Last updated: Jun-18-2019
Avora Holdings LTD., doing business as Invisible, complies with the EU-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information transferred from the European Union (EU) to the United States.
Avora Holdings LTD., doing business as Invisible, has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms of the Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit http://www.privacyshield.gov.
Your privacy is important to us, as well as being transparent about how we collect, use, and share information about you. This policy is intended to help you understand:
This Policy also explains what choices you have regarding the use of information about you. These choices include a possibility to object to certain uses of information about you and the ways you can access and update certain information about you. If you do not agree with this Policy, do not access or use our Services or interact with any other aspect of our business.
We collect information about you when you provide it to us directly or via our partners, after you give your consent while using our Services, and when other sources (Data Controllers) provide it to us.
Information you provide to us
We collect/process information about you when you input it into the Services or otherwise provide it directly to us.
Account and Profile Information: We collect information about you when you register an account, set product preferences, sign-up for or make purchases through the Services. For example, you provide your contact information and, in some cases, billing information when you register for the Services.
Content you provide through our websites: The Services include our websites owned or operated by us. We collect content that you submit on these websites. For example, you provide content to us when you share your feedback or when you engage with any interactive features, take part in surveys, promotions or online events.
Information you provide through our support channels: The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing with the Service. Whether you identify yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide your contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Payment information: We collect certain payment and billing information when you register for certain paid 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.
Information we collect automatically when you use the Services
We collect information about you when you use our Services, including browsing our websites and taking certain actions within the Services.
Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the links you click on and how you interact with others on the Services.
Device and connection information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
Information we receive from other sources
We receive information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.
Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned by your CRM administrator when submitting an issue to our technical support. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator may provide your contact information when they designate you as the billing contact for your company’s account.
Partners of Invisible: Some of our partners help us to market and promote our products, generate leads for us, and resell our products. We sometimes receive contact information, company name, what Invisible products you have purchased or may be interested in, evaluation information you have provided, what events you have attended, and what country you are in.
Other partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertisers that provide us with information about your interest in and engagement with our Services and online advertising.
Our Services are responsible for transferring data between systems using API technologies. None of that data is ever being stored on our servers or passed to any third party systems.
How we use information we collect depends on what Services you use, how you use them, and any preferences you may have communicated to us. Below are specific purposes of using information about you.
To provide the Services and personalize your experience: We use information about you to provide the Services to you, including to process transactions with you, authenticate you when you log in, provide customer support, and operate and maintain the Services. Our Services also include tailored features that personalize your experience and enhance your productivity.
For research and development: We constantly look for ways to make our Services smarter, faster, and more secure, integrated and useful to you. We use collective findings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. In some cases, we apply these findings across our Services to improve and develop similar features or to better integrate the services you use.
To communicate with you about the Services: We use your contact information to communicate with you via email and within the Services to confirm your purchases, remind you about subscription expiration, respond to your questions and requests, provide customer support, send you technical notices, updates, security alerts, and administrative messages, and so on. We also provide tailored communications based on your activity and interactions with us. We also send you communications as you on-board to a particular Service to help you become more proficient in using that Service.
To market, promote and drive engagement with the Services: We use your contact information and information about how you use the Services to send promotional communications that may be of specific interest to you, including by email and by displaying Invisible ads on other companies’ websites and applications, as well as on platforms like Facebook and Google. These communications include information about new features, survey requests, newsletters, and events we think may be of interest to you and are aimed at driving engagement and maximizing the Services’ value for you. We also communicate with you about new product offers, promotions and contests. You can always opt out from our email newsletters.
Customer support: We use your information to resolve technical issues you may encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
With your consent: We use information about you when you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Legal basis for processing (for EEA users):
If you are an individual in the European Economic Area (EEA), we collect and process information about you only when we have legal basis for doing so under applicable EU laws. The legal basis depend on the Services you use and how you use them. This means we collect and use your information only when:
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. When we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use. However, in some cases, this may mean that you will no longer use the Services.
Our solution SmartCloud Connect (hereinafter the “Service” for the purposes of this section) can synchronize records of the following types of information: Calendar items, Tasks, Contacts and Email message texts of the authorized user (collectively “User Data”). Using the Dashboard, the authorized user can choose which record types to synchronize with the use of the Service.
Any User Data (retrieved by the Service from Microsoft Exchange, Office 365, Google, Salesforce) including any personally identifiable information being processed by the Service is only passed through the Service, temporarily kept in memory of the Service and is NEVER written to any persistent storage.
We do not allow anybody to read the User Data unless 1) we first obtained the user’s affirmative agreement for that; 2) it is necessary for security purposes; 3) it is necessary to comply with applicable law.
We DO NOT share User Data with other Service users or any third parties. We may transfer User data exclusively as necessary to comply with requirements of applicable law. We will notify you of any such requirement should they arise.
