This Privacy Policy explains how Avolvia collects, uses, stores, shares, and protects your personal information. We are committed to your privacy and to full compliance with applicable data protection laws.
Avolvia (Pty) Ltd ("Avolvia", "we", "us", "our") is the data controller responsible for your personal information collected through the Avolvia Platform, including the web application, mobile application, and associated services accessible at avolvia.app and related domains.
Our registered address is: The Colab, 194 Bankor Avenue, Menlyn Maine, Pretoria, 0081, South Africa.
For all privacy-related matters, you may contact us at support@avolvia.app.
Coach as Data Controller: Where a Coach collects personal data from Clients through their Program (including in communications, proof reviews, and feedback), the Coach acts as a separate data controller for that data. Avolvia acts as a data processor in facilitating the storage and display of that data on behalf of the Coach. Clients should review the individual privacy practices of any Coach they enrol with.
We collect the following categories of personal information, depending on your role and how you use the Platform:
| Category | Data Points | Who |
|---|---|---|
| Account Data | Full name, email address, password (hashed), date of registration, role | All Users |
| Profile Data | Display name, profile photo, bio, headline, credentials, specialties, years of experience | Coaches |
| Execution Data | Daily commitment records, completion status, streak history, integrity scores, timestamps | Clients |
| Proof Submissions | Text, images, and video submitted as proof of task completion; reflection entries | Clients |
| Program Data | Program content, modules, lessons, action definitions, accountability rules, challenge configurations | Coaches |
| Communication Data | Messages sent through the Platform's messaging system between Users | All Users |
| Payment Data | Transaction identifiers, billing details (processed by third-party payment provider; card numbers are not stored by Avolvia) | Clients, Coaches |
| Technical Data | IP address, device type, operating system, browser type, session tokens, access logs, timestamps | All Users |
| Usage Data | Pages visited, features used, actions taken, session duration, error logs | All Users |
| Audit Log Data | Records of proof approvals/rejections, certification events, rule changes, role changes, manual overrides | All Users |
| Coach Application Data | Application information, credentials submitted, approval/rejection status and reason | Coach Applicants |
We do not intentionally collect sensitive categories of personal data (such as health data, racial or ethnic origin, political opinions, religious beliefs, or biometric data). If you voluntarily include such information in a proof submission or reflection, it is stored and processed in accordance with this Policy. We recommend avoiding the submission of sensitive personal data where it is not required by your Program.
We collect your personal data through the following means:
Avolvia processes personal data on the following legal bases, in accordance with applicable data protection law including GDPR, UK GDPR, and POPIA:
| Processing Purpose | Legal Basis |
|---|---|
| Account creation and management | Contract performance |
| Delivering the Platform and its features | Contract performance |
| Payment processing | Contract performance / Legal obligation |
| Security and fraud prevention | Legitimate interests |
| Audit logging and compliance | Legal obligation / Legitimate interests |
| Service improvement and analytics | Legitimate interests |
| Sending service notifications and updates | Contract performance / Legitimate interests |
| Marketing communications (where applicable) | Consent (opt-in) |
| Compliance with legal obligations | Legal obligation |
Where we rely on legitimate interests, we have assessed that those interests are not overridden by your rights and freedoms. You have the right to object to processing based on legitimate interests.
We use collected data for the following purposes:
We do not sell your personal data. We do not use your personal data for behavioural advertising or share it with data brokers. Proof Submissions and personal reflections are never used for training machine learning models or shared beyond the Coach-Client relationship they relate to.
We share personal data only in the following limited circumstances:
When a Client enrols in a Program, the relevant Coach has access to that Client's execution data, Proof Submissions, streak and integrity records, and messaging within the Platform, for the purpose of administering the Program and providing accountability oversight.
The Platform Owner has access to aggregated analytics and individual Coach and User records for the purpose of platform governance, Coach approval, and compliance monitoring.
We engage trusted third-party service providers to assist with operating the Platform. These include:
All service providers are bound by data processing agreements that require them to process your data only on our instructions and in compliance with applicable data protection law.
We may disclose your personal data where required to do so by applicable law, court order, regulatory authority, or to protect the rights, property, or safety of Avolvia, our Users, or the public.
In the event of a merger, acquisition, reorganisation, or sale of all or part of our business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections. We will notify you of any such transfer.
We may share your data in any other circumstances with your explicit prior consent.
Avolvia operates from South Africa and your data may be processed or stored in countries other than your country of residence, including where our cloud infrastructure providers are located (which may include countries in the European Economic Area, United States, or other regions).
