Privacy Policy
Last updated on August “__”, 2025
AVB Invest Inc together with its affiliated entities (“AVB“) is committed to protecting your privacy. This Privacy Policy describes how we process (collect, use, store, disclose, analyze, delete, or modify) your personal data, and what rights you have with respect to your data.
AVB Invest Inc is a controller and processor of financial data.
We have updated this version of our Privacy Policy to reflect changes in data protection law.
AVB informs the Users of Launch Design website that this Privacy Policy applies to the Natural persons who are adults, have civil rights and obligations, to acquire and exercise civil rights by their actions, to create civil obligations for themselves and fulfill them, to independently bear responsibility for harm caused by an unlawful action or inaction, to be aware of their actions and their harmful results.
At the same time this Privacy Policy doesn’t apply to an individual acting in a commercial or employment context or as an employee, owner, director, officer, or contractor of AVB whose communications or transactions with the AVB occur solely within the context of that individual's role with the company or partnership.
Table of Contents
Section 1. Applicability of the Privacy Policy
This Privacy Policy applies to Launch Design website and other services, offerings, and other interactions (e.g., customer service inquiries, or your participation in user conferences, community events, etc.) you may have with us that are subject to this Privacy Policy (together with Launch Design website, collectively referred to as our “Services“). If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services through Launch Design website (“Third Party Services“), or any other third party products, services or businesses.
Section 2. Information We Collect and Receive
We process data that relates to identified or identifiable individuals (“personal information “) as follows:
Processing is implemented is the data subject has given consent to the processing of his or her personal data for one or more specific purposes, or if it is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, or it is necessary for compliance with a legal obligation to which AVB is subject.
Section 3. How We Collect Personal Information
Information you give us
You may give us personal information when you apply for Launch Design, register for the Platform, or otherwise submit information to use through the Services or other communications with us. For example:
We have the right to send informational messages to the User's email address and/or subscriber number, including, but not limited to, messages related to the functioning of Launch Design website, notifications related to the execution of the contracts concluded with the User, information on password recovery, etc. Confirmation of the User's consent to receive from us the informational messages specified in this paragraph is acceptance of the terms of the Agreement.
We have the right to transfer the User's data to our subsidiaries (companies) and implement measures to increase the client base - advertising mailings using the user's contact information.
Information we get from others
We may subscribe to databases or contract with third party data providers from which we collect personal information such as Contact Data, Professional/Biographical Data, Inference Data, and other personal data regarding individuals that may be interested in our Events and programs. We may also collect, and combine with other personal data we maintain, personal data that is publicly available, such as that provided by business networking sites and databases, information related to the organization for which you work and personal interests and skill sets, and other similar information.
We also may obtain information from those in the AVB network such as our event organizers, contractors, and local representatives who have agreed to a relationship with us in order to deliver our Services. This may include information about potential interest in our programs, company and individual progress, interest in local events, and attendance at other similar events.
Information automatically collected
We may automatically collect personal information such as Device/Network Data when you access and use Launch Design website. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to Launch Design website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on Launch Design website. We collect this information about you using cookies.
Changes to your personal information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at team@avbinvest.com.
Section 4. How We Use Your Information
To provide the Services you request
If you use Launch Design website, sign up for, or request to participate in the Employment Program, we will process your personal information you give us or that we receive from relevant parties as necessary or appropriate for us to provide that Service. For example, we may process your personal information as follows:
If you request information from us, register on Launch Design website, or participate in our surveys, promotions or events, where allowed by law, we or our third party partners, mentors, and members of the AVB network may use your personal information, such as Identity Data and Contact Data, as well as Inference Data or Profile Data, to send you updates, newsletters, surveys, offers, and other promotional materials, including communications that may be targeted to you based on your personal information, as permitted by law. We also may, from time to time, contact you about a particular offering that may be of interest to you based on publicly available information, or information obtained through the AVB network, Events you’ve attended, or your participation in AVB Services. You will have the ability to opt out of such communications.
Section 5. Cookies and Similar Technologies.
What are cookies and similar technologies?
