Privacy Policy

Effective Date: January 31, 2025

This Privacy Policy describes how Sparrow Ventures LLC (trade name: Avora) collects, uses, discloses, and protects your personal information when you visit or make a purchase from our website.

By using our Site, you consent to the data practices described in this policy.

1. INFORMATION WE COLLECT

We collect information that you provide directly and information collected automatically when you use our Site.

1.1 Information You Provide

When you place an order, create an account, or contact us, we collect:

Contact Information:

  • Full name
  • Email address
  • Phone number

Billing and Shipping Information:

  • Billing address
  • Shipping address
  • Zip code
  • We may also collect VAT information for UK orders where required.

Payment Information:

  • Payment method details (processed securely by our payment processors — we do not store full credit card numbers)

Order Information:

  • Products purchased
  • Order history
  • Transaction details

Communications:

  • Messages sent via email, contact forms, or customer support
  • Feedback, reviews, and survey responses

1.2 Information Collected Automatically

When you visit our Site, we automatically collect:

Technical Information:

  • IP address
  • Browser type and version
  • Device type and operating system
  • Referring website
  • Pages viewed and time spent on Site
  • Date and time of visit

Cookies and Tracking Technologies:

  • Session cookies (required for Site functionality)
  • Persistent cookies (for preferences and analytics)
  • Web beacons and pixels (for advertising and analytics)

Shopify Platform Data:

Our Site is hosted on Shopify. When you use our Site, Shopify collects:

  • Device and browser information
  • IP address and geolocation data
  • Shopping behavior and cart activity
  • Fraud detection signals
  • Site performance metrics

This data is used to operate our store, prevent fraud, improve site performance, and provide customer support.

Shopify's privacy practices are governed by their Privacy Policy: https://www.shopify.com/legal/privacy

2. HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes:

2.1 Order Fulfillment

  • Process and complete your orders
  • Send order confirmations and shipping updates
  • Handle returns, refunds, and exchanges
  • Provide customer support

2.2 Marketing and Communications

  • Send promotional emails about new products, sales, and offers (with your consent)
  • Send transactional emails (order confirmations, shipping notifications, account updates)
  • Conduct surveys and request feedback
  • Personalize your experience on our Site

You can opt out of marketing emails at any time by clicking "Unsubscribe" in any email or contacting us at contact@avora-store.com.

2.3 Site Improvement and Analytics

  • Analyze Site traffic and user behavior
  • Improve Site functionality and user experience
  • Develop new products and features
  • Conduct market research

2.4 Fraud Prevention and Security

  • Detect and prevent fraudulent transactions
  • Protect against unauthorized access
  • Enforce our Terms of Service
  • Comply with legal obligations

2.5 Legal Compliance

  • Respond to legal requests and prevent harm
  • Comply with applicable laws and regulations
  • Maintain business records for tax and accounting purposes

2.6 Legal Basis for Processing (UK & EEA Residents)

If you are located in the United Kingdom or European Economic Area, we process your personal data under the following legal bases:

• Contractual Necessity — To process and fulfill your orders  
• Legitimate Interests — To improve our services, prevent fraud, and secure our Site  
• Legal Obligations — To comply with applicable laws and regulations  
• Consent — For marketing communications and advertising cookies  

You may withdraw consent at any time by contacting us or unsubscribing from marketing emails.

3. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information to third parties. We share your information only as described below:

3.1 Service Providers

We share your information with trusted third-party service providers who assist us in operating our business:

E-commerce Platform:

Payment Processors:

  • Shopify Payments (powered by Stripe — payment processing, fraud detection)
  • PayPal (payment processing)

When you complete a purchase, payment information is processed securely by Shopify Payments or PayPal. We do not store full credit card numbers on our servers. Payment data is encrypted and handled according to PCI DSS standards.

Shipping and Fulfillment:

  • USPS, UPS, FedEx, or other carriers (to deliver your order)
  • Third-party fulfillment centers (if applicable)

Email Marketing:

  • Klaviyo, Mailchimp, or similar platforms (to send marketing and transactional emails)

Analytics and Advertising:

  • Google Analytics (site traffic analysis)
  • Meta Pixel (Facebook/Instagram advertising and retargeting)
  • Google Ads (advertising and retargeting)
  • TikTok Pixel (advertising and retargeting, if applicable)

Customer Support:

  • Zendesk, Gorgias, or similar platforms (to manage support tickets and live chat)

These service providers are contractually obligated to protect your information and use it only for the purposes we specify.

3.2 Business Transfers

If we sell, merge, or transfer any part of our business, your information may be transferred to the new owner as part of that transaction. You will be notified via email or prominent notice on our Site.

