Availo - Privacy Policy
Last updated: 30 September 2026
1. Who we are
IE Demishev Kostiantyn Evhenovich ("Availo", "we"), code 3064805770, Naberejnaya Peremogy 136A, Dnipro, Ukraine, runs Availo, a booking and client management platform for service businesses. Contact us about privacy at info@impactful.agency.
We play two roles:
- Controller for data about our own customers, their Users, website visitors and billing, and for End Client accounts and Reviews in the Availo client app. This policy covers that data.
- Processor for the data businesses store about their End Clients in their own Account (appointments, contact details, notes). The business is the controller of that data and decides how it is used. If you are an End Client, contact the business you booked with first about its records; we will help them answer you.
2. Data we collect and why
| Data | Examples | Purpose | Legal basis |
|---|---|---|---|
| Account data | Name, business name, email, phone, password hash, role | Create and run your Account, sign-in, support | Contract |
| Billing data | Billing contact, company and tax details, Seat count, invoices, card brand, last 4 card digits and the provider's recurring-payment token (from WayForPay) | Charge subscriptions, issue invoices, prevent fraud | Contract; legal obligation (tax, accounting) |
| Client account data | Name, email, phone, language, password hash, booking history (End Clients using the Client App) | Create the End Client's account, show and manage their bookings | Contract |
| Reviews | Rating, comment, the business and service reviewed, display name, date | Publish Reviews, keep the directory trustworthy | Legitimate interests; contract |
| Usage and device data | IP address, browser, device, log-in times, pages and features used, error logs | Security, troubleshooting, improving the Service | Legitimate interests |
| Support communications | Emails, chat messages, call notes | Answer requests, keep a record | Contract; legitimate interests |
| Marketing preferences | Newsletter sign-up, email opens | Send product news | Consent (withdraw any time) |
| Website analytics and cookies | Cookie IDs, pages visited, referral source | Measure and improve the website | Consent (non-essential cookies) |
We do not sell personal data, and we do not use End Client data for our own marketing or to train models for other customers.
3. End Clients, the client app and booking pages
Booking pages. When you book through a business's Availo booking page, the business collects your name, phone, email, chosen service, time, and any notes you add. The business is the controller of this data and its own privacy notice applies. We store and process it on the business's behalf.
Client app. If you create an Availo account to find businesses and book, we are the controller of your account data, booking history and Reviews. The app is a single directory shared across all businesses on the platform. When you book, the business receives the details needed to provide the service (your name, contact details, the service and time), and from then on it is also a controller of that booking data.
Reviews. A Review you write, with your display name, is visible to other users of the Client App and to the business reviewed. If you delete your account, we remove your name from your Reviews on request; we may keep the rating and text in anonymous form, so the business's overall rating stays accurate.
Messages. We send End Clients service messages about their account and bookings, such as confirmations and reminders. We do not send our own marketing to End Clients without their consent.
Technical data. We act as controller for technical data needed to run the booking page and the app securely (for example, IP address and device data to prevent abuse).
If a business takes a deposit or payment, the payment is processed by the payment provider. We receive only the payment status, not full card details.
4. Cookies and analytics
We use three kinds of cookies and similar technologies:
| Type | What it does | Consent needed |
|---|---|---|
| Strictly necessary | Keeps you signed in, remembers security and cookie choices, balances load | No |
| Analytics | Counts visits and shows how the website and app are used (e.g. [Google Analytics / other tool]) | Yes |
| Marketing | Measures ad campaigns (e.g. [Meta Pixel / Google Ads], if used) | Yes |
Non-essential cookies are set only after you accept them in the cookie banner. You can change your choice at any time via "Cookie settings" in the website footer, or by clearing cookies in your browser. We do not place marketing cookies on businesses' booking pages.
5. Who we share data with
We share personal data only with service providers that help us run Availo, under contracts that require them to protect it and use it only on our instructions:
| Provider | Purpose | Location |
|---|---|---|
| WayForPay | Card verification and subscription payments | Ukraine / EU |
| Supabase | Database, authentication, file storage and backups | [REGION chosen for the Supabase project] |
| Vercel | Hosting of the web apps | Washington, D.C., USA (East) – iad1 |
| Resend | Transactional and account emails | Ireland (eu-west-1) |
6. International transfers
Some providers process data outside Ukraine or the EEA. Where GDPR applies, we transfer data only to countries with an EU adequacy decision (including under the EU–US Data Privacy Framework for certified US providers) or under the European Commission's Standard Contractual Clauses. For transfers from Ukraine, we rely on the consent or contractual necessity grounds and the safeguards allowed under Ukrainian law. Contact us for a copy of the safeguards used.
7. How long we keep data
| Data | Retention |
|---|---|
| Account data | While the Account is active, then deleted within 60 days of closure |
| Customer Data incl. End Client records | Exportable for 30 days after closure, deleted within 60 days after that |
| Client account data | While the account is active, then deleted within 60 days of the End Client closing it |
| Reviews | While the account is active; after deletion, anonymised rather than removed (see section 3) |
| Billing records and invoices | As required by Ukrainian tax and accounting law (at least 1,095 days) and EU rules where applicable |
| Logs and usage data | Up to 12 months |
| Support communications | Up to 24 months after the last contact |
| Marketing data | Until you unsubscribe or withdraw consent |
| Backups | Overwritten on a rolling cycle of up to [35] days |
8. Security
We protect data with encryption in transit (TLS) and at rest, role-based access, least-privilege staff access, regular backups, logging and monitoring. Each business's data is logically separated from others. No system is completely secure; if a breach is likely to put your rights at risk, we will notify you and the relevant authority as the law requires.
9. Your rights
Depending on where you live, you have the right to:
- know what data we hold and get a copy of it;
- correct inaccurate data;
- have data deleted, or processing restricted;
- receive your data in a portable format;
- object to processing based on legitimate interests or to direct marketing;
- withdraw consent at any time, without affecting earlier processing;
- complain to a supervisory authority.
These rights come from Article 8 of the Law of Ukraine "On Personal Data Protection" and Articles 15–22 GDPR.
How to ask. Email info@impactful.agency. We may need to confirm your identity. We reply within 30 days. For your Client App account and Reviews, contact us. For records a business keeps about you, contact the business first, since it controls them.
Where to complain. In Ukraine: the Ukrainian Parliament Commissioner for Human Rights (ombudsman.gov.ua). In the EU: your local data protection authority.
10. Children, changes and contact
Children. Availo is for businesses and is not aimed at children. Businesses that record data about minors (for example, a child's haircut booked by a parent) are responsible for getting any required parental consent.
Changes. We may update this policy. We will post the new version with a new date and, for material changes, notify customers by email or in-app in advance.
Contact. IE Demishev Kostiantyn Evhenovich, Naberejnaya Peremogy 136A, Dnipro, Ukraine · info@impactful.agency · +380980071171