Privacy policy

1. Introduction

1.1. This Privacy Policy (together with our Terms and Conditions set out at, together our “Terms of Use”) applies to your use of:

  2. the Avolo app;
  3. the Make it big app;
  4. any service you receive through the items listed in paragraphs 1.1.2-1.1.4, the “Services” and the apps listed at paragraphs 1.1.1 to 1.1.4, the “Avolo App”.

1.2. Our Terms of Use set out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1.3. Our Terms of Use do not apply to any third party websites, applications or software that is (i) reached through the Services or (ii) accessed from or via the Avolo App.

2. Information we may collect from you and how we use it

We only collect the data that is essential for the Services to run smoothly. Through the Services, you give us:

2.1. Information through services like Discord

2.2. Answers to surveys about Ephyna Apps

2.3. If you get in touch with us, we will also collect the email address you use and the contents of your email (including any attachments).

3. Reason for using your information

3.1. We use your data to fulfill our legal obligations and for our legitimate interests, or those of a third party. We:

  1. Use data in a way you would expect us to, for example to ensure the smooth running of the Avolo App, fix issues and improve performance.
  2. Meet our legal and moral reporting obligations. If the Services are being used for criminal purposes (including but not limited to being used to incite, encourage, instigate, facilitate or enable crime) we will work to provide the data we collect to the relevant authorities and/or law enforcement authorities.
  3. Carry out security and maintenance checks to ensure our services run smoothly.
  4. Manage Ephyna Ltd's business risk and financial affairs.

3.2. We use details about you to:

  1. Send you messages about your account and any of our services you use if you get in touch with us.
  2. Investigate and resolve complaints and other issues.

4. Disclosing your data

We may disclose your data to:

4.1. Anyone you give us permission to share your data with.

4.2. We may share your data with authorities and/or law enforcement authorities (including but not limited to the police, Interpol, a court of law or other dispute resolution bodies), particularly if the law says we need to or if we consider it is necessary.

5. International transfers

External third parties may be based outside the European Economic Area (the “EEA”). Their processing of your data will involve a transfer of data outside the EEA.

6. Data retention

Generally we will not hold your personal information for longer than 6 years after our relationship with you has ended, unless we need to hold on to it for a legal reason, or if we believe you have misused the Services or used the Services for unlawful or criminal purposes.

7. Third parties sites

Any website or service accessible to you from or via the Services have their own privacy policies. We do not accept any responsibility or liability for such policies or for any personal data that may be collected through such websites or services.

8. Data controller and contact details

We are Ephyna Ltd. and operate under the name Avolo.

If you’ve got a question or want to contact our Data Protection Office, you can email us at:

9. Changes to our terms

This Privacy Policy is reviewed regularly and was last updated in October 2022. Our Privacy Policy may change and any changes will be posted on this page. You may be required to accept the changed Privacy Policy in order to continue using any portion of the Services which may process your personal data.

10. Your legal rights

10.1. You have the right to:

  1. Request access to any of your personal data held by us.
  2. Request correction of any personal data we hold about you.
  3. Request deletion of any personal data we hold about you, although we may not always be able to do this for legal reasons.
  4. Withdraw any consent you’ve given us.

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