Updated: May 24, 2023

 

Thank you for choosing to be part of our community at AveNew Solutions, LLC (“Company,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this Global Privacy Policy (“Privacy Policy”), or our practices with regards to your personal information, please contact us at Awespira@AveNew.org.

 

When you visit our website https://www.AveNew.org (the "Website"), use our mobile application, as the case may be (the "App"), and more generally, use any of our Services (collectively, the "Services,” which include the Website and App), we appreciate that you are trusting us with your personal information. We take your privacy very seriously. In this Privacy Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. Please take the time to read through it carefully, as it is important. 

 

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF USE, PLEASE DO NOT USE OUR WEBSITE AND ONLINE SERVICES AND DO NOT PROVIDE US WITH YOUR PERSONAL INFORMATION

 

This Privacy Policy applies to all information collected through our Services (which, as described above, includes our Website and App), as well as any related services, sales, texts, marketing, or events.

 

It does not apply to information collected by us offline or through any other means, including on any other website operated by the Company (or any third party). It does not apply to information collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or through the Services.

 

Please read this Privacy Policy carefully as it will help you understand what we do with the information that we collect.

 

CALIFORNIA RESIDENTS: Please click here for the Special Notice regarding more information about specific privacy rights applicable to California residents.

 

COLORADO, VIRGINIA, UTAH, CONNECTICUT RESIDENTS: Please click here for the Supplemental Privacy Notice for these states. 

 

EUROPEAN UNION, EUROPEAN ECONOMIC AREA AND UNITED KINGDOM: Please click here for our European Union, European Economic Area and United Kingdom Privacy Policy Addendum, if you reside in the European Union (“EU”) or the European Economic Area (“EEA”), or the United Kingdom (UK), for certain rights with respect to your personal information. 

 

This Privacy Policy is incorporated into and made part of our Terms of Use. Please read this Privacy Policy and our Terms of Use carefully. When you submit or provide Personal Information to us, you consent to the collection, use and disclosure of your Personal Information as described in this Privacy Policy.

 

SECTION 1. CHANGES TO THIS PRIVACY POLICY

 

The Effective Date of this Privacy Policy is set forth at the top of this webpage. As business needs change, we will review our practices regarding the collection and use of your Personal Information, and we may amend this Privacy Policy as appropriate. The amended Privacy Policy supersedes all previous versions. We will alert you about any changes by updating the “Updated” date to this Privacy Policy, and you waive any right to receive specific notice of each such change. It is your responsibility to periodically review this Privacy Policy to stay informed of updates. You will be subject to and will be deemed to have been made aware of and to have accepted the changes in any revised Privacy Policy by your continued use of this website after the date such revised Privacy Policy is posted. Your continued use of the Services after the posted “Updated” date constitutes your acceptance of the revised or amended Privacy Policy. If you do not agree with the Privacy Policy on this website or any revisions to the Privacy Policy, you agree to immediately stop accessing and using this website.

 

SECTION 2. PERSONAL INFORMATION WE MAY COLLECT

 

In this Privacy Policy, “Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, with an individual (e.g., you) or household. Personal Information does not include aggregated information to the extent that an individual’s identity cannot reasonably be derived from it.

 

The Personal Information we collect about you depends on your interactions and engagement with us.

 

We may collect the following types of Personal Information:  

 

1. Direct Identifiers and Personal Information Provided by You such as your name, postal address, email address, telephone or mobile number, unique personal identifiers, online identifier, Internet Protocol, email address, account name, your signature, social security number, driver’s license or state identification card, employment, employment history, financial information, and any information needed to assist you with a financial matter, debit card, payment card, or payments we receive from you, or make or send on your behalf.

2. Protected Characteristics provided by you such as your age (including birthdates), marital status, sex (including gender), gender identity, gender expression, race, ancestry, national origin, citizenship, veteran, or military status.

3. Commercial Information such as records of purchase history of products or services, financial details, payment information, any background information provided by you or collected by us as part of our business analysis, client onboarding, regulatory compliance checks and other related processes, and other client information provided to or made available to us by or on behalf of you, as well as information generated by us in the course of providing our products or services to you.

4. Internet or Other Electronic Network Activity Information such as records of your use of our website, mobile applications, or other online services. This may include your online identifiers, IP address, details of your device, operating system and browser, browser history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.

5. Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, such as your Facebook, Twitter, or other social media account. If you choose to register this way, we will collect the information as follows: 

 

SOCIAL MEDIA LOGINS.

 

We may offer you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.

 

We will use the information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

 

True, Complete and Accurate. 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.

 

The app does use third party services that may collect information used to identify you.

 

• Privacy policy of Google Play Store.

• Privacy policy of Apple App Store.

• Privacy policy of Facebook.

• Privacy policy of Twitter.

• Privacy policy of Google.

 

1. Geolocation Data such as your location as derived from your IP address, or information collected through your use of our mobile applications, including (i) the location of the mobile device or tablet derived from GPS or WiFi use and (ii) other information made available by a user or others that indicates the current or prior location of the user, such as geotag information in photographs. If you do not want us to collect such data from your device, please delete the App or disable the location setting on your device or tablet. Disabling the location setting may affect your ability to access and use our mobile applications. 

2. Audio, electronic, visual, or other sensory information, such as records of building and suite access and parking card use, and footage from building security cameras that indicate your location.

3. Sensitive Personal Information such as government-issued identification information, social security number, visa and passport information, account names and passwords, and (where necessary to fulfil our legal obligations or to provide you with a requested service). 

4. Inferences drawn from other Personal Information. 

 

Example: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s taste, color, or purchasing preferences and characteristics.

 

We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

 

• Receiving help through our customer support channels;

• Participation in customer surveys, rewards programs, or contests; and

• Facilitation in the delivery of our Services and to respond to your inquiries.

 

SECTION 3. COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

 

We collect, use, and disclose Personal Information for all lawful purposes in the operation and conduct of our business.

 

HOW WE MAY COLLECT PERSONAL INFORMATION

 

Directly From You: We may collect Personal Information through your use of the Services when you provide us Personal Information in the course of us providing you services. 

 

Through Social Media: Certain Services may link to social media platforms and plug-ins, such as Facebook and Twitter (collectively, “Social Media”). When accessing the Services through a Social Media account, we may (depending on the applicable user privacy settings) automatically receive Personal Information from that Social Media platform. We may collect and use this Personal Information for the purposes described in this Privacy Policy or as described at the time the information is collected.

 

From Third Parties: We may collect Personal Information about you from third parties, which include but is not limited to, vendors, distributors, licensees, business partners, etc., where such information is required for us to fulfil our legal obligations or to provide you with a requested service.

 

Through Gathering Service Usage Data, including from our Website and Apps: When you use the Services, including Apps, we and our vendors may collect the Internet Usage Information that is collected by most browsers or automatically through your device. When you download and use an App, we and our vendors may track and collect App data, including when you accessed our servers and what information has been downloaded via the App. We also collect Usage Data through our use of Data Collection Technology. Where Usage Data includes Personal Information, or is combined with Personal Information, it will be treated as Personal Information itself. 

 

HOW WE MAY USE PERSONAL INFORMATION

 

We may use Personal Information for the purposes described at the time of its collection or as described in this Privacy Policy. For example, we may use your Personal Information:

 

A.    To provide you or your company with our Services, such as carrying out any applicable contractual obligations that we have to you or third parties; verifying your identity; processing payments that you make to us or that we make or send on your behalf; accomplishing customer onboarding, confirming registrations, responding to your inquiries or fulfilling your requests, sending you information that we think may interest you; enabling you to provide us with further information; keeping a record of your contact information and correspondence to use when responding to you if you contact us through the Services or through other methods both online and offline. 

B.    For our internal business purposes, such as updating our records of your details, including contact and marketing details, where we identify that they are inaccurate or incomplete.

C.     For our internal research and product and services improvement purposes, such as analyzing use of the Services to help us detect problems, identify usage trends, and improve user experience.

D.    For legal, safety or security reasons, such as complying with legal requirements; complying with reporting and similar requirements; investigating and responding to claims against us and our customers; completing due diligence (such as in connection with a corporate transaction); protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents; and protecting against malicious, deceptive, fraudulent, or illegal activity.

E.     In connection with a corporate transaction, such as if we acquire, or some or all of our assets are acquired by, another entity, including through a sale in connection with bankruptcy and other forms of corporate change.

F.     For marketing, such as marketing our products or services or those of our affiliates. For example, we may use Personal Information we collect to send you newsletters, surveys, questionnaires, or information about our products and services. You can unsubscribe from our email marketing by contacting us using the information in Section 10 “Contact Us” of this Privacy Policy. 