We may collect personal information using “cookies“. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on Launch Design website.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits Launch Design website; and (2) third party cookies, which are served by service providers on Launch Design website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites or online services.
For online advertising
We use may use Device/Network Data and Inference Data we collect from cookies and similar technologies in order to market certain products and services to you, such as Events you may be interested in. For example, if you attend an Event, we may use your personal data in connection with online advertising campaigns on Google, Facebook, Instagram and LinkedIn. We, or our third party advertising partners, may combine this information in order to create profiles that are used to make more relevant profiles. You can control how these third parties use your data, and the ads you see on these platforms, using the tools described in the Your Rights and Choices section below.
With your consent
We may use or share your personal information with your consent, such as when you: agree to participate in additional surveys regarding the operation of the site, as well as services provided by the site, allow us to publish your reviews or recommendations on the Job Games website, instruct us to take certain actions regarding your personal information, or agree to third-party marketing communications.
For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
To create aggregated or de-identified information
We may disclose or use aggregated or de-identified information for any purpose, subject to limits under applicable law. For example, we may share aggregated or de-identified information with prospects, partners, or sponsors for business or research purposes, such as when we analyze and report on demographic trends to measure our objective of having healthy diversity ratios across our programs.
Miscellaneous processing
If we process personal information in connection with our Services in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated when you provide it.
Note that we may, without your consent, also process your personal information on certain public interest grounds. For example, we may process personal information as necessary to fulfill our legal obligations, to protect the vital interests of any individual, or otherwise in the public interest. Please see the Data Sharing section for more information about how we disclose personal information in extraordinary circumstances.
Section 6. How We Share Your Information
Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations. We generally disclose personal information to third parties for the following purposes:
The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we can’t guarantee the security of your information.
Section 9. Other Sites and Services
Launch Design website may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We don’t exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Section 10. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy we will post an updated version of the Privacy Policy on Launch Design website.
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on Launch Design website (or as otherwise indicated at the time of posting). In all cases, your continued use of our Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Section 11. Retention
We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Personal data storage period is 5 years. In accordance with the practice of the US Federal Trade Commission (FTC), we do not store personal information longer than is necessary to achieve the stated purposes and comply with legal requirements.
Section 12. Applicable Law and Dispute resolution
Applicable Law
The Parties agree that the application of the Privacy Policy, the processing of personal data and the use of cookies shall be governed by the rules of international law aimed at protecting the rights of AVB and Launch Design website Users in this area.
The federal law of the United States of America and the law of the Delaware. In the event of any conflict, mandatory provisions of USA law shall prevail, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) if the User is a California resident.
State shall also apply to Launch Design website Users, in the event of gaps in international law in the legal regulation of these legal relations.
Dispute resolution
In the event of a dispute, the Parties agree to resolve it through good faith negotiations. To initiate dispute negotiations, a Party must send a written Claim to the other Party, outlining his/her position, the claim’s nature, and the dispute.
The claim procedure is mandatory. The response period to a written claim is 15 calendar days from its receipt by the Party. A claim is considered received if sent to the email address specified by the Parties. If a response to the claim isn’t received within 15 calendar days or if the other Party refuses to negotiate, or if negotiations don’t resolve the dispute, the Party has the right to submit the dispute to court.
If you disagree with our decision regarding the processing of your personal data (e.g. denial of access, deletion or correction of data), you can appeal by sending a request to [team@avbinvest.com]. Your appeal will be forwarded to the competent department for consideration. The appeal will be considered by other persons who were not involved in the claim procedure.
No later than 60 days after receiving appeals, we will notify you in writing of any actions taken or not taken in response to the appeal, including written reasons for written decisions in accordance with Section 12D-104 of the DPDPA.
Pursuant to Section 12D-111(d), enforcement authority is vested exclusively in the Delaware Department of Justice. Therefore, if you disagree with our decision on your appeal, you have the right to file a complaint with the Delaware Department of Justice.
You can do this online at https://attorneygeneral.delaware.gov/consumer-protection/, or contact them by email at attorney.general@delaware.gov, by phone at (302) 683-8800, or by mail at: Delaware Department of Justice Office of Consumer Protection 820 N. French Street Wilmington, DE 19801.
