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Legal center · Avacom

Legal documents in plain language.

Terms and conditions, privacy policy by region (Colombia, the USA, Europe, China, Mexico and Brazil), cookies, legal notice and accessibility statement. If any clause is unclear, send your query to the legal team and we will review it.

Document status
Current versionv4.2 · April 2026
Last revision18 Apr 2026
Next revision18 Oct 2026
Official languagesES · EN · ZH · FR
Coverage7 regions
General index · 11 documents

Each policy, in its own block.

01

Terms and conditions

Rules of use for the AVACOM ecosystem: hardware, software, content and services. Applies to institutional clients and teacher users.

v4.2·10 sections·~ 18 min
02

Privacy policy

How we collect, use and protect personal data, including minors' data. A commitment not to sell data.

v4.2·9 sections·~ 14 min
03

Cookie policy

Necessary, analytics and preference cookies. How to manage consent from any browser or from your panel.

v3.1·4 sections·~ 5 min
04

Legal notice

Identity of the controller, registration data and formal obligations by jurisdiction. DPO contact information.

v2.0·5 sections·~ 4 min
05 · CO

Privacy · Colombia

Compliance with Law 1581 of 2012 and Regulatory Decree 1377 of 2013. Habeas Data, authorizations and the role of the SIC.

Law 1581·Habeas Data·SIC
06 · US

Privacy · United States

Compliance with FERPA, COPPA, CCPA, SHIELD Act and TX HB18. Specific to K-12 student data protection.

FERPA·COPPA·CCPA
07 · EU

Privacy · Europe

Compliance with GDPR (EU 2016/679) and Spain's LOPDGDD. Legal bases, international transfers and ARSULIPO rights.

GDPR·LOPDGDD·AEPD
08 · CN

Privacy · China

Compliance with PIPL (Personal Information Protection Law), DSL and CSL. Local storage on certified servers.

PIPL·DSL·CAC
09 · MX

Privacy · Mexico

Compliance with LFPDPPP and INAI. ARCO rights and parental consent for minors' data.

LFPDPPP·INAI·ARCO
10 · BR

Privacy · Brazil

Compliance with LGPD and ANPD. Article 14: reinforced protection for children's and adolescents' data.

LGPD·ANPD·Art. 14
11

Accessibility

AVACOM's commitment to WCAG 2.2 AA. Accessibility features in whiteboards, platform and curriculum content.

v2.1·WCAG 2.2 AA
01 · Terms and conditions

The rules of the game, no surprises.

Version v4.2 In force since 18 Apr 2026 Replaces v4.1 (15 Oct 2025) Official language Spanish

01 Purpose of the contract

These terms govern the use of the AVACOM 2.0 ecosystem, which comprises: (a) Hardware: interactive whiteboards, the teacher tablet, classroom audio and AVACOM peripherals; (b) Software: the eClass Digital platform, the student app, eClass Studio and their components; (c) Content: curriculum lessons, pedagogical resources and media libraries; (d) Services: implementation, training, technical support and pedagogical consulting.

In plain terms: if you acquire an AVACOM whiteboard, contract eClass or access curriculum content, these terms apply. They do not apply to third-party products that we sell as explicit resale.

02 Definitions

  • "Institution": educational entity that contracts AVACOM (school, university, education authority, NGO, ministry).
  • "Teacher user": a person registered as a teacher at the contracting institution.
  • "Student user": a person registered as a student; if a minor, their data is governed by the privacy safeguards described below.
  • "Ecosystem": the combination of hardware + software + content + services.
  • "AVACOM office": the responsible regional office: Colombia (Bogotá), USA (New York), Europe (Barcelona), Asia (Shenzhen), Africa (Accra).

03 Acceptance and modifications

By signing the purchase order, activating the hardware or creating an account on eClass Digital, the institution accepts these terms. Modifications are notified with 30 days' notice by email to the registered contact and appear in this same document with a new version number. Substantial changes require express confirmation.

04 Software license

AVACOM grants the institution a non-exclusive, non-transferable and revocable license to use eClass Digital and other software during the contracted period. The license is tied to the agreed number of classrooms, teachers and students.

