Privacy Policy

Last updated January 01, 2024

This Privacy Policy for Avori, LLC (‘we’, ‘us’, or ‘our’), describes how and why we might access, collect, store, use, and/or share (‘process’) your personal information when you use our services (‘Services’), including when you:

• Visit our website at https://avori.by, or any website of ours that links to this Privacy Notice
• Contact us through our contact form, by email, or by applying for a job with us
• Engage with us in other related ways, including any sales, marketing, or events

Who we are. Avori, LLC is a limited liability company registered in the Republic of Belarus (registration number / УНП 193021538), with its registered office at Jasminovaya Street 2D, Suite 31, 220076, Minsk, Belarus. We are the operator (controller) responsible for making decisions about how your personal information is processed.

Which law applies. Our processing is governed primarily by the Law of the Republic of Belarus of 7 May 2021 No. 99-З ‘On Personal Data Protection’ (the ‘Belarusian Law’). Where the GDPR, UK GDPR or a US state privacy law also applies to you, we honour the rights those laws give you as well. Where two regimes both apply, we apply the stricter requirement. In practice this usually means the Belarusian one, because it does not recognise ‘legitimate interests’ as a basis for processing.

Russian-language policy. We publish an authoritative Russian-language «Политика в отношении обработки персональных данных» at https://avori.by/legal/politika-personalnyh-dannyh, as required by Article 17 of the Belarusian Law. In case of any discrepancy between that document and this one, the Russian text prevails.

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at legal@avori.by.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Policy, but you can find out all the details by reviewing the policy in full.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the features you use.

Do we process any sensitive personal information? Some information may be considered ‘special’ or ‘sensitive’ in certain jurisdictions — for example racial or ethnic origin, sexual orientation, and religious beliefs. We do not request sensitive personal information and we do not use it. We ask job applicants not to include it in a CV. If a CV nevertheless contains it, we do not extract it, do not record it separately, and do not use it in any decision. See section 1.

Do we collect any information from third parties? No. We do not obtain personal information from public databases, data brokers, marketing partners, or other outside sources.

How do we process your information? We process your information to respond to your enquiries, to provide and administer our Services, to consider job applications, for security, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

In what situations and with which parties do we share personal information? We share information in the limited situations described in section 4. We do not sell or share personal information for advertising purposes.

Do we transfer information to other countries? Yes. Our operations are in Belarus, and some service providers are outside it. See section 6.

How do we keep your information safe? We apply the organisational and technical measures required by Article 17 of the Belarusian Law. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.

What are your rights? Everyone has rights under the Belarusian Law. Depending on where you are located, GDPR, UK GDPR or US state law may give you further rights. See section 10.

How do you exercise your rights? The easiest way is by contacting us at legal@avori.by. We will consider and act upon any request in accordance with applicable data protection laws and within the deadlines set out in section 10.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our Services, when you apply for a job with us, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include the following:

• names
• email addresses
• phone numbers
• company names and job titles
• the content of your message and any attachments
• if you apply for a job: your CV, cover letter, education, qualifications, work experience and professional skills, links to professional profiles or portfolios, interview notes, and your stated salary expectation

We do not operate user accounts on this website, and we do not collect usernames, passwords, authentication credentials, billing addresses, payment card details, or order histories.

Sensitive Information. Under the Belarusian Law, ‘special personal data’ means data concerning racial or national origin, political views, trade union membership, religious or other beliefs, health or sex life, administrative or criminal liability, and biometric and genetic data. Comparable definitions exist under GDPR and US state laws.

We do not request sensitive personal information and we do not use it. Our job application form asks candidates not to include information about racial or national origin, political views, trade union membership, religion or beliefs, health, marital status or criminal record, and not to attach a photograph. None of it is relevant to how we assess candidates and none of it is taken into account in a hiring decision.

