Last Updated: October 8, 2024
GOODSIZE INC., a Delaware Corporation, is the owner and operator of Avaturn.Live.
This Privacy Policy describes the privacy practices of Goodsize Inc. (“Goodsize”, ‘us’, or “we”) in connection with Avaturn.Live services and the Avaturn.live website (the “Site”).
Welcome to Goodsize’s Privacy Policy!
If you decide not to read this entire Privacy Policy, we want you to walk away with a few key points about Goodsize’s privacy practices:
If you have any questions about our privacy practices, please email at [email protected].
Here’s more on our privacy practices. Individuals located in the European Economic Area should also read our Notice to European Users below.
When you use the services, we may collect information about you, including:
We do not use the information you provide when using the Site other than to provide you with our services or to use anonymized data internally for Avaturn.live development.
We do not use the videos you provide for any reason other than to provide you with creation of your own avatar functionality of Avaturn.Live or to use anonymized data internally for the technology improvement.
We may use information other than videos and information described above for the following purposes:
To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the Opt out of marketing section below.
For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes.
We do not disclose user videos to third parties other than to our cloud providers (including, but not limited to Amazon Web Services and Google Cloud Platform) when uploading encrypted images to provide the 3D head scanning features of Avaturn.live, or to our service providers for the purposes of data annotation for the technology improvement (in this case user data is not linked to the account).
We do not disclose information (including, but not limited to text and audio) you provide on the Site other than to third-party providers (including but not limited to Google Cloud, Cockroach Labs, Inc., Daily, ElevenLabs, OpenAI), or to our service providers for the purposes of data annotation for the product improvement (in this case user data is not linked to the account).
We may share your other information in the following circumstances:
Affiliates. We may share Avaturn.live usage information with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.
Service providers. We may share your personal information with service providers that perform services on our behalf or help us operate Avaturn.live (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
Third-party platforms and social media networks. If you have enabled features or functionality that connect Avaturn.live to a third-party platform or social media network (such as by logging into Site using your account with the third-party, providing your API key or similar access token for Abaturn.live to a third-party, or otherwise linking your account with Avaturn.live to a third-party’s services), we may disclose the personal information that you authorized us to share (such as when you elect to upload a photograph to your social media account). We do not control the third-party platforms’ use of your personal information, which is governed by that third party’s privacy policy and terms and conditions.
Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
We may be required to use and share your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
In this section, we describe the rights and choices available to all users. Users who are located within the European Union can find additional information about their rights below.
Opt out of marketing communications and other push notifications. You may opt out of marketing-related communications and other notifications. If marketing communications and other notifications are sent via email you may opt out of them by sending ‘Unsubscribe’ at [email protected].
Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera or camera roll, through the settings on your mobile device.
Cloud processing. You may request that we remove your information, including videos, by sending us an email at [email protected].
Cookies & Browser Web Storage. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Site may not work properly. Similarly, your browser settings may allow you to clear your browser web storage.
Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide Avaturn.live to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to use Avaturn.live by designating it as required at the time of collection or through other appropriate means.
Third-party platforms or social media networks. If you choose to connect to Avaturn.live via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third-party at the time you login to Avaturn.live using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.
Avaturn.live may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We use commercially reasonable security practices to help keep the information collected through Avaturn.live secure and take reasonable steps to verify your identity before granting you access to your account (if you have an account with us). However, Goodsize Inc. cannot ensure the security of any information you transmit to Goodsize or guarantee that information on Avaturn.live may not be accessed, disclosed, altered, or destroyed.
Please do your part to help us. You are responsible for maintaining the confidentiality of your login information and device identifiers, and for controlling access to communications between you and Goodsize Inc, at all times. Your privacy settings may also be affected by changes the social media services you connect to Goodsize Inc. make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.
We may store anonymized video information and information you provide using Avaturn.live for the technology and product improvement purposes on our cloud provider for as long as necessary to fulfill the purposes we have set out in this Privacy Policy. With respect to other information that we may collect, we will retain such information in a personally identifiable format only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy. You may also ask that we delete your information by contacting us at [email protected].
We store the information we collect in connection with Avaturn.live on Amazon Web Services, Cockroach Labs, Inc. and Google Cloud Platform. Your personal information may be accessed by our service providers in other locations outside of your state, province, or country. Your device ID (and general Avaturn.live usage information) may also be accessed by the Company’s technical support team in other locations outside of your state, province, or country. We rely on the Privacy Shield, as described below, for transfers of data to Goodsize Inc. in the United States.
Goodsize Inc. is the US entity that publishes and hosts Avaturn.live. Goodsize Inc. complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Goodsize Inc. has submitted its certification to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.
