Privacy Policy
Version 1.1
Effective Date: 22 July 2024
Thank you for choosing to use the AVI-GO website or mobile application (hereinafter referred to as the "Digital Products") operated by AVI-GO (referred to as "we" or "our").
This Privacy Policy aims to inform you about how we collect, use, and disclose the various types of personal data detailed in Section 1 of this Privacy Policy (collectively, the "Personal Data") and your related choices regarding such Personal Data.
By continuing to use our Digital Products and/or other services, you signify that you have read and understood this Privacy Policy and that you agree and consent to our collection, use and disclosure of your Personal Data according to the terms and conditions of this Privacy Policy.
1. Data Collection
AVI-GO collects various types of Personal Data to provide and improve our Digital Products and/or other services, including: All data (whether true or not) about an individual who can be identified from that data, or from that data in combination with other information to which we may have access or are likely to have access, which includes but is not limited to the following examples of data collected when you register, book services, or contact us:
- Identity Data: Full name, username, or similar identifier.
- Contact Data: Billing address, delivery address, email address, and telephone numbers.
- Financial Data: Bank account and payment card details.
- Transaction Data: Details about payments to and from you and other details of services you have purchased from us.
Information on how you access and use our Digital Products and/or other services and other diagnostic data to help us understand how you interact with our Digital Products and/or other services, which includes but is not limited to the following examples:
- Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Profile Data: Your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data: Information about how you use our website, products, and services.
- Marketing and Communications Data: Your preferences in receiving marketing from us and your communication preferences.
AVI-GO use cookies, beacons, tags, and scripts to collect and track information, remembering your preferences, enhancing user experience, and monitoring service usage. Cookies are small bits of data automatically stored on the hard drive of the end user and are commonly used to track preferences in relation to the subject of such a website. If you enable these cookies, then your web browser adds the text to a small file. You may wish to set your web browser to notify you of a cookie placement request or refuse to accept cookies by modifying relevant internet options or browsing preferences of your computer system, but by doing so, you may not be able to utilise or activate certain available functions on our website. AVI-GO gathers information on its website activity through cookies, such as data on the number of visitors, the pages they visit, the duration of their stay, etc. We do not automatically collect Personal Data on our website unless you provide such information or log in with your account credentials.
AVI-GO uses Google Analytics to track and report website traffic. Google Analytics collects data such as your IP address, browser type, and pages visited, which helps us understand how you use our website and improve our Digital Products and/or other services. Google may use the collected data to contextualise and personalise the ads of its own advertising network. You can opt out of having made your activity on the website available to Google Analytics by installing the Google Analytics opt-out browser add-on. Furthermore, we use the Google Analytics Advertising Features (“Advertising Features”). By enabling the Advertising Features, we enable Google Analytics to collect data about your traffic via Google advertising cookies and identifiers, in addition to data collected through a standard Google Analytics implementation. We implemented the following Google Analytics Advertising Features:
- Google Signals
- Granular Location Device Data Collection
- Ads Personalisation
- Cross Platform Reporting
- Remarketing with Google Analytics
- Advertising Reporting Features
- Demographics and Interests
We use these Advertising Features to evaluate website usage and obtain reports and metrics that help us improve performance and user experience and serve relevant advertising. We use third-party advertising services, which means that our advertisements may be displayed on other websites, such as partner websites. Through these advertising services, we can display ads that are tailored to your individual interests. These advertising services may also track your online activity over time across multiple websites and apps by collecting information through automated means. This data collection takes place both on our website and on third-party websites and apps that participate in these advertising services.
You can opt out of Google Analytics by the following means:
- Google Analytics Opt-out Browser Add-on: You can opt out of having your activity on the service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about your visit activity.
- Managing Cookies in Your Browser: Most browsers allow you to manage how cookies are set and used as you're browsing, and to clear cookies and browsing data. Also, your browser may have settings letting you manage cookies on a site-by-site basis. For example, Google Chrome's settings allow you to delete existing cookies, allow or block all cookies, and set cookie preferences for websites. Google Chrome also offers incognito mode, which deletes your browsing history and clears cookies on your device after you close your incognito windows.
- Managing Other Technologies in Your Apps and Devices: Most mobile devices and applications allow you to manage how other technologies, such as unique identifiers used to identify a browser, app, or device, are set and used. For example, the advertising ID on Android devices or Apple's advertising identifier can be managed in your device's settings, while app-specific identifiers may typically be managed in the app's settings.
For more information on the privacy practices of Google, please visit the Google Privacy Policy.
We may also collect Personal Data from third parties, such as our customers who may be providing your Personal Data to us for the purpose of arranging for our services. We may also collect information from publicly available sources and data suppliers to validate or supplement the information we hold.
Purpose of Collection
AVI-GO collects Personal Data to:
- Ensure a seamless and personalised user experience.