If a CV nevertheless contains such information, it remains only as part of the document you sent us: we do not extract it, do not record it separately in any system, do not use it, and we delete it together with your CV at the end of the retention period in section 7. Where this occurs, our legal basis under the Belarusian Law is your consent under Article 8, given when you submit your application. You may ask us to delete your application, including the CV file, at any time.

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.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookies Policy: https://avori.by/legal/cookies-policy.

The information we collect includes:

Log and Usage Data. 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. This log data may include your IP address, browser type and version, operating system, language preferences, referring URLs, date and time stamps, and the pages and files you viewed.

Approximate Location. We derive an approximate country from your IP address for security and analytics purposes. We do not collect precise geolocation data and we do not use GPS.

Information collected from other sources

In Short: We do not collect personal information from outside sources.

We do not obtain information about you from public databases, joint marketing partners, affiliate programmes, data providers, social media platforms, or other third parties. All the personal information we hold about you comes either from you directly or is collected automatically as described above.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to respond to your enquiries, provide and administer our Services, consider job applications, for security, and to comply with law.

We process your personal information for the following reasons:

• To respond to your enquiries and offer support. We process your information to respond to your enquiries and to prepare and send you information or a proposal at your request.
• To deliver and facilitate delivery of services. We process your information to provide the services you or your organisation have requested and to administer our contract.
• To consider your job application. We process the information in your application to assess your suitability for a role, arrange and conduct interviews, and decide whether to offer you employment.
• To send administrative information to you. We process your information to send you details about our Services, changes to our terms and policies, and other similar information.
• To request feedback. We process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications, where you have separately agreed to receive them. You can opt out at any time. We do not add people who use our contact form to marketing lists without a separate opt-in.
• To identify usage trends. We process information about how you use our Services to better understand how they are being used so we can improve them.
• For security and to comply with law. We process your information to keep our Services secure, to prevent and investigate fraud, and to comply with our legal obligations.
• To save or protect an individual’s vital interest, such as to prevent harm.

We do not carry out profiling for targeted advertising, and we do not make automated decisions that produce legal or similarly significant effects concerning you.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we have a valid legal reason to do so. Because we are established in Belarus, Belarusian law sets the floor; where GDPR or another law also applies, we meet its requirements too.

Everyone: the Belarusian Law

The Belarusian Law does not recognise ‘legitimate interests’ as a basis for processing. We therefore rely on one of the following:

• Consent (Article 5). We process your information where you have given consent for a specific purpose — for example when you tick the box on our contact form or job application form, or accept a cookie category. Consent must be free, unambiguous, informed and specific, and you can withdraw it at any time, without giving reasons.
• Data contained in a document you addressed and signed (Article 6). Where you write to us directly, we may process the personal data contained in your message in accordance with its content.
• Performance of a contract (Article 6). Where we have entered into, or are entering into, a contract with you.
• Legal obligations (Article 6). Where processing is necessary to perform duties imposed on us by legislative acts, such as accounting, tax and employment obligations.
• Vital interests (Article 6). Where processing is necessary to protect the life or health of a person.

Special personal data is processed only on the narrower grounds in Article 8, as described in section 1.

If you are located in the EU or UK

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on. We may rely on:

• Consent. Where you have given us permission to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. Where processing is necessary to fulfil our contractual obligations to you, including providing our Services, or to take steps at your request before entering into a contract.
• Legitimate Interests. Where processing is reasonably necessary to achieve our legitimate business interests and those interests do not override your interests and fundamental rights and freedoms — for example to analyse how our Services are used so we can improve them, or to keep our Services secure. Note that where the Belarusian Law also applies to the same processing, we do not rely on legitimate interests alone; we obtain consent or rely on one of the Belarusian grounds above.
• Legal Obligations. Where processing is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. Where processing is necessary to protect your vital interests or those of a third party.

If you are located in Canada

We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be the victim of financial abuse
• If it is reasonable to expect that collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share information only in the limited situations described in this section. We do not sell or share personal information for advertising.