The software is delivered with the following commitments:

  • Security updates guaranteed for at least 5 years from the sale date of the associated hardware.
  • Guaranteed offline operation with no mandatory telemetry.
  • Twelve months' notice if an LTS version is discontinued.

05 Support and SLA

SLA by criticality level: Critical < 4h · High < 24h · Normal < 72h. If AVACOM fails to meet the agreed SLA in a month, that month is not billed. Full details on the Support page.

06 Intellectual property

Original hardware, firmware, software and content are the property of AVACOM. The institution retains ownership of:

  • Lessons that the institution's teachers create in eClass Studio.
  • Its own curriculum material incorporated into the system.
  • Anonymized usage data generated by its educational community.

The trademarks AVACOM, eClass Digital and the associated logos are registered trademarks. Any use requires express authorization.

07 Personal data

The processing of personal data is governed by the Privacy Policy and, depending on jurisdiction, by the regional policies (CO · US · EU · CN · MX · BR). AVACOM acts as a data processor for student data and as a controller for administrative and platform-usage data.

08 Limitation of liability

AVACOM is liable for direct damages up to the amount paid by the institution in the last 12 months. Loss of profit, moral damage and indirect damages are excluded, except in cases of willful misconduct or gross negligence. Liability for personal injury or for breach of personal-data obligations is not limited.

09 Termination

Either party may terminate the contract with 90 days' notice. On termination, the institution receives its data in an exportable format (standard CSV/JSON) and AVACOM deletes copies in its systems within 30 days.

10 Applicable law and jurisdiction

The contract is governed by the law of the country of the AVACOM office that signs the order (CO, US, ES, CN or GH). In the event of a dispute, first mediation at the competent chamber of commerce; if there is no agreement within 90 days, ordinary jurisdiction applies. The institution retains its rights as a consumer where applicable.

Legal contact: [email protected] · Formal notices to the AVACOM Legal Department.
02 · Privacy policy

Your data, especially a minor's, are not a product.

AVACOM does not sell user data to third parties. Minors' data is never shared for advertising purposes under any circumstances. Verifiable compliance under Colombia's Habeas Data, COPPA (USA) and GDPR (Europe).

Version v4.2 In force since 18 Apr 2026 Applicable globally · see regional ones below

01 What data we collect

We only collect what is needed for the ecosystem to work:

  • Identification: name, institutional email, role (teacher / student / administrator), grade and institution.
  • Pedagogical use: assigned lessons, grades and learning progress. This information belongs to the institution, not to AVACOM.
  • Technical: error logs, system version, device model. Needed for support.

Beyond that scope, we do not collect: precise location outside the classroom, personal contacts, camera or microphone outside active class sessions, or browsing in other apps.

02 What we use the data for

  • Operating the ecosystem (syncing, access, assignments).
  • Technical support when you open a ticket.
  • Product improvement, based on aggregated and anonymized data.
  • Fulfilling legal and contractual obligations with the institution.
Our commitment: never targeted advertising, never sale of data to third parties, never profiling of minors for commercial purposes, never scoring of students.

03 Minors' data

When the institution registers students, AVACOM processes their data as a data processor. The institution is responsible for obtaining consent from parents or guardians in accordance with its jurisdiction (Habeas Data in CO, COPPA in the US, GDPR/LOPDGDD in the EU, PIPL in CN, LFPDPPP in MX, LGPD in BR).

For students who are minors:

  • Their data is not used to improve the product, not even anonymized, without explicit consent from the institution.
  • It is shared only with the operational suppliers strictly necessary, listed in the sub-processors annex.
  • The institution can request immediate export or deletion.

04 Who we share with

Only with essential sub-processors: hosting (regional AWS), transactional email, support platform. A public, updated list at avacomworld.com/legal/subencargados. None of them may use minors' data for purposes other than providing the service.

05 How long we keep the data

  • Active teacher / administrator account: as long as the account exists.
  • Inactive account: 24 months; then anonymized.
  • Students' pedagogical data: as indicated by the institution; by default, until the end of the academic year.
  • Technical logs: 90 days.

