PRIVACY POLICY

Create Avalon Corp. Privacy Notice

Last Updated: February 1, 2025     

Create Avalon Corp. of 36 West Pine Street, Orlando Florida 32801 (“Avalon”, “we”, “our” or “us”) is committed to protecting the privacy of those who entrust us with their personal information. Our clients and employees trust and expect that we will protect their personal information in accordance with the promises we make. “Personal information” means any information pertaining to an identified or identifiable individual and may include, for example, email addresses and contact details and any similar information provided to us in the course of our business operations. Personal information that is de-identified or anonymized is not considered personal information. This Privacy Notice details our commitment to your privacy.

In respect of personal information covered by the EU or UK General Data Protection Regulation (GDPR), we shall act as a controller of your personal information that is collected or received in accordance with this Privacy Notice. If we process personal information as a data processor, we will process such personal information in accordance with the terms of the contract we have with the third party for whom we act as data processor, and this Privacy Notice shall not apply to the processing of such personal information.

To receive this notice in another format (for example, audio, large print, braille) please contact us using the contact details in the “Contacting Us” section below.

1. What does this Privacy Notice cover?

Avalon is a full-service provider of customer experience solutions, headquartered in Orlando, FL, dedicated to providing an international and fully remote gaming studio. This Privacy Notice describes our privacy practices regarding personal information we receive in connection with the services and products we provide to our clients (the “Client Services”), as well as through our website (the “Site”).

By using our Client Services, visiting the Site or otherwise interacting with us, you acknowledge that we will process your personal information as described in this Privacy Notice. We recommend that you review this Privacy Notice periodically, as it may be updated from time-to-time. 

2. What information does Avalon collect, and how is it used and shared?

We explain here what categories of personal information we may collect, where we may get it from, and with whom we may share it: 

Avalon will only use personal information to the extent it is necessary to deliver the Client Services and the Site. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in Sections 10, 11, and 12. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by Avalon, including requirements that such information be maintained in a confidential and secure manner. 

We require all our data processors and any other third party that we provide your personal information to respect the security of your personal information and to treat it in accordance with applicable law.

We do not allow our data processors to use your personal information for their own purposes and only permit      them to process your personal information for specified purposes and in accordance with our instructions.

Special Categories of Personal Information. We do not collect any special categories of personal information about you (this includes details about race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). 

In Connection with Business Transfers: In the event that a division, a product or all of Avalon is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.

To Comply with Laws: Avalon may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, our clients’ customers or employees or others, in accordance with or as authorized by law.

Information from our Client’s Customers: Avalon processes transactions or applications that are supplied and managed by our clients. As a result, although we may access certain personal information of our client’s customers pursuant to the contractual relationships with have with our clients, we typically do not collect and store personal information in our own systems, with the exception of call recordings. Typically, our clients are responsible for complying with all notices, notifications and alerts to individuals whose information is entered into our systems or portals. We do not use or share that personal information except as directed by our clients.

Automated Decision Making: We do not make any decisions regarding you solely using automated decision making (including profiling) based on your personal information. 

3. What are cookies and how do we use them and other technologies? 

A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities or receive a promotion tailored to you. Avalon does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.

Avalon does not currently participate in interest-based or behavioral online advertising, and information automatically collected from the Site is not used by Avalon for that purpose.

Where you are resident in the EEA or the UK and have consented to such use, Avalon may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners. 

Any and all personal information collected on the Site will be kept strictly confidential and will not be sold, reused, rented, disclosed, or loaned to third parties, except as otherwise described in this Privacy Notice.

Do Not Track (DNT): This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore Avalon and the Site do not recognize DNT.

4. How does Avalon protect personal information?

Where applicable, Avalon uses industry-standard technology in connection with our Client Services and on the Site to help protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Personal information received from our clients or others in connection with Client Services is typically stored on servers hosted by our clients or their vendors—with limited exceptions, such as call recordings required by our client contracts for quality assurance or other legitimate purposes, personal information collected by our clients is not stored on our or our service provider’s services.

5. How long does Avalon retain my personal information?

Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or deidentified.

6. What are my choices concerning my personal information, including marketing?

Avalon depends primarily on our clients to notify and provide their customers and employees choices regarding the personal information that they provide. Our clients are therefore responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to Avalon.

In addition, as part of the Client Services, our clients may use personal information that we have collected on their behalf for their own communication and promotional purposes. Our clients are responsible for ensuring that any commercial emails sent by them to their employees or customers comply with applicable law. If we are instructed by our clients to transmit communications on their behalf, clients remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete.

We do not sell, rent, or share the personal information of our clients’ employees or their customers with third parties for their own marketing purposes.

Avalon may, subject to applicable laws, use personal information from our clients and their employees to contact them about our Site and Client Services, including to provide them with information on additional products from Avalon that may be of interest to them. Client contacts may exercise choices regarding these communications as follows:

• Mail Marketing, Telephone Marketing, Surveys and Quality Control Communications. You may decide that you prefer Avalon not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse that we contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the “Contacting Us” section below.
• Emails/Commercial Electronic Communications. You can always limit the communications that Avalon sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account.