 

HOW WE MAY DISCLOSE PERSONAL INFORMATION

 

We may disclose your Personal Information for the following reasons and to the following categories of third parties:

 

• With your consent. We may disclose your Personal Information to any party for whom your consent has been provided.

• To our affiliated entities. We may disclose your Personal Information within our business and corporate family for the purposes described in this Privacy Policy and as required by law. 

• To our service providers. We may disclose your Personal Information to third-party vendors that support our operations such as internet service providers, data analytics providers, external consultants, advertising networks, operating systems and platforms, distributors, licensees, and vendors that facilitate registering and hosting webcast and live events.

• Legitimate interests. We may disclose your Personal Information when it is reasonably necessary to achieve out legitimate business interests. Where we have entered into a contract with you, we may process and disclose your personal information to fulfill the terms of our contract. 

• To professional consultants. We may disclose your Personal Information to such professional consultants as accountants, lawyers, and financial advisors.

• To vendors necessary to complete transactions you request. We may disclose your Personal Information to such third-party vendors as shipping companies and logistics providers.

• In relation to a corporate transaction. We may disclose and transfer your Personal Information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (whether in whole or in part), including negotiation and diligence of such transaction.

• Business partners. We may disclose your Personal Information to our business partners, to offer you certain products, services, or promotions. Such companies may operate cookies and other tracking technologies. 

• For legal, security, or safety purposes. We may also disclose your Personal Information: (i) where we are legally required to do so in order to comply with applicable law, government requests, a judicial proceeding, court order, or legal process, such as in response to a court order or subpoena; (ii) as permitted by law; (iii) to protect the legitimate rights, privacy, property, interests or safety of our company or our affiliated entities, customers, business partners, employees or the general public; (iv) to pursue available remedies or limit damages; (v) to enforce our Terms of Use; and (vi) to respond to an emergency.

• Vital Interests. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Offer Wall. Our App may display a third-party hosted “offer wall.” Such an offer wall allows third-party advertisers to offer virtual currency, gifts, rewards, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our App and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our App. A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward. Please note that we do not control third- party websites and have no responsibility in relation to the content of such websites. The inclusion of any link towards a third-party website does not imply an endorsement by us of such website. Accordingly, we do not make any warranty regarding such third-party websites, and we will not be liable for any loss or damage caused by the use of such websites. In addition, when you access any third-party website, please understand that your rights while accessing and using those websites will be governed by the privacy policy and terms of service relating to the use of those websites.

 

SECTION 4. COOKIES AND OTHER TRACKING TECHNOLOGIES  

 

We use cookies and similar automatic tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in this section.

 

A.    About cookies. A cookie is a small computer file that can be placed on your device. It is sent to your Web browser and stored on your computer or mobile device. Cookies are used to “remember” you, to provide you with content relevant to your interests, for security reasons, and to help us understand how our Website and App are being used.

B.    Types of Cookies We Use. We may use three types of cookies in providing the Service: required cookies, analytics/performance, and advertising. Required cookies are essential to provide necessary security, enable you to browse around our Website and App, and use the features. Performance cookies collect information about how you use our Website and App. Advertising cookies allow us to provide you with meaningful content related to your interests and browsing history. 

C.     Our Website and App may also contain cookies set by third parties. Some of our Website’s pages rely on cookies from third parties such as Stripe to facilitate online purchases. We use cookies from Google to perform analysis on our Website and the App to help us understand how our products are being used. Third party cookies may also be used to deliver content of interest to you when you navigate away from our Website or the App.

D.    Examples of Cookies that We Use. Our cookies may change as our Website, App, and business needs change; however, the following is a list of some of the cookies we use and what they do:

 

Cookie: 1P_JAR

Type: Advertising

Purpose: Used to provide ad delivery or retargeting.

 

Cookie: hs

Type: Required

Purpose: Security cookie.

 

E.     Information Automatically Collected

 

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 who 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.

 

We collect information automatically through cookies and similar technologies. The information we collect includes:

 

(i)   Log 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).

(ii)  We may use three types of cookies in providing the Services: required, analytics/performance, and advertising. Required cookies are essential to provide necessary security, enable you to browse around our Website and App, and use the features. Performance cookies collect information about how you use our Website and App. Advertising cookies allow us to provide you with meaningful content related to your interests and browsing history. Our cookies may change as our Website, App, and business needs change; however, the following is a list of some of the cookies we use and what they do:

 

Cookie: 1P_JAR

Type: Advertising

Purpose: Used to provide ad delivery or retargeting.