06 How we protect the data

Encryption in transit (TLS 1.3) and at rest (AES-256). Role-based access, mandatory multi-factor authentication for AVACOM staff, annual audits. Hosting in certified regions (ISO 27001, SOC 2 Type II). Incidents are notified within the applicable legal deadline (72h GDPR, Habeas Data equivalent, etc.).

07 International transfers

By default, data is stored in the client's region: LATAM in São Paulo, USA in Virginia, EU in Frankfurt, China in Shanghai, Mexico in AWS us-east region, West Africa in the AWS Cape Town region. Transfers between regions only with a valid legal basis (standard clauses, explicit consent or adequacy decision).

08 Your rights

RightWhat it means
AccessKnow what data of yours we hold and how we use it.
RectificationCorrect inaccurate or incomplete information.
ErasureRequest deletion, except for a legal obligation to retain.
RestrictionRestrict processing while a request is being resolved.
PortabilityReceive your data in an exportable format (JSON/CSV).
ObjectionObject to non-essential processing.

To exercise your rights: write to [email protected]. We respond within a maximum of 15 business days (or the deadline required by local law, if shorter).

09 DPO contact

The Data Protection Officer (DPO) handles queries, complaints and reports regarding data:

D.M. · AVACOM Global DPO
General email: [email protected] · Barcelona, Spain
03 · Cookie policy

Three types. Only one optional.

We use our own cookies to make the site work, remember your preferences (language) and, if you choose, understand which pages are used most.

TypeWhat forOptional?
Necessary Session, access, CSRF security, selected language. No. Without these, the site does not work.
Preferences Display mode, theme, last showroom viewed. Yes, manageable from the bottom panel.
Analytics Aggregated page-view metrics. No individual profiling. Yes, disabled by default.

For analytics we use Google Analytics 4 with Consent Mode: it only sets cookies if you accept them in the banner shown on your first visit. If you reject them, the site works exactly the same and only anonymous, aggregated measurements are collected, without identifying you. We do not load advertising or social-media pixels on the AVACOM domain. You can change your decision at any time by clearing this site's data in your browser.

Technical detail: necessary cookies expire when the session ends. Your cookie decision is stored in your browser. Google Analytics cookies (_ga), if you accept them, last up to 14 months; data is processed by Google LLC under its privacy terms.
05 – 10 · Privacy by region

One base policy, six legal adaptations.

Each section describes the local legal framework, the supervisory authority, the applicable rights and the regional contact channel.

Legal frameworkLaw 1581 of 2012
Regulatory DecreeDecree 1377 of 2013
Supervisory authoritySIC · Habeas Data
LanguagesSpanish

Habeas Data in Colombia

AVACOM complies with Law 1581 of 2012 and Regulatory Decree 1377 of 2013, as well as with the guidelines of the Superintendency of Industry and Commerce (SIC).

  • Authorization: the data owner or their representative authorizes the processing in writing (physical or electronic). Minors require authorization from a parent or guardian.
  • Rights: to know, update, rectify, delete and revoke authorization.
  • Complaints: [email protected] · a response within a maximum of 15 business days, extendable by 8 days for justified cause.
  • Sensitive data (health, biometrics): only requested for a specific pedagogical need and with additional authorization.
If you are not satisfied with our response, you can turn to the SIC after exhausting the internal complaint: www.sic.gov.co
Federal frameworkCOPPA · FERPA
State frameworksCCPA · SHIELD Act · TX HB18
AuthorityFederal Trade Commission
LanguageEnglish

K-12 student data protection, United States

AVACOM is committed to FERPA-aligned handling of student educational records and COPPA-compliant data practices for students under 13.

  • We do not advertise to students. We do not build behavioral profiles for marketing.
  • We honor verifiable parental consent collected by the institution.
  • We support the Student Privacy Pledge 2026 framework and have signed.
  • State-level requests (e.g., California CCPA) are handled with a 45-day SLA.
Privacy requests: [email protected] · AVACOM USA Inc.
Legal frameworkGDPR (EU) 2016/679
National lawLOPDGDD 3/2018
AuthorityAEPD · CNIL and equivalents
DPOBarcelona

GDPR · European compliance

AVACOM Europa SL, domiciled in Barcelona, acts as the data controller for commercial and administrative data, and as a processor for the institution's pedagogical data.

