Aventiv Technologies™ is a diversified technology company that provides innovative solutions to customers in the corrections and government services sectors. Aventiv® is the parent company of Securus Technologies®, JPay®, and Securus Monitoring. This Privacy Statement explains how Aventiv Technologies, LLC (referred to herein as “Aventiv” or “we” or “us” or “our” to collectively include our family of brands, subsidiaries, and related entities when they specifically reference this Privacy Statement) collects, uses, discloses, and otherwise processes personal information (as defined below) in connection with our websites (the “Sites”) and other websites we own and operate that link to this Privacy Statement, and any other related content, platform, services, products, and functionality offered on or through our services (collectively, the “Services”).
Certain parts of this Privacy Statement, including Section 6 below, specifically apply to personal information collected, used, retained, or disclosed by Aventiv while acting in the capacity of a “data controller” or a “business”, as those terms are defined across data privacy laws throughout the United States and abroad, for the purposes and legal basis set out in further detail below. For example, when individuals access and use any one of our websites and we place cookies in their browser or when individuals create accounts within our platform/ portal and provide certain personal information (such as name and email address) that is used for authentication purposes, we act as a data controller.
Our services are provided pursuant to contracts with government agencies (our “Customers”) for professional use. In providing these services, we process personal information relating to consumers or end-users (“Customer Data”) on behalf of and at the direction of our Customers as a “data processor” or “service provider”. Section 8 of this Privacy Statement describes our role as a “data processor” or “service provider” in connection with our data processing activities. When collecting, using, and disclosing personal information for their own purposes, our Customers are responsible for making their own disclosures concerning the rights of individuals with respect to personal information and other information regarding data collection and use, in accordance with applicable law. If you are a consumer end-user of one of those parties or organizations, you should direct any privacy inquiries to the relevant party. You are also strongly encouraged to read our Biometric Policy in Section 14 below which sets forth the terms under which Aventiv collects Biometric Information (as defined below) as may be required by our Customers.
IMPORTANT: COMMUNICATIONS MADE THROUGH OUR SERVICES ARE RECORDED AND MAY BE PRESERVED, REVIEWED, MONITORED, INTERCEPTED, ACCESSED, AND DISCLOSED. IF YOU ARE INCARCERATED AND CHOOSE TO USE ANY OF THE AVENTIV SERVICES, YOU EXPRESSLY ACKNOWLEDGE AND AGREE THAT YOU DO NOT HAVE ANY EXPECTATION OF PRIVACY WITH RESPECT TO YOUR USE OF OUR SERVICES, INCLUDING WITHOUT LIMITATION, YOUR USE OF ANY COMMUNICATIONS SOLUTIONS THAT WE MAKE AVAILABLE. WHEN YOU USE OUR SERVICES, YOU CONSENT TO THE RECORDING OF YOUR COMMUNICATIONS, ACTIVITY AND DATA, AND TO YOUR COMMUNICATIONS, ACTIVITY AND DATA BEING PROVIDED TO THE FACILITY AND LAW ENFORCEMENT.
IF YOU ARE AN INCARCERATED PARTY OR ATTORNEY USING OUR SERVICES FOR LEGAL COMMUNICATIONS, DO NOT USE OUR SERVICES TO SEND WRITTEN ATTORNEY-CLIENT COMMUNICATIONS OR OTHER CONFIDENTIAL COMMUNICATIONS. YOU OR YOUR ATTORNEY SHOULD INSTEAD ASK FACILITY PERSONNEL HOW TO SCHEDULE A NON-RECORDED PHONE CALL OR VISIT.
When we use the term “personal information” in this Privacy Statement, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. The term does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual and does not apply to other information that is excluded from privacy protections under applicable law.
The personal data we collect and the manner in which we use such data depends on how you interact with us, the Services you use, and the choices you make. We collect personal information about you from different sources and in various ways when you use our Services, including information collected automatically when you interact with our Services, directly from you, or about you from other sources and third parties.
