Privacy Policy

This Privacy Policy describes how AavionD LLC ("AavionD," "we," "us," or "our") collects, uses, and protects your personal information when you use our services or visit our website at https://aaviond.com.

AavionD LLC is a technology-first company vendored with the California Regional Center system. We leverage technology to deliver smarter, more accessible support to individuals with developmental disabilities and their families. We currently provide Independent Facilitation services, helping clients navigate the services and supports available through their Regional Center.

By using our services or contacting us, you agree to the practices described in this Privacy Policy.

Who this policy applies to: This policy applies to our clients, their families, authorized representatives, guardians, and any individual who contacts AavionD LLC for services or information.

2. Information We Collect

We collect personal information that is necessary to provide Independent Facilitation services to our clients. We collect the following categories of information:

Personal Identification Information

• Name
• Date of birth
• General location
• Phone number
• Email address
• Primary contact information

Regional Center Information

• Regional Center client ID / UCI number
• Individual Program Plan (IPP) details
• Service history and support needs

Sensitive Health Information

Disability diagnosis and related medical information necessary to provide appropriate facilitation services.

Website and Communication Information

• Information submitted through our website contact form or online intake form
• Emails and phone call records related to your services
• Documents you send to us directly

How We Collect This Information

We collect your information through the following methods:

• Directly from you or your authorized representative via our online intake form, contact form, phone calls, or email
• From documents you provide to us such as IPP records, Regional Center authorizations, and medical or diagnostic reports
• Automatically through our website when you visit or submit a form

How We Store This Information

We are a technology-first company and store your information securely using Microsoft 365, a case management system, and cloud storage. All platforms we use are protected by password access, encryption, and security protocols to keep your information safe.

3. How We Use Your Information

We collect and use your personal information only for the purposes necessary to provide Independent Facilitation services and to operate AavionD LLC. Specifically we use your information for the following purposes:

To Provide Independent Facilitation Services

We use your information to deliver Independent Facilitation services authorized by your Regional Center, support you in understanding and navigating your IPP, and help you identify and access the services and supports that meet your needs and goals.

To Communicate With You

We use your contact information to respond to your questions and requests, send you important updates about your services, and keep your authorized representatives and primary contacts informed as needed.

To Send Service Updates and Announcements

We may use your email address or phone number to send you updates about AavionD services, new technology features, or announcements that may be relevant to you as a client. You may opt out of these communications at any time by contacting us at info@aaviond.com.

To Improve Our Technology and Services

As a technology-first company we may use general, non-identifiable information to improve our platforms, tools, and service delivery. We will never use your personal or sensitive health information for this purpose.

What We Will Never Do

• We will never sell your personal information.
• We will never use your disability diagnosis or health information for marketing purposes.
• We will never share your information with anyone outside of your Regional Center and authorized service providers without your explicit consent.

4. How We Share Your Information

We take your privacy seriously. We do not sell, rent, or trade your personal information to any third party. We share your information only in the following limited circumstances and always with your written consent first.

Your Regional Center

As an Independent Facilitator vendored with the California Regional Center system, we may share relevant information with your assigned Regional Center to coordinate and support your services. This includes information necessary to fulfill our obligations under your Regional Center authorization. We will always obtain your written consent before sharing your information.

Your Authorized Representative or Guardian

If you have an authorized representative or legal guardian, we may share your information with them as part of providing your facilitation services. We will verify authorization in writing before sharing any information with a representative or guardian. AavionD is not liable for any unauthorized access resulting from misrepresentation of identity or authority by any individual claiming to be an authorized representative.

Technology and Cloud Service Providers

As a technology-first company, AavionD builds and operates its own proprietary technology to deliver lean, efficient facilitation services. Your information may be stored and processed across multiple secure cloud-based platforms including Microsoft 365 and DigitalOcean. Each platform maintains its own security protocols and privacy policies. While we take every reasonable measure to protect your data, AavionD is not liable for security incidents, breaches, or data loss that occur at the platform level outside of our direct control. We encourage you to review the privacy policies of these platforms directly.

