This Privacy Notice for Guest.Tech, LLC (doing business as Avvail) ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:
Avvail primarily acts as a "data processor," meaning we process personal information on behalf of our clients, who act as the "data controllers." In this role, our clients determine the purposes and means of the data processing, and we process personal data strictly in accordance with their instructions and the terms of our data processing agreements.
However, in certain situations, Avvail may act as a "data controller." This occurs when we independently determine the purposes and means of processing. This Privacy Notice applies only to the personal information we process in our capacity as a data controller. It does not apply to data we process on behalf of our clients. For information on how our clients handle your personal data, including your rights and how to exercise them, please refer to their respective privacy policies and contact them directly.
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. This Privacy Notice does not apply to your use of any third-party sites linked to this website. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@avvail.com.
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
Personal Information refers to any information that identifies, relates to, or is reasonably capable of being associated with an identifiable individual or household. This includes, but is not limited to, names, addresses, geolocation data, online identifiers, and other unique characteristics. Personal Information can also include indirect identifiers such as device identifiers and aggregated data if it can reasonably be linked to an individual.
An identifiable natural person, or "Data Subject," is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location information, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
In Short: Some information, such as your Internet Protocol (IP) address and/or browser and device characteristics, is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The personal information we collect includes:
| Context | Types of Information | Primary Purpose for Collection and Use of Information |
|---|---|---|
| Client Information | We collect the names, usernames, and contact data of our clients and their employees with whom we may interact. | We collect this information based on your consent. We are also executing on a contractual obligation in contacting our clients and communicating with them concerning normal business administration such as billing, registration, and our services. |
| Client and User Account Information | We collect personal information from our clients and users of our Services when they create an account with us to access and use our Services. This information could include business contact data such as name, email address, title, company information, and phone number. | We are executing on our contract by delivering services to our clients and managing the associated client relationship. |
| Cookies and First-Party Tracking | We use cookies and small data files. "Cookies" are small pieces of data that a website sends to a computer's hard drive while a website is viewed. | We have a legitimate interest in making our website operate efficiently and in improving our marketing efforts and Services. See our Cookie Notice below. |
| Cookies and Third-Party Tracking | We participate in behavior-based advertising and the gathering of analytics. This means that a third-party uses technology (e.g., a cookie) to collect data about your use of our websites so that they can provide us with website and user analytics, as well as for the purposes of advertising products and services tailored to your interests on our website, or on other websites. | We have a legitimate interest in engaging in behavior-based advertising and capturing website analytics in improving our marketing efforts. For additional information on our use of cookies, please see our Cookie Policy below. Additionally, you can manage your cookie consent preferences in the cookie consent manager via our website's cookie banner. |
| Email Interconnectivity | If you receive an email from us, we may use certain tools to capture data related to when you open our message or click on any links or banners contained within. | We have a legitimate interest in understanding how you interact with our communications to improve relevance and engagement. |
| Employment-related information | If you apply for a job posting or become an employee of Avvail, we collect the information necessary to process your application or to retain you as an employee. This may include, among other things, your name, address, email address, I-9 information, Social Security Number or Personal Public Service Number, work history, resume, EEO information, veteran status, disability status, healthcare information, and bank account information. Providing this information is required for employment. | We use information about current employees to fulfil our contract of employment or the anticipation of a contract of employment with you. In some contexts, we are also required by law to collect information about our employees. We are executing on a contractual obligation in using your information to have efficient staffing and workforce operations. |
| Feedback and Support | We collect personal information from you contained in any inquiry you submit to us regarding our Services, such as completing our online forms, calling, or emailing for the purposes of general inquiries, support and chat requests, or to report an issue. When you communicate with us through our live support chat or over the phone, your messages and calls may be recorded and analyzed for training, quality control, and for sales and marketing purposes. During such interactions, we will notify you of the recording via either voice prompt or script. | We have a legitimate interest in receiving and acting upon your feedback, issues, or inquiries to improve support and service offerings. |
| Mailing List | When you sign up for one of our blogs, newsletter, mailing lists, or webinars, we collect contact information such as your name, email address, and company affiliation. | We collect this information based on your consent, which you provide when you sign up for our blog, newsletter, mailing list, or webinar. You may withdraw your consent at any time by using the unsubscribe link in our communications or by contacting us directly. |