  • Usual legal basis: performance of the contract (art. 6.1.b) and legal obligation (art. 6.1.c).
  • Minors' data: explicit parental consent required for those under 14 (Spain); 16 in other EU countries unless a specific local rule applies.
  • ARSULIPO rights can be exercised at [email protected]; a response within 30 days.
  • Complaint to the Spanish Data Protection Agency (AEPD) or the authority of your member country.
Legal frameworkPIPL · DSL · CSL
AuthorityCAC (Cyberspace Administration of China)
Languages简体中文 · English
PIPL year2021

PIPL · Personal Information Protection Law

AVACOM Asia Ltd. operates in China in accordance with the Personal Information Protection Law (PIPL, 2021), the Data Security Law (DSL) and the Cybersecurity Law (CSL).

  • International transfers only with separate consent and an impact assessment.
  • Data of those under 14 constitutes sensitive personal information under PIPL; explicit guardian consent is required.
  • Rights: access, copy, correction, deletion, portability and the right not to be subject to automated decisions.
  • Requests: [email protected]
Legal frameworkLFPDPPP
AuthorityINAI
RightsARCO
LanguageSpanish

LFPDPPP · Data protection in Mexico

AVACOM complies with the Federal Law on the Protection of Personal Data Held by Private Parties (LFPDPPP) and the guidelines of the National Institute for Transparency, Access to Information and Personal Data Protection (INAI).

  • ARCO rights: access, rectification, cancellation and objection. The institution is the controller for student data processing.
  • Parental consent required for the processing of data of children and adolescents under the LFPDPPP.
  • Privacy notice available at the time of data collection, in accordance with Art. 16 of the law.
  • Requests: [email protected] · response within 20 days.
Legal frameworkLGPD (Law 13.709/2018)
AuthorityANPD
Children & adolescentsArt. 14
LanguagePortuguese

LGPD · General Data Protection Law

AVACOM operates in Brazil in accordance with the General Data Protection Law (LGPD, Law 13.709/2018) and the guidelines of the National Data Protection Authority (ANPD).

  • Children's and adolescents' data: processing subject to Article 14 of the LGPD, with specific and prominent consent from at least one parent or legal guardian.
  • Legal basis: performance of contract with the educational institution and compliance with a legal obligation.
  • Data subject rights: confirmation, access, correction, anonymization, portability and deletion.
  • Requests: [email protected] · response within 15 days.
11 · Accessibility

The ecosystem works for more bodies.

WCAG 2.2 AA on the platform and site. Hardware with native accessibility features.

Commitment

AVACOM commits to its digital platform, content and hardware meeting at least the WCAG 2.2 AA level. We carry out an annual external audit and report known gaps with a remediation deadline.

On the eClass Digital platform

  • Full keyboard navigation, including the lesson editor.
  • Color contrast measured against AA across all critical flows.
  • Captions on curriculum videos and downloadable transcripts.
  • Compatibility with NVDA, JAWS and VoiceOver screen readers.
  • Reduced-motion mode (prefers-reduced-motion) is respected.

On AVACOM Pro hardware

  • Adjustable whiteboard height (motorized on AVACOM Pro+).
  • High-contrast mode and zoom up to 400%.
  • HDMI and USB-C output to connect students' assistive devices.
  • Classroom audio with an optional magnetic loop for hearing aids.

Reporting barriers

If you find an accessibility barrier, write to us at [email protected]. We respond within 48 business hours and publish an estimated remediation deadline. Cases blocking a teacher or student with a disability are escalated to critical priority.

Legal queries

Contact the legal team whenever you need.

We answer requests for access, rectification or deletion within the applicable legal deadline by region. The DPO oversees compliance across the covered jurisdictions.

In force since 18 Apr 2026 · next revision 18 Oct 2026