Privacy Policy Last updated: 24/02/2024

At Avara Ledgira™ (“we,” “our,” or “us”), we take your privacy seriously and are committed to protecting your personal data with the highest standards of care.

This Privacy Policy explains how your personal information is collected, stored, and used when you interact with the Avara Ledgira platform (the “Website”), including when accessing investment tools and third-party trading services.

Our commitment is built on the following principles:

• Transparency in how your data is used:

You deserve to know exactly how and why your data is handled. Whether you’re browsing from Manila, Cebu, or elsewhere in the Philippines, we aim to present clear and timely information about how your data is processed — especially when connecting to third-party trading platforms.

Should you need more details, we’re always available at [email protected].

• Purpose-driven data processing:

We collect and use your personal data to: deliver the Website and its services to you, connect you with regulated third-party trading partners, personalize your user experience, fulfill legal duties under Philippine and international regulations, and continuously improve our platform.

We also analyze aggregated user behavior (without identifying individuals) to enhance the performance of our crypto services.

• Your rights, fully respected:

You can access, correct, delete, restrict, or transfer your personal data at any time. We are committed to responding promptly and lawfully to any such request in line with applicable privacy legislation such as the Philippines Data Privacy Act of 2012.

• Strong security measures:

While no system is entirely immune from risk, we employ robust digital safeguards, encryption technologies, and operational protocols to help ensure that your personal information remains confidential and secure.

1. Scope of This Policy

This Policy describes the types of personal data we collect, how we collect it, how it's used and shared (including with select partners), and the rights and choices you have regarding your data.

“Personal Data” means any data that identifies or can be linked to you as an individual — such as your name, email, phone number, or device data.

“Processing” refers to any operation performed on personal data, including collection, storage, access, modification, sharing, restriction, or deletion.

Avara Ledgira is not intended for children under the age of 18. If we become aware of any personal data from a minor, we will act swiftly to remove it.

2. When We Collect Your Data

We collect personal data when you:

  • Register or log in to the platform
  • Submit a contact or registration form
  • Connect to a broker or trading partner via our service
  • Use the Website, allowing us to gather device/browser data
Some data is provided directly by you; some is collected automatically or via third-party providers.

3. Your Choice to Share Data

You are not legally required to share your personal data. However, without certain information — such as your name, phone number, or email — we may be unable to create your account or provide full platform access.

4. What Data We Collect

When you use Avara Ledgira, we may collect:

  • Technical Data: IP address, device type, browser version, pages visited, language preferences, and crash/error logs.
  • Contact Data: Information such as your name, phone number, and email address, especially when submitted through forms.
  • Trading Intent: Any data you provide to facilitate account creation with a connected trading platform or broker.

5. Why We Use Your Data

At Avara Ledgira™, we process your Personal Data strictly for the purposes described below, in full compliance with applicable legal frameworks and ethical standards.

We will never process your information without a valid legal reason. Our handling of your data is grounded in one or more of the following legal bases:

  • Consent: You have given us clear permission to process your Personal Data for one or more specific purposes — for instance, when you submit your contact details to be matched with a third-party trading platform.
  • Legitimate Interest: We process data as needed to improve user experience, strengthen platform security, or ensure legal protection for Avara Ledgira™ and our partners.
  • Legal Obligation: We process data to comply with financial, regulatory, and cybersecurity laws applicable in the Philippines and internationally.

Still have questions about how your data supports our services or legal obligations? Contact us anytime at [email protected].

How and Why We Process Your Data

Purpose Legal Justification
1 Facilitating Registration with Trading Platforms
When requested, we transfer your information to third-party brokers or trading partners to enable AI-based crypto trading or portfolio setup. 		Consent
2 Responding to Inquiries and Support Requests
We use your data to reply to questions or issues regarding Avara Ledgira™ services or trading functionality. 		Legitimate Interest
3 Compliance with Legal or Regulatory Obligations
Including anti-money laundering (AML), data protection, tax, and reporting rules. 		Legal Obligation
4 Improving Platform Performance and Usability
Through analysis of system logs, crash reports, and user behavior data to enhance reliability and user satisfaction. 		Legitimate Interest
5 Preventing Fraud and Abuse
Monitoring unusual activity to detect and block potential misuse or cyberthreats. 		Legitimate Interest
6 Supporting Internal Business Operations
Includes back-office processes, financial forecasting, audits, and compliance reviews. 		Legitimate Interest
7 Data Analytics and Insights
We analyze aggregated user behavior to improve decision-making and offer optimized trading services. 		Legitimate Interest
8 Protecting Legal Rights
We may process your data to assert or defend legal claims or in response to court directives. 		Legitimate Interest

6. Sharing of Your Personal Data with Trusted Partners

Avara Ledgira™ may share your Personal Data with verified third-party vendors who support us in delivering fast, secure, and personalized services. These partners assist in areas like secure hosting, data storage, IP analytics, AI diagnostics, and performance monitoring.