You also have the right to file a complaint with the Federal Trade Commission (FTC) or your state Attorney General's office.
Section 13. Contact Us
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at team@avbinvest.com, or write to us at: 373 Lexington Avenue, 369 New York, NY, 10017.
Section 14. Information for California Residents
Your California privacy rights
If you are a California resident, you have the following rights:
To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:
Website: https://launchdesign.avbinvest.com
Email: team@avbinvest.com
We will request that you provide information necessary to verify your identity. That information may vary based on the context and scope of your request. For example, we may require you to verify access to an email address, or provide other forms of identification appropriate to the request. We may require agents submitting a request on your behalf to provide proof of agency in order to respond to a request.
Response Timing and Format
We aim to respond to requests for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
AVB Invest Inc is a controller and processor of financial data.
We have updated this version of our Privacy Policy to reflect changes in data protection law.
AVB informs the Users of Launch Design website that this Privacy Policy applies to the Natural persons who are adults, have civil rights and obligations, to acquire and exercise civil rights by their actions, to create civil obligations for themselves and fulfill them, to independently bear responsibility for harm caused by an unlawful action or inaction, to be aware of their actions and their harmful results.
At the same time this Privacy Policy doesn’t apply to an individual acting in a commercial or employment context or as an employee, owner, director, officer, or contractor of AVB whose communications or transactions with the AVB occur solely within the context of that individual's role with the company or partnership.
Table of Contents
- Applicability of the Privacy Policy
- Information We Collect and Receive
- How We Collect Personal Information
- How We Use Your Information
- Cookies and Similar Technologies
- How We Share Your Information
- Your Rights and Choices
- Security
- Other Sites and Services
- Changes to this Privacy Policy
- Retention
- Applicable Law and Dispute Resolution
- Contact Us
- Information for California Residents
Section 1. Applicability of the Privacy Policy
This Privacy Policy applies to Launch Design website and other services, offerings, and other interactions (e.g., customer service inquiries, or your participation in user conferences, community events, etc.) you may have with us that are subject to this Privacy Policy (together with Launch Design website, collectively referred to as our “Services“). If you do not agree with the data practices described in this Privacy Policy, you should not use our Services.
This Privacy Policy does not apply to any third party applications or software that integrate with the Services through Launch Design website (“Third Party Services“), or any other third party products, services or businesses.
Section 2. Information We Collect and Receive
We process data that relates to identified or identifiable individuals (“personal information “) as follows:
Purpose for processing | Types of personal data |
To verify your identity | full name; email address |
To deal with your enquiries and reply to your requests | personal and business contact information, such as email address or other identifiers used for communication |
To provide security and fraud detection | information regarding your interaction with a website, application, or advertisement (e.g., IP Address, MAC Address, SSIDs, etc.), online user ID, device characteristics (such as browser/OS version), web server logs, application logs, cookie data, web beacons, clear GIFs, pixel tags, and information about how you use Launch Design website and interact with us; protected class data: characteristics of protected classifications under New York or federal law |
To send you a marketing communication | Full name and email address |
Processing is implemented is the data subject has given consent to the processing of his or her personal data for one or more specific purposes, or if it is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract, or it is necessary for compliance with a legal obligation to which AVB is subject.
Section 3. How We Collect Personal Information
Information you give us
You may give us personal information when you apply for Launch Design, register for the Platform, or otherwise submit information to use through the Services or other communications with us. For example:
- We may collect your name and email for the purpose of further communication and commercial relations.
We have the right to send informational messages to the User's email address and/or subscriber number, including, but not limited to, messages related to the functioning of Launch Design website, notifications related to the execution of the contracts concluded with the User, information on password recovery, etc. Confirmation of the User's consent to receive from us the informational messages specified in this paragraph is acceptance of the terms of the Agreement.
We have the right to transfer the User's data to our subsidiaries (companies) and implement measures to increase the client base - advertising mailings using the user's contact information.
Information we get from others
We may subscribe to databases or contract with third party data providers from which we collect personal information such as Contact Data, Professional/Biographical Data, Inference Data, and other personal data regarding individuals that may be interested in our Events and programs. We may also collect, and combine with other personal data we maintain, personal data that is publicly available, such as that provided by business networking sites and databases, information related to the organization for which you work and personal interests and skill sets, and other similar information.
