Aivo Privacy Policy (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

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

Information may be disclosed to authorities, Aivo affiliates, partners, and third-party service providers. Transfers outside the EU/EEA, the UK or Switzerland, including to the United States and Latin American countries, are performed subject to appropriate safeguards to protect your data in a manner which provides a degree of protection similar to the EU (or UK or Switzerland as applicable). To achieve this, we rely on Standard Contractual Clauses or other lawful transfer mechanisms approved by the European Commission with our third-party providers outside of the EEA (or UK or Switzerland as applicable). By providing us with your Information, you agree to such transfer and/or processing.  

Aivo remains accountable for processing of the personal data in case of onward transfer. 

Aivo and its US affiliates (TimeTrade Systems, Inc., SilverCloud, LLC, and Aivo America Corp.) comply with the EU-U.S. Data Privacy Framework (“EU-US DPF”), the UK Extension to the EU-U.S. DPF and the Swiss – U.S. Data Privacy Framework (“Swiss – U.S. DPF”) as set forth by the U.S. Department of Commerce. Aivo has certified to the U.S. Department of Commerce that we adhere to the EU – U.S., UK Extension to the EU-US DPF and Swiss – U.S. DPF Principles with regard to the processing of personal data received from the EU, the UK (and Gibraltar) and Switzerland in reliance (each to the extent applicable) on the EU – U.S., UK Extension to the EU-US DPF and Swiss – U.S. DPF. 

If there is any conflict between the terms in this Privacy Statement and the EU-U.S., UK Extension to the EU-US DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles (each to the extent applicable) shall govern. To learn more about the Data Privacy Framework, and to view Aivo’s and its US affiliates' certifications, please visit https://www.dataprivacyframework.gov/. 

In compliance with the EU – U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss U.S. DPF, Aivo commits to resolve complaints about our collection or use of your personal information. Individuals in the European Union, the United Kingdom and Switzerland, as applicable, with inquiries or complaints regarding our Privacy Statement or EU-US DPF Principles the UK Extension to the EU-U.S. DPF and or the Swiss-US DPF should first contact privacy@engageware.com. We will respond to your inquiry promptly. 

In compliance with the EU – U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss U.S. DPF Aivo commits to cooperate and comply with the advice of the panel established by the EU data protection authorities (DPAs), the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs, the UK’s ICO or the Swiss FDPIC for more information or to file a complaint. Their services are provided at no cost to you. 

If we transfer personal information received under the EU-US DPF, the UK Extension to the EU-U.S. DPF and or the Swiss-US DPF to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our EU-US DPF, the UK Extension to the EU-U.S. DPF and or Swiss-DPF obligations, and Aivo will remain liable under the EU-US DPF, the UK Extension to the EU-U.S. DPF and or the Swiss-US DPF for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage. Engageware is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). Under certain conditions, an individual can invoke binding arbitration. Aivo will disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 

When we transfer data outside of other countries which provide for specific international transfer mechanisms or other governmental clauses, we will apply those as specified under the privacy laws and regulations.

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

Last reviewed 31-10-2025