| Payment Information | We collect payment and billing information when you receive certain Services. For example, we ask you to designate a billing representative, including name and contact information, upon registration. You might also provide payment information, such as payment card details, which we collect via secure payment processing services. | We are executing on a contractual obligation in obtaining payments for certain Services. |
| Website Interactions | We use technology to monitor how you interact with our Services. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser. | We have a legitimate interest in understanding how you interact with our Services to better improve them, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud. |
| Social Media | When an individual interacts with our Services through various social media networks, such as when someone follows us or shares our content on LinkedIn, or other social networks, we may receive some information about individuals that they permit the social network to share with third-parties. The information we receive is dependent upon an individual's privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you permit the social network to share with third-parties. | We use this information to update and maintain the page to provide you with content and features of our Services, as well as to improve our product outreach. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We have a legitimate interest and/or may obtain your consent to collect this information. |
| Web Logs and Usage Data | Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings). | We have a legitimate interest in monitoring our networks and visitors to our Services. Among other things, it helps us to monitor performance and to understand which of our Services and features are the most popular. |
| Device Data | We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information. | We have a legitimate interest in collecting device data to ensure the security, stability, and performance of our Services. This information helps us detect and prevent fraudulent activity, monitor system usage, optimize compatibility across different devices, and understand how users interact with our Services to improve functionality. |
| Location Data | We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services. | We collect geolocation information based on our legitimate interest in enhancing service relevance, optimizing user experience, and ensuring compliance with applicable location-based legal requirements. |
| User-generated Content (UGC) | Reviews, comments, or questions you submit, including feedback provided through surveys, contact forms, social media channels, or direct communications with our team. | We have a legitimate interest in collecting user-generated content to enhance our services and improve user experience. |
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third-parties, business partners, our affiliates, or publicly available sources. For example, if you submit a job application, or become an employee, we may conduct a background check.
Avvail has committed to complying with laws applicable to individual privacy and privacy breach notification that are enacted in the various jurisdictions in which it operates and offers its Services, collectively referred to as "Data Protection Laws."
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
Please do not include or provide any personal information unless specifically requested as part of the registration or other applicable processes. Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you sign up for our Services, we may collect your information to complete that transaction, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about our Services.
If we wish to use your personal information for a purpose which is not compatible with the purpose for which it was collected, we will request your consent, unless there is an exception which applies under applicable law. In all cases, we balance our legal use of your personal information with your interests, rights, and freedoms in accordance with applicable laws and regulations.
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
The categories of third parties we may share personal information with are as follows:
In Short: We may use cookies and other tracking technologies to collect and store information for analytics and site functionality.
We use cookies (small text files placed on your device to track activity) and similar tracking technologies (such as web beacons and pixels) to collect information when you interact with our Services. These technologies help us maintain security, prevent crashes, fix bugs, save your preferences, and assist with basic site functions. We also use them for our own analytics to understand how users interact with our Services and improve their experience.
We also permit third parties and service providers to use cookies and similar technologies for analytics and advertising purposes. These technologies may:
These advertisements may appear both on our Services and across other websites.
In Short: We engage subprocessors to support the delivery of our Services.
Avvail engages certain third-party service providers ("subprocessors") to support the delivery of our Services. We maintain an up-to-date list of these subprocessors which is available upon request. We may add or replace subprocessors as our business needs evolve and will update our subprocessor list accordingly.
We encourage users to review this list periodically to stay informed of any updates. In situations where we are required to provide notice under applicable law or a specific contractual obligation, we will notify users of such changes directly. By continuing to use our Services, you acknowledge and accept any changes made to our subprocessor list. If you have questions or concerns about our subprocessors, please contact us at privacy@avvail.com.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements), or unless you request that we delete it.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. Aggregated, anonymized, or de-identified data may be retained indefinitely. Additionally, we may retain personal data for a commercially reasonable period to meet backup, archival, audit, dispute resolution, or legal compliance needs.
The specific retention period depends on the nature of the personal information and the reasons for which it was collected. When determining how long to retain personal information, we consider several factors, including:
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. These measures include access restrictions, encryption, procedural safeguards, and secure data hosting environments.