 

Cookie: hs

Type: Required

Purpose: Security cookie.

 

Cookie: SvSession 

Type: Required

Purpose: Used in connection with user login.

 

Cookie: XSRF-TOKEN 

Type: Required

Purpose: Prevents cross-site request forgery.

 

F.   Information Collected Through Our App.

 

When you use our App, we also collect the following information:

 

(i)   Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings. The information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

(ii)  Personal Information. In addition to your name, email, company name and phone number, which you voluntarily provide us, we automatically collect browsing history and interests.

 

G.  Information Collected From Other Sources

 

In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g., Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings.

 

Our App may rely on Tribe to provide a platform for a discussion forum. Your comments may be publicly available. Tribe’s privacy policy may be found here: https://tribe.so/privacy-policy.

 

SECTION 5. CHOICES

 

Marketing Emails: If you do not wish to receive marketing-related emails from us, please click the unsubscribe link at the bottom of a marketing email or email us at Awespira@AveNew.org

 

Geolocation data linked to App use: If you do not want us to collect such data from your device, please delete the App or disable the location setting on your device or tablet. Disabling the location setting may affect your ability to access and use our mobile applications.

 

Cookies and web trackers: Although you are not required to accept cookies, web trackers or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Your ability to limit browser-based tracking technologies is subject to your browser settings and limitations.  

 

• You may disable the use of advertising cookies and other tracking technologies. Please click here for Cookie and Privacy Settings. You must complete this step on each of our websites from each browser and on each device that you use. These steps are necessary so that we can place a first-party cookie signaling that you have opted out on each browser and each device you use. Please note:

  • If you block cookies, we will be unable to comply with your request to opt out with respect to device data that we automatically collect and disclose to third parties online using cookies, pixels, and other tracking technologies.

  • If you clear cookies, you will need to disable the use of all advertising cookies and tracking technologies in the preference center again on each browser on each device where you have cleared cookies.

 

Regular cookies generally may be disabled or removed using tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. The choices available, and the mechanism used, will vary from browser to browser. Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or alert you when a cookie is placed on your computer or device. 

 

You may also be able to reject mobile device identifiers by adjusting the appropriate setting on your mobile device. Such browser settings are typically found in the “options,” “tools” or “preferences” menu of your browser. You may also consult your browser’s “help” menu.

 

SECTION 6. LINKS TO OTHER WEBSITES AND SERVICES

 

The Services may include links to third-party websites and services that we do not operate, such as social media plug-ins. If you visit a third-party website or service via a link on the Services, you are subject to that third party’s privacy practices and policies. This Privacy Policy does not apply to any Personal Information that you provide to third-party websites or services. A link to a third-party website or service does not mean that we endorse that third party or the quality or accuracy of the information presented on its website or service.

 

SECTION 7. NOTICE TO INTERNATIONAL VISITORS

 

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than the United States. Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers. Your use of the Services may involve the collection, processing, and transfer of information to or from countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country. For visitors from the EU, EEA, or UK, please see our European Union, European Economic Area and United Kingdom Privacy Policy Addendum.

 

SECTION 8. SECURITY

 

We take reasonable precautions intended to help protect the Personal Information that we collect and store; however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services. Any transmission is at your own risk. Please use security measures to protect your Personal Information.

 

SECTION 9. CHILDREN’S PRIVACY

 

The online content and Services are not directed to or intended for use by minors. Consistent with the requirements of the US Children’s Online Privacy Protection Act. If we learn that we have received information directly from a child under age 16 without his or her parent’s or legal guardian’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. Subsequently, we will make commercially reasonable efforts to delete such information.

 

OUR SERVICES NOT INTENDED FOR MINORS UNDER 18 YEARS OF AGE

 

Our Services are not directed to, nor are they intended for minors under 18 years of age. We do not knowingly solicit data from or market to minors under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from a minor 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 minors under age 18, please contact us at Awespira@AveNew.org.

 

SECTION 10. CONTACT US

 

We welcome your questions and comments about this Privacy Policy.  You may contact us by email at Awespira@AveNew.org, by phone at 213-387-0780, or by mail to:

 

AveNew Solutions, LLC

5256 S. Mission Rd. Ste 703, #335 

Bonsall, CA  92003