- Optimise our Digital Products and/or other services.
- Perform analytical purposes.
- Process transactions and manage your bookings.
- Communicate with you, including sending newsletters and promotional materials.
- Improve our customer service and respond to queries.
Legal Basis for Collection
Our legal grounds for collecting Personal Data include:
- Consent: When you provide clear consent for us to process your Personal Data for specific purposes.
- Contractual Necessity: To fulfil a contract with you or to take steps at your request before entering into a contract.
- Legal Obligation: To comply with legal obligations that AVI-GO are subject to.
- Legitimate Interests: When processing is necessary for our legitimate interests, provided these interests are not overridden by your rights and interests available under applicable laws.
2. Data Usage
AVI-GO uses Personal Data obtained through our services for various purposes, including but not limited to:
2.1 Service Provision and Maintenance:
- Operation and Maintenance: To operate and maintain our Digital Products and/or other services, ensuring they function as intended.
- Availability and Support: Making our Digital Products and/or other services available, responding to requests or queries, and providing customer support.
- Feature Management: To provide, manage, and improve the features and functionalities of our Digital Products and/or other services.
- Contractual Obligations: Performing the services contracted or requested by our customers, facilitating bookings, and enabling integrations with customer systems.
2.2 Customer Support:
- Inquiries and Assistance: To respond to your queries, provide assistance, and resolve any issues.
- Personalised Support: To offer personalised customer support and enhance user satisfaction.
2.3 Marketing and Communications:
- Promotions and Updates: To send newsletters, promotional materials, and other information that may interest you.
- Service Notifications: To communicate with you about updates, new features, and important notices regarding our Digital Products and/or other services.
2.4 Analytics and Service Improvement:
- Enhancements: Improving our Digital Products and/or other services and other offerings, developing new products, and customising the user experience.
- Analytics: Generating statistics, performing data analytics, and anonymising or aggregating data to prepare internal, customer, and industry insights
- User Behaviour Analysis: To understand user behaviour and analyse how our Digital Products and/or other services are used.
- Service Optimisation: To gather valuable information to enhance and optimise our Digital Products and/or other services, ensuring they meet user needs.
2.5 Compliance and Legal Obligations:
- Legal Requirements: To comply with legal requirements such as contractual obligations, court orders and subpoenas.
- Rights Protection: To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others.
2.6 Backup and Recovery:
- Data Protection: Backing up our systems for disaster recovery and enhancing the security of our Digital Products and/or other services.
These uses help us to enhance your experience, deliver quality services, and continually improve our offerings.
3. Legal Basis for Processing
AVI-GO processes your Personal Data based on several legal grounds to ensure compliance with applicable data protection laws and to maintain transparency about our data practices. These legal grounds include:
- Consent: AVI-GO relies on your express consent for processing activities such as subscribing to our newsletters or participating in surveys. This consent can be withdrawn at any time, without affecting the lawfulness of processing your Personal Data based on prior consent given before its withdrawal.
- Contractual Necessity: Processing Personal Data is essential to fulfil our contractual obligations to you or to take steps at your request before entering into a contract. This includes processing Personal Data that is necessary to provide our services, manage your account, and handle transactions.
- Legal Obligation: AVI-GO processes your Personal Data to comply with our legal obligations, such as tax regulations, reporting requirements, and responding to lawful requests from government authorities.
- Legitimate Interests: Processing your Personal Data is necessary for our legitimate business interests, provided these interests are not overridden by your rights and interests available under applicable laws. Our legitimate interests include improving our Digital Products and/or other services, ensuring the security of our systems, preventing fraud, and conducting our business operations effectively.
- Performance of a Task in the Public Interest: Processing Personal Data necessary for performing a task carried out in the public interest or in the exercise of any official authority that has been vested in us.
4. Data Retention
AVI-GO shall retain your Personal Data only for as long as necessary to fulfil the purposes described in this Privacy Policy, as well as to comply with our legal obligations, resolve disputes, and enforce our agreements. The criteria used to determine retention periods include:
- Purpose Fulfilment: We retain your Personal Data for the duration needed to fulfil the specific purposes for which it was collected.
- Legal Requirements: We retain your Personal Data to comply with legal obligations and regulations, such as tax laws and mandatory reporting requirements.
- Dispute Resolution and Enforcement: We retain your Personal Data for periods during which we might need to resolve disputes or enforce our agreements.
- Data Minimisation and Deletion: We regularly review the Personal Data we hold and securely delete personal data that is no longer necessary for the purposes for which it was collected.
- Review Schedule: We implement a regular schedule for reviewing data retention periods to ensure ongoing compliance with legal and operational requirements.
- Anonymisation: When appropriate, we anonymise Personal Data that is no longer needed in an identifiable form but may be useful for statistical purposes.