3.3 Legal Requirements

We may disclose your information if required by law, court order, or government request, or if we believe disclosure is necessary to:

  • Comply with legal obligations
  • Protect our rights, property, or safety
  • Prevent fraud or illegal activity
  • Enforce our Terms of Service

3.4 With Your Consent

We may share your information with third parties when you explicitly consent to such sharing.

4. COOKIES AND TRACKING TECHNOLOGIES

4.1 What Are Cookies?

Cookies are small text files placed on your device by websites you visit. They are widely used to make websites work efficiently and provide information to site owners.

4.2 Types of Cookies We Use

Essential Cookies:

  • Required for Site functionality (shopping cart, checkout, login)
  • Cannot be disabled without affecting Site performance

Analytics Cookies:

  • Google Analytics (tracks Site usage, traffic sources, user behavior)
  • Helps us improve Site performance and user experience

Advertising Cookies:

  • Meta Pixel (Facebook/Instagram retargeting)
  • Google Ads (retargeting and conversion tracking)
  • TikTok Pixel (retargeting, if applicable)

Preference Cookies:

  • Remember your settings (language, currency, preferences)

4.3 How to Control Cookies

Browser Settings: You can configure your browser to refuse cookies or alert you when cookies are being sent. However, disabling cookies may limit your ability to use certain Site features.

Opt-Out Links:

Do Not Track: We do not currently respond to Do Not Track (DNT) signals. However, you can control tracking through the opt-out methods above.

For visitors located in the United Kingdom and EEA, we display a cookie consent banner that allows you to accept or manage non-essential cookies in compliance with applicable data protection laws.

5. YOUR PRIVACY RIGHTS

Depending on your location, you may have certain rights regarding your personal information.

5.1 California Residents (CCPA/CPRA)

If you are a California resident, you have the right to:

Right to Know: Request disclosure of the categories and specific pieces of personal information we have collected about you in the past 12 months.

Right to Delete: Request deletion of your personal information, subject to certain exceptions (e.g., legal obligations, fraud prevention).

Right to Opt-Out: Request that we do not share your personal information with third parties for their marketing purposes.

Right to Correct: Request correction of inaccurate personal information.

Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

How to Exercise Your Rights:

Email us at: contact@avora-store.com Subject line: "CCPA Request" Include: Your name, email address, order number (if applicable), and specific request.

We will respond to your request within 45 days. We may require additional information to verify your identity before processing your request.

5.2 Other U.S. State Residents

Residents of Virginia, Colorado, Connecticut, and Utah have similar rights under their respective state privacy laws. Contact us using the method above to exercise these rights.

5.3 United Kingdom & European Economic Area (GDPR)

If you are located in the United Kingdom (UK) or European Economic Area (EEA), you have certain rights under applicable data protection laws, including the UK GDPR and EU GDPR.

These rights include:

• Right of Access — Request access to the personal data we hold about you  
• Right to Rectification — Request correction of inaccurate or incomplete data  
• Right to Erasure — Request deletion of your personal data  
• Right to Restrict Processing — Request limitation of how we use your data  
• Right to Data Portability — Request transfer of your data to another provider  
• Right to Object — Object to certain types of processing (e.g., marketing)  
• Right to Withdraw Consent — Withdraw consent at any time  

To exercise your rights, contact us at: contact@avora-store.com

You also have the right to lodge a complaint with your local data protection authority:

UK Supervisory Authority:  
Information Commissioner’s Office (ICO)  
https://ico.org.uk 

If required under applicable law, we will appoint a UK or EU data protection representative.

5.4 All Users

Regardless of location, you can:

  • Update your account information by logging into your account
  • Unsubscribe from marketing emails by clicking "Unsubscribe" in any email
  • Contact us to request access, correction, or deletion of your information

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Order Information: Retained for 7 years for tax, accounting, and legal compliance purposes.

Account Information: Retained until you request deletion or close your account.

Marketing Data: Retained until you unsubscribe or request deletion.

Anonymized Data: We may retain anonymized or aggregated data indefinitely for analytics and business purposes.

