Privacy Policy

Last Updated: December 4, 2025

This website is operated by Avala Global LP, also referred to in this Notice as “Avala Global,” "we," or "us". Avala Global is committed to protecting and respecting your privacy. This Notice describes how we will collect and use your information both from your use of this website (www.avalaglobal.com) and through any services that we may provide to you and the rights you have in relation to your information.

By using any of our services, including this website, and by providing us with any personal information, you acknowledge the use of your personal information and any other data you provide us as set out in this Notice. Please do not further browse our website or send us any personal information if you do not want that information to be used in this way.

References in this Notice to “your information” are also to personal information and any other data that you provide to us.

1. Information We Collect

Avala Global may ask for and collect from you personal information at certain points via this website and in the course of your relationship and interactions with us. Depending on the information and/or services you request, you may be asked to provide your name, email address, date of birth, Social Security number or other government identifiers, transaction history, credit history and investment experiences, employment information, bank account information, and any other information you choose to provide us.

In addition to the information you knowingly provide, Avala Global may collect the domain names and IP addresses of its website visitors, along with usage statistics (e.g., types of web browsers and operating systems used) and browsing history. For such purpose, Avala Global may combine this information with the personally identifiable and other information it collects.

2. How We Collect Your Information

We may collect information from you through various means. For example, we may collect personal information directly from you when you use this website. We also may collect your personal information from other third parties, such as our service providers, business partners, vendors, affiliates, or other non-affiliated companies or entities. We may also collect information from publicly available sources

We and our service providers may also collect data about your use of the Website through Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website that enables us to: (a) recognize your computer; (b) understand the web pages of the Site you have visited; (c) recognize repeat users; (d) facilitate the ongoing access to and use of a website; (e) allow the Sites to track usage behavior and compile aggregate data that will allow content improvements and targeted advertising; (f) enhance your user experience by delivering content and advertisements specific to your inferred interests; (g) perform searches and analytics; and (h) assist with security administrative functions.

3. How We Use Your Information – Legal Basis For Processing

At Avala Global we are committed to protecting and respecting your privacy and will only use your personal information:

  • To provide our services to you or to communicate with you in response to your requests, on the basis of the performance of our contract with you;
  • To improve our services to you, on the basis of our legitimate interest to better understand your requirements and to adapt our offering accordingly;
  • To compile anonymous statistics, for example, website usage statistics, on the basis of our legitimate interest to analyze the reach of our website;
  • To market our services, on the basis of our legitimate interest to develop our business or your consent;
  • To manage our relationship with you, on the basis of our legitimate interest to develop our business or your consent;
  • To fulfill our legal obligations or enforce our legal rights, on the basis of our obligation to comply with mandatory legal provisions, in particular relating to anti-money laundering regulations regarding knowing our clients;
  • To provide you with personalized content, on the basis of our legitimate interest to market and promote our products and services;
  • To process and respond to inquiries, on the basis of our legitimate interest to develop our relationship with you; 
  • To alert you to new features, special events, and service offerings, on the basis of our legitimate interest to develop our relationship with you or your consent;
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer or some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred;
  • As otherwise described to you when collecting your personal information, for any other purpose for which you provide consent, or as otherwise required or permitted by law; and
  • For other legitimate business purposes.

4. How And Why We May Disclose Your Information

Avala Global may disclose your personal information to another entity (i) for purposes of assisting us or outsourcing one or more of the functions described above; (ii) to confirm or update information provided by you; (iii) to inform you of events, information about our services, and other important information; or (iv) for other purposes disclosed at or before the time the information is collected. We may also share your information when legally required to do so. We may disclose your information to:

  • Service providers, vendors, and business partners that assist us in operating and developing our services, or otherwise fulfilling the purposes set forth above.
  • Affiliates related by common ownership or control that assist us with providing the services.
  • Successor(s) of our business, relating to all or part of the business, to evaluate a proposed transaction or sale, reorganization, merger, acquisition, or other change of control.
  • Law enforcement or other third parties to comply with the law or in response to a subpoena, court order, government request, or other legal process.
  • Other third parties or nonaffiliates as permitted by law or contract as described by this privacy policy, including for the purposes of providing the services or protecting our or other’s rights, property, or safety.
  • Any other sharing or disclosure with your consent.

In order to achieve said purposes, your personal information may be communicated to the relevant authorized persons within Avala Global or to other affiliates and nonaffiliates in charge of marketing, business development, client servicing, information technology, legal and compliance, depending on the processing purpose concerned.

