone number or any other identifier by which you may be contacted online or offline.

We ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) on or through the Site or otherwise to us.

 

  1. The Personal Data that Avow collects through the Site

When you access the Site, Avow’s servers log ‘traffic/session’ information from your device, such as your user agent and the Internet Protocol (IP) address.

When you use the Site, Avow will collect information about your activity, for example, your log-in and log-out time, the duration of sessions, web-pages that you have viewed or specific content on web-pages, activity measures and geo-location of your device

 

  1. Third Party’s Services included on the Site

The Avow Site may include links to Avow profiles on third-party social media websites such as Youtube®, Facebook®, Twitter®, LinkedIn® and associated social media features. These are only redirect links and do not contain any third-party cookies.

These social media websites have their own privacy policies. When you use their platforms, features, widgets and other services, you should read their privacy policies to understand their practices.

 

  1. What does Avow do with Personal Data it receives through the Site

Avow uses Personal Data that you provide through the Site for its business’ purposes, such as responding to your inquiries or support requests and improving the website performance.

Avow may also use the Site traffic information, including Personal Data to understand users’ interests in order to improve and further develop the Site.

Avow uses information that we collect about you or that you provide to us, including any Personal Data:

  • To provide you with information that you request from us and respond to inquiries;
  • To present the Site and its content correctly to you;
  • To help us carry out analyses of usage patterns of our Site and Services in order to continually better our services, to develop new services and to improve and personalize user experiences, understand customer interest and market trends;
  • For any other purpose with your consent;
  • For audits, regulatory purposes, such as providing law enforcement authorities with the

information necessary for criminal prosecution, e.g. in case of a cyber-attack

Avow might share Personal Data related to you with third party service providers if necessary, to fulfil the purposes for collecting the Personal Data, on condition that any such third party will commit to protect your privacy as Applicable Laws and this policy require.

Avow will only share Personal Data with law enforcement and/or government agencies, courts, and/or other organization if and as the law requires, such as to comply with a subpoena, a government request or a similar legal process.

If involved in a merger, acquisition, or sale of all or a portion of its assets, Avow might need to transfer Personal Data as part of such transaction. Avow will provide a prominent notice on the Site of any change in ownership or uses of this information if applicable. The entity which will assume the ownership of the Site will continue to protect Personal Data related to you under this Policy.

Avow may also share your Personal Data with other third parties if Avow receives your written request to do so.

Avow does not engage in any automated decision making, profiling or retargeting.

Avow does not sell any data or Personal Data.

 

  1. Use of Own Cookies

Cookies are small packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. The primary purpose of our cookies is to facilitate the use of the Site, its features and tools. We use cookies to save your preferences on our website (eg. For language settings) to provide an offer tailored to you and to make using our services as time-efficient as possible. These services are based on the above-stated legitimate interests. The legal basis is Art. 6(1) Letters b & f of the GDPR.

In addition, we also use cookies and comparable technologies (e.g., web beacons) of partners for analysis and marketing purposes. This is described further in the following section.

 

  1. Use of Cookies and Comparable Technologies for Analysis Purposes

To improve the Site, we use cookies and comparable technologies (e.g., web beacons) for statistical assessments and to analyse general user behavior through access data. The legal basis for the data processing described in the following section is Art. 6(1) Letter f of the GDPR, based on our legitimate interest in the needs-based design and continuous optimization of our website.

Our website uses Google Analytics, a web analysis service from Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”). Google Analytics uses cookies and similar technologies to analyse and improve our website on the basis of your user behavior. Google may transmit the data collected thereby to a server in the US where it will be assessed and saved. For transmissions of Personal Data to the US, Google subjected itself to the EU Commission’s standard data protection model clauses. However, your IP address will be shortened prior to assessing usage statistics so that you cannot be identified.

Google will process the information provided by the cookies to assess your use of this website, to compile reports about website activity and to perform additional services related to use of the website and the Internet.

If you wish to delete cookies or limit the kinds of cookies that can be placed on your device you need to check out the settings in your browser, use the ‘Help’ tab or look for settings like ‘Options’ or ‘Privacy.’ From there, you can delete cookies, block them or control when they can be placed.