We also may obtain information from those in the AVB network such as our event organizers, contractors, and local representatives who have agreed to a relationship with us in order to deliver our Services. This may include information about potential interest in our programs, company and individual progress, interest in local events, and attendance at other similar events.
Information automatically collected
We may automatically collect personal information such as Device/Network Data when you access and use Launch Design website. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to Launch Design website, pages you viewed, how long you spent on a page, access times and information about your use of and actions on Launch Design website. We collect this information about you using cookies.
Changes to your personal information
It is important that the personal information we hold about you is accurate and current. Please let us know if your personal information changes during your relationship with us by updating your registration profile or emailing us at team@avbinvest.com.
Section 4. How We Use Your Information
To provide the Services you request
If you use Launch Design website, sign up for, or request to participate in the Employment Program, we will process your personal information you give us or that we receive from relevant parties as necessary or appropriate for us to provide that Service. For example, we may process your personal information as follows:
- We process Device/Network Data to operate, maintain, administer and improve Launch Design website, (e.g., to show the content you request, secure the Launch Design website, and understand how users interact with Launch Design website).
- We process personal information related to support and maintenance for our Services that you may request.
If you request information from us, register on Launch Design website, or participate in our surveys, promotions or events, where allowed by law, we or our third party partners, mentors, and members of the AVB network may use your personal information, such as Identity Data and Contact Data, as well as Inference Data or Profile Data, to send you updates, newsletters, surveys, offers, and other promotional materials, including communications that may be targeted to you based on your personal information, as permitted by law. We also may, from time to time, contact you about a particular offering that may be of interest to you based on publicly available information, or information obtained through the AVB network, Events you’ve attended, or your participation in AVB Services. You will have the ability to opt out of such communications.
Section 5. Cookies and Similar Technologies.
What are cookies and similar technologies?
We may collect personal information using “cookies“. Cookies are small data files stored on the hard drive of your computer or mobile device by a website. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer or mobile device until you delete them) to provide you with a more personal and interactive experience on Launch Design website.
We use two broad categories of cookies: (1) first party cookies, served directly by us to your computer or mobile device, which we use to recognize your computer or mobile device when it revisits Launch Design website; and (2) third party cookies, which are served by service providers on Launch Design website, and can be used by such service providers to recognize your computer or mobile device when it visits other websites or online services.
For online advertising
We use may use Device/Network Data and Inference Data we collect from cookies and similar technologies in order to market certain products and services to you, such as Events you may be interested in. For example, if you attend an Event, we may use your personal data in connection with online advertising campaigns on Google, Facebook, Instagram and LinkedIn. We, or our third party advertising partners, may combine this information in order to create profiles that are used to make more relevant profiles. You can control how these third parties use your data, and the ads you see on these platforms, using the tools described in the Your Rights and Choices section below.
With your consent
We may use or share your personal information with your consent, such as when you: agree to participate in additional surveys regarding the operation of the site, as well as services provided by the site, allow us to publish your reviews or recommendations on the Job Games website, instruct us to take certain actions regarding your personal information, or agree to third-party marketing communications.
For compliance, fraud prevention and safety
We use your personal information as we believe necessary or appropriate to (a) enforce the terms and conditions that govern the Service; (b) protect our rights, privacy, safety or property, and/or that of you or others; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
To create aggregated or de-identified information
We may disclose or use aggregated or de-identified information for any purpose, subject to limits under applicable law. For example, we may share aggregated or de-identified information with prospects, partners, or sponsors for business or research purposes, such as when we analyze and report on demographic trends to measure our objective of having healthy diversity ratios across our programs.
Miscellaneous processing
If we process personal information in connection with our Services in a way not described in this Privacy Policy, this Privacy Policy will still apply generally (e.g. with respect to your rights and choices) unless otherwise stated when you provide it.
Note that we may, without your consent, also process your personal information on certain public interest grounds. For example, we may process personal information as necessary to fulfill our legal obligations, to protect the vital interests of any individual, or otherwise in the public interest. Please see the Data Sharing section for more information about how we disclose personal information in extraordinary circumstances.