We, and providers working on our behalf, collect the following personal information you may submit to us when you access and use the Services:
We, and our third-party providers, automatically collect information you provide to us as a data controller, including information about how you access and use the Services when you visit our Services, open our emails, or otherwise engage with us. We typically collect this information through our use of tracking technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, mobile SDKs, location-identifying technologies and logging technologies (collectively, “tracking technologies”) and we may use third-party providers or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.
We, and our third-party providers, use tracking technologies to automatically collect usage and device information, such as:
The information collected automatically through these tools allows us to improve your customer and end-user experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Services, and to improve the effectiveness of our Services, offers, advertising, communications, features such as live and automated chat and customer service. We and our third-party providers may also use cookies and tracking technologies for advertising purposes.
For more information about these practices and your choices regarding cookies, please see our Cookie Notice. To opt-out of targeted advertising cookies, you may send an email to privacy@aventiv.com and instruct us not to sell or share your personal information to adjust your targeting cookie preferences. You can also use the Global Privacy Control setting in a web browser or browser extensions (as described more fully in our Cookie Notice ). Depending on where you live, we may also provide you with a website cookie banner when you first visit our Site and you can manage your preferences from that banner. Finally, see our Cookie Notice for additional options offered by the organizations our advertising partners may participate in. These choices are specific to the device or browser you are using. If you access our Services from other devices or browsers, take these actions from those devices or browsers to ensure your choices apply to the data collected when you use them.
We infer new information from other data we collect as a data controller, including using automated means to generate information about your likely preferences or other characteristics (“Inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address or your interests or preferences based on your browsing history on our Services.
When you are asked to provide personal information, you may decline, and you may use web browser or operating system controls to prevent certain types of automatic data collection. If, however, you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.
We obtain personal information from various sources in our role as both data controller or data processor, as applicable, which we may combine with personal information we collect automatically or directly from you.
We may receive the same categories of personal information which are described above from the following sources:
We may use personal information we collect to:
Where you choose to contact us, we may need additional information to fulfill the request or respond to inquiries. We may provide you with additional privacy-related information where the scope of the inquiry/request and/or personal information we require falls outside the scope of this Privacy Statement. In that case, the additional privacy notice will govern how we may process the information provided at that time.
We may disclose, share, transmit, grant access to, make available, and provide personal information with and to internal and external recipients, as follows:
As described above, we also process personal information as a data processor in accordance with our agreements with government agencies (the “Government Contracts”). Under these circumstances, our Customers, the government agencies, are the data controllers. The subject matter and details of our processing of personal data will be as described in each of our Government Contracts and as directed by our Customers. At all times, the processing of personal data will comply with applicable privacy laws.
Where Aventiv processes personal information on behalf of a Customer and receives individual requests regarding the personal information use or disclosure relating to an end user (e.g., incarcerated persons), Aventiv will work with the Customer to comply with applicable law and our obligations under the corresponding Government Contract. The foregoing includes, without limitation, data subject access requests (“DSAR”) submitted to Aventiv, which will be referred to the corresponding Customer for guidance and instructions. If requested to remove personal information, we will respond to the requesting party within a reasonable timeframe.
Any personal information processed by Aventiv in connection with or arising from a Government Contract may be disclosed by Aventiv in accordance with the terms of such agreement.
You may submit a DSAR to us by completing the form linked here.