If you express interest in AI-powered crypto trading, we may also transfer your provided details (such as name, phone, and email) to licensed third-party trading platforms. These platforms are independently responsible for managing your data under their own privacy policies.

Additionally, Avara Ledgira™ may cooperate with affiliated companies and strategic business partners that enhance our product ecosystem or user onboarding in the Philippines.

We may disclose your Personal Data to regulators, law enforcement, or legal entities when required to protect our operations, your rights, or in case of legal proceedings involving us or our users.

In the event of an acquisition, merger, restructuring, or investment activity involving Avara Ledgira™ or our affiliates, your Personal Data may be included as part of the business assets transferred under strict confidentiality safeguards.

7. Cookies and External Service Providers

Avara Ledgira™ may work with external services such as analytics providers or marketing platforms that use cookies and similar technologies. These tools help us offer a seamless, secure, and personalized experience — while third-party tools are subject to their own data use policies.

Cookies are small text files stored on your device when you visit our Website. These help us:

  • Recognize returning users;
  • Retain your preferences (e.g., language, location);
  • Improve performance and usability;
  • Suggest trading tools that match your behavior and interests.

Some cookies are temporary (session cookies), while others remain longer (persistent cookies). You can manage or disable cookies at any time via your browser settings.

Cookie Categories We May Use:

Cookie Type Function Notes
Essential Cookies Provide core functionality — enabling site navigation, user login, and access to secure areas. Automatically deleted when browser session ends; may store login ID, session token, or preference flags.
Preference Cookies Remember your settings such as language, device type, or trading region. Stored for a predefined duration; deleted after cookie expires or is manually cleared.
Analytics & Performance Cookies Help us monitor how visitors interact with the platform and which features need improvement. Data is anonymized; used solely for aggregate insights. Some cookies persist; others are session-based.

Blocking and Removing Cookies

You can adjust your browser settings to block and remove some or all cookies. Below are links with instructions for the most popular browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Please note that doing so may impact certain features or functions on the Login page.

ONLINE TRACKING NOTICE

AT THIS TIME, THE LOGIN PAGE DOES NOT RESPOND TO DO-NOT-TRACK REQUESTS.

8. Retention Of Personal Data About You

Avara Ledgira will retain your Personal Data as long as it is necessary to provide access to the Login page or as required by applicable law or regulations.

We may share your details with third-party trading platforms for a period of 12 months. If you give consent, this period can be extended for another 12 months.

To avoid keeping your Personal Data longer than needed, we regularly evaluate what we store and delete data when appropriate.

9. Transfers of Personal Data To A Third Country Or An International Organization

Your Personal Data might be transferred to a country outside your jurisdiction or to an international organization. In such cases, Avara Ledgira will ensure appropriate safeguards are applied to protect your data and enforce your rights.

If you reside in the European Economic Area (EEA), these safeguards include:

  • The country or organization has been deemed adequate by the EU Commission under Article 45(3) of the GDPR.
  • The transfer is covered by a legally binding agreement between public bodies under Article 46(2)(a) of the GDPR.
  • The transfer uses standard contractual clauses approved by the EU Commission under Article 46(2)(c) of the GDPR. See: EU Commission Contracts.

If you would like more details about these safeguards, contact us at: [email protected]

10. Protection Of Your Personal Data

10. Protection Of Your Personal Data

We take the implementation of appropriate technical and organizational measures seriously to ensure a high level of security for Personal Data, especially on the Login page. These measures aim to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to Personal Data that is transmitted, stored, or otherwise processed.

While we aim for the highest standards, we cannot guarantee complete error-free handling of your Personal Data. We disclaim liability for any indirect, incidental, consequential, or punitive damages related to the use or disclosure of your Personal Data, including but not limited to, unauthorized access or transmission errors beyond our reasonable control.

In some cases, legal or regulatory requirements may compel us to disclose your Personal Data to third parties, such as public authorities. In such instances, the level of protection offered by those entities may be beyond our control.