You may also prevent the collection of cookie-generated data on your use of this website (incl. your IP address) and the processing of this data by Google by downloading and installing a browser add-on provided by Google or, when accessing our website from a mobile device, activating this opt-out link: Disable Google Analytics. This will prevent the collection of data by Google Analytics on this website (the opt-out cookie will only work on the browser used and only for this domain). If you delete your cookies from this browser, you must activate this link again.

For more information, please see Google’s Privacy Policy located at https://support.google.com/analytics/answer/6004245?hl=en.

 

  1. Your EU Data Subject Rights

7.1 Data basis for processing

In operating the Site, Avow processes Personal Data as a Data Controller.

As the Data Controller, Avow relies on the explicit consent of the EU individual when entering Personal Data through the Site (such as when completing the online form available on the Site). In response, Avow may process the Personal Data to respond to your inquiry. On other occasions, we may process Personal Data when it is necessary for the performance of a contract or where required by law.

Avow may also process Personal Data when it is in Avow’s legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights. Those legitimate interests include improving Avow’s Site or Services.

We rely on our legitimate interests for processing your Personal Data, which we believe are not overridden by your fundamental rights and freedoms, for the following purposes:

o Communications with you, where you make contact with us through our Site or other digital assets;

o Enhancements and improvements to yours and other users’ experience with our Site

o Support, service operations;

 

7.2 Data Subject Rights

Avow is committed to fulfilling Data Subjects’ rights under the GDPR, the most important being:

 

a) Right of confirmation

Each data subject (you) shall have the right granted by the European legislator to obtain from us the confirmation as to whether or not Personal Data concerning you is being processed. If you wish to avail yourself of this right of confirmation, you may, at any time, contact us.

 

b) Right of access

You have the right granted by the European legislator to obtain from us free information about your Personal Data stored at any time and a copy of this information. Furthermore, the European directives and regulations grants you access to the following information:

  • the purposes of the processing;
  • the categories of Personal Data concerned;
  • the recipients or categories of recipients to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organisations. Where this is the case, you shall have the right to be informed of the appropriate safeguards relating to the transfer;
  • where possible, the envisaged period for which the Personal Data will be stored, or, if not possible, the criteria used to determine that period;
  • the existence of the right to request from Avow rectification or erasure of Personal Data, or
  • restriction of processing of Personal Data concerning you, or to object to such processing;
  • the existence of the right to lodge a complaint with us;
  • where the Personal Data are not collected from you directly, any available information as to their source;

Such a Subject Access Request can be made by sending a letter to Avow GmbH, at Grimmstrasse 23, 10967 Berlin, Germany or in the form of an email to [email protected].

We endeavor to respond to a verifiable consumer request within 30 days of the request being made. We do not charge a fee to process or respond to your request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

c) Right to rectification

You shall have the right granted by the European legislator to obtain from us without undue delay the rectification of inaccurate Personal Data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete Personal Data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may, at any time, contact us through our contact details.

 

d) Right to erasure (Right to be forgotten)

You have the right granted by the European legislator to obtain from us the erasure of Personal Data concerning you without undue delay, and we shall have the obligation to erase your Personal Data without undue delay where one of the following grounds applies:

  • The Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
  • You withdraw consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
  • You object to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or you object to the processing pursuant to Article 21(2) of the GDPR.
  • The Personal Data have been unlawfully processed.
  • The Personal Data must be erased for compliance with a legal obligation in the European Union or Member State law to which Avow is subject.
  • The Personal Data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR (i.e. a child younger than 13 years old).

If one of the aforementioned reasons applies, and you wish to request the erasure of Personal Data stored by Avow, you may at any time contact us. We shall promptly ensure that the erasure request is complied with full in accordance with the GDPR regulations

 

e) Right of restriction of processing

You have the right granted by the European legislator to obtain from Avow restriction of processing where one of the following applies:

  • The accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of the Personal Data.
  • The processing is not lawful and the data subject opposes the erasure of the Personal Data and requests instead the restriction of their use instead.
  • The controller no longer needs the Personal Data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
  • The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
  • If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of Personal Data stored by Avow, he or she may at any time contact us. We will arrange the restriction of the processing.