We may need to share your personal information in the following situations:

• Service providers (processors). We share personal information with providers who process it on our behalf and on our instructions — website hosting, corporate email, and analytics. Under the Belarusian Law these are ‘authorised persons’ (уполномоченные лица) and we engage them only under a written contract meeting Article 7. We remain responsible to you for what they do with your data. The current list, with the country where each stores data, is maintained in section 6 of our Russian-language Policy.
• Legal requirements. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, or to protect the rights, property, or safety of Avori, our clients or others.
• 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.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice.

We do not share your information with business partners to offer you products, services or promotions. We do not sell personal information, and we do not share it for cross-context behavioural advertising.

When we act for our clients

When we provide software development, maintenance and support services, we may access personal data held in our clients’ systems. In that role we act as a processor (‘authorised person’ under Article 7 of the Belarusian Law) on the client’s documented instructions. We do not determine the purposes of that processing and do not use the data for our own purposes. If your data is held in one of our clients’ systems, your request should go to that client, though we will help you identify them.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use cookies and similar technologies, and — apart from strictly necessary ones — only after you consent.

We use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some of these help us maintain the security of our Services, prevent crashes, fix bugs, save your preferences, and support basic site functions.

Strictly necessary cookies are set without consent, because the site cannot work without them. Every other category — functional, analytics and advertising — is set only after you have accepted it in our cookie banner. Until you make a choice, those scripts do not load and no data is sent to the providers concerned. This reflects the requirement in Article 5 of the Belarusian Law that consent be given before processing begins.

You can change or withdraw your choices at any time through the Cookie Consent Manager in the banner, available on every page, or through your browser settings.

We do not use cookies or tracking technologies to sell or share personal information, or for cross-context behavioural advertising.

Specific information about the technologies we use and how you can refuse them is set out in our Cookies Policy: https://avori.by/legal/cookies-policy.

Google Analytics

We use Google Analytics and Google Tag Manager to measure and analyse use of the Services. These tags fire only if you accept the analytics cookie category, and they involve transferring data about your visit to the United States — see section 6.

We do not enable Google Analytics Advertising Features (such as Demographics and Interests Reporting or Display Network Impressions Reporting).

To opt out of being tracked by Google Analytics across all websites, visit https://tools.google.com/dlpage/gaoptout. For more information on Google’s privacy practices, see https://policies.google.com/privacy.

6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: Yes. We are based in Belarus, and some of our providers are elsewhere. Different rules apply depending on where you are.

Transfers out of Belarus

Article 9 of the Belarusian Law prohibits transferring personal data to a country that does not provide an adequate level of protection, unless a specific exception applies. Countries party to Council of Europe Convention 108 and members of the Eurasian Economic Union are treated as providing adequate protection.

The United States is not. Our use of Google Analytics and Google Tag Manager transfers website usage data there. This happens only if you accept analytics cookies, and by accepting you consent to that transfer having been informed that the level of protection in the destination country may be lower than under Belarusian law and that enforcing your rights there may be more difficult. Where any other provider stores data outside Belarus, the country is identified in section 6 of our Russian-language Policy.

Transfers into Belarus, if you are in the EEA or UK

Our operations are located in Belarus. If you are in the EEA or UK, sending us your personal information means transferring it to a country for which the European Commission and the UK government have not issued an adequacy decision. We rely on the derogations in Article 49 of the GDPR:

• where you contact us about our Services or we are negotiating or performing a contract with you or your organisation, the transfer is necessary for the performance of a contract or for pre-contractual steps taken at your request (Article 49(1)(b));
• where you apply for a job with us, the transfer is necessary to take steps at your request prior to entering into a contract, and you also give your explicit consent having been informed of the possible risks (Article 49(1)(a)).

You may withdraw that consent at any time, though this will not affect processing carried out before withdrawal.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information only as long as necessary for the purposes set out in this notice, unless a longer period is required by law.

