Effective Date: April 15, 2025

Last Updated: April 15, 2025

Introduction

This Privacy Policy outlines how AVIL LAB LLC ("we," "us," "our"), a company registered in Armenia, collects, uses, discloses, and protects user data in the AVIL AI Email Creator mobile application (the "App"). AVIL LAB LLC acts as the Data Controller for purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR) and UK GDPR.

Definitions

• Account: A unique account created for you to access the App or its functionalities.
• Application/App: AVIL AI Email Creator software provided by AVIL LAB LLC.
• Cookies: Small files placed on your device by third-party services to analyze interactions.
• Personal Data: Information relating to an identifiable individual.
• Service Providers: Third-party companies and individuals we engage to facilitate the App.
• Usage Data: Automatically collected data generated by the use of the App.
• Interaction Data: Information you input to generate content, including email text and generation parameters.
• You/User: The individual accessing or using the App.

Information We Collect

We collect the following types of information to provide and improve our services:

1. Profile Information (optional):

• Name: Helps personalize your experience.
• Profession/Role: Used to tailor email content recommendations.
• Gender: Optional field for content personalization.
• LinkedIn/Website URL: Enables integration with professional profiles.
• User Interests: Helps refine content suggestions.
• Email Address: Used for marketing communications if you opt-in.

Profile information enhances email creation by personalizing generated content. This information is stored solely on your device and can be modified or deleted at any time through the App. Email addresses, if provided, are stored securely on our servers for marketing communications.

2. Email and Content Information:

• Input Emails or Texts: Used to generate content via the OpenAI API.
• Anonymous Transmission: All personally identifying information is removed before processing.
• Temporary Processing: Content input is not stored on our servers and is only temporarily processed to generate recommendations.
• Local Storage: Generated content is stored locally on your device only.

3. Technical and Usage Information:

• IP Address: Used for security and analytics purposes.
• Usage and Interaction Data: Helps analyze app usage and improve performance.
• Device Information: Includes model and OS version to ensure compatibility and performance.
• Push Notification Token: Used for delivering notifications.

This data is collected to analyze app usage, enhance performance, and improve user experience. It is stored primarily in secure European data centers with appropriate encryption (AES-256) and access controls.

Legal Basis for Processing Personal Data

We process your data based on the following legal grounds:

• Consent: Where you have given clear consent for us to process your personal data for a specific purpose.
• Contract: Where processing is necessary for the performance of our contract with you (app functionality).
• Legitimate Interests: Where processing is necessary for our legitimate interests in improving our services, ensuring security, and analyzing usage patterns, without overriding your rights and freedoms.
• Legal Obligation: Where we need to comply with a legal or regulatory obligation.

Advertising and Analytics

We integrate advertising SDKs such as Google AdMob and Unity Ads to display advertisements. These third-party services may independently collect certain user information. For details:

• Google AdMob Privacy Policy
• Unity Ads Privacy Policy

We utilize Google Analytics and Firebase to enhance app usage analysis. We have signed Data Processing Agreements (DPAs) with these providers to ensure GDPR compliance. Please refer to Google Privacy Policy.

Push Notifications

We use OneSignal to deliver push notifications. When you opt in to receive push notifications, OneSignal will collect and process your device token. You can manage notification preferences or opt out completely through your device settings or the App. For more information about OneSignal's privacy practices, please visit their Privacy Policy.

Email Marketing

If you provide your email address and opt in to receive marketing communications, we may use email marketing tools such as Mailchimp and SendGrid to send you newsletters, updates, and promotional materials. Each email will include an option to unsubscribe. We will not sell your email address to third parties. For more information on their privacy practices, please visit:

• Mailchimp Privacy Policy
• SendGrid Privacy Policy

Data Storage, Retention, and Security

• Profile data is stored locally on your device and is not accessible to us.
• Email addresses (if provided for marketing) are stored securely on our servers for up to 3 years after your last interaction or until you unsubscribe.
• IP addresses are stored for 90 days and then automatically deleted.
• All data transfers between the app, servers, and third-party services occur securely over HTTPS with TLS encryption.
• We implement security measures including encryption, access controls, regular security audits, and employee training on data protection.
• Our infrastructure undergoes quarterly security assessments to identify and address vulnerabilities.