 

f) Right to data portability

You have the right, granted by the European legislator, to receive the Personal Data concerning yourself, which was provided to Avow, in a structured, commonly used and machine-readable format. You have the right to transmit those data to any other controller without hindrance from the controller to which the Personal Data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, you have the right to have Personal Data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, you may at any time contact us through our contact details.

 

g) Right to object

You have the right granted by the European legislator to object, on grounds relating to your particular situation, at any time, to processing of Personal Data concerning yourself, which is based on point (e) or (f) of Article 6(1) of the GDPR.

Avow shall no longer process the Personal Data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

In addition, you have the right, on grounds relating to your particular situation, to object to processing of Personal Data concerning yourself by Avow for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

In order to exercise the right to object, you may directly contact us. In addition, you are free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to your right to object by automated means using technical specifications on the Site.

 

h) Right to withdraw data protection consent

You have the right granted by the European legislator to withdraw your consent to processing your Personal Data at any time. If you wish to exercise the right to withdraw the consent, you may at any time directly contact us.

Users will have the right to equal service and price, even for consumers who exercise their privacy rights.

A summary and further details about your rights under EU data protection laws, is available on the EU Commission’s website at: https://ec.europa.eu/info/law/law-topic/data-protection/reform/rightscitizens_en.

If you do not agree with our Policy, activities and/or practices, you have the choice not to use our Site. By accessing or using our Site or providing us with your Personal Data, you agree to our Policy and consent our use of your Personal Data. This Policy may change from time to time (see Changes to our Privacy Policy). Your continued use of our Site after we make changes is deemed to be acceptance of those changes, so please check periodically for updates.

You can revoke your consent at any time by sending a letter to Avow GmbH, Grimmstrasse 23, 10967 Berlin, Germany or in the form of an email to [email protected]

 

  1. California Privacy Rights

Additional to the rights listed in Par.7 above, residents of the American state of California have the right to know if their Personal Data is being sold and the right to opt-out of the sale of their Personal Data to third parties. Our Site does not include a “Do Not Sell My Personal Data” link because Avow does not, under any conditions, sell any data or Personal Data to third parties

 

  1. Data Retention

Avow stores the data collected through the Site for so long as required for the fulfilment of the contractual or legal obligations for which we collected your data. Afterwards, the data will be deleted without delay, unless we need your data as evidence for civil law purposes or until the legal storage period expires.

 

  1. Data Transfers

The Personal Data we collect on you will only be transferred if:

  • You provided your express consent under Art. 6(1) Sentence 1 Letter a of the GDPR,
  • The transfer is required under Art. 6(1) Sentence 1 Letter f of the GDPR for the establishment, exercise or defense of legal claims and if there is no reason to believe that you have an overriding interest in the non-disclosure of your data,
  • We are required by law under Art. 6(1) Sentence 1 Letter c of the GDPR to transfer your data or if
  • Permitted by law and required under Art. 6(1) Sentence 1 Letter b of the GDPR for the performance of a contractual relationship with you or for pre-contractual measures requested by you.
  • Furthermore, your Personal Data may be transferred if required by public authorities, court orders or legal proceedings if necessary for litigation or legal defense.

Data processing may partially be performed by service providers engaged by us. If we transfer data to our service providers, the service providers may only use this data for the performance of their tasks. Service providers are diligently selected and commissioned by us. There service providers might process your data outside the European Union, in countries which may have data protection rules that are different from those of your country. By using the Site and providing us your data, you consent to such transfers. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

 

  1. Children Under the Age of 16

Our Site and Services are not intended for children under 16 years of age. No one under age 16 may provide any information to us. We do not knowingly collect information from children under 16. If you are under 16, do not use or provide any information on our Site or on or through any of its features/register on the Site, use any of the interactive or public comment features of this Site or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

 

  1. Information Security

Avow implements industry-standard systems, applications and procedures to secure Personal Data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

Avow is concerned about safeguarding the confidentiality of Personal Data related to you and together with our hosting services implement systems, applications and procedures to secure Personal Data that minimize the risks of theft, damage, loss, unauthorized access or use of Personal Data.