Where we transfer personal data outside of South Africa or the European Economic Area, we ensure appropriate safeguards are in place, including:
By using the Platform, you acknowledge and consent to the transfer of your data as described in this section, subject to the safeguards above.
We retain personal data for as long as necessary to fulfil the purposes set out in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. The following general retention periods apply:
| Data Category | Retention Period |
|---|---|
| Account data | Duration of account + 3 years after deletion |
| Execution and commitment records | Duration of account + 2 years |
| Proof Submissions (text, image, video) | Duration of Program enrolment + 1 year, or until deletion request |
| Certification records | Indefinitely (immutable record of achievement) |
| Audit logs | Minimum 5 years (legal compliance requirement) |
| Payment and financial records | Minimum 5 years (statutory accounting requirement) |
| Technical and usage logs | Up to 12 months |
| Coach application data | Duration of Coach status + 3 years |
| Support communications | 3 years from last interaction |
Where you request deletion of your account, we will delete or anonymise your personal data within 30 days, except where retention is required by law or legitimate business interest (such as audit logs and Certification records).
Avolvia implements industry-standard technical and organisational security measures to protect your personal data, including:
While we take all reasonable steps to protect your data, no method of transmission over the internet or electronic storage is 100% secure. You use the Platform at your own risk, and we encourage you to use a strong, unique password and to report any suspected security incidents immediately to support@avolvia.app.
In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant supervisory authorities in accordance with applicable law (within 72 hours where required under GDPR/UK GDPR, and within required timeframes under POPIA and other applicable laws).
Subject to applicable law and certain exceptions, you have the following rights in relation to your personal data:
Request a copy of the personal data we hold about you and information about how we process it.
Request correction of inaccurate or incomplete personal data we hold about you.
Request deletion of your personal data where there is no compelling reason for continued processing (subject to legal retention obligations).
Request that we limit how we use your personal data in certain circumstances.
Receive your personal data in a structured, machine-readable format and transfer it to another service.
Object to processing of your data based on legitimate interests or for direct marketing purposes.
Where processing is based on your consent, withdraw that consent at any time without affecting prior processing.
Lodge a complaint with your local data protection supervisory authority if you believe we have violated your rights.
To exercise any of these rights, contact us at support@avolvia.app with the subject line "Privacy Rights Request". We will respond within 30 days (or within any shorter period required by applicable law). We may ask you to verify your identity before processing your request.
Avolvia uses cookies and similar tracking technologies to operate and improve the Platform. The cookies we use fall into the following categories:
| Type | Purpose | Can Be Disabled |
|---|---|---|
| Essential | Required for the Platform to function: session management, authentication, security tokens | No (Platform will not function without these) |
| Functional | Remember your preferences and settings to improve your experience | Yes |
| Analytics | Aggregate, anonymised data on how the Platform is used to guide improvements | Yes |
We do not use advertising, retargeting, or third-party marketing cookies. You may manage cookie preferences through your browser settings. Note that disabling non-essential cookies will not affect your ability to use the core Platform.
The Avolvia Platform is intended for use by individuals aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If you are a parent or guardian and believe your child has registered on the Platform, please contact us immediately at support@avolvia.app and we will delete the account and associated data promptly.
In jurisdictions where a higher age of digital consent applies, we comply with the applicable minimum age requirement for that jurisdiction.
If you are located in the European Union or European Economic Area, you have rights under the GDPR as described in Section 10 above. You may lodge a complaint with your national data protection authority. A list of EU supervisory authorities is available at edpb.europa.eu.
UK residents have equivalent rights under UK GDPR. Complaints may be lodged with the Information Commissioner's Office (ICO) at ico.org.uk.
South African residents have rights under POPIA, including the right to be notified of data collection, to access and correct your information, to object to processing, and to lodge a complaint with the Information Regulator of South Africa at inforegulator.org.za.
California residents have the right to know what personal information is collected, to delete personal information, to opt out of the sale of personal information (Avolvia does not sell personal information), and to non-discrimination for exercising these rights. To submit a CCPA request, email support@avolvia.app with subject "CCPA Request".
Canadian residents have the right to access their personal information, to challenge its accuracy, and to withdraw consent. Complaints may be made to the Office of the Privacy Commissioner of Canada at priv.gc.ca.
Australian residents have rights under the Australian Privacy Principles. Complaints may be lodged with the Office of the Australian Information Commissioner at oaic.gov.au.
Brazilian residents have rights under the Lei Geral de Proteção de Dados, including access, correction, anonymisation, deletion, and data portability rights. Complaints may be directed to the Autoridade Nacional de Proteção de Dados (ANPD).
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