General

This Privacy Policy describes how AVRA collects, uses and discloses information, and what choices you have with respect to the information. Updates in this version of the Privacy Policy reflect changes in data protection law. In addition, we have worked to make the Privacy Policy clearer and more understandable by:
• organizing it into the sections listed in the Table of Contents below,
• providing a series of examples that help illustrate how the policies may be implemented by AVRA and
• defining and capitalizing a few terms that are used more than once for simplicity and brevity.
When we refer to “Us”, “We”, “AVRA”, “AVRA”, we mean the AVRATOURS S.A.. entity that acts as the controller or processor of your information, as explained in more detail in the “Identifying the Data Controller and Processor” section below.

Applicability Of This Privacy Policy

This Privacy Policy applies to AVRA’s online collaboration platform, including the associated AVRA mobile and desktop applications and bot messaging platforms on Microsoft Teams (collectively, the “Services”), avra.travel and other AVRA websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, user conferences, etc.) you may have with AVRA. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of AVRA’ business.

Information We Collect And Receive

AVRA may collect and receive Customer Data and other information and data (“Other Information”) in a variety of ways:

Customer Data. Content and information submitted by users of the Services is referred to in this policy as “Customer Data.” As further explained below, Customer Data is controlled by the organization or other third party entities that creates the content (the “Customer”). Where AVRA collects or processes Customer Data, it does so on behalf of the Customer. Customers or individuals granted access to a AVRA Community (“Authorized Users”) routinely submit Customer Data to AVRA when using the Services.
Some examples of Customer Data include: feedback items, responses to feedback, comments, images and videos.
A user of the services is able to enter information into their user profile such as name, email address, photo and information related to their position in their organizational hierarchy (i.e information about their manager and/or direct reports). If you are joining an organization and creating a user account on the Service or were invited to use the platform, you are a “User”.

Other Information. AVRA also collects, generates and/or receives Other Information:
Community and Account Information. To create or update a community account, you or your Customer (e.g., your employer) supply AVRA with an email address, domain and/or similar account details including authentication information via common social providers (i.e Google / Office 365). In addition, Customers that purchase a paid version of the Services provide AVRA (or its payment processors) with billing details such as credit card information, banking information and/or a billing address.
Usage Information

• Services Metadata. When an Authorized User interacts with the Services, metadata is generated that provides additional context about the way Authorized Users work. For example, AVRA logs the Community, channels, people, features, and content you interact with.
  
• Log data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  
• Device information. AVRA collects information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data. Whether we collect some or all of this Other Information often depends on the type of device used and its settings.
  
• Location information. We receive information from you, your Customer and other third-parties that helps us approximate your location. We may, for example, use a business address submitted by your employer, or an IP address received from your browser or device to determine approximate location. AVRA may also collect location information from devices in accordance with the consent process provided by your device.
  
• Cookie Information. AVRA uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.
  
• Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import (such as an address book from a device) is collected when using the Services.
  
• Third Party Data. AVRA may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
  
• Additional Information Provided to AVRA. We receive Other Information when submitted to our Websites or if you participate in a focus group, contest, activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with AVRA.

Generally, no one is under a statutory or contractual obligation to provide any Customer Data or Other Information (collectively, “Information”). However, certain Information is collected automatically and, if some Information, such as Community setup details, is not provided, we may be unable to provide the Services.

How We Use Information

Customer Data will be used by AVRA in accordance with Customer’s instructions, including any applicable terms in the Customer’s Use of Service, and as required by applicable law. AVRA is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Community, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.

AVRA uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, AVRA uses Other Information:

To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
As required by applicable law, legal process or regulation.
To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
To develop and provide search, learning and productivity tools and additional features. AVRA tries to make the Services as useful as possible for specific Communities and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, andimportant Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about AVRA. These are marketing messages so you can control whether you receive them.
For billing, account management and other administrative matters. AVRA may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
To investigate and help prevent security issues and abuse.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, AVRA may use it for any business purpose. To the extent Information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”

Data Retention

AVRA will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Depending on the Services plan, Customer may be able to customize its retention settings and apply those customized settings at the Community level, channel level or other level. Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. AVRA may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for AVRA to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

How We Share And Disclose Information

This section describes how AVRA may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and AVRA does not control how they or any other third parties choose to share or disclose Information.

• Customer’s Instructions. AVRA will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
• Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Communities. For example, an Authorized User’s email address may be displayed with their AVRA profile.
• Collaborating with Others. The Services provide different ways for Authorized Users working in independent Workspaces to collaborate, such as shared channels. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Workspace(s).
• Customer Access. Owners, administrators, Authorized Users and other Customer representatives and personnel may be able to access, modify or restrict access to Other Information. This may include, for example, your employer using Service features to export logs of Workspace activity, or accessing or modifying your profile details.
• Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services. Additional information about the subprocessors we use to support delivery of our Services is set forth at AVRA Subprocessors.
• Corporate Affiliates. AVRA may share Other Information with its corporate affiliates, parents and/or subsidiaries.
• During a Change to AVRA’s Business. If AVRA engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of AVRA’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective AVRA customer the average amount of time spent within a typical community.
• To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of AVRA or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With Consent. AVRA may share Other Information with third parties when we have consent to do so.

Security

AVRA takes security of data very seriously. AVRA works hard to protect Other Information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Other Information we collect, process and store, and the current state of technology.

Given the nature of communications and information processing technology, AVRA cannot guarantee that Information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others.

We utilise industry best practices for SaaS companies in the handling, storing and dissemination of information.

Age Limitations

To the extent prohibited by applicable law, AVRA does not allow use of our Services and Websites by anyone younger than 16 years old. If you learn that anyone younger than 16 has unlawfully provided us with personal data, please contact us at privacy@avra.travel and we will takes steps to delete such information.

Changes To This Privacy Policy

AVRA may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, AVRA will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

International Data Transfers Privacy Shield And Contractual Terms

AVRA does not transfer your Personal Data to countries other than the one in which you live.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, Customer is the controller of Customer Data. In general, AVRA is the processor of Customer Data and the controller of Other Information.

Your Rights

Individuals located in certain countries, including the European Economic Area, have certain statutory rights in relation to their personal data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete or correct this Information. You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact Customer for additional access and assistance. Please contact our customer support team.

To the extent that AVRA’s processing of your Personal Data is subject to the General Data Protection Regulation, AVRA relies on its legitimate interests, described above, to process your data. AVRA may also process Other Information that constitutes your Personal Data for direct marketing purposes and you have a right to object to AVRA’s use of your Personal Data for this purpose at any time.

Data Protection Authority

Subject to applicable law, you also have the right to (i) restrict AVRA’s use of Other Information that constitutes your Personal Data and (ii) lodge a complaint with your local data protection authority. If you are a resident of the European Economic Area and believe we maintain your Personal Data within the scope of the General Data Protection Regulation (GDPR), you may direct questions or complaints to our privacy contact at privacy@avra.travel.

Contacting AVRA

If you have any questions about this Privacy Policy or our practices. Please contact us at privacy@avra.travel.
Or the following physical address:
AVRATOURS S.A.
13, Didous str N. Alikarnassos
Heraklion/CreteM5V 2K4/Greece