However, although Avow makes efforts to protect your privacy, Avow cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

 

  1. Changes to this Privacy Policy

From time to time, Avow will update this policy. If the updates have minor consequences, they will take effect 7 days after Avow posts a notice on the Site. Substantial changes will be effective 30 days after Avow has initially posted the notice.

Until the new policy takes effect, you can choose not to accept it and terminate your use of the Site. Continuing to use the Site after the new policy takes effect means that you agree to the new policy.

 

  1. How to contact us

If you have any questions about Avow’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Email us at: [email protected]

Or write to us at: Avow GmbH, Grimmstrasse 23, 10967 Berlin, Germany

 

B. The Avow Services Privacy Policy 

 

  1. The Services

Avow provides its Services to Media Partners and Advertisers and enables them to run ad campaigns on mobile applications. This Policy explains Avow’s privacy practices for processing Personal Data through the Services. It applies when individual users access and use mobile applications that are connected to or use the Services.

When providing the Services, Avow has no direct engagement or interaction with the Users of the mobile application, except as specifically indicated in this Policy. Avow requires its Customers to provide a privacy notice, as required by Applicable Laws, and if required by such laws, to also provide an adequate notice to their mobile application’s users about this Policy.

Customers should have a legal basis for processing the Personal Data and inform users about the use of processors, such as Avow.

The Services are not directed to children under 16 years of age and Avow does not intentionally or knowingly collect Personal Data on such users.

 

  1. Categories of data processed in connection with the Services

In-app advertising is implemented using device identifiers and IDs or cookies and comparable technologies. The following usage data is collected and made available to us:

– current IP address of the device

– country, region, city where the app was installed

– date and time when the app was installed

– unique device identifiers and IDs (e.g. advertising ID such as IDFA on iOS or the Google advertising ID on Android)

– technical data about the device and operating system used

– browser type and version, mobile phone carrier, network status

– in some cases, post-install events such as acquisitions, registrations, etc. incurred after the app was installed

 

  1. Purposes of data processing in connection with the Services

Avow only collects Personal Data that the Customers have instructed Avow to collect via a written agreement, prior to such collection and subject to a User’s permissions within the mobile application or a User’s mobile device, or as otherwise permitted under Applicable Laws.

Moreover, the app providers or app aggregators who work with us to deploy advertising to the users of their apps by means of Avow’s services are responsible for the associated data controlling, respectively processing. Avow only processes data on behalf of the app providers so that the latter can monetise the ad space in their apps.

Avow does not know the name, address or email address of the users of the apps in which advertising is displayed. The unique device identifiers and IP addresses are needed for the delivery of our Services. Avow does not gather more data than needed for the delivery of the Services to our partners, does not create user profiles or deliver targeted advertising.

If the user clicks on the deployed advertising, for example to reach the advertised app in the respective app store, this is recorded by Avow. If the app is downloaded and installed or then opened, this is recorded by the respective app provider and Avow is notified. Here Avow does not know the identity of users, but by means of the identifiers can only recognise those users who have previously received one of the deployed ads. Avow receives this data about interactions with ads and installations of the new apps and the IP addresses, so that it can use this data to bill for its own services with customers (e.g. campaign costs), to enable billing verification, to create statistical overviews for customers and to measure the reach and efficiency of ads for Avow’s customers.

The IP addresses are used to roughly determine the region or approximate location of the user or device on which the app is currently being used. In particular, this location determination is intended to ensure that advertising is only deployed for apps that are also available at the user’s respective location, in their app store and in the national language. In their campaigns, customers of Avow specify in which regions the respective ad should be deployed.

Avow may use data about interactions with ads, installations of the new apps and events realised in the app after the app install if requested and allowed by the Customer for billing and fraud detection purposes.

 

  1. Legal Basis for Processing

As the Data Processor, Avow relies on the explicit consent of the User that is given through our Customer’s mobile application in order for our Services to process Personal Data.

On other occasions, we may process Personal Data when it is necessary for the performance of a contract or where required by law. Avow may also process Personal Data when it is in Avow’s or its Customer’s legitimate interests to do so and when these interests are not overridden by the individual’s data protection rights.

