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1. Scope of this privacy policy

Last updated – 11/11/2018

This privacy policy (“Privacy Policy”) describes how Avetta, LLC and its worldwide affiliated group companies, whether acting as data controllers or as data processors on behalf of our customers (collectively, “Avetta”), will use the personal data collected when you visit the Avetta websites, application websites and mobile platforms that contain a link to this Privacy Policy (each, a “Service”) or provide goods or services to Avetta. A Service may supplement this Privacy Policy with additional privacy terms or with additional privacy notices in connection with certain features of that Service. For the purpose of applicable European data protection legislation, the “data controller” for your personal data is Avetta, LLC, 17671 Cowan, Suite 150, Irvine, California 92614, USA.

This Privacy Policy does not apply to websites, applications or mobile platforms that are operated by third parties, even if linked to a Service. For example, a Service also may provide access to social media features, message boards, chat, forums, blogs, profile pages and other services to which you are able to post personal data and materials. Any information that you post or disclose through these services is public. Please be careful when disclosing personal data in these public areas. We encourage you to review the privacy policies posted on third-party websites, applications and mobile platforms.

By using any of our Services, you agree that any information, including personal data, that we collect from or about you through a Service will be handled as described in this Privacy Policy. Your use of any Services, and any dispute over privacy, is subject to this Privacy Policy and any other applicable policy or terms, such as the End User Service Agreement.


2. Collection of information

Avetta may collect information, which may include personal data directly from your input, from third parties and/or automatically through a Service’s technologies. We may combine information collected from or about you from these various sources. In order to enter into our End User Service Agreement and provide the Services to you, it is necessary for you to provide the personal data requested on our relevant websites, application websites and mobile platforms. Failure to provide that personal data will result in our inability to provide the Services to you.

a. Information provided by you


The types of information that Avetta collects directly from you may include the following, as well as any other information type that we expressly request, such as by entering and submitting the information to a Service:

  • Contact information, such as your name, email address and telephone number;
  • Usernames and passwords;
  • Payment information, such as a credit or debit card number;
  • Educational and employment background information, including information required for background tests or other employment-related screenings;
  • Comments and feedback;
  • Interests and communication preferences; and
  • Any other information that you provide to Avetta through a Service.

You are free to submit personal data to us. However, your failure to provide such information may prevent us from providing a Service to you or purchasing goods or services from you.

b. Information we collect from third parties

We may also collect information about you from third parties. For example, we may also collect information about you from vendors who provide background and screening services. We may collect information about you from your employer or a company wishing to engage you as a contractor. To the extent that you provide personal data about someone other than yourself, you warrant that you are duly authorized to provide such personal data to us for the purposes described in this Privacy Policy.

c. Information collected automatically


Each Service automatically collects certain information regarding your use of that Service. Examples of information collected automatically include:

  • Internet Protocol (“IP”) address used to connect your computer to the Internet;
  • Computer, device and connection information, such as browser type and version, operating system, mobile platform and unique device identifier (“UDID”), and other technical identifiers;
  • Uniform Resource Locator (“URL”) click stream data, including date and time, and content you viewed or searched for on a Service;
  • Location information for location-aware Services to provide you with more relevant content for where you are in the world.

We may use and disclose automatically collected information for any purpose as set forth in this Privacy Policy, except where we are restricted by applicable law. If we combine any automatically collected information with personal data, the combined information will be treated by us as personal data. We may also use aggregated information for any purpose insofar as this information does not identify specific individuals and so is not personal data.


3. Cookies and other tracking technologies

The Service may also automatically collect information through the use of cookies or similar technologies, such as web beacons. Cookies are small text files that a website sends to the browser on your computer or mobile device when you first visit a web page so that the website can recognize your device the next time you visit. Most websites typically use the following:

  • “Session” cookies, which are temporary and deleted when you close your browser;
  • “Persistent” cookies, which remain until you delete them or they expire;
  • Web beacons, which are electronic images also known as single-pixel GIFs.

Avetta and its service providers use these technologies for various purposes, including: facilitating the login process; administering, customizing and improving the Service; personalizing the browsing experience; advertising, promotions and surveys; reporting and paying royalties and licence fees to third-party providers and content distributors; as well as tracking and analyzing user preferences and trends.

There are a number of ways to manage cookies. On selected Avetta websites, a cookies banner will appear on the home page to ask for your consent to set any cookies that are not required to enable you to visit the website and remember your preferences. In addition, the “help” portion of the toolbar on most browsers will tell you how to stop accepting cookies, how to be notified when you receive a new browser cookie and how to disable existing browser cookies. However, if you block cookies, you may not be able to register, log in or make full use of the Service. You can also use your mobile device’s settings to manage the available privacy options.