You may control your information in the following ways:
In accordance with applicable privacy laws, you may have the following rights in respect of your personal information that we’re processing as a data controller:
NOTE: IN THE CASE OF PERSONAL INFORMATION THAT WE PROCESS ON BEHALF OF OUR CUSTOMERS IN THE CAPACITY OF A ‘DATA PROCESSOR’, YOU WILL BE REQUIRED TO SUBMIT YOUR INQUIRY OR REQUEST TO THE APPLICABLE GOVERNMENT AGENCY THAT HAS INSTRUCTED US TO PROCESS YOUR PERSONAL INFORMATION. THIS IS GENERALLY THE AGENCY AT WHICH YOU AND/OR YOUR INCARCERATED CONTACT WERE INCARCERATED OR USED OUR SERVICES TO TRANSACT WITH SOMEONE WHO WAS INCARCERATED. WE WILL NOT BE PERMITTED TO MAKE ANY CHANGES, DISCLOSURES OR DELETIONS TO ANY OF THE PERSONAL INFORMATION THAT HAS BEEN PROCESSED BY US AS A ‘DATA PROCESSOR’ UNLESS WE ARE GIVEN STRICT INSTRUCTIONS TO DO SO BY OUR CUSTOMER.
We store the personal information we collect about you for no longer than necessary for the purposes set out in this Privacy Statement, and in accordance with our legal obligations and legitimate business interests. The criteria used to determine the period for which personal data about you will be retained varies depending on the legal basis under which we process the personal data. For example:
We also consider the volume, nature, and sensitivity of your personal information, as well as any potential risk of harm from unauthorized use or disclosure of that personal information.
We may use Third Party Services (as defined below) to operate, maintain, and manage our Services and to provide services and support.
The Services have functionality that allows certain kinds of interactions with Third-Party Services (each, a “Third-Party Service”). By using a Third-Party Service, the third party provider may collect and send us personal information about you. If you use Third-Party Services, information you post or provide access to may be publicly displayed on the Services and/or by the Third-Party Service that you use, depending on your privacy settings on each. Similarly, if you post information on a Third-Party Service that references the Services (e.g., by using a hashtag associated with us in a tweet or status update), your post may be used on or in connection with the Services or otherwise by us. Also, both we and the third-party service provider may have access to certain information about you and your use of the Services and any Third-Party Service.
Third-Party Service providers may use their own cookies, web beacons, and other tracking technologies to independently, collect information about you, including Third-Party Services to which you are directed from the Services, including where you click a link and leave the Services entirely. There are certain websites and other Third-Party Services to which we may link from the Services, which are third-party websites using our name under license but with their own terms and policies (except where we have explicitly linked to this Privacy Statement).
We are not responsible for the policies or business practices of Third-Party Service providers, including how they collect, use, or share your information, including through tracking technologies that collect information regarding your visit to the Services as well as after your visit is over. These Third-Party Services may have their own terms of service, privacy policies or other policies, for which they may request your agreement. Be sure to review any available policies before submitting any Personal Information to or otherwise interacting with any Third-Party Services.
In our capacity as both data controller and data processor, we may use artificial intelligence, machine learning, automated systems, and similar technologies (“AI Technologies”) to support, operate, protect, analyze, improve, and develop our Services, including to provide customer service and technical support, verify information, maintain and secure accounts, detect and prevent fraud or misuse, monitor compliance with applicable terms and policies, troubleshoot issues, improve Service functionality, and conduct internal research and development. AI Technologies may process personal information that we collect or receive in connection with the Services, including identifiers, account and transaction information, Service usage information, communications information, audiovisual information, geolocation data, biometric data, sensitive personal information, and inferences drawn from personal information, depending on the Services you use and the context in which the information is collected.
We may use AI Technologies to help us generate, classify, summarize, search, analyze, or otherwise process information in order to provide and improve the Services, support customer and technical service interactions, enhance security and reliability, identify potentially fraudulent, abusive, unsafe, or unlawful activity, and support our contractual obligations to our customers. Where we provide Services to government agencies as a data processor, personal information and other data may be accessed, stored, monitored, searched, analyzed, disclosed, and transferred in accordance with applicable law and our contractual obligations to those entities.
As part of our enterprise recruitment process, we may use AI-enabled technologies to assist in screening, assessing, and managing candidate applications. These tools help improve efficiency and consistency but are not the sole basis for employment decisions. Human review remains a component of the decision-making process. Candidate personal data used in connection with AI-assisted processing is handled in accordance with applicable data protection laws and our privacy practices, including without limitation, obtaining affirmative consents from candidates as and when required by applicable law.
