1. Introduction
Avely ("we," "us," "our") is committed to protecting your personal data and privacy. This Privacy Policy explains how we collect, use, store, share, and protect personal information when you use the Avely platform, website, or related services (collectively, the "Services").
This Privacy Policy applies to all Users of the Platform, including buyers, sellers, and visitors.
We operate under the Israeli Privacy Protection Law, 5741-1981 (as amended) and its regulations, and we observe internationally recognized data protection principles, including those reflected in the EU General Data Protection Regulation (GDPR), where applicable to our Users.
By using the Platform, you consent to the data practices described in this Privacy Policy.
2. Data Controller
Avely operates as the data controller for personal data collected through the Platform.
Contact for privacy matters: privacy@avely.com
3. Types of Data We Collect
3.1 Account and Registration Data
When you create an account, we collect: full name, email address, password (encrypted), account type (buyer or seller), and date of account creation.
3.2 Seller-Specific Data
For sellers, we additionally collect identity verification documents (via Stripe KYC), bank account or payment account information (managed through Stripe), business information where applicable, and product listings, photographs, and descriptions.
3.3 Transaction Data
When purchases or payments occur, we collect order details (items purchased, price, date), payment information processed through Stripe, and transaction history and wallet balance data. We do not directly store full card numbers or payment credentials.
3.4 Technical and Usage Data
When you access the Platform, we automatically collect: IP address, browser type and version, device type and operating system, pages visited, referral source, session duration, navigation patterns, and cookie data.
3.5 Communications Data
If you contact us or communicate through the Platform, we collect support correspondence, in-platform messages between buyers and sellers, and feedback responses.
3.6 AI-Processing Data
When sellers upload photographs, those photographs are processed by our AI system to generate model images. We do not intentionally collect biometric data through this process.
4. How We Use Your Data
4.1 Service Provision
Creating and managing your account; processing and fulfilling transactions; enabling buyer-seller communication; generating AI model images; operating the seller wallet and payout system.
4.2 Platform Safety and Integrity
Verifying user identity; detecting and preventing fraud and abuse; enforcing our Terms of Service; investigating disputes and complaints.
4.3 Payments and Financial Compliance
Processing payments through Stripe Connect; managing wallet balances and payouts; complying with anti-money laundering obligations.
4.4 Communication
Sending transactional notifications, service announcements, and important policy updates; responding to support enquiries.
4.5 Platform Improvement
Analyzing usage patterns; testing new features; conducting internal research and analytics.
4.6 Legal and Regulatory Compliance
Complying with applicable laws; responding to lawful requests from authorities; maintaining records as required by law.
4.7 Marketing (With Consent)
We may send promotional communications where you have provided consent. You may withdraw consent at any time by unsubscribing using the link in any marketing email or updating your account preferences.
5. Legal Basis for Processing
- Contract performance — processing necessary to provide Services, fulfil transactions, and maintain your account;
- Legitimate interests — fraud prevention, platform security, analytics, and improving Services;
- Legal obligation — processing required by applicable law;
- Consent — marketing communications and non-essential cookies.
6. Data Storage and Retention
6.1 Storage Location
Your data is stored on secure cloud servers. Data may be stored in jurisdictions outside Israel, including within the EEA and the United States. Where data is transferred outside Israel, we implement appropriate safeguards to ensure an equivalent level of data protection.
6.2 Retention Periods
- Account data: Duration of account plus up to 5 years following closure;
- Transaction data: 7 years to comply with financial record-keeping requirements;
- Technical logs: Up to 12 months;
- Support communications: Up to 3 years.
After applicable retention periods, data will be securely deleted or anonymized.
7. Third-Party Services and Data Sharing
7.1 Stripe
Payments are processed through Stripe, Inc. Stripe acts as an independent data controller for payment data. By using payment features, you agree to Stripe's Privacy Policy. We share transaction and identity data with Stripe as necessary to process payments and comply with financial regulations.
7.2 AI and Technology Providers
We use third-party AI services to generate model images. Product photographs may be processed by third-party AI providers subject to appropriate data processing agreements.
7.3 Cloud Infrastructure
We use cloud infrastructure providers for server hosting and data storage. These providers process data on behalf of Avely and are bound by data processing agreements.
7.4 Legal and Regulatory Authorities
We may disclose personal data to governmental or law enforcement authorities when required by applicable law, court order, or lawful request.
7.5 Business Transfers
In the event of a merger, acquisition, or sale of Avely's assets, personal data may be transferred to the relevant successor entity. We will notify Users of any such transfer.
7.6 No Sale of Personal Data
We do not sell, rent, or trade your personal data to third parties for their independent marketing or commercial purposes.
8. Your Rights
Subject to applicable law, you have the following rights regarding your personal data:
- Right of Access — request a copy of the personal data we hold about you;
- Right to Rectification — request correction of inaccurate or incomplete data;
- Right to Erasure — request deletion where we no longer have a legal basis for retaining your data;
- Right to Restriction — request restriction of processing in certain circumstances;
- Right to Data Portability — request your data in a structured, machine-readable format;
- Right to Object — object to processing based on legitimate interests;
- Right to Withdraw Consent — withdraw consent at any time without affecting prior processing.
To exercise any of the above rights, please submit a request to: privacy@avely.com. We will respond within 30 days.
9. Cookies and Tracking Technologies
We use essential cookies (required for the Platform to function), functional cookies (remembering preferences such as language selection), analytics cookies (understanding usage), and marketing cookies (where you have consented). You may manage non-essential cookies through your browser settings or our cookie consent tool.
10. Security
We implement appropriate technical and organizational measures to protect your personal data, including encrypted storage of passwords, HTTPS encryption for all data in transit, access controls, and regular security assessments. No data transmission over the internet is completely secure, and while we take reasonable precautions, we cannot guarantee absolute security.
11. Children's Privacy
The Platform is not directed at children under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have collected data from a minor, we will delete it promptly.
12. Updates to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting an updated version on the Platform and, where appropriate, by email notification.
13. Contact
For privacy-related questions, requests, or complaints, please contact: privacy@avely.com
You also have the right to lodge a complaint with the Israeli Privacy Protection Authority (PPA) or, where applicable, the supervisory authority in your jurisdiction.