Internal Access Controls

Currently your information is accessed only by AavionD's founder and principal facilitator. As AavionD grows its team, access to client information will be strictly limited on a need-to-know basis through role-based access controls. All team members will be required to acknowledge and comply with this privacy policy before accessing any client information.

Law Enforcement and Legal Requirements

We may be required to disclose your personal information if compelled to do so by law, court order, or valid request from a government authority. In such cases we will notify you to the extent permitted by law before disclosing your information. Compliance with a legal obligation does not constitute a violation of this privacy policy.

Our Liability Limitations

AavionD takes reasonable and appropriate measures to protect your personal information. However we cannot guarantee absolute security of information transmitted over the internet or stored in cloud-based systems. By using our services you acknowledge and accept that AavionD is not liable for unauthorized access, data breaches, or loss of information that results from circumstances beyond our reasonable control, including but not limited to third party platform failures, cyberattacks, or natural disasters.

What We Will Never Do

• We will never sell your personal information.
• We will never share your disability diagnosis, health information, or IPP details with anyone outside of your Regional Center without your explicit written consent.
• We will never share your information with advertisers, data brokers, or any party for commercial purposes.

5. Your Privacy Rights

As a California resident and client of AavionD LLC, you have the following rights regarding your personal information under the California Consumer Privacy Act (CCPA). We are committed to honoring these rights promptly and without discrimination.

The Right to Know

You have the right to know what personal information AavionD collects about you, why we collect it, how we use it, and who we share it with. You may request a full summary of the personal information we hold about you at any time.

The Right to Access

You have the right to request a copy of the personal information AavionD has collected about you. Upon receiving and verifying your request we will provide you with the specific pieces of personal information we hold about you in a clear and accessible format.

The Right to Delete

You have the right to request that AavionD delete your personal information. Upon receiving and verifying your request we will delete your information from our records and direct our cloud service providers to do the same. Please note that we may need to retain certain information in the following circumstances:

• To comply with our legal obligations as a Regional Center vendored provider
• To complete active services you have authorized us to provide
• To resolve disputes or enforce our agreements
• To comply with a court order or government request

The Right to Correct

You have the right to request that AavionD correct any inaccurate personal information we hold about you. Upon receiving and verifying your request we will use commercially reasonable efforts to correct your information across all platforms and systems where it is stored.

The Right to Opt Out

You have the right to opt out of the sharing of your personal information. To exercise this right please contact us directly. Please note that opting out of certain information sharing may limit our ability to provide Independent Facilitation services that require coordination with your Regional Center.

The Right Not to Be Discriminated Against

You have the right not to be discriminated against for exercising any of your privacy rights. AavionD will never deny services, charge different rates, or provide a different level of service based on your exercise of any right described in this section.

How to Submit a Privacy Rights Request

To exercise any of the rights described above please contact us through one of the following methods:

• Email: info@aaviond.com
• Contact form: aaviond.com/contact

Your request must include sufficient information to allow us to verify your identity and confirm that the request relates to your personal information. This protects you from unauthorized access to your data. We will respond to all verified requests within 45 days as required by California law. If we need additional time we will notify you within the initial 45 day period and may extend our response by an additional 45 days.

A Note on Authorized Representatives

If you are submitting a request on behalf of a client as their authorized representative or legal guardian, you must provide written proof of your authorization before we can process the request. This protects our clients from unauthorized access to their sensitive information.

6. Data Retention

AavionD LLC retains your personal information only for as long as necessary to provide our services, meet our legal obligations as a Regional Center vendored provider, and protect our legitimate business interests. We do not keep your information longer than necessary.

Our Standard Retention Schedule

Why We Keep Records for These Periods

We retain client service records and consent forms for 5 years to comply with California Department of Developmental Services vendor requirements and California business law. We retain invoices and billing records for 7 years to comply with IRS and California tax law requirements. These are the minimum periods required by law and we do not retain your information beyond these periods unless legally required to do so.

