Privacy Policy

This website, www.avelacom.com (the “Website”), is operated by Avelacom HK Limited, registered address: Level 19, China Building, 29 Queen’s Road Central, Hong Kong (“Avelacom”, “we”, “us”).

Avelacom operates through affiliated companies in Latvia, the United States, Hong Kong and Brazil (together, the “Avelacom group”). Depending on the nature and location of an inquiry, other Avelacom group companies may process personal data as described in this Privacy Policy.

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at legal@avelacom.com.

We collect personal data when you choose to provide it to us or when it is generated through your use of the Website:

1. Contact and inquiry forms. Your full name, email address, country, and any information you include in the inquiry field, for example details of your current technical setup and regions of interest.
2. Newsletter subscription. Your email address.
3. Website and analytics data. IP address and other online identifiers, device and browser information, approximate location, pages visited and information about how you interact with the Website, including information collected through cookies and similar technologies.

We do not intend to collect special categories of personal data through the Website. Please do not include sensitive personal information in free-text inquiry fields unless it is necessary for your request.

We do not knowingly collect personal data from children through the Website.

We use your personal data to:

1. respond to your inquiries and discuss your service requirements;
2. arrange meetings, calls and service trials;
3. send you newsletters and marketing communications where you have subscribed;
4. measure Website traffic, understand how the Website is used and improve the Website and our services; and
5. comply with legal obligations and establish, exercise or defend legal claims.

We process personal data in accordance with applicable data protection laws, including the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). Where the UK GDPR or EU GDPR applies to our processing, we rely on the following legal bases:

• Legitimate interests - where necessary for our legitimate business interests, including responding to business inquiries, communicating with prospective and existing customers, and promoting and improving our services, provided that those interests are not overridden by your rights and interests.
• Steps prior to entering into a contract - where you request information or services with a view to entering into a contract with us.
• Consent - where you subscribe to newsletters or other marketing communications and where consent is required for the use of cookies or similar technologies.
• Legal obligations - where processing is necessary for us to comply with applicable law.

Where we rely on consent, you may withdraw your consent at any time. You may unsubscribe from marketing communications at any time using the unsubscribe mechanism provided in the relevant communication or by contacting us.

Website form submissions are delivered to the corporate Google Workspace accounts of authorised Avelacom employees.

Depending on the nature and location of your request, your inquiry may be forwarded to the relevant sales representative or other authorised personnel at an Avelacom group entity in Latvia, the United States, Hong Kong or Brazil.

We also use third-party service providers in connection with the Website and our communications, including:

1. Google - Google Workspace is used for corporate email and handling inquiries, and Google Analytics is used to measure Website traffic and usage. We also use Google Search Console to obtain aggregated information about the Website's performance in Google search results.
2. Calendly - some pages on the Website may link to Calendly to allow you to book meetings. Information you provide directly through Calendly is processed in accordance with Calendly's applicable privacy terms.

We do not sell your personal data.

We may also disclose personal data where required by applicable law, regulation or legal process, to competent regulators or courts, or where necessary in connection with a merger, acquisition, restructuring, sale or other corporate transaction involving Avelacom or an Avelacom group company.

Because Avelacom operates internationally, your personal data may be accessed by or transferred to Avelacom group entities and service providers located outside the United Kingdom and the European Economic Area, including in the United States, Hong Kong and Brazil.

Some of these countries may not provide the same level of protection for personal data as the country in which you are located.

Where applicable data protection law requires safeguards for an international transfer, we use an appropriate transfer mechanism or other measures required by applicable law. Depending on the applicable legal regime, these may include an adequacy decision, the European Commission's Standard Contractual Clauses, the UK International Data Transfer Agreement or UK Addendum, or another legally recognised transfer mechanism.

You may contact us at legal@avelacom.com for further information about international transfers of your personal data.

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including any follow-up communications, and to meet applicable legal, accounting or reporting requirements.

Inquiry data will generally be retained for 24 months after our last contact with you, unless a business relationship is established, the information remains reasonably necessary for ongoing communications, or a longer retention period is required or permitted by law.

Newsletter subscription information is retained until you unsubscribe or we otherwise cease the relevant marketing activity.

Analytics data is retained in accordance with our applicable Google Analytics retention settings.

We take reasonable and appropriate technical and organisational measures designed to protect personal data against unauthorised or unlawful access, use, alteration, disclosure or loss.

Access to Website inquiries is limited to personnel who require access for relevant business purposes.

However, no method of transmission or storage of information is completely secure, and we cannot guarantee absolute security.

The Website uses cookies and similar technologies. Some cookies may be necessary for the Website to operate, while others are used for analytics and to help us understand Website traffic and user behaviour.

We use Google Analytics for these purposes. Google Analytics may collect information such as your IP address, device and browser information, approximate location, pages visited and information about how you interact with the Website.

Where applicable law requires your consent before analytics or other non-essential cookies are used, such cookies will be used on the basis of your consent.

You can also manage or delete cookies through your browser settings. Restricting certain cookies may affect some Website functionality.

We use Google Search Console to obtain aggregated information about how the Website performs in Google search results.

Depending on your location and applicable law, you may have the right to:

1. request access to the personal data we hold about you and receive a copy;
2. request correction of inaccurate or incomplete personal data;
3. request deletion of your personal data in certain circumstances;
4. request restriction of processing in certain circumstances;
5. object to processing based on our legitimate interests;
6. object to direct marketing at any time;
7. request portability of certain personal data; and
8. withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us at legal@avelacom.com.

We will respond to requests in accordance with applicable data protection law.

You may also have the right to lodge a complaint with the competent data protection authority in your jurisdiction. In Hong Kong, this is the Office of the Privacy Commissioner for Personal Data. If you are located in the United Kingdom or European Economic Area, you may have the right to lodge a complaint with the competent data protection authority under applicable UK or EU data protection law. In the United Kingdom, this is the Information Commissioner's Office.

The Website may contain links to third-party websites and services, including Calendly and social media platforms.

When you follow a link to a third-party website or service, that third party may process your personal data under its own privacy policy. We are not responsible for the privacy practices or content of third-party websites and services.

We may update this Privacy Policy from time to time to reflect changes in our processing activities, the Website or applicable law.

The current version of this Privacy Policy, together with its effective date, will be available on this page.

Avelacom HK Limited

Registered address: Level 19, China Building, 29 Queen’s Road Central, Hong Kong

Email: legal@avelacom.com