Section 6. How We Share Your Information
Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations. We generally disclose personal information to third parties for the following purposes:
- Partners and Employers. We may disclose your personal information to our partners with whom we have contracted to deliver Employment Programs. When you participate in the Employment Program, your personal information may be shared with the identified employer.
- Affiliates. We may disclose your personal information to our parent company, subsidiaries, joint ventures, or other corporate affiliates for purposes consistent with this Privacy Policy.
- 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.
- Compliance with Laws and Law Enforcement; Protection and Safety. AVB may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Services; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
- Service Providers & Business Purposes. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as account creation, quality assurance testing, technical support, hosting, email delivery and database management services). We may also disclose your data in connection with certain other business and operational purposes, such as data security monitoring, service analytics, internal research, quality control, etc. We generally share your personal data as you request, or in accordance with certain business purposes. When we disclose information for business purposes (e.g., where we disclose information as part of our own internal operations, such as security operations, internal research, etc.), we may disclose the following categories of information: Identity Data, Contact Data, Content, Financial Data, Professional/Biographical Data, Commercial Data, Device/Network Data, Inference Data, Audio/Visual Data, Government ID Data, Protected Class Data, and Special Category Data (each to the extent collected).
- Access, update, correct or delete your information. All account holders may review, update, correct or delete the personal information in their registration profile by logging into their account. You may also contact us at team@avbinvest.com to accomplish the foregoing or if you have additional requests or questions.
- Obtain a list of the categories of third parties to which we have disclosed your personal data. You may contact us at team@avbinvest.com to send relevant inquiry.
- Email communications. You may opt out of newsletters and marketing-related emails from us by following the unsubscribe instructions on a link at the bottom of each such email, or by contacting us at team@avbinvest.com. You may continue to receive service-related and other non-marketing emails. If you authorized the sharing of your contact information with a third party, contact that third party directly to opt out of receiving any communications they may send.
- Withdrawing consent. If you gave us consent to use your personal information, but wish to update or delete it, please contact us at team@avbinvest.com.
- 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 the Services 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 the Services and may need to close your account. We will tell you what information you must provide to receive the Services by designating it as required in the Services or through other appropriate means.
- Uninstalling our applications. You can stop all collection of information by the application(s) by uninstalling the application(s). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
- Cookies and similar technologies. You can typically remove or reject cookies via your browser settings. In order to do this, follow the instructions provided by your browser (usually located within the “settings,” “help” “tools” or “edit” facility). Many browsers are set to accept cookies until you change your settings. Further information about cookies, including how to see what cookies have been set on your computer or mobile device and how to manage and delete them, visit www.allaboutcookies.org. If you do not accept our cookies or similar technologies, you may not be able to use certain features or services. For example, we may not be able to recognize your computer or mobile device and you may need to log in every time you visit Launch Design website.
- Do Not Track Signals. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to do not track signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
- Google Analytics. You must opt out of other third party technologies directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.
- Retargeting and Behavioral Advertising. When we share your information with third parties for retargeting purposes, or for behavioral advertising, you have a right to revoke your consent (if provided) or otherwise opt-out of such services. Where a third party processes data on our behalf, (e.g. Custom Audiences, or Customer Match) you may contact us to opt-out. However, to the extent the third party processes your information for its own purposes, you should opt out with that third party directly.
The security of your personal information is important to us. We take a number of organizational, technical and physical measures designed to protect the personal information we collect, both during transmission and once we receive it. However, no security safeguards are 100% secure and we can’t guarantee the security of your information.
Section 9. Other Sites and Services
Launch Design website may contain links to other websites and services. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We don’t exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.
Section 10. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make material changes to this Privacy Policy we will post an updated version of the Privacy Policy on Launch Design website.
Any modifications to this Privacy Policy will be effective upon our posting of the new terms and/or upon implementation of the new changes on Launch Design website (or as otherwise indicated at the time of posting). In all cases, your continued use of our Services after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.