What Happens When the Retention Period Ends

When your retention period expires AavionD will anonymize your personal information for internal use. This means all identifying information including your name, contact details, Regional Center ID, and health information will be permanently removed. Only non-identifiable general data may be retained to help us improve our technology and services. You will never be identifiable in any anonymized data we retain.

Early Deletion Requests

If you request deletion of your personal information before your retention period ends we will honor that request to the fullest extent permitted by law. Please note that we may be required to retain certain records to comply with our Regional Center vendor obligations, active service agreements, or legal requirements as described in Section 5 of this policy. We will always inform you of any records we are legally required to retain and explain why.

Data Stored in Cloud Platforms

As a technology-first company your information is stored across multiple secure cloud platforms including Microsoft 365 and DigitalOcean. When your retention period ends we will delete your information from all platforms where it is stored. Please note that each cloud platform may have its own backup and deletion timelines. While we will initiate deletion promptly we cannot guarantee the exact timeline of deletion at the platform infrastructure level. This is consistent with industry standard practice for cloud-based businesses.

7. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the personal information AavionD LLC holds about you, we are here to help. As a technology-first company we are committed to responding to all privacy inquiries promptly and transparently.

How to Reach Us

• Email: info@aaviond.com
• Phone: 940.220.9772
• Contact form: aaviond.com/contact
• Website: aaviond.com

When to Contact Us

Please reach out to us if you would like to:

• Know what personal information AavionD holds about you
• Request a copy of your personal information
• Request correction of inaccurate information
• Request deletion of your personal information
• Opt out of data sharing
• Ask questions about this Privacy Policy
• Report a concern about how your information is being handled
• Submit a formal privacy rights request as described in Section 5

How We Will Respond

We take all privacy inquiries seriously. Upon receiving your request we will first verify your identity to protect the security of your personal information. Once verified we will respond to your request within 45 days as required by California law. If we need additional time we will notify you within the initial 45 day period and explain why an extension is necessary.

Authorized Representatives

If you are contacting us on behalf of a client as their authorized representative or legal guardian please include written proof of your authorization with your request. This protects our clients from unauthorized access to their sensitive personal information. We cannot process requests from representatives without verified authorization.

Complaints

If you are a California resident and feel that AavionD has not adequately addressed your privacy concern you have the right to contact the California Attorney General's Office. For clients served by the Regional Center system you also have the right to file a complaint with the California Department of Developmental Services pursuant to Welfare and Institutions Code Section 4704.6. You may contact the Department of Developmental Services at 916.654.1987 or visit their website for more information.

8. Regional Center Disclosure

AavionD LLC is a vendored service provider with the California Regional Center system and is subject to the requirements of the California Welfare and Institutions Code. We are committed to transparency about your rights as a Regional Center client and our obligations as a vendored provider.

Our Regional Center Relationship

AavionD LLC provides Independent Facilitation services to clients served by all Regional Centers throughout the State of California operating under the California Department of Developmental Services (DDS). As a vendored provider we are required to comply with all applicable Regional Center vendor standards, policies, and procedures including those related to the privacy and protection of your personal information.

Information We Share With Your Regional Center

As part of providing Independent Facilitation services AavionD may share relevant information with your assigned Regional Center including service notes, progress updates, and information necessary to fulfill your authorized services. We will always obtain your written consent before sharing your information and will share only the minimum information necessary to provide your services. You have the right to know what information we share with your Regional Center at any time by contacting us at info@aaviond.com.