The data processing described in this Policy serves to implement and measure in-app advertising campaigns for the Customers of Avow. As such, data is only processed as part of Customer agreements or orders. Insofar as data from Avow is processed for purposes of billing, abuse monitoring or fraud prevention, error correction and for optimising Avow’s services, this is done on the basis of Avow’s legitimate interests. The legal basis in this respect is Art. 6 Para. 1 (f) GDPR.

 

  1. Data transfers

Avow only discloses data to third parties if this is necessary for the deployment of ads and the implementation of campaigns or other purposes listed in this privacy notice or if another legal basis for the disclosure of the data exists. The collection, storage and disclosure of usage data by the providers of apps in which the ad space is deployed, as well as the collection, storage and disclosure of data on interactions with ads and installations of the new apps, are controlled by and the exclusive responsibility of the respective providers of those apps. Avow processes these data for and on behalf of the Customers.

If Avow uses external service providers and discloses data to them, they may only use the data to fulfil their task and in connection with specific instructions. The service providers are contractually bound to the data protection requirements. In cases where data is processed in countries outside the European Union, appropriate safeguards are always in place to protect Data Subjects.

 

  1. Retention period

If an ad has been deployed or if an interaction with ads or an installation or interaction with a new app has occurred, Avow stores information on the successful deployment, interaction or installation. This is used to monitor the type and number of deployments in order to process and check the billing of campaigns to Avow’s customers, to detect fraud, identify and correct technical and other errors in the context of the deployment of ads or the installation of and interaction with apps. The data is stored for as long as the usage data and data about interactions with ads and installations of the new apps are required for these purposes. After that the data is erased.

 

  1. EU Data Subject Rights

Under GDPR, Avow processes Personal Data as part of its Services as a Data Processor at the instructions of Advertiser and Media Partner. As a Data Processor, Avow is committed to assist the Controllers to fulfil Data Subjects’ GDPR rights.

Avow however has no direct relationship with our Customers’ users whose information we may process. A user of a Customer’s app or services, who seeks access, or who seeks to correct, amend, or delete inaccurate data should direct his query to our Customer directly as they are the body collecting the data and therefore the Data Controller.

 

  1. California Residents’ Privacy Rights

Under the California Consumer Privacy Act, Avow collects Personal Data as part of its Services as a Service Provider at the instructions of Customers who are the Businesses under the CCPA. As a service provider, Avow is committed to assist its Customers-businesses to fulfil Consumers’ rights, as required under the CCPA. Therefore, the User is advised to contact the relevant Customer, to exercise the User’s rights under the CCPA.

If a Customer request us to delete any User’s Personal Data that we collected from him/her, on their behalf, and retained as part of our Services to it, we will delete the User’s Personal Data from our records, unless retaining such information is necessary for us to detect security incidents, identify and repair errors, exercise free speech or another right provided by law, comply with specific laws or legal obligations, or any other internal and lawful uses.

Avow does not sell any data or Personal Data.

 

  1. Transfer of data outside the EEA

If Avow will transfer Personal Data to any country outside the European Union, which is not recognised as providing an adequate level of protection of Personal Data, it shall first take all such measures as necessary to ensure an adequate level of protection of Personal Data in accordance with the requirements of GDPR.

To the extent necessary under EU privacy laws and regulations, Avow will implement data onward transfer instruments, such as the Standard Contractual Clauses.

 

  1. Information Security

Avow commits to safeguarding the confidentiality of Personal Data. Avow implements systems, applications and procedures to secure Personal Data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.

While all measures provided reflect the current industry standard of security, Avow cannot guarantee that the Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

 

  1. Changes to this Policy

From time to time, Avow will update this Privacy Policy. If the updates have minor consequences, they will take effect 7 days after Avow posts a notice on the Services’ website or requests its applicable Customers to provide the notice. Substantial changes will be effective 30 days after Avow’s notice was initially posted.

In case of Policy changes due to changes in legal requirements, the new policy will become effective immediately or as required.

 

  1. Contact

If you have any questions about the Policy, please do not hesitate to contact us by

Email at: [email protected]

Or write to us at: Avow GmbH, Grimmstrasse 23, 10967 Berlin, Germany