Avarole
Products
How it Works?PricingContact Us
Explore AvatarsGet StartedSign In

Products

Explore live avatars
How it Works?PricingContact Us
Get StartedExplore AvatarsSign In

Legal

Avarole Privacy Notice

This Privacy Notice explains how Qorden AI Ltd collects, uses, shares and protects personal data when you visit avarole.com or use Avarole Agent, Avarole Executive, Avarole Interactive and the Avarole APIs. It should be read with the Avarole Terms and Conditions. Avarole avatars are AI systems, not people.

On this page

  1. 1. Who we are
  2. 2. Our role: controller or processor
  3. 3. Personal data we collect
  4. 4. How we use personal data and our legal bases
  5. 5. AI processing notice
  6. 6. Camera, voice, biometrics and sensitive data
  7. 7. Who we share personal data with
  8. 8. International transfers
  9. 9. How long we keep personal data
  10. 10. How we protect personal data
  11. 11. Your rights
  12. 12. Cookies and similar technologies
  13. 13. Marketing
  14. 14. Children
  15. 15. Changes to this notice
  16. 16. Contact and complaints
  17. 17. Additional information for US residents

1. Who we are

Avarole is operated by Qorden AI Ltd, a company incorporated in the Dubai International Financial Centre (DIFC), Dubai, United Arab Emirates (DIFC commercial licence CL6291), with its registered office at Unit GA-00-SZ-L1-RT-208, Level 1, Gate Avenue South Zone, DIFC, Dubai, UAE (Qorden, we, us or our).

Qorden is registered with the DIFC Commissioner of Data Protection and has appointed a Data Protection Officer (DPO). You can contact our DPO at legal@avarole.com (subject line: Data Protection Officer) or by post at the address above.

This notice applies to:

  • visitors to avarole.com and its subdomains (the Website);
  • people who create an Avarole account, subscribe to a plan or use the Free plan;
  • authorised users of our business customers, including Avarole Executive users;
  • business contacts, prospects and people who contact us.

It does not cover how our business customers use personal data when they deploy Avarole for their own visitors, customers or staff. That use is described in each customer's own privacy notice (see section 2).

2. Our role: controller or processor

We act as controller for personal data we use for our own purposes, and as processor for personal data we handle on a business customer's instructions.

SituationQorden's roleWho to contact first
Website visits, account sign-up, billing, support, security, marketing to business contactsControllerQorden (legal@avarole.com)
Avarole Executive used by you or your organisation (connected email, CRM, files, avatar conversations)Processor for your organisation; controller for account, billing and security dataYour organisation's administrator, or Qorden for account matters
Speaking with an Avarole Agent or Avarole Interactive avatar deployed by a business on its website, app or kioskProcessor for that businessThe business that deployed the avatar
Avatars and voices we create from a person's likeness for a customerProcessor for the customerThe customer, or Qorden where you cannot reach them

When we act as processor, we process personal data only on the customer's documented instructions under a Data Processing Addendum (DPA). The customer decides why the data is collected and is responsible for giving you its own privacy notice and AI notice. If you contact us about a customer deployment, we will pass your request to that customer and support them in responding.

3. Personal data we collect

We collect the personal data you give us, data generated when you use Avarole, and limited data from third parties. We do not ask for more than we need for the purposes in section 4.

CategoryExamplesWhere it comes from
Account and identityName, business email, job title, company, password (stored hashed), role and permissionsYou or your organisation's administrator
Billing and subscriptionPlan, billing address, VAT number, invoices, payment status, last four digits and expiry of your cardYou and our payment service provider (we do not store full card numbers)
Conversation contentVoice audio, video of you where a camera feature is used, transcripts, detected language, translations, prompts and avatar responsesYou, when you speak with an avatar
Customer contentKnowledge base files, website content, uploaded documents, avatar images, voice samples and custom avatar or voice assetsYou or your organisation
Executive connected dataEmails, CRM records, calendar entries, files and contacts, limited to the permissions you grant when connecting an accountYour connected services, at your request
Interactive captureCamera images, scanned documents and data extracted from them (for example name or document number) where the deploying organisation has enabled these featuresYou, at a kiosk or device
Lead captureName, email, phone number and enquiry details a visitor gives to a customer's avatarVisitors to our customers' deployments
Analytics and usageMinutes used, session counts, conversation insights and summaries, feature usage, error reportsGenerated by your use of Avarole
Technical and securityIP address, device and browser type, operating system, app version, log files, authentication eventsYour device and our systems
Cookies and similar technologiesSession identifiers, preferences, and analytics data where you consentYour browser (see section 12)
Communications and marketingSupport tickets, emails, sales enquiries, event registrations, marketing preferencesYou, and business contact sources where permitted

You do not have to give us personal data, but without account, billing or conversation data we cannot provide the Services.