Where you are resident in the EEA or the UK, we will only undertake electronic or telephone marketing activity where you have consented or we are otherwise permitted by law.  

7. How is this Privacy Notice enforced?

Avalon has put in place mechanisms to monitor and verify our ongoing adherence to this Privacy Notice. We encourage individuals covered by this Privacy Notice to raise any concerns that they have about the way that we process their personal information by contacting Avalon as described below. We take your questions and concerns seriously, and will do our best to resolve them.

8. Links to Other Websites

This Site may contain links to other websites that are not controlled in any way by us. Please be aware of this when you click on any such links; we are not responsible for the privacy practices and/or policies of any website other than our own. Consequently, we strongly suggest that you review the privacy notice of every website you visit, whether or not they are linked to by our own Site.

9. What is Avalon’s policy on kids’ privacy?

Avalon and our Site are not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If Avalon learns that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13, please contact us using the information detailed in the “Contacting Us” section below.

10. Access, Objection, Correction and Deletion

In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal information have been or will be disclosed. You may also have the right to receive a copy of the personal information you have provided and/or request its deletion.

Our clients are responsible for managing any request made by their employees or customers regarding access to and rectification of their personal information that is transferred to us. However, if you have questions about your rights, please feel free to contact using the contact information detailed in the “Contacting Us” section below.

11. Your California and Other Privacy Rights

If you are a California, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia resident, the law in your state law provides you with the following rights with respect to your personal information:

• The right to access  the categories or specific personal information we have collected, used, disclosed and sold about you. 
• The right to obtain a copy of Personal Information we have obtained about you in a portable and, to the extent technically feasible, readily usable format.
• The right to request that we delete any personal information we have collected about you. 
• The right to correct any inaccuracies in the personal information we have collected and maintain about you. 
• The right to opt-out of the sharing of your Personal Information for purposes of targeted advertising (also called cross-context behavioral advertising and/or the profiling in furtherance of decisions that produce legal or similarly significant effects), which you can exercise on our website here or by modifying your privacy preferences (e.g., Global Privacy Control), available through certain internet browsers and extensions, that signal your preference to opt out.  Please note that clearing your cookies at any time will remove the signal of your selected privacy preferences. 
• The right to limit the use of your Sensitive Personal Information, which you can exercise through the contact form available on our website.
• If we deny your request, the right to appeal our decision.

To exercise any of the rights set out above, please contact us using the contact details provided in the “Contacting Us” section below. When you exercise these rights and submit a request to us, we will verify your identity by asking you for your email address, telephone number, information about your company’s contract with Avalon, or the last four digits of a credit or debit card used at Avalon. We also may use a third party verification provider to verify your identity.

Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.

For the 12-month period prior to the date of this Privacy Notice, Avalon has not sold any personal information; nor does it have any plans to do so in the future.

This Privacy Notice also describes how we may share your information for marketing purposes, as described above. If you are a California resident, the Shine the Light law permits you to request and obtain from us once per calendar year information about any of your Personal Information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information and for any other questions about our privacy practices and compliance with California law, please contact us, as described below in Section 16.

12. Your GDPR rights

Where you are resident in the EEA or the UK, you have the following rights in relation to your personal information: 

To exercise any of the rights set out above, please contact us using the contact details provided in the “Contacting Us” section below. Where you have any such rights under applicable laws, we will respond to any such rights that you want to exercise within one (1) month of receiving the request, unless the request is complex, in which case it may take longer. 

We may need to request specific information from you to help it confirm your identity and your right to access the personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask it for further information in relation to your request to speed up our response. 

Please be aware that there are exceptions and exemptions that apply to some of the rights, which we will apply in accordance with the applicable data protection laws.

13. Transfer of personal information to other countries

In some cases, personal information that we process, including information from our clients and their employees and/or customers located in various countries, including in Canada, the EU and Switzerland or relative to queries or visitors to the Site may be transferred to the United States or other countries that may not have data privacy laws that provide the same protection as the countries where you reside. You understand that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions. In such circumstances, to the extent we are required to do so under applicable law, we will ensure contractual or other measures that have been adopted or approved by the UK Government, the European Commission or the Swiss Federal Counsel (as applicable) are taken (such as ensuring applicable standard contractual clauses are in place).

You can obtain more information about the countries to which your personal information is transferred and copies of the additional measures put in place by contacting us using the contact details in the “Contacting Us” section below.

14. Right to Lodge Complaints

We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside. 

15. Changes to this Privacy Notice

Avalon will review and update its Privacy Notice as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on the Site and/or update the Privacy Notice modification date below. In certain cases and if the changes are material, we will provide written notice to clients directly by email or otherwise.

This policy is effective December 20, 2024.

16. Contacting Us

If there are any questions regarding this Privacy Notice or to request a copy of this Privacy Notice in another format you may contact us using the information below.

privacy@playavalon.com or 36 West Pine Street, Orlando Florida 32801.