Access to your personal information is limited to authorized personnel who require the data to perform their duties and who are trained on the importance of maintaining its confidentiality. Our service providers and business partners are contractually obligated to protect personal information and are prohibited from using it for unauthorized purposes.
If we are legally required to inform you of a data breach, we may notify you electronically, in writing, or by telephone, in accordance with applicable laws.
However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We implement appropriate safeguards to ensure your personal data remains safe during international transfers.
We transfer and store data in the USA. Where required, we implement appropriate safeguards for international data transfers, such as Standard Contractual Clauses (SCCs), Binding Corporate Rules (BCRs), industry best practices, and compliance with applicable regulations. These measures ensure that personal data remains protected even when transferred outside these jurisdictions.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly collect, solicit data from, or market to children under eighteen (18) years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at privacy@avvail.com.
In Short: You may access, review, delete, change, or terminate your account at any time, depending on your country, province, or state of residence.
Depending on your location, you may have the following rights regarding your personal information:
To exercise any of the above rights, please email privacy@avvail.com. We will consider and act upon any request in accordance with applicable data protection laws.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent by contacting us using the contact details provided in the section HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you may email us at privacy@avvail.com.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last Updated" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may email us at privacy@avvail.com or contact us by post at:
Guest.Tech, LLCIf you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.
We have collected the following categories of personal information in the past twelve (12) months:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, or account name | YES |
| B. Personal information as defined in the California Customer Records statute | Name, contact information, education, employment, employment history, or financial information | YES |
| C. Protected classification characteristics under state or federal law | Gender, age, date of birth, race and ethnicity, national origin, marital status, or other demographic data | NO |
| D. Commercial information | Transaction information, purchase history, financial details, or payment information | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, or interactions with our and other websites, applications, systems, or advertisements | YES |
| G. Geolocation data | Device location | YES |
| H. Audio, electronic, sensory, or similar information | Images and audio, video, or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details in order to provide you our Services at a business level or job title, work history, or professional qualifications if you apply for a job with us | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from collected personal information | Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences or characteristics | NO |
| L. Sensitive personal Information | Social Security numbers, driver's license numbers, passport numbers, credit or debit card numbers, bank account details, fingerprints, facial recognition data, DNA profiles, medical conditions, health insurance information, precise geolocation data, religious beliefs, political opinions, racial or ethnic origin, sexual orientation, or union membership | NO |
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Learn more about the sources of personal information we collect in WHAT INFORMATION DO WE COLLECT?
Learn more about how we use your personal information in the section, HOW DO WE PROCESS YOUR INFORMATION?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:
Depending upon the state where you live, you may also have the following rights:
To exercise these rights, you can contact us by emailing us at privacy@avvail.com, or by referring to the contact details at the bottom of this document.
Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide a written and signed permission from you to submit such request on your behalf.
Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@avvail.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at privacy@avvail.com.
If you have questions or comments about this notice, you may email us at privacy@avvail.com or contact us by post at:
Guest.Tech, LLCIf you are a resident of the European Economic Area, we rely on our legitimate interest, contractual relationship, and your consent as described in this Privacy Statement to process your personal information. Additionally, subject to any exemptions as provided by law, you may have certain rights regarding the personal information we maintain about you. We offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the "HOW CAN YOU CONTACT US ABOUT THIS STATEMENT?" section below.
According to the GDPR, UK GDPR, and FADP, you have the following rights:
Please note that the above rights are not absolute, and we may be entitled to refuse requests, wholly or partly, where exceptions under applicable law apply. We will not discriminate against you for exercising such rights.
Learn more about the sources of personal information we collect in WHAT INFORMATION DO WE COLLECT?
Learn more about how we use your personal information in the section, HOW DO WE PROCESS YOUR INFORMATION?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
Except as described in this Statement or provided for under applicable privacy laws, there is no charge to exercise your legal rights. However, if your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may charge a reasonable fee taking in account the administrative costs of providing the information or taking the action requested; or refuse to act on the request and notify you of the reason for refusing the request.
If you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
You may contact our privacy function of record, Goeun Son (BD Emerson LLC), by sending an email to privacy@avvail.com.
If you have questions or comments about this Statement, you may email us at privacy@avvail.com or contact us by post at:
Guest.Tech, LLC