- User Notifications: We inform users when their Personal Data is nearing the end of its retention period and will be deleted or anonymised, offering them the option to extend retention if legally permissible.
- These measures ensure that your Personal Data is not kept longer than necessary and is securely deleted when no longer needed.
5. User Rights
AVI-GO is committed to ensuring that your Personal Data is handled in accordance with applicable data protection laws. As part of this commitment, you have the following rights regarding your personal data:
- Access: You have the right to request access to your Personal Data and obtain information about how we process it.
- Correction: You have the right to request correction of any inaccurate or incomplete Personal Data.
- Deletion: You have the right to request deletion of your Personal Data when it is no longer necessary for the purposes for which it was collected, or if you withdraw consent (where consent is the legal basis for processing).
- Data Portability: You have the right to request that we provide your Personal Data in a structured, commonly used, and machine-readable format, and to transmit such Personal Data to another organisation nominated by you.
- Restriction of Processing: You have the right to request the restriction of processing of your Personal Data under certain conditions, such as when you contest the accuracy of such Personal Data or object to our processing such Personal Data.
- Objection to Processing: You have the right to object to the processing of your Personal Data based on our legitimate interests or for direct marketing purposes.
- Withdrawal of Consent: Where we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time.
- Timeframe for Responses: We will respond to your requests regarding your rights in relation to your Personal Data within 30 days, and in accordance with the applicable personal data protection laws.
- Verification Process: To ensure the security of your Personal Data, we will verify your identity before fulfilling your request. This may involve requesting additional information or documentation to confirm your identity.
6. Third-Party Sharing
AVI-GO may share your Personal Data with third parties for various purposes only to the extent necessary. We shall ensure that your data is protected and only used in accordance with applicable laws. The categories of third parties we share data with and the purposes for such sharing include:
- Service Providers: We engage third-party service providers to assist in operating our Digital Products and/or other services, such as payment processors, marketing platforms, IT support, and cloud service providers. These service providers are contractually obligated to protect your Personal Data and are only permitted to process your Personal Data for specified purposes.
- Business Partners: We may share your Personal Data with trusted business partners for joint marketing initiatives or to offer integrated services. These partners are required to comply with applicable data protection laws and to use the Personal Data only for the agreed purposes.
- Legal Requirements: We may disclose your Personal Data to comply with legal obligations, respond to lawful requests from government authorities, including to meet national security or law enforcement requirements, or to protect our rights, privacy, safety, or property, as well as those of our users and affiliates.
- Corporate Transactions: In the event of a merger, acquisition, or sale of assets, your Personal Data may be transferred as part of the transaction. We will notify you of such changes in ownership or transfer of assets.
- International Transfers: Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. We shall ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected. Measures include standard contractual clauses approved by the relevant authorities, binding corporate rules, or other lawful mechanisms to ensure your Personal Data is adequately protected.
Please note that our Digital Products and/or other services may link to third-party websites and services that are outside our control. We are not responsible for the security or privacy of any information collected by third-party websites or other services. You should exercise caution and review the privacy statements applicable to the third-party websites and services you use. To the fullest extent permitted under applicable laws, we cannot be responsible for a third party's acts, omissions, data policies, or their use of cookies nor the content or security of any third-party websites, even if linked to our Digital Products and/or other services. Any such liability is expressly disclaimed and excluded.
7. Security Measures
AVI-GO takes the security of your Personal Data seriously and has implemented appropriate technical and organisational measures to protect your Personal Data against unauthorised access, loss, destruction, or alteration. These measures include:
- Data Encryption: We use encryption to protect Personal Data both in transit and at rest. This ensures that such Personal Data is unreadable to unauthorised individuals.
- Access Controls: We implement strict access controls to limit access to your Personal Data to authorised personnel only. This includes the use of passwords, authentication, and authorisation mechanisms.
- Regular Security Assessments: We conduct regular security assessments, including vulnerability assessments and penetration testing, to identify and address potential security threats.
- Security Policies: We have established comprehensive security policies and procedures to guide our employees and contractors in protecting Personal Data. These policies are regularly reviewed and updated.
- Incident Response Plan: We have an incident response plan in place to manage and respond to security incidents swiftly. This includes procedures for detecting, reporting, and mitigating the impact of any data breaches.
- Employee Training: We provide regular training to our employees on data protection and security best practices to ensure they are aware of their responsibilities in safeguarding Personal Data.
- Physical Security: We ensure that our physical premises are secure, with measures such as access controls, surveillance, and security personnel to protect against unauthorised physical access to data storage areas.
8. Data Breach Notification
AVI-GO is committed to protecting your Personal Data and will promptly notify you and the relevant authorities in the event of a data breach that results in, or is likely to result in, significant harm to you. Our data breach notification procedures include:
- Detection and Response: We have implemented systems and processes to detect and respond to data breaches promptly. This includes real-time monitoring of our systems and regular security audits.