We keep personal information only for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). Our standard periods are:

When we have no ongoing legal basis to process your personal information, we will either delete or anonymise it. If deletion is not technically possible (for example because it is held in backup archives), we will securely store it and isolate it from any further processing until deletion is possible, and we will tell you when we have done so.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We apply the legal, organisational and technical measures required by Article 17 of the Belarusian Law. These include a designated person responsible for internal control over personal data processing, documented processing policies, staff training and access controls, and technical and cryptographic protection in the manner established by the Operational and Analytical Centre under the President of the Republic of Belarus.

If a personal data security breach occurs, we notify the National Personal Data Protection Center without delay and in any event within three working days of becoming aware of it, and we notify affected individuals where required.

However, despite our safeguards, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

9. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children.

Our Services are not directed at children and we do not knowingly collect, solicit data from, or market to them, nor do we knowingly sell such personal information.

Under Article 5 of the Belarusian Law, consent in respect of a person under 16 is given by their legal representative. Our Services are intended for business users and job applicants, and by using them you represent that you are at least 18, or that you are the parent or guardian of a minor and consent to that minor’s use of the Services.

If we learn that we have collected personal information from a child without the required consent, we will take reasonable measures to promptly delete it from our records. If you become aware of any data we may have collected from a child, please contact us at legal@avori.by.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Everyone has rights under the Belarusian Law. Depending on where you live, you may have further rights under GDPR, UK GDPR or a US state privacy law.

Your rights under the Belarusian Law

You have the right to:

• withdraw your consent at any time, without giving reasons (Article 10)
• obtain information about our processing of your data, including confirmation that we process it, the data itself and its source, the legal basis and purposes, the term of your consent, and details of any authorised person (Article 11)
• have your data corrected where it is incomplete, out of date or inaccurate (Article 11(4))
• find out whether your data has been disclosed to third parties — once per calendar year, free of charge (Article 12)
• have processing stopped and your data deleted where there is no basis to continue (Article 13)
• complain to the National Personal Data Protection Center, and challenge its decision in court (Article 15)

How to make a request. Send it in writing or as an electronic document to legal@avori.by or to our postal address. Article 14 of the Belarusian Law requires your request to state your full name and address, your date of birth, the substance of your request, and to carry your signature or electronic digital signature. Your identification number is required only where you gave it to us when consenting, or where we process your data without consent.

Our deadlines: 5 working days for a request for information under Article 11; 15 days for withdrawal of consent, correction, disclosure information, and deletion. If we refuse, we will tell you why in writing and explain how to challenge the decision.

Supervisory authority: National Personal Data Protection Center of the Republic of Belarus, 24-3 K. Tsetkin Str., 220004, Minsk; info@cpd.by; +375 (17) 367-07-90; https://cpd.by.

If you are in the EEA, UK, Switzerland or Canada

You have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure, (iii) to restrict the processing of your personal information, (iv) if applicable, to data portability, and (v) not to be subject to automated decision-making. In certain circumstances you may also have the right to object to processing. You can make such a request using the contact details in section 14.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or the UK Information Commissioner’s Office. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

Where we rely on your consent, you have the right to withdraw it at any time by contacting us using the details in section 14, or — for cookies — through the Cookie Consent Manager. Withdrawal will not affect the lawfulness of processing before its withdrawal, nor, where applicable law allows, processing carried out on other lawful grounds.

Under the Belarusian Law, we will stop processing and delete the data concerned within 15 days of receiving your withdrawal, and confirm this to you.

Opting out of marketing communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in any email we send, by replying ‘UNSUBSCRIBE’, or by contacting us using the details in section 14. You will then be removed from our marketing lists. We may still send you service-related messages that are necessary to respond to your requests or for other non-marketing purposes.

Cookies and similar technologies

Most web browsers are set to accept cookies by default. You can usually set your browser to remove or reject cookies. If you do so, this could affect certain features of our Services. For further information, please see our Cookies Policy: https://avori.by/legal/cookies-policy.

If you have questions or comments about your privacy rights, you may email us at legal@avori.by.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of certain US states, you may have rights to access, correct, obtain a copy of, or delete your personal information.