Goodsize Inc. may transfer your personal information to third parties as described in this Privacy Policy. Goodsize Inc. maintains contracts with its third-party service providers restricting their access, use and disclosure of personal information in compliance with our Privacy Shield obligations. Goodsize Inc. may be liable if these third parties fail to meet those obligations and we are responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, Goodsize Inc. commits to resolve complaints about our collection or use of your personal information. European individuals with inquiries or complaints regarding our Privacy Policy should first contact Goodsize Inc. at [email protected] Goodsize Inc. has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither Goodsize Inc. nor JAMS resolves your complaint, you may have the ability to engage in binding arbitration through the Privacy Shield Panel. Additional information on the arbitration process is available on the Privacy Shield website at www.privacyshield.gov.
Goodsize Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. The Federal Trade Commission has jurisdiction over Goodsize Inc.’s compliance with the Privacy Shield. Goodsize Inc.’s commitments under the Privacy Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.
Avaturn.live is not directed at children under the age of 13, and our Terms of Use do not allow children under 13 years of age to use Avaturn.live.
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on Avaturn.live. We may, and if required by law, will provide notification of changes in another way that we believe is reasonably likely to reach you, such as through Avaturn.live or by email.
Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on Avaturn.live (or as otherwise indicated at the time of posting). In all cases, your continued use of Avaturn.live after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Please direct any questions or comments about this Policy or privacy practices [email protected].
The information provided in this «Notice to European Users» section applies only to individuals who reside in Europe.
Personal information. References to «personal information» in this Privacy Policy are equivalent to «personal data» governed by European data protection legislation.
Controller and EU Representative. Goodsize Inc. is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.
Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.
| Processing purpose. Details regarding each processing purpose listed below are provided in the section above titled "How we use your personal information" | Legal Basis |
|---|---|
| To operate and improve Avaturn.live | Processing is necessary to perform the contract governing our provision of services in connection with Avaturn.live, or to take steps that you request prior to signing up for Avaturn.live. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request in connection with Avaturn.live. |
| To send you marketing and promotional communications, To display advertisements to you, For compliance, fraud prevention and safety, To create anonymous, aggregated or de-identified data | These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). |
| Compliance with Law | Processing is necessary to comply with our legal obligations. |
| With your consent | Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or on Avaturn.live. |
European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:
You may submit these requests by email to [email protected].
If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
We are required by the California Consumer Privacy Act of 2018 («CCPA») to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California residents regarding our handling of their personal information. We do not sell personal information. As we explain in this Privacy Policy, we use cookies and other tracking technologies to analyze Site traffic and use, and to facilitate advertising.
In addition to disclosures of personal information to our service providers and professional advisors, for compliance, fraud prevention and safety, and in connection with a business transfer, as described in the «How We Share Your Personal Information» section of the Privacy Policy, the following chart further describes our privacy practices with respect to the personal information of our California consumers.
| Personal Information We Collect | CCPA-Defined Categories | Sources | Purpose | Data Sharing |
|---|---|---|---|---|
| Videos | Physical Description | You | To operate and improve Avaturn.live | Shared with third-party platforms (e.g., social media networks) at your direction, shared with cloud service providers (i.e., Google Cloud Platform and Amazon Web Services) |
| Text or audio information user provides on Site | Professional Information, Audio | You | To operate and improve Avaturn.live | Shared with third-party platforms (e.g., Daily, ElevenLabs, OpenAI), shared with cloud service providers (i.e., Google Cloud Platform, Amazon Web Services, Cockroach Labs, Inc.) |
| Avaturn.live Usage Information | Online Identifiers, Internet or Network Information, Inferences | You, Automatic Collection | To operate and improve Avaturn.Live, to send you marketing and promotional communications | Shared with affiliates that provide services to us |
| Purchase History | Commercial Information, Online Identifiers | The Avaturn.live provider through which you purchased your subscription (i.e., Stripe) | To operate and improve Avaturn.live | None |
| Social Media Information | Identifiers, Online Identifiers | Third-party platforms | To operate and improve Avaturn.live | Shared with third-party platforms (e.g., social media networks) at your direction |
| Device Data, Online Activity Data | Online Identifiers, Internet or Network Information, Inferences | You, Automatic Collection | To display advertisements to you | Collected directly by advertising partners |
Except as excluded from the scope of this notice above, the CCPA grants California residents the following rights.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination.
To request access to or deletion of personal information
Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We may attempt to verify your identity by asking you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.
Authorized agents. California residents can empower an «authorized agent» to submit requests on their behalf. We will require the authorized agent to have written authorization confirming such authority.