5. Retention Of Personal Data

How long Avala Global holds personal data for will vary. The retention period will be determined by various criteria including:

  • The purpose for which Avala Global is using it - Avala Global will need to keep the data for as long as is necessary for that purpose;
  • For as long as you have provided consent; and
  • Legal obligations - laws or regulation may set a minimum period for which Avala Global has to retain personal data.

6. How We Protect Information

Avala Global is committed to protecting your personal information against loss, misuse, and alteration. Avala Global has implemented appropriate administrative, technical, and physical measures to protect your personal information. We endeavor to maintain the confidentiality of and protect your information in accordance with this Notice and all applicable laws. However, no method of transmission over the Internet nor any means of electronic or physical storage is absolutely secure. Notwithstanding the measures to provide a secure environment for users accessing this website, Avala Global cannot guarantee the confidentiality or security of the personal and other information being provided and we make no warranty whatsoever, express or implied, in that regard.

7. Advertising

We do not sell, rent, distribute or otherwise make personal information commercially available to any third party, except that we may share information with our service providers for the purposes set out in this Notice, including for marketing purposes.

8. Your Rights

Depending on applicable laws or the jurisdiction in which you reside, you may have certain privacy rights:

  • You may have the right to access or confirm the processing of the information we hold about you, including the categories of, and sources of, personal information we collect about you; the business or commercial purpose(s) for collecting, selling, or sharing your personal information; the categories of third parties to which your personal information is disclosed; and the specific pieces of personal information we have collected about you.
  • You may have the right to correct your personal information, including to ensure that your personal information that we have collected is accurate and up to date.

You may ask us to delete personal information that we have collected from you, including information that you think is no longer up to date. Please note that there may be circumstances where you ask Avala Global to delete your personal data, but we are legally entitled or required to retain it.

  • You may have the right to object to Avala Global’s processing of your sensitive personal information or request that Avala Global restrict the processing of your personal information for the purpose of the “sale” or “sharing” of your personal information or for “targeted advertising” (as these terms are defined under applicable privacy laws). When your personal information is processed on the basis of your consent, you may withdraw it at any time without affecting the lawfulness of processing based on consent before its withdrawal.
  • In some circumstances, you may have the right to receive some personal information in a structured, commonly used and machine-readable format and/or request that Avala Global transmit such data to a third party where this is technically feasible.
  • You may have the right to lodge a complaint with the relevant data protection authority if you think that any of your rights have been infringed by Avala Global. If you are in the EEA, Switzerland, or the UK, you may lodge a complaint (but before doing so, please tell us your concerns so that we can try to resolve them). You may contact the UK Information Commissioner’s Office to initiate a complaint by clicking here. The contact information for other data protection authorities in the EEA is located here.

We will not discriminate against you for exercising your privacy rights.

Certain exceptions under applicable laws may apply, which may limit our ability to fulfill your request to exercise your privacy rights. We will inform you of any such limitation, consistent with our legal obligations. You may designate an authorized agent to submit a request on your behalf to exercise these privacy rights. We may request or require additional information to verify your identity, or your authorized agent’s identity and ability to act on your behalf, in order to fulfill the request. Please note, we may deny a request if we are unable to verify your identity or if an authorized agent does not submit proof that they have been authorized by you to act on your behalf. Depending on your residence, you may have the right to appeal our decisions regarding your requests concerning your personal information. If we deny your request, we will provide you with an explanation for why we have denied the request. To appeal our decision with respect to your request, please contact us using the contact information provided in this privacy policy.

We may disclose your personal information, including financial information or information about our transactions and experience with you, to affiliates and nonaffiliates. Federal law gives consumers and customers the right to limit some but not all sharing of information. Specifically, you may limit the disclosure of information about your creditworthiness to our affiliates, and the disclosure of your personal information with affiliates and nonaffiliates for joint marketing purposes or their own marketing purposes. To exercise the right out to opt out of such sharing, please contact us using the information provided in this Privacy Policy. If you share or jointly hold an account with another person, any choices to exercise these rights will apply to anyone on the account, unless you tell us otherwise. Other laws may furnish you additional rights to limit sharing of your personal information.

For California residents: We will not share the information that we collect about you with nonaffiliated third parties except where required to provide services to you, with your consent, or where permitted by law.