Your Appeal and Complaint Rights Under WIC 4704.6

Pursuant to Welfare and Institutions Code Section 4704.6, individuals served by Regional Centers have certain appeal and complaint rights regarding vendored services. These rights include:

• The right to appeal a Regional Center decision regarding your services
• The right to file a complaint about a vendored service provider including AavionD LLC
• The right to request a fair hearing regarding any dispute about your services or supports
• The right to receive assistance in understanding and exercising these rights

To learn more about your appeal and complaint rights or to file a complaint please contact the California Department of Developmental Services:

• Phone: 916.654.1987
• Website: dds.ca.gov

How to File a Complaint About AavionD

If you have a concern or complaint about the services or privacy practices of AavionD LLC we encourage you to contact us first so we can work to resolve your concern directly:

• Email: info@aaviond.com
• Phone: 940.220.9772
• Contact form: aaviond.com/contact

If you are not satisfied with our response you have the right to escalate your complaint to your Regional Center or to the California Department of Developmental Services as described above. AavionD LLC will never retaliate against a client for filing a complaint or exercising their rights under WIC 4704.6.

Our Commitment to Compliance

AavionD LLC is committed to full compliance with all Regional Center vendor requirements and California Department of Developmental Services regulations. We will always prioritize the rights, dignity, and privacy of the individuals we serve. As we grow we are actively developing formal grievance and complaint procedures to ensure every client has a clear and accessible path to resolution. Updates to these procedures will be reflected in future versions of this Privacy Policy.

9. Sensitive Health Information

AavionD LLC handles sensitive personal information about individuals with developmental disabilities. We take this responsibility seriously and have implemented multiple layers of protection to safeguard your information.

How We Collect Sensitive Health Information

AavionD collects sensitive health and disability related information exclusively through questionnaires completed directly by our clients and their parents or guardians. We do not pull, request, or collect medical records, clinical files, or documents from any third party including Regional Centers, doctors, or healthcare providers. The information we receive is limited to what you or your authorized representative voluntarily provide through our questionnaires or share with us directly.

What Information Our Questionnaires Collect

Our questionnaires are designed to help us prepare for your Person Centered Planning (PCP) process. The questions focus on understanding your needs, goals, and current supports so we can effectively facilitate your planning meeting with your Regional Center.

Additionally clients and their parents or guardians may voluntarily share additional information with us through email or other communications such as Regional Center documents or service related updates. We treat any information you voluntarily share with us with the same level of care and security as our questionnaire responses.

How We Store Questionnaire Responses

Your questionnaire responses and any information you voluntarily share with us are stored securely using the following protections:

• Password protected devices for all systems that store or access client information
• Two factor authentication on all platforms used to store or access client data
• Encrypted cloud storage across Microsoft 365 and DigitalOcean platforms

Minimum Necessary Standard

AavionD accesses, uses, and shares only the minimum amount of information necessary to provide your services. We do not access or share your questionnaire responses beyond what is directly required for your Independent Facilitation services and Person Centered Planning process.

Communicating Sensitive Information

AavionD may communicate sensitive information via email or messaging when necessary to provide your services. We use Microsoft 365 (Outlook) for email communications which provides standard business level security and encryption in transit. However please be aware that no method of electronic communication is 100% secure. By providing your contact information and engaging in email or messaging communications with AavionD you acknowledge and accept this inherent limitation of electronic communication. If you prefer not to communicate sensitive information electronically please notify us at info@aaviond.com and we will make alternative arrangements.

Your Rights Regarding Sensitive Health Information

In addition to your rights under CCPA described in Section 5 you have the following specific rights regarding your sensitive health information:

• The right to know exactly what sensitive information AavionD holds about you
• The right to request that we limit how we use or share your sensitive information
• The right to request deletion of your sensitive information subject to our legal retention obligations described in Section 6
• The right to withdraw consent for us to handle your sensitive information at any time, understanding that this may affect our ability to provide services

Our Liability Limitations

While AavionD takes every reasonable measure to protect your sensitive information we cannot guarantee absolute security of information stored or transmitted through cloud based platforms. In the event of a security incident affecting your sensitive information we will notify you promptly and take immediate steps to contain and address the incident. AavionD is not liable for security breaches or data loss that occur at the platform infrastructure level of Microsoft 365 or DigitalOcean as these are governed by their own security policies and terms of service.