4. How we use personal data and our legal bases

We use personal data only for the purposes below, under the DIFC Data Protection Law (DIFC Law No. 5 of 2020) and, where they apply, the EU or UK General Data Protection Regulation and other applicable laws.

PurposeData usedLegal basis
Create and manage your account, provide the plan you chose, run avatar conversations, translation and text-to-speechAccount, conversation content, customer content, Executive connected data, usagePerformance of our contract with you, or with your organisation
Bill you, collect payment, apply taxes and keep financial recordsBilling and subscription, accountPerformance of contract; compliance with legal obligations
Provide conversation analytics and summaries to the account ownerConversation content, analyticsPerformance of contract
Provide support and respond to enquiriesAccount, communications, relevant conversation or technical dataPerformance of contract; legitimate interests in helping you
Keep Avarole secure, detect fraud and abuse, enforce our Terms, prevent misuse of AI (including deepfakes and prohibited uses)Technical and security, usage, conversation content where needed for an investigationLegitimate interests in security and safe AI; compliance with legal obligations
Monitor, test and improve service quality and AI safety, including reviewing reported harmful or inaccurate outputsUsage, analytics, and conversation content only where reported or needed to fix a faultLegitimate interests; never to train generalised AI models (see section 5)
Create a custom avatar or cloned voice of a real personImages, video and voice samples of that personExplicit consent of that person, collected by the customer and evidenced to us
Enable camera, document scanning or any biometric feature at a kiosk or deviceInteractive captureThe deploying organisation's legal basis, and explicit consent where the law requires it
Send product updates and B2B marketingBusiness contact details, marketing preferencesLegitimate interests (business contacts) or consent where required; you can opt out at any time
Website analytics and non-essential cookiesCookies, technical dataConsent
Comply with law, respond to lawful requests from authorities, establish or defend legal claimsAny relevant dataCompliance with legal obligations; legitimate interests

Where we rely on legitimate interests, we have balanced our interests against your rights. You can ask us for details and you can object (see section 11). Where we rely on consent, you can withdraw it at any time without affecting earlier processing.

5. AI processing notice

Avarole uses AI systems that process your personal data automatically, without a person starting or directing each step. This section is our notice under Regulation 10 of the DIFC Data Protection Regulations and our transparency statement under Article 50 of the EU AI Act. It is shown, or linked, when you first use Avarole.

Human-defined purposes only. Avarole processes personal data only for the purposes set by people at Qorden and by the customer who configures a deployment, as listed in section 4. Avarole cannot define new purposes for itself. Where an avatar adapts its replies during a conversation, it stays within the customer's instructions, knowledge base and scope limits, and our built-in safeguards.

What the AI systems do and what they produce.

AI functionProviderWhat it outputsHow the output is used
Avatar video generation and renderingQorden's own managed avatar modelAI-generated avatar video synchronised to speechShown to you during the conversation
Conversation responsesQorden's AI services, using the customer's knowledge baseSpoken answers, information, drafts and suggested actionsShown to you; actions in Executive run only with your confirmation or a separately enabled workflow
Translation and text-to-speechOpenAI APITranslated text and synthetic speech in the avatar's voiceSpoken by the avatar in your language
Conversation analyticsGroq and Anthropic (Claude) APIsSummaries, topics, insights and lead detailsShown to the account owner in their dashboard
Camera and document scanning (Avarole Interactive, where enabled)Configured per deploymentExtracted text and fieldsUsed for the deploying organisation's stated purpose

No decisions with legal effects. Avarole does not make decisions about you that have legal or similarly significant effects. Our customers must not use it for that purpose without human review. If an organisation uses Avarole output in such a decision, you can ask that organisation for human review, give your point of view and contest the outcome.

No model training on your data. We do not use your conversations, voice, images, documents, connected emails or outputs to train generalised AI models, including our own avatar model. Our AI providers receive data under commercial API terms under which, by default, it is not used to train their models.

Design principles and safeguards.

  • You are told at the start of each session that you are speaking with an AI avatar. Avatars must never claim to be human.
  • Avatar video and synthetic speech may carry labels or machine-readable markings identifying them as AI-generated.
  • Content filtering, scope limits and prompt and output controls reduce harmful or off-topic responses.
  • Human intervention is triggered where processing may be unfair, discriminatory or biased, where an authority makes a lawful request, or where a user reports a concern.
  • Emotion recognition, biometric categorisation and biometric identification are not enabled by default.
  • We maintain a register of our AI use cases, keep risk and impact assessments, and log processing for accountability.

