Aivo Privacy Policy, an Engageware Company (GDPR Compliance)

This Privacy Statement sets out how Engageware uses and protects any personal information and data (“Information”) given to an Engageware group  company, including TimeTrade Systems, Inc., SilverCloud, LLC, Aivo America Corp., and its affiliates, all DBA Engageware (collectively, “Engageware”). Engageware is fully committed to maintaining your confidence, trust and your privacy. Any questions you have regarding this policy can be directed to privacy@engageware.com.

This Privacy Statement describes the treatment and handling of all Information collected by Engageware through its services and websites, including:

  • What personally identifiable information is collected;
  • How Engageware may use the personally identifiable information and with whom and when this information may be shared with third parties;
  • Your rights to your Information and how you can submit a request to view, remove, change, or transfer the collected Information; and
  • To whom questions regarding this Privacy Statement should be directed.

By using this website, you agree to comply with and be bound by this Privacy Statement and the Terms and Conditions of Use published at engageware.com/terms-of-use/ (the “Terms”). This Privacy Statement is incorporated into those Terms, and capitalized terms used, but not defined herein, have the meanings ascribed to them in the Terms.

PLEASE READ THIS PRIVACY STATEMENT CAREFULLY, AND PLEASE CHECK THIS PRIVACY STATEMENT FREQUENTLY, AS ENGAGEWARE RESERVES THE RIGHT TO CHANGE THIS PRIVACY STATEMENT AT ANY TIME WITHOUT NOTICE. BY ACCESSING THE WEBSITES OR THE SERVICES AFTER THE “LAST UPDATED” DATE SET FORTH BELOW, YOU ARE DEEMED TO CONSENT TO OUR THEN-CURRENT PRIVACY STATEMENT.

  1. Introduction
  2. Scope
  3. Use of Data and Legal Bases
  4. Data Collection and Processing as Data Controller
  5. Devices, Cookies, and Similar Technologies
  6. Data Transfers
  7. Data Subject Rights
  8. Data Security and Retention
  9. Children’s Privacy
  10. Record of Processing Activities
  11. GDPR Compliance Audits
  12. Changes to This Privacy Policy
  13. Contact Information

1. Introduction

Welcome to Aivo, an Engageware Company. At Aivo, we prioritize the privacy of our clients ("Clients") and their users or customers ("Users"). This Privacy Policy applies to both our websites and our services, detailing how Aivo collects, stores, uses, and discloses data from clients, users, and prospects in compliance with the General Data Protection Regulation (GDPR).

2. Scope

This Privacy Policy covers:

  • Use of data and legal bases
  • Data collection and processing
  • Devices, cookies, and usage data
  • Data transfers
  • Data subject rights
  • Data security and retention
  • International data transfers
  • Children’s privacy
  • Record of processing activities
  • GDPR compliance audits
  • Changes to this Privacy Policy
  • Contact information

3. Use of Data and Legal Bases

3.1. Aivo as Data Controller

Data protection laws in certain jurisdictions distinguish between “data controller” and “data processor” of personal data. In general, our Clients are the controller of Client and User Information, and we act as the processor of Client and User Information. For other personal data—for example, the business contact information of our Clients—we may be the controller of such personal data.

When acting as a data controller, Aivo processes personal data under the following legal bases in accordance with the GDPR:

  • Contractual necessity: To fulfill service agreements, process payments, and communicate with clients and/or users.
  • Legal obligations: To comply with regulatory requirements.
  • Legitimate interests: To improve security, optimize services, and perform business analysis.
  • Consent: For data processing, marketing communications, cookies, and optional service enhancements. Clients/users may withdraw their consent at any time.

4. Data Collection and Processing as Data Controller

We collect and process the following types of personal data:

  • Client Information: Name, email address, physical address, billing information, and time zones.
  • Browsing Information: IP addresses, geographic location, browser type, referral sources, and browsing activity.

5. Devices, Cookies, and Similar Technologies

Aivo uses cookies and similar tracking technologies to analyze trends, manage the website, and obtain demographic information. Users can manage their cookie preferences through browser settings or our Cookie Policy.

6. Data Transfers

Personal data may be transferred to authorities, affiliated companies, business partners, and/or external service providers. If transfers occur outside the EU/EEA, Aivo ensures adequate safeguards, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission.
  • Data Transfer Impact Assessments (DTIAs) when required.
  • Additional technical and organizational measures to protect the data.

7. Data Subject Rights

Clients and Users have the following data protection rights:

  • They may request access to, correction, updating, or deletion of personal data.
  • They may object to the processing of their personal data, ask us to restrict the processing of personal data, or request the portability of their personal data.
  • If we have collected and processed personal information with their consent, they may revoke it at any time. Revoking their consent will not affect the lawfulness of any data processing we have carried out prior to such revocation, nor will it affect the processing of their personal data carried out on a valid legal basis.

To exercise these rights, they may send an email to legal@aivo.co / privacy@engageware.com.

8. Data Security and Retention

Aivo implements technical and organizational measures to protect personal data against unauthorized access, alteration, and loss, including:

  • Data encryption (TLS 1.2+ for transmission, AES-256 for storage).
  • Access controls and authentication mechanisms.
  • Security audits and periodic compliance checks.

Personal data is retained only for as long as necessary for the purposes of processing and to comply with legal obligations. When no longer needed, data is securely deleted or anonymized.

9. Children’s Privacy

Aivo’s services are not intended for individuals under 16 years of age. We do not intentionally collect personal data from individuals under 16 years of age. If the accidental collection of such data is detected, it will be deleted immediately. If you are a parent or legal guardian and believe that your child has provided us with personal information, please contact us at legal@aivo.co / privacy@engageware.com to request its deletion.

10. Record of Processing Activities

Aivo maintains a Record of Processing Activities in accordance with Article 30 of the GDPR, documenting:

  • Categories of personal data processed
  • Purpose of each processing activity
  • Legal bases for processing
  • Data recipients (partners, authorities, service providers, etc.)
  • International data transfers and applicable safeguards
  • Data retention periods
  • Implemented security measures

This record is available for review by data protection authorities and is updated periodically.

11. GDPR Compliance Audits

Aivo conducts regular audits to evaluate and verify compliance with GDPR requirements. These audits include:

  • Review of processing activities
  • Evaluation of security measures and data protection policies
  • Analysis of data transfers and international compliance mechanisms
  • Awareness training for employees who handle personal data

As part of our compliance framework, Aivo uses automated security and compliance platforms to monitor and document our GDPR-related controls. These tools help ensure continuous compliance through real-time monitoring, automated evidence collection, and security audits.

12. Changes to This Privacy Policy

Aivo reserves the right to update this Privacy Policy. Any changes will be communicated through our website and other appropriate channels. We recommend reviewing this policy periodically to stay informed about our privacy practices.

13. Contact Information

For any inquiries related to privacy, you may contact:

📧 Email: legal@aivo.co / privacy@engageware.com

European Representative:
María Daniela Sargiotto
María de las Mercedes de Borbón 174, 10 B, Madrid, Spain