We may use vendors and other service providers that use AI Technologies to provide services on our behalf, including customer service tools, technical support tools, analytics services, security tools, hosting services, and other operational technologies. For example, if you use a chat or similar support feature, the information you provide through that feature may be recorded, processed, and shared with our vendors so that we can provide customer service and technical support, and those vendors may use automated systems that employ machine learning to process that information.
We may use de-identified, aggregated, or otherwise non-identifying information to train, test, evaluate, improve, or develop AI Technologies and other features, products, and services. We will not attempt to reidentify information that we maintain as deidentified, and we take reasonable measures designed to ensure that deidentified information cannot reasonably be associated with a consumer or household. We also contractually obligate recipients of deidentified information not to reidentify that information where required by applicable law.
We do not use AI Technologies to make decisions that produce legal or similarly significant effects concerning end users unless we provide any notice, consent, opt-out, appeal, or other rights required by applicable law. If we materially change our use of AI Technologies or begin using AI Technologies for automated decision-making or profiling that is subject to consumer rights under applicable privacy laws, we will update this Privacy Statement and provide any required notices and rights.
Where required by applicable law, we will obtain your consent before using personal information, including sensitive personal information, with AI Technologies for a purpose that is materially different from the purpose for which the information was originally collected. We do not sell or share sensitive personal information and we do not knowingly sell, share, or process for targeted advertising the personal information of consumers under the age of 16.
This section describes how Aventiv collects and uses Biometric Information (as defined below) in connection with our Identity Verification Features (as defined below). Aventiv together with our service providers collect and use various forms of Biometric Information that may be necessary to verify your identity and provide our services.
By using our services which incorporate the Identity Verification Features, you must first agree to our Terms of Use and this Privacy Statement.
As described in this Privacy Statement, Aventiv provides different products and services to government agencies. For most services, government agencies are our customers and we process personal information on their behalf as a data processor (“Government Processor”).
Identity Verification Features Overview: Many of our services incorporate identity verification features which utilize the microphone or camera or both, depending on the Service, on the device that you are using (the “Identity Verification Features”). The Biometric Information that is collected via any of the Identity Verification Features is then used by Aventiv to verify your identity and secure our services.
Secure Storage: Aventiv protects your Biometric Information using a reasonable standard of care at least as protective as the standard used for other confidential and sensitive personal information in its possession or under its control.
Retention/Destruction: Aventiv retains and will permanently destroy your Biometric Information consistent with the direction of the government agencies for which the data is collected.
For questions about this Notice, please contact us via e-mail at privacy@aventiv.com or by mail at:
Attn: Director of Compliance
Aventiv Technologies, LLC
5360 Legacy Drive
Plano, Texas 75024
We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful access, destruction, loss, alteration, or damage. Please note that emails sent over the Internet may not be secure and should not be used to communicate confidential and/or sensitive personal information to us.
When you make a payment through the Services using your credit card or debit card, we use methods designed to keep your payment card information secure that comply with Payment Card Industry Data Security Standards (“PCI DSS”).
Although we have implemented security measures and strive to protect your personal information, we cannot guarantee the security of personal information you transmit to us, particularly any information you send to us over the Internet when using email or other means of transmission.
We are based in the U.S. and the personal information we and our vendors collect via the Services is governed by U.S. federal and state laws and regulations. We reserve the right to process your personal information abroad.
If you are accessing our Services from outside of the U.S., please be aware that information collected through the Services may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may differ from those of your country of residence. Your use of the Services, or provision of any information, constitutes your acknowledgement of the transfer to and from, processing, usage, sharing, and storage of your information, including personal information, in the U.S. (and potentially other territories worldwide) as set forth in this Privacy Statement.