Standards we rely on. Qorden AI Ltd holds ISO/IEC 27001:2022 (information security) and ISO/IEC 27018:2025 (protection of personal data in the cloud) certifications. We design Avarole with reference to the OECD AI Principles and the transparency requirements of the EU AI Act.

Limits on your rights. AI processing does not limit your rights under section 11. Because we do not train models on your data, erasure removes it from our systems and backups on the schedule in section 9. Copies held by AI providers for abuse monitoring expire within their limited retention period.

You can ask for a plain-language explanation of how Avarole processed your data, or report an AI concern, at legal@avarole.com (subject line: AI concern).

6. Camera, voice, biometrics and sensitive data

We use your voice and, where enabled, your camera image to run the conversation, not to identify you.

  • Microphone and camera. Avarole asks for microphone or camera access through your browser, app or device before using it. You can refuse or withdraw access in your settings at any time; some features will then stop working. Device permission is not consent from other people, so do not capture people who have not been told.
  • Biometric data. We do not use voice, face or other biometric data to identify you or to infer your emotions or characteristics. A deploying organisation may only enable biometric identification or matching after a separate assessment, with a valid legal basis, a clear notice and your explicit consent where the law requires it.
  • Custom avatars and cloned voices. We create an avatar or voice from a real person's likeness only with that person's documented, informed and revocable consent. If consent is withdrawn, we delete the related avatar and voice assets and the customer must stop using them.
  • Identity documents. Avarole Interactive can scan documents where the deploying organisation enables it. A scan does not on its own verify your identity. Only the data needed for the stated purpose is extracted.
  • Special category data. Avarole is not designed to collect health, religious, political, biometric or other special category data. Please do not share it in a conversation unless the organisation you are speaking with has asked for it for a clear purpose. If it is shared, we process it only to provide the conversation and under the customer's instructions. Avarole is not used to process protected health information under the US Health Insurance Portability and Accountability Act (HIPAA) unless we have signed a business associate agreement with the organisation concerned.

7. Who we share personal data with

We do not sell personal data, and we do not share it for cross-context behavioural advertising. We share it only with the recipients below, each under a written contract that limits use to providing services to us.

RecipientWhyData shared
OpenAITranslation and text-to-speechText to be translated or spoken, and the target language
GroqConversation analyticsTranscripts and conversation metadata
Anthropic (Claude)Conversation analyticsTranscripts and conversation metadata
Cloud hosting and infrastructure providersHosting, storage, backups and content deliveryAll data we hold, encrypted
Payment service providerTaking and refunding payments, fraud checksBilling and payment data
Email, support and communication toolsSending service emails and handling supportContact details, support content
Website analytics providers (with your consent)Measuring Website useCookie and technical data
Our business customersProviding their deployment, analytics and leadsConversation content and lead data from their own deployments
Qorden group companies, including our Ireland subsidiarySupport, sales and operationsData needed for the task
Professional advisers, auditors and insurersLegal, audit, certification and insuranceData needed for the task
Regulators, courts and law enforcementWhere required by law or to protect rights and safetyData required by the lawful request
A buyer or successorIf our business or assets are sold or restructuredData relating to the transferred business

The current list of our AI providers and sub processors, with their roles and processing locations, is published on the Website and available from legal@avarole.com. We notify business customers of material changes as set out in their DPA.

8. International transfers

Avarole is a global service, so your personal data may be processed outside the country where you live, including in the UAE, the European Economic Area and the United States, where our AI providers OpenAI, Groq and Anthropic process data.

When we transfer personal data out of the DIFC, the European Economic Area or the United Kingdom to a country without an adequacy decision, we use the safeguards the law requires. These include the DIFC Standard Contractual Clauses, the European Commission's Standard Contractual Clauses or the UK International Data Transfer Addendum, together with a transfer risk assessment and supplementary measures such as encryption. Where a business customer has agreed a specific data residency arrangement with us in writing, we follow it.

You can ask for a copy of the relevant safeguards at legal@avarole.com.

9. How long we keep personal data

We keep personal data only as long as we need it for the purposes in section 4, then delete or anonymise it. A business customer's DPA or Order Form may set different periods for its deployment.