We may also use other tracking technologies, such as GIFs, web beacons, web bugs or pixel tags. In contrast to cookies, which are stored on your computer’s hard drive, such technologies may be embedded invisibly on web pages and in emails. We may use such technologies to, among other things, track the activities users of our Services, help us manage content and compile statistics about usage of our Services. We and our third-party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed and track whether our emails are forwarded.

We also use automated devices and applications, such as Google Analytics, to evaluate usage of Services. We use these tools to gather information about users to help us improve our Services, performance and user experiences. We may disclose information, including personal information, to certain third-party services in order to obtain such services. These analytics providers may use cookies and other technologies to perform their services and may combine the information that they collect about you on our Services with other information that they have collected on our Services. This Privacy Policy does not cover such third parties’ use of the data. To opt out of being tracked by Google Analytics across all websites, you can download the Google Analytics Opt-out browser add-on.


4. Do Not Track disclosure

Our Services do not respond to Do Not Track signals. For more information about Do Not Track signals, please click here. You may, however, disable certain tracking as discussed in the “Cookies and other tracking mechanisms” section above, such as by disabling cookies.


5. Use of your personal data and legal basis for use

We use the personal data we collect about you for the following purposes:

  • To register you as a user of a Service;
  • To review eligibility to use a Service;
  • To assist you in soliciting, bidding for or completing a transaction or order;
  • To provide and improve our Service and support;
  • To update you on relevant new services and benefits (with your specific, prior opt-in consent, where required);
  • To personalize the Services and to select content to be communicated to you or to use features on the Service, such as sharing content with a friend or colleague;
  • To contact you regarding our products or Services or other products and services from third parties (with your specific, prior opt-in consent, where required);
  • To invite you to participate in surveys, sweepstakes, competitions and similar promotions (with your specific, prior opt-in consent, where required);
  • To conduct business with our service providers;
  • For data analysis, audits, developing new products, enhancing the Services, identifying usage trends and determining the effectiveness of our promotional campaigns, or in other ways to which you have expressly agreed in a customer agreement with us;
  • To aggregate information in order to anonymize it for data analysis, audits, developing new products, enhancing the Service, identifying usage trends and determining the effectiveness of our promotional campaigns;
  • To prepare or implement reorganization or sale of assets or shares;
  • To prevent and detect security threats, fraud or other malicious activity; and
  • To comply with our legal obligations, respond to government or judicial requests for information (including in the context of private litigation), resolve disputes and enforce our agreements.

We may, on occasion, also match or combine the personal data that you provide with information that we obtain from other sources or that is already in our records, whether collected online or offline, or by predecessor or affiliated group companies, for the purposes described above.

We process your personal data on the following legal bases: for the performance of our agreement with you and/or for our legitimate interests. Our legitimate interests include operating and improving our Services and business; developing our current and new Services, features and products; improving or actualizing our Services; personalizing your experience of our Services; communicating with you; understanding user preferences; complying with legal obligations; and protecting business interests.


6. Sharing or disclosing your personal data

We may share your personal data, or the Service may permit sharing, in the following ways:

  • Subscribers: Subscribers to a Service may be able to directly share personal data with each other, or make personal data available to all other subscribers. If the Service offers a content database or subscription service (“Subscription Service”) and you access the Subscription Service through a subscription, your personal data and certain usage data gathered through the Subscription Service may be shared with your institution for the purposes of usage analysis, subscription management, and testing and remediation. If your institution is a corporation or other business entity, additional usage data, such as the types of records you viewed and the number of searches you ran, also may be shared for the purposes of cost attribution and departmental budgeting.
  • Operators: Some of our Services offer you the ability to create a profile and upload information to our database. Your profile and information may be then made available for searching, viewing over the Internet and download by our operator customers.
  • Agents, representatives, sponsors and business partners: Your personal data may be accessible to our agents, representatives, sponsors and entities for which we are acting as an agent, licensee, joint venturer or publisher.
  • Service providers: Your personal data may be accessible to our service providers and suppliers, which assist us with producing and delivering our products and services, operating our business, and marketing, promotion and communications. These providers and suppliers include, for example, editors, reviewers, credit, debit and payment card processors, payments processors, customer support, email service providers, IT service providers, banks and shipping agents.
  • Other third parties: We may share personal data with other third parties if we expressly told you about such potential disclosure in our Customer or Supplier Agreements, our Service Agreements or at the point at which you submitted the personal data to us. If you do not want us to share your personal data with these companies, you may contact us at: [email protected].
  • Compliance with law and similar obligations: We may share personal data in order to: (i) respond to or comply with any law, regulation, subpoena or court order, or government or judicial request (including in the context of private litigation); (ii) investigate and help prevent security threats, fraud or other malicious activity; (iii) enforce and protect the rights and properties of Avetta or its affiliates; or (iv) protect the rights or personal safety of our employees and third parties on or using our property. We may disclose your personal data to domestic or foreign government or public authorities in any of the countries in which we or our affiliates operate in order to respond to enquiries or requests, or as otherwise required by law or legal process. Where relevant, we may share or transfer your personal data in order to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
  • Change in corporate circumstances: If Avetta, the Service or a related asset or line of business is acquired by, transferred to or merged with another company, or otherwise reorganized, including in the unlikely event of a bankruptcy, your personal data may be disclosed to the prospective or actual purchasers, or other persons involved in the transaction.