Transmission of Personal Data over the internet carries inherent risks. Therefore, Avara Ledgira cannot guarantee the full security of your Personal Data during transmission through the Login page.

11. Links to Third-Party Websites

The Login page may contain links to websites or applications managed by third parties. Avara Ledgira is not responsible for these external sites or their data collection practices. This Policy does not apply to such third-party websites or apps.

When visiting external links from the Login page, we recommend reviewing their privacy policies before submitting any Personal Data.

13. Your Rights Regarding Your Personal Data

You have the right to request confirmation of whether we process your Personal Data, to review such data, correct inaccuracies, or request deletion if it’s no longer needed. You can also limit or withdraw consent for certain processing activities.

If you are a resident of the EEA:

You have the following rights concerning your Personal Data. To exercise them, contact us at:

Right of Access

You may request confirmation from Avara Ledgira about whether we process your Personal Data and, if so, access to that data and information such as: (1) processing purposes; (2) types of Personal Data; (3) data recipients, especially outside the EEA; (4) storage duration or criteria; (5) rights to correct, erase, restrict, or object; (6) right to file a complaint; (7) data source (if not collected directly); (8) profiling existence; (9) safeguards for international transfers.

A copy of the Personal Data undergoing processing will be provided. If requested electronically, we’ll provide it in a commonly used digital format. Reasonable fees may apply for additional copies.

This right does not extend to data that would compromise others' rights or freedoms.

Right to Rectification

You may ask Avara Ledgira to correct any inaccurate Personal Data. You may also submit supplementary statements to complete incomplete data.

Right to Erasure

You can request deletion of your Personal Data if: (a) it’s no longer needed; (b) you withdraw consent; (c) you object due to your specific situation and there are no overriding reasons; (d) you object to direct marketing; (e) it was processed unlawfully; or (f) deletion is required to comply with a legal obligation under EU or Member State law.

This right does not apply where processing is needed to fulfill a legal obligation or for legal claims.

Right to Restrict Processing

You may request restriction of processing if: (a) you contest the data’s accuracy; (b) the processing is unlawful and you prefer restriction over deletion; (c) we no longer need the data but you do for legal claims; (d) processing is based on our or a third party’s legitimate interests, but you object and we’re assessing whether those interests override yours; or (e) your data is used for direct marketing, including profiling.

Right to Restrict Processing

Should the processing of your Personal Data be restricted at your request, such data, apart from storage, will only be processed with your consent or for establishing, exercising, or defending legal claims, protecting the rights of another natural or legal person, or for significant public interest reasons of the European Union or a Member State.

Right to Data Portability

You are entitled to receive your Personal Data, which you have provided to the Company, in a structured, commonly used, and machine-readable format. You may also transfer this data to another entity if processing is based on your consent or a contract and carried out by automated means.

Where technically feasible, you may request direct transmission of your Personal Data from Avara Ledgira to another organization. This right does not impact the right to erasure and must not negatively affect the rights and freedoms of others.

Right to Withdraw Consent

You can withdraw your consent for processing your Personal Data at any time. This does not affect the legality of any processing carried out before such withdrawal.

Right to Object

You may object to the processing of your Personal Data at any time on grounds relating to your specific situation, especially where processing is based on the legitimate interests of the Company or a third party, including related profiling. Upon objection, we will cease processing your data unless we can demonstrate overriding legitimate grounds or the need for legal claims.

Additionally, you have the right to object at any time to processing your data for direct marketing purposes, including profiling connected to such marketing.

Right to Lodge a Complaint with a Supervisory Authority

You are entitled to file a complaint with a supervisory authority in your Member State to protect your rights and freedoms concerning the processing of Personal Data.

Note: Your rights described above may be subject to limitations imposed by applicable European Union or Member State law.

We will respond to your requests regarding your Personal Data without undue delay and within one month. This deadline may be extended by two additional months if necessary due to complexity or number of requests. If an extension applies, we will inform you within one month and explain the reason.

Requests are generally handled free of charge. However, if a request is clearly unfounded or excessive, especially if repetitive, we may charge a reasonable fee or refuse to act.

Avara Ledgira may request additional information to verify your identity if we have reasonable doubts about the requestor’s identity.

12. Updates To This Policy

We may revise this Policy periodically. Any updates will be published on our Website. In cases of significant changes, we will attempt to notify you through effective communication methods and a notice on the Website. Unless otherwise stated, updates take effect once published.