DataRetention period
Account and billing dataUp to 7 years, as required by legal, tax and financial obligations
Conversation transcripts, translations and conversation analyticsUp to 1 year, or a shorter period set by the customer; deleted within 30 days after the subscription ends, if sooner
Conversation recordings (only where the customer has enabled recording)Up to 90 days; deleted within 30 days after the subscription ends, if sooner. Live audio and video that is not recorded is processed in real time and not stored
Customer content (knowledge base files, documents and website content)While the subscription is active; deleted after the 30-day retrieval window that follows termination
Executive connected dataAccessed on demand; cached copies deleted when you disconnect the account or close your subscription
Custom avatar and voice assetsUntil the customer deletes them, the subscription ends, or the person withdraws consent, and biometric information no later than three years after the person's last interaction (see section 17)
Usage logs and service analyticsUp to 2 years; deleted within 90 days after the subscription ends, if sooner
Security and access logsUp to 1 year, or longer while an incident or claim is investigated; otherwise deleted within 90 days after the subscription ends, if sooner
AI inference cacheUp to 30 days, deleted on a rolling basis
Copies held by AI providersUp to 30 days for abuse monitoring, or not retained where zero data retention applies
Free plan accountsClosed and deleted after 90 days without activity, after 14 days' notice by email, except data we are required by law to retain
Support tickets and correspondenceUp to 3 years after the ticket is closed
Marketing preferencesUntil you opt out; we keep a minimal suppression record, so we do not contact you again
BackupsOverwritten on a rolling cycle; deleted data leaves backups at the end of that cycle

We may keep data longer where the law requires it or to establish, exercise or defend legal claims, and only for that purpose.

10. How we protect personal data

We protect personal data with technical and organisational measures certified under ISO/IEC 27001:2022 and ISO/IEC 27018:2025.

  • Encryption of data in transit and at rest.
  • Role-based access, least privilege and multi-factor authentication for staff with access to production systems.
  • Logical separation of each customer's data.
  • Security monitoring, logging and regular vulnerability testing.
  • Security and data protection assessment of AI providers and other sub processors before use and periodically after.
  • Staff confidentiality obligations and privacy and security training.

No system is completely secure. If a personal data breach is likely to put your rights at risk, we will notify the DIFC Commissioner of Data Protection and, where required, you and affected customers without undue delay. Report a suspected security issue to security@avarole.com.

11. Your rights

You can exercise the rights below free of charge by emailing legal@avarole.com. We respond within one month, which we may extend by up to two further months for complex requests, telling you why.

  • Access: get a copy of your personal data and information about how we use it.
  • Rectification: correct inaccurate or incomplete data.
  • Erasure: ask us to delete your data where there is no good reason to keep it.
  • Restriction: ask us to limit how we use your data while a concern is resolved.
  • Portability: receive data you gave us in a structured, machine-readable format, or have it sent to another provider.
  • Objection: object to processing based on legitimate interests, and to direct marketing at any time.
  • Withdraw consent: where we rely on consent, including for cookies, cloned voices or custom avatars.
  • Automated decisions: not to be subject to a decision based solely on automated processing that has legal or similarly significant effects, and to obtain human review.
  • Explanation of AI processing: a plain-language explanation of how Avarole processed your data.

We may need to verify your identity before acting on a request. If your request concerns a business customer's deployment, we will forward it to that customer and help them respond.

Residents of other countries. You may have additional rights under local law, for example in the European Union, the United Kingdom or US states such as California. We honour those rights where they apply. We do not sell or share personal information as those terms are defined in California law, and we will not discriminate against you for exercising your rights.

12. Cookies and similar technologies

We use strictly necessary cookies to run the Website and keep you signed in. We use analytics and marketing cookies only with your consent, which you can give, refuse or change at any time through the cookie banner or settings on the Website. Our cookie notice on the Website lists the cookies we use and how long they last.

13. Marketing

We send product news and offer to business contacts where the law allows, and with consent where it is required. Every marketing email has an unsubscribe link, and you can opt out at any time by emailing legal@avarole.com. Service messages about your account, billing or security are not marketing and will still be sent.

14. Children

Avarole is a business service for people aged 18 and over. We do not knowingly collect personal data from children. If you believe a child has given us personal data, contact legal@avarole.com and we will delete it.

15. Changes to this notice

We update this notice when our processing changes. We show the date of the latest version at the top and notify account holders of material changes by email or in the product before they take effect. Earlier versions are available on request.