7. Children’s privacy

We do not knowingly collect personal data from children under the age of 18 and Avetta does not target its Services to children under 18.


8. Your choices and selecting your privacy preferences

If you are a user of a Service, you can manage available communications preferences when you register with the relevant Service (including by providing your opt-in consent, where required), by updating your account preferences, or, where applicable, by using the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive. We reserve the right to notify you of changes or updates to the Service whenever necessary.



9. Access to and accuracy of your personal data – exercising your rights

You may request a copy of and correct the personal data that we hold about you. Under certain circumstances, you may have the right to object to the processing of your personal data or to have it erased. If a Service allows registered users to access their registration information and make corrections or updates, the accuracy of such information is solely the responsibility of the user. Subject to any right you may have to access, review, correct, raise an objection or block personal data, no access is given to personal data or data that may have been collected about other users.

You have the right to withdraw your consent at any time where we use your personal data on the basis of your consent.

In addition, if you are located in the EU, you may have the following additional rights as of 25 May 2018:

  • Right to data portability. You can request a machine-readable copy of personal data that you have provided to us, which can be transmitted to another service provider where technically feasible. This only applies to personal data that we use by automatic means, and on the basis of your consent or our performance of a contract with you.
  • Right to restriction of processing. You may ask us to restrict our use of your personal data where, for example, we no longer need your personal data for the purposes of which we are using it, but it is required by you for the establishment, exercise or defence of legal claims.
  • Right to object. To the extent that we are relying upon legitimate interest as a legal basis to use your personal data (which may include profiling), or to the extent we process your personal data for direct marketing purposes (which may include profiling), you have the right to object to such use.

You also have the right to lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that our use of your personal data infringes applicable data protection law.

To protect your privacy and security, we may take reasonable steps to verify your identity whenever you have requested to exercise your rights. To view and change the personal data that you have directly provided to us, you can return to the web page or application where you originally submitted your personal data and follow the instructions on that web page or application, or contact us at the address listed below.

For further data regarding your rights, or to exercise any of your rights, please contact us at [email protected].


10. Data retention and security

We will retain your information for as long as your account is active or as needed to provide you with a Service. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

The security of your personal data is important to us. We use a variety of data security measures intended to ensure the confidentiality and integrity of your personal data. However, unfortunately no data transmission over the Internet or data storage system is 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us at [email protected].


11. Changes to this privacy policy

If we modify this Privacy Policy to reflect changes to our information practices, we will post the revised version here, with an updated revision date. We encourage you to periodically review this page for the latest information on our privacy practices.


12. Cross-border transfer of data

For the purposes described in Section 5 above, your personal data may be transferred to recipients mentioned in Section 6 above, who are located in other countries, that may have personal data protection rules that are less protective than the rules in your country.

For users of a Service, you acknowledge that Service subscribers may be located in one of more than 110 countries in the world, most of which do not benefit from a decision of the European Commission finding that their laws adequately protect personal data. By accepting this Privacy Policy and using the Service, you consent to the transfer of personal data to countries outside your country of residence consistent with the terms of this Privacy Policy. You consent to the transfer of personal data to countries that do not benefit from a decision of the European Commission finding that their laws adequately protect personal data.

For transfers of personal data from the EU or Switzerland to the United States, Avetta, LLC and Avetta Subsidiary Holdings, LLC have self-certified to the US Department of Commerce under the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework. Our Privacy Shield notice is available here.


13. Contacting us

If you have comments or questions about this Privacy Policy or our processing of your information, please contact:

Attention: Privacy Officer
17671 Cowan, Suite 150
Irvine, California 92614, USA
Telephone: 1 949-936-4500
[email protected]

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