User Consent and Rights

By using our App, you consent to data practices described in this Privacy Policy. You may withdraw consent at any time by:

1. Deleting your profile within the App
2. Contacting our Data Protection Officer at [email protected]
3. Using the opt-out features in the App Settings

Data Subject Rights

You have the right to:

• Access: Request copies of your personal data (fulfilled within 30 days).
• Rectification: Request correction of inaccurate data.
• Erasure: Request deletion of your data ("right to be forgotten").
• Restriction: Request restriction of processing your data.
• Portability: Request transfer of your data to you or a third party.
• Object: Object to processing of your data.
• Withdraw consent: Withdraw previously given consent.

To exercise these rights, contact our Data Protection Officer at [email protected]. We will respond to all requests within 30 days and may require verification of your identity.

Social Profile Deletion Process

You can delete your account and associated data by:

1. Going to App Settings > Account
2. Selecting "Your Profile"
3. Pushing the "Delete" Button

Upon confirmation, we will:

1. Immediately delete your profile data
2. Delete your usage data within 30 days
3. Send you a confirmation email when deletion is complete
4. Remove your email address from our marketing databases

California Privacy Rights (CCPA/CPRA)

California residents have the right under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) to:

1. Know what personal information is collected, used, shared, or sold
2. Delete personal information held by businesses
3. Opt-out of the sale of personal information
4. Non-discrimination for exercising their CCPA rights

AVIL LAB LLC does not sell user data. To exercise these rights, contact us at [email protected].

General Data Protection Regulation (GDPR) and UK GDPR

EEA and UK residents have rights under GDPR/UK GDPR to access, rectify, erase, restrict or object to data processing, and request data portability. To exercise these rights, contact [email protected].

International Data Transfers

Your information may be transferred to and stored in locations outside your jurisdiction. For transfers outside the EEA/UK, we ensure appropriate safeguards are implemented through:

• Standard Contractual Clauses approved by the European Commission
• Binding Corporate Rules
• Processing only in countries with adequacy decisions

Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

1. Notify relevant supervisory authorities
2. Inform affected users without undue delay
3. Provide information about the breach and steps to mitigate potential effects
4. Offer guidance on protecting your information

Age Restrictions

The App is intended for users aged 13 and above. We do not knowingly collect data from users under 13. If we discover we have collected data from a child under 13, we will:

1. Immediately cease processing the data
2. Delete all relevant information within 14 days
3. Document the incident and take measures to prevent recurrence

If you believe we have collected such data, contact our Data Protection Officer immediately.

Cookies and Tracking

Our App does not directly utilize cookies. Third-party services (Google Analytics and Firebase) may use cookies or similar tracking technologies.

We honor Do Not Track (DNT) signals. When we detect a DNT signal from your device, we will disable all analytics tracking.

Payment Processing

Subscriptions within the App are processed via Apple App Store and Google Play Store. We do not directly handle or store financial data. For payment privacy, refer to:

• Apple Privacy Policy
• Google Privacy Policy

Third-party Integrations

• OpenAI API: User-generated content is sent anonymously to OpenAI with all personally identifying information removed. We have a Data Processing Agreement with OpenAI. Review OpenAI Privacy Policy.
• Google Analytics and Firebase: Data is collected to track app usage and performance. We have implemented IP anonymization. See Google Privacy Policy.
• Social Media Logins: If you register using third-party services (Google or Apple), certain personal information may be collected. Review their respective privacy policies.
• OneSignal: Used for push notifications. Review OneSignal Privacy Policy.
• Email Marketing Services (Mailchimp, SendGrid): Used for sending marketing communications if you opt-in. Review their respective privacy policies.

Contact Information

For questions or requests regarding your personal data, contact:

• Data Protection Officer: [email protected]
• General Privacy Inquiries: [email protected]
• Company Name: AVIL LAB LLC

Changes to this Privacy Policy

We reserve the right to periodically update this Privacy Policy. Significant changes will be communicated:

• Within the app via notification
• Via email (if you've provided one)
• On our website

Compliance

This Privacy Policy complies with global privacy standards, including guidelines from Google Play, Apple App Store, CCPA/CPRA, GDPR, and UK GDPR.

Thank you for using AVIL AI Email Creator!