7. DATA SECURITY

We implement industry-standard security measures to protect your personal information, including:

Technical Safeguards:

  • SSL/TLS encryption for data transmission
  • Secure servers and databases
  • PCI DSS compliance for payment processing (via Shopify Payments and PayPal)
  • Regular security audits and vulnerability assessments

Organizational Safeguards:

  • Access controls (only authorized personnel can access personal information)
  • Employee training on data protection
  • Confidentiality agreements with service providers

Limitations: No method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

8. DATA BREACH NOTIFICATION

In the event of a data breach that compromises your personal information, we will:

  1. Investigate the breach and assess its scope and impact
  2. Notify affected users via email within 72 hours of discovery (where required by law)
  3. Notify relevant authorities (e.g., California Attorney General, state regulators)
  4. Take immediate steps to mitigate harm and prevent future breaches

Notification will include:

  • Description of the breach
  • Types of information affected
  • Steps we are taking to address the breach
  • Recommendations for protecting your information

9. CHILDREN'S PRIVACY

Our Site is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18.

If you are a parent or guardian and believe your child has provided us with personal information, contact us immediately at contact@avora-store.com. We will delete such information promptly.

Compliance with COPPA (Children's Online Privacy Protection Act): We do not knowingly collect information from children under 13.

10. THIRD-PARTY LINKS

Our Site may contain links to third-party websites, including social media platforms, payment processors, and partner sites.

We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review their privacy policies before providing any personal information.

Third-party sites we may link to:

11. INTERNATIONAL DATA TRANSFERS

Your information may be transferred to and processed in the United States or other countries where our service providers operate.

By using our Site, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection laws.

For residents of the United Kingdom and European Economic Area, we rely on approved transfer mechanisms such as:

• Standard Contractual Clauses (SCCs)  
• UK International Data Transfer Agreement (IDTA)  
• Adequacy decisions where applicable  

These safeguards ensure your personal data remains protected when transferred outside your jurisdiction.

12. CALIFORNIA "SHINE THE LIGHT" LAW

California Civil Code Section 1798.83 permits California residents to request information about our disclosure of personal information to third parties for their direct marketing purposes.

We do not share personal information with third parties for their direct marketing purposes without your consent.

To request information, contact us at: contact@avora-store.com

13. NEVADA RESIDENTS

Nevada residents have the right to opt out of the sale of their personal information.

We do not sell personal information as defined under Nevada law. If you have questions, contact us at: contact@avora-store.com

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Notice of Changes:

  • We will post the updated Privacy Policy on this page with a new "Effective Date"
  • Material changes will be communicated via email or prominent notice on our Site
  • Continued use of our Site after changes constitutes acceptance of the updated Privacy Policy

Version History: We maintain a record of previous versions. Contact us to request prior versions.

15. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact us:

Sparrow Ventures LLC (d/b/a Avora)

Email: contact@avora-store.com

Mailing Address: 8206 Louisiana Boulevard Northeast, Albuquerque, New Mexico, 87113

Business Hours: Monday - Friday, 9:00 AM - 5:00 PM MST (New Mexico Time)

CCPA Requests: contact@avora-store.com (Subject: "CCPA Request")

GDPR Requests: contact@avora-store.com (Subject: "GDPR Request")

SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This section provides additional disclosures required under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Categories of Personal Information Collected (Past 12 Months)

Copy table
Category Examples Collected?
Identifiers Name, email, phone, IP address, device ID Yes
Commercial Information Order history, purchase records, payment method Yes
Internet Activity Browsing history, search history, Site interactions Yes
Geolocation Data IP-based location, shipping address Yes
Inferences Preferences, behavior patterns, purchase likelihood Yes
Sensitive Personal Information Not collected No

Sources of Personal Information

  • Directly from you (orders, account creation, contact forms)
  • Automatically through cookies and tracking technologies
  • From third parties (Shopify, payment processors, analytics providers)

Business Purposes for Collection

  • Order fulfillment and customer service
  • Marketing and advertising
  • Site improvement and analytics
  • Fraud prevention and security
  • Legal compliance

Categories of Third Parties with Whom We Share Information

  • E-commerce platform (Shopify)
  • Payment processors (Shopify Payments, PayPal)
  • Shipping carriers (USPS, UPS, FedEx, Royal Mail)
  • Email marketing providers
  • Analytics and advertising platforms (Google, Meta)

Sale or Sharing of Personal Information

We do not sell personal information for monetary consideration.

We may share personal information with advertising partners for targeted advertising purposes, which may be considered a "sale" or "sharing" under CCPA.

Categories shared for advertising:

  • Identifiers (email, IP address)
  • Internet activity (Site behavior)
  • Inferences (preferences, interests)

Opt-Out: To opt out of sharing for advertising purposes, contact us at contact@avora-store.com with subject line "Do Not Share My Information."

Retention Period

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, typically:

  • Order data: 7 years
  • Account data: Until deletion requested
  • Marketing data: Until unsubscribe

Exercising Your Rights

See Section 5.1 for instructions on exercising your CCPA rights.

We do not discriminate against users who exercise their privacy rights.