Section 11. Retention
We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
Personal data storage period is 5 years. In accordance with the practice of the US Federal Trade Commission (FTC), we do not store personal information longer than is necessary to achieve the stated purposes and comply with legal requirements.
Section 12. Applicable Law and Dispute resolution
Applicable Law
The Parties agree that the application of the Privacy Policy, the processing of personal data and the use of cookies shall be governed by the rules of international law aimed at protecting the rights of AVB and Launch Design website Users in this area.
The federal law of the United States of America and the law of the Delaware. In the event of any conflict, mandatory provisions of USA law shall prevail, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) if the User is a California resident.
State shall also apply to Launch Design website Users, in the event of gaps in international law in the legal regulation of these legal relations.
Dispute resolution
In the event of a dispute, the Parties agree to resolve it through good faith negotiations. To initiate dispute negotiations, a Party must send a written Claim to the other Party, outlining his/her position, the claim’s nature, and the dispute.
The claim procedure is mandatory. The response period to a written claim is 15 calendar days from its receipt by the Party. A claim is considered received if sent to the email address specified by the Parties. If a response to the claim isn’t received within 15 calendar days or if the other Party refuses to negotiate, or if negotiations don’t resolve the dispute, the Party has the right to submit the dispute to court.
If you disagree with our decision regarding the processing of your personal data (e.g. denial of access, deletion or correction of data), you can appeal by sending a request to [team@avbinvest.com]. Your appeal will be forwarded to the competent department for consideration. The appeal will be considered by other persons who were not involved in the claim procedure.
No later than 60 days after receiving appeals, we will notify you in writing of any actions taken or not taken in response to the appeal, including written reasons for written decisions in accordance with Section 12D-104 of the DPDPA.
Pursuant to Section 12D-111(d), enforcement authority is vested exclusively in the Delaware Department of Justice. Therefore, if you disagree with our decision on your appeal, you have the right to file a complaint with the Delaware Department of Justice.
You can do this online at https://attorneygeneral.delaware.gov/consumer-protection/, or contact them by email at attorney.general@delaware.gov, by phone at (302) 683-8800, or by mail at: Delaware Department of Justice Office of Consumer Protection 820 N. French Street Wilmington, DE 19801.
You also have the right to file a complaint with the Federal Trade Commission (FTC) or your state Attorney General's office.
Section 13. Contact Us
If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, please contact us at team@avbinvest.com, or write to us at: 373 Lexington Avenue, 369 New York, NY, 10017.
Section 14. Information for California Residents
Your California privacy rights
If you are a California resident, you have the following rights:
- Information. To request that we disclose the following information about our collection and use of your personal information during the past 12 months:
- the categories of personal information that we have collected about you;
- the categories of sources from which personal information is collected;
- the business or commercial purpose for collecting or selling personal information;
- the categories of third parties with whom we share your personal information;
- whether we have disclosed your personal information for a business purpose, and if so, the categories of personal information received by each category of recipient.
- Access. To request a copy of the personal information that we have collected about you during the past 12 months.
- Deletion. To request that we delete personal information about you that we have collected from you.
- Non-Discrimination. You have the right not to be discriminated against with respect to the quality or level of services we provide as a consequence of your exercise of your rights under CCPA.
- Other Rights. You can request certain information about our disclosure of personal information to third parties for their own direct marketing purposes during the preceding calendar year. This request is free and may be made once a year.
- Right of civil action. Under the CCPA, Cal. Civ. Code §1798.150, California residents have the right to bring a civil action in certain expressly provided circumstances.
- Right to correct personal information (CPRA §1798.106).
- Right to opt-out of sale or sharing of data (CCPA §1798.120, CPRA §1798.121).
To request access to or deletion of your personal information, or to exercise any other data rights under California law, please contact us using one of the following methods:
Website: https://launchdesign.avbinvest.com
Email: team@avbinvest.com
We will request that you provide information necessary to verify your identity. That information may vary based on the context and scope of your request. For example, we may require you to verify access to an email address, or provide other forms of identification appropriate to the request. We may require agents submitting a request on your behalf to provide proof of agency in order to respond to a request.
Response Timing and Format
We aim to respond to requests for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