For Vermont residents: We will not share the information that we collect about your creditworthiness with our affiliates, except with your consent or as permitted by law. We will not share information that we collect about you with nonaffiliated third parties, except to provide services to you, with your consent, or where permitted by law.

To exercise the above rights, you can contact Avala Global by using the details below in the “CONTACT INFORMATION” section.

9. Links to Other Websites or Services

Our website and services may contain links to third-party websites or services not operated by us. We do not control these third-party websites or services and are not responsible for any information you may provide while on such websites or services. We encourage you to read the privacy policies on those websites or services before providing your information on such websites or services.

10. Children’s Privacy

Our services are not intended for, and we do not knowingly collect personal information from, children under 18. If you are under 18, do not use or provide any personal information without express parental consent through our services. If we learn we have collected or received personal information from a child under 18, we will promptly take steps to remove that information. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us.

11. Changes To This Notice

From time to time, we may change this Notice. Unless as provided otherwise, changes to this Notice are effective as of the effective date listed above and indicates the last time this Notice was revised or materially changed.

12. How To Contact Us

If you have any questions in relation to this Notice, or if you would like to contact us to exercise your rights as stated in this Notice, you may contact us at: info@avalaglobal.com

13. Privacy Notice - California Residents

This privacy notice for California residents supplements the information contained in the privacy policies of Avala Global LP and applies solely to individuals who are residents of the State of California and who interact with or have a relationship with Avala Global. We have adopted this Privacy Notice to comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA”).

In the past 12 months, we may have collected, used, and disclosed Personal Information (as defined in the CCPA) as described by this Privacy Policy. For more information about the categories of Personal Information that we collect, please review the “Information We Collect” section above. For details regarding the sources from which we obtain Personal Information, please see the “How We Collect Your Information” section above. We collect,  use, and disclose Personal Information for the business or commercial purposes described in the “How We Use Your Information” and the “How and Why We Disclose Your Information” sections above.

Under the CCPA, California residents have certain rights regarding the Personal Information collected by businesses, including Avala Global. These rights include:

A. Right to Know About Personal Information Collected, Disclosed, or Sold

You may have the right to request what Personal Information, if any, we collect about you and the manner in which it is processed; the categories of any Personal Information we collected about you in the preceding twelve months; the categories of sources used to collect any Personal Information; the business or commercial purposes for collecting any of your Personal Information; and the categories of third parties with whom we share any of your Personal Information, each as it pertains to our activities in the preceding twelve months.

B. Right to Request Deletion of Personal Information

You may have the right to request the deletion of Personal Information that we have collected about you, subject to certain exception, as permitted by the CCPA. We retain Personal information in accordance with our information management policies and record-keeping requirements, which establish general standards and procedures regarding the retention and handling of our records. We retain Personal Information for as long as necessary to meet legal and regulatory requirements; however, retention may be extended if we are required to preserve Personal Information as required by law, such as pursuant to legally binding subpoenas, court orders or similar instruments, or in connection with litigation, investigations or other proceedings. 

C. Right to Correct Personal Information

You may have the right to correct inaccurate or incomplete Personal Information that we process about you.

D. Right to Opt-Out of Sale or Sharing

You may have the right to opt out of the sale or sharing of your Personal Information. Please note, Avala Global does not sell any Personal Information to third parties, but we may use cookies and tracking technologies on our website, which may constitute sharing of Personal Information.

E. Limit Sensitive Personal Information Processing

You may have the right to limit the disclosure of your sensitive Personal Information to third parties in some circumstances.

F. Right to Non-Discrimination

Avala Global will not discriminate against you in any way for exercising any rights conferred by the CCPA.

Submitting a Request

Under the CCPA, we are required to verify your identity when you submit a request to exercise the rights noted above, and we are not permitted to respond to your request if we cannot verify your identity and confirm that the Personal Information at issue relates to you.  Accordingly, any request should provide sufficient identifying detail that allows us to properly respond to it.  The information provided in your request may be checked against third party identity verification services.

You may designate an agent to exercise certain of the rights listed above on your behalf.  We will require any agent who makes a request on your behalf to verify his/her authority to do so, including by requesting a copy of your written authorization, and/or by contacting you directly. We will not honor any requests from agents until authorization is verified.

California Shine the Light

Individuals who are residents of California may request to prevent the disclosure of Personal Information to third parties for their direct marketing purposes. If you would like to exercise this right, please submit your request to us by contacting us.

Contact Information

If you would like to discuss or exercise any rights under the CCPA, please contact us at info@avalaglobal.com.