If an end-user registers or accesses the Service using an email address with a domain that is owned by end-user’s employer or organization, and such organization wishes to establish an account on the site, the name of that end-user, email address of that end-user, and dates of past use of end-user account with the Service may become accessible to that organization’s administrators so they would be able to perform their functions as administrators and adjust and/or customize the Service for users.
Sharing with third parties
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our services.
Service providers: We work with our contracted service providers to provide website and application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, analysis, and other services for us, which may require them to access or use information about you. If a service provider needs to access information about you to perform services on our behalf, they do so under strict instruction from us, including Policies and Procedures designed to protect your information.
Third party apps: You, your administrator or other Services users may choose to add new functionality or change the behavior of the Services by installing third-party apps within the Services. Doing so may give third-party apps access to your account and information about you like your name and email address, and any content you choose to use in connection with those apps. We encourage you to review privacy policies of third parties before connecting to or using their applications or services to learn more about their privacy and information handling practices. If you object to information about you being shared with these third parties, please uninstall the app.
With your consent: We share information about you with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name by the testimonial.
Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our Agreements, Policies and Terms of Service, (c) protect the security and integrity of our products and services, (d) protect Invisible, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Security and storage of information
We use data hosting service providers in the United States and Europe to host the information we collect, and we use technical measures to secure your data.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your account information for as long as your account is active and for a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. When we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your team members or other users to make full use of the Services.
Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or stopped using your Invisible account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
You have several choices available to you regarding access and control of your information. Below is a summary of these choices, ways to exercise them and limitations that might apply.
You have a right to request a copy of your information; to object to our use of your information (including for marketing purposes); to request deletion or restriction of your information; or to request your information to be presented in a structured, electronic format. Below, we describe tools and processes for making these requests. When the Services are administered for you by an administrator in your organization, you may need to contact your administrator to assist with your requests first. In other occasions, you may contact us as provided in the Contact Us section below.
Your requests and choices may have some limitations in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we or your administrator are permitted by law or have compelling legitimate interests to keep. When you have asked us to share data with third parties, for example, by installing third-party apps, you will need to contact those third-party service providers directly to have your information deleted or otherwise restricted. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country you reside, work or where you feel your rights were infringed.
Request to deactivate your account: If you no longer wish to use our Services, please contact our support team.
Request to stop using your information: In some cases, you may ask us to stop accessing, storing, using and otherwise processing your information where you believe we don’t have the appropriate rights to do so. Where you gave us consent to use your information for a limited purpose, you can contact us to withdraw that consent, but this will not affect any processing that has already taken place at the time. You can also opt out of our using of your information for marketing purposes by contacting us. When you make such requests, we may need time to investigate and facilitate your request. If there is a delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of your information until the request is honored or the dispute is resolved, provided your administrator does not object (where applicable). If you object to information about you being shared with a third-party app, please disable the app or contact your administrator to do so.
Request to opt out of communications: You may opt out of receiving promotional communications from us by using the unsubscribe link within each email. Even after you opt out from receiving promotional messages from us, you will continue to receive transaction messages from us regarding our Services. You can opt out of some notification messages in your account settings.
We comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce (the “Privacy Shield”) regarding the collection, use and retention of personal information transferred from the European Union (EU) to the United States (“EU Personal Data”). We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles. To learn more about the Privacy Shield program, and to view our certification, please visit http://www.privacyshield.gov.
Should you have any Privacy Shield-related complaints about our collection or use of your personal information or any inquiries, please, contact Avora Holdings LTD at: [email protected]. We will respond within 45 days.
If You do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, you may contact your relevant Data Protection Authority using the information provided at https://ec.europa.eu/info/law/law-topic/data-protection_en. Avora Holdings, LTD has committed to refer unresolved complaints or disputes under the EU-U.S. Privacy Shield to the panel established by the EU Data Protection Authorities (“DPAs”). Avora Holdings, LTD commits to cooperate with the panel established by the EU DPAs and comply with the advice given by the panel established by the EU DPAs with regard to unresolved Privacy Shield complaints concerning data transferred from the EU.
Under certain conditions, more fully described on the Privacy Shield website, You may be entitled to invoke binding arbitration through the Privacy Shield Panel if neither we nor the panel established by the DPAs resolves your Privacy Shield complaint.
We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
We may be required to disclose personal information in response to lawful requests by public authorities, including to meet the national security or law enforcement requirements.
Notice to End Users
Many of our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Service sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this Policy.
Administrators are able to:
In some cases, administrators can also:
Please contact your organization or refer to your administrator’s organizational policies for more information.
Our Policy towards children
The Services are not directed to individuals under 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact our support services.
Your information is controlled by Avora Holding LTD. If you have questions or concerns about how your information is handled, please direct your inquiry to Avora Holdings LTD, which we have appointed to be responsible for facilitating such inquiries.Avora Holdings LTD. 650 Castro St, Suite 120/385 Mountain View, CA 94041 E-Mail: [email protected]