- Risk Assessment: Upon detection of a data breach, we will immediately assess the potential impact and risk to your Personal Data. This assessment will help determine the severity of the breach and the necessary steps to mitigate the impact.
- Notification to Authorities: If a data breach is likely to result in a risk to your rights and freedoms, we will notify the relevant data protection authorities without undue delay and, where feasible, within 72 hours of becoming aware of the breach.
- Notification to Affected Individuals: If the data breach is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay. The notification will include:
- A description of the nature of the data breach.
- The name and contact details of our Data Protection Officer or other contact point where more information can be obtained.
- A description of the likely consequences of the data breach.
- A description of the measures taken or proposed to be taken to address the breach, including, where appropriate, measures to mitigate its possible adverse effects.
- Mitigation Measures: We will take immediate steps to contain and mitigate the impact of the data breach. This may include securing our systems, restoring data from backups, and implementing additional security measures to prevent future breaches.
- Review and Improvement: After addressing the immediate impact of the data breach, we will conduct a thorough review of the incident to understand its cause and identify any necessary improvements to our security measures and procedures.
By implementing these data breach notification procedures, AVI-GO aims to protect your Personal Data and minimise any potential harm in the event of a data breach. If you have any questions or need further information about our data breach notification procedures, please contact us at contact@avi-go.com.
9. Automated Decision-Making
AVI-GO may use automated decision-making processes, including profiling, in certain circumstances to enhance our Digital Products and/or other services and provide a better user experience. Automated decision-making involves using technology to make decisions without human intervention. Our use of automated decision-making is guided by the following principles as well as all applicable laws:
- Purpose and Scope: Automated decision-making is used to improve our Digital Products and/or other services, personalise user experiences, and streamline our operations. This may include recommendations, credit scoring, fraud detection, and other similar activities.
- Transparency: We are committed to transparency in our use of automated decision-making. You will be informed if a decision affecting you is made solely based on automated processing, and you will be provided with information about the logic involved and the significance and potential consequences of such processing.
- Human Intervention: You have the right to request human intervention, to express your point of view, and to contest decisions based on automated processing. We will ensure that there is a mechanism in place for you to appeal and seek a human review of such decisions.
- Data Accuracy: We ensure that the Personal Data used in automated decision-making processes is accurate and up-to-date to minimise the risk of errors and unfair outcomes.
- Security Measures: We implement appropriate security measures to protect the Personal Data used in automated decision-making from unauthorised access, alteration, or misuse.
- Compliance with Legal Standards: Our use of automated decision-making complies with applicable data protection laws and regulations, ensuring that your rights and freedoms are protected.
By implementing these principles, we aim to use automated decision-making in a way that enhances our Digital Products and/or other services while protecting your rights and interests.
10.Data Minimisation
AVI-GO adheres to the principle of data minimisation, which means we only collect and process the Personal Data that is necessary to achieve the specific purposes outlined in this Privacy Policy. Our data minimisation practices include:
- Purpose Limitation: We collect Personal Data for specified, explicit, and legitimate purposes and do not process it in a manner that is incompatible with those purposes.
- Data Relevance: We ensure that the Personal Data we collect is adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed.
- Regular Data Reviews: We regularly review the Personal Data we hold to ensure it is accurate, up-to-date, and no more than necessary for the purposes for which it is processed.
- Retention Policies: We establish and enforce retention policies that specify how long Personal Data is kept and ensure it is securely deleted or anonymised when no longer needed.
- Employee Training: We provide regular training to our employees on the principles of data minimisation and the importance of collecting only the necessary Personal Data.
By adhering to these data minimisation principles, AVI-GO ensures that your Personal Data is handled responsibly and only processed as necessary to provide and improve our Digital Products and/or other services.
11. Policy Updates
AVI-GO may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or other operational reasons. When we make changes to this Privacy Policy, we will notify you in one or more of the following ways:
- Notification: We will notify you of significant changes by email, through a notice on our website, or through other appropriate communication channels.
- Review and Consent: We will provide an updated version of the Privacy Policy on our website. If the changes require your consent, we will provide a clear mechanism for you to give your consent to the updated terms.
- Effective Date: The effective date of the updated Privacy Policy will be indicated at the top of the policy document. Continued use of our Digital Products and/or other services after the effective date constitutes your acceptance of the updated policy.
By keeping you informed of updates and ensuring your consent when necessary, AVI-GO strives to maintain transparency and trust in our data protection practices.
12. Contact Information
AVI-GO is committed to protecting your privacy and welcomes any questions, comments, or concerns you may have about this Privacy Policy or our data protection practices. You can contact us using the following information:
Email / Data Protection Officer (DPO): You can reach our data protection team at [contact@avi-go.com]. Please include your name and detailed information about your query or request.