We are established in Belarus and do not meet the applicability thresholds of the California Consumer Privacy Act or comparable state privacy laws. We nevertheless extend the rights below to residents of those states as a matter of policy.

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing.

Categories of Personal Information We Collect

The table below shows the categories of personal information we have collected in the past twelve (12) months.

Notes on the entries above. Category B is marked YES because a CV contains education and employment history. Category G is marked NO because we derive only an approximate country from your IP address and do not collect device location; the IP address itself is covered by Category A. Category C is marked NO because we do not request, extract or use any such information — see the explanation of CVs in section 1.

We may also collect other personal information outside of these categories where you interact with us in person, online, or by phone or mail in the context of receiving help through our support channels, or in the course of delivering our Services and responding to your enquiries.

Retention. We retain the collected personal information for the periods set out in section 7.

Sources of Personal Information

All personal information comes from you directly or is collected automatically as described in section 1. We do not obtain personal information from outside sources.

How We Use and Share Personal Information

Learn more in sections 2 and 4.

Will your information be shared with anyone else?

We may disclose your personal information to our service providers pursuant to a written contract between us and each service provider. See section 4.

We may use your personal information for our own business purposes, such as undertaking internal research for technological development and demonstration. This is not considered ‘selling’ of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information belonging to website visitors, users, and other consumers in the future.

Your Rights

These rights are not absolute, and in certain cases we may decline a request as permitted by law. They include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects — note that we do none of these

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed
• Right to obtain a list of the categories of third parties to which we have disclosed personal data
• Right to obtain a list of specific third parties to which we have disclosed personal data
• Right to review, understand, question, and correct how personal data has been profiled
• Right to limit use and disclosure of sensitive personal data
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature

How to Exercise Your Rights

To exercise these rights, contact us by emailing legal@avori.by, by post to the company’s registered address, or by using the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf. We may deny a request from an authorised agent that does not submit proof of valid authorisation.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. If we cannot verify your identity from the information already maintained by us, we may request additional information for the purposes of verification and for security or fraud prevention.

If you submit the request through an authorised agent, we may need to collect additional information to verify your identity before processing your request, and the agent will need to provide written and signed permission from you.

Appeals

If we decline to take action regarding your request, you may appeal our decision by emailing legal@avori.by. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons. If your appeal is denied, you may submit a complaint to your state attorney general.

California ‘Shine The Light’ Law

California Civil Code Section 1798.83, also known as the ‘Shine The Light’ law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. We do not disclose personal information to third parties for their direct marketing purposes. If you are a California resident and would like to make such a request, please submit it in writing using the contact details in section 14.

13. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia’s Privacy Act 1988 and New Zealand’s Privacy Act 2020 (Privacy Act).

This Privacy Notice satisfies the notice requirements defined in both Privacy Acts, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfil the applicable purpose, it may affect our ability to offer you the products or services that you want, respond to or help with your requests, or confirm your identity.

At any time, you have the right to request access to or correction of your personal information, using the contact details in section 14.

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner, and a breach of New Zealand’s Privacy Principles to the Office of the New Zealand Privacy Commissioner.

Republic of South Africa

At any time, you have the right to request access to or correction of your personal information, using the contact details in section 14.

If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator:

• The Information Regulator (South Africa)
• General enquiries: enquiries@inforegulator.org.za
• Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at legal@avori.by or contact us by post at:

Avori, LLC
Jasminovaya Street 2D, Suite 31
220076, Minsk, Belarus
УНП 193021538

Person responsible for internal control over personal data processing: [Viktor Goroshko, Director], legal@avori.by.

Supervisory authority: National Personal Data Protection Center of the Republic of Belarus, 24-3 K. Tsetkin Str., 220004, Minsk; info@cpd.by; +375 (17) 367-07-90; https://cpd.by.

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at legal@avori.by. Please see section 10 for what your request needs to contain and how quickly we will respond.

16. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated date at the top of this Privacy Notice. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.