16. Contact and complaints

TopicContact
Privacy questions, rights requests, AI concerns and our DPOlegal@avarole.com
Security incidentssecurity@avarole.com
Account and billingsupport@avarole.com
PostData Protection Officer, Qorden AI Ltd, Unit GA-00-SZ-L1-RT-208, Level 1, Gate Avenue South Zone, DIFC, Dubai, UAE

If you are not satisfied with our response, you can complain to the DIFC Commissioner of Data Protection (through difc.com) or to the data protection authority where you live or work, including in the European Union or the United Kingdom. We would appreciate the chance to resolve your concern first.

17. Additional information for US residents

This section applies to residents of US states with consumer privacy laws, including California, Colorado, Connecticut, Texas, Utah and Virginia, and supplements the rest of this notice.

Notice at collection. In the last 12 months we have collected the categories of personal information below, from the sources and for the purposes in sections 3 and 4, and kept them for the periods in section 9.

Category (California law)ExamplesDisclosed for a business purpose toSold or shared
IdentifiersName, email, IP address, account IDService providers, AI providers, business customersNo
Customer recordsBilling address, phone number, card last four digitsPayment providerNo
Commercial informationPlan, purchase and usage historyService providersNo
Internet or network activityWebsite and app usage, logsService providers, analytics providers (with consent)No
Audio, electronic and visual informationVoice, video, camera images, transcriptsAI providers, business customersNo
Professional informationJob title, companyService providersNo
InferencesConversation insights and summariesBusiness customersNo
Sensitive personal informationAccount login credentials; identity document data and biometric information only where a customer enables those featuresService providers, business customersNo

No sale, sharing or targeted advertising. We do not sell personal information, share it for cross-context behavioural advertising, or use it for targeted advertising, and we have not done so in the last 12 months. We do not knowingly sell or share personal information of consumers under 16. We use sensitive personal information only to provide the Services, keep them secure and comply with law, and not to infer characteristics about you.

Your rights. Depending on your state, you can ask us to tell you what personal information we collect, use and disclose; give you a copy; correct it; delete it; and opt out of sale, sharing, targeted advertising and profiling for significant decisions. Because we do not sell, share or profile in those ways, no opt-out is needed, but we honour Global Privacy Control signals for non-essential cookies. We will not discriminate against you for exercising your rights.

How to make a request. Email legal@avarole.com. We verify your identity by matching information we already hold. An authorised agent can make a request for you with your signed permission. We respond within 45 days, extendable by a further 45 days where reasonably necessary.

Appeals. If we decline your request, you can appeal by replying to our decision with the subject line Privacy appeal. We respond within the time your state law requires. If you disagree with the outcome, you can contact your state attorney general.

Biometric information. This is our public policy for biometric identifiers and information, including face geometry and voiceprints, under the Illinois Biometric Information Privacy Act and similar laws in Texas, Washington and elsewhere.

  • We collect biometric information only for custom avatars, cloned voices or a biometric feature a customer has enabled, and only after the individual has given informed written consent.
  • We do not sell, lease, trade or otherwise profit from biometric information, and we disclose it only to process it on the customer's instructions, with consent, or where the law requires it.
  • We permanently destroy biometric information when the purpose for collecting it has been satisfied, or within three years of the individual's last interaction with Avarole, whichever comes first.
  • We store and protect biometric information with at least the same care as our other most sensitive data.

Conversation recording and transcription. Avarole conversations are processed, transcribed and analysed by AI in real time, including by our AI providers, as described in sections 5 and 7. You are told this before a conversation starts. If you do not agree, do not start the conversation. We process conversation content only to provide the Services to the organisation you are speaking with, and for security, abuse prevention and legal compliance. We do not use it to train AI models or for our own marketing.

Other notices. You are always told when you are interacting with an AI avatar, as required by AI disclosure laws such as those in California and Utah. Avarole is not directed at children under 13. We do not share personal information with third parties for their own direct marketing. Because there is no common standard for browser Do Not Track signals, we respond to Global Privacy Control signals instead.

Also read

Avarole Terms and ConditionsThe terms that govern avarole.com and the Avarole Services.
Avarole

The enterprise AI customer concierge & executive assistant that sees, speaks, triages email, and executes complex workflows in real time.

Global Headquarters:

Dubai, UAE

European Office:

Dublin, Ireland

Products

  • Avarole Agent
  • Avarole Executive
  • Avarole Interactive

Explore

  • Explore Avatars
  • How It Works
  • Blog
  • Contact Us
  • Developer Docs
  • SDK for Developers
  • Integrations

Terms & Policies

  • Privacy Policy
  • Terms of Service
  • Amazon Web Services
  • ISO 27001 certified - Information Security Management
  • ISO 27018 certified - Information Security
  • NVIDIA Inception Program member

© 2026 Avarole. - Powered by Qorden AI. All rights reserved.