Our Sites and Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16 as a data controller. If an individual is under the age of 16, they should not use our Sites and Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect as a data controller has been provided by a child under the age of 16, we will promptly delete that personal information. If, however, we collect personal information by a child under the age of 16 as a data processor, we will comply with the instructions provided to us by our corresponding Customer in respect of such information.
Our Sites and Services may include links to third-party websites, plug-ins, and applications. Except where we post, link to or expressly adopt or refer to this Privacy Statement, this Privacy Statement does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
We will update this Privacy Statement from time to time in our sole discretion. When we make changes to this Privacy Statement, we will change the date at the beginning of this Privacy Statement. If we make material changes to this Privacy Statement, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.
All general questions and comments about this Privacy Statement or other privacy-related matters, may be directed by email to privacy@aventiv.com.
How to contact our Data Protection Officer (DPO) / Privacy Officer:
If you wish to make a complaint about how we have handled your personal information, please contact our Data Security Team via e-mail at privacy@aventiv.com or by mail at:
Attn: Director of Compliance
Aventiv Technologies, LLC
5360 Legacy Drive
Plano, Texas 75024
THE DISPUTE RESOLUTION AND ARBITRATION AGREEMENT, WAIVER OF RIGHT TO BRING CLASS ACTION AND REPRESENTATIVE CLAIMS, AND GOVERNING LAW AND CHOICE OF LAW/VENUE PROVISIONS SET FORTH IN OUR TERMS OF USE ARE EXPRESSLY INCORPORATED HEREIN BY REFERENCE AND EQUALLY APPLY TO ANY DISPUTES (PAST, PRESENT, OR FUTURE) ARISING UNDER OR RELATED TO THIS PRIVACY STATEMENT.
These Additional U.S. State Privacy Disclosures (“U.S. Disclosures”) supplement the information contained in our Privacy Statement by providing additional information about our personal information controller processing practices relating to individual residents of these States. For a detailed description of how we collect, use, disclose, and otherwise process personal information in connection with our services, please visit our Privacy Statement. Unless otherwise expressly stated, all terms defined in our Privacy Statement retain the same meaning in these U.S. Disclosures.
For the purposes of these U.S. Disclosures, personal information does not include publicly available information or deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
When we use the term “personal information” in these U.S. Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
California Notices and Rights
The California Consumer Privacy Act of 2018 (as amended), and its implementing regulations (“CCPA”), requires certain notices and provides specific rights to California residents, which are detailed below. This California Notice of Collection and Privacy Supplement is applicable only to California residents. If you are not a California resident these CA Notices and Rights do not apply to you.
Notice at Collection
At or before the time of collection of your personal information, you have a right to receive notice of our practices. We provide this notice through our Privacy Statement, including this CA Supplement. The notice includes the categories of personal information and sensitive personal information we may collect, the purposes for which such information is collected or used, whether such information is “sold or shared” as defined under California law and how long such information is retained.
We collect personal information from and about consumers for a variety of purposes. To learn more about the types of personal information we collect, the sources from which we collect or receive personal information, and the purposes for which we use this information, please refer to the Our Collection of Personal Information and Our Use of Personal Information sections of our Privacy Statement.
In the last 12 months, we have collected the following categories of personal information:
We collect this information from a variety of sources, including: directly from you, from your employer or organization, from our customers and other users, from our business partners and affiliates, from your browser or device when you use our Sites and Services, or from third parties that you permit to share information with us. Please see the Our Collection of Personal Information section of the Privacy Statement for more information about the sources of personal information we collect.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. However, if you specifically request disclosure beyond such 12-month period, we will process your request with respect to Personal Information we have collected during the time period you specify, provided that (a) the earliest date that your request may apply to is January 1, 2022, and (b) processing your request does not require disproportionate effort.
We disclose personal information with other parties for our business purposes. While we generally do not engage in the sale of personal information for monetary or other valuable consideration that we obtain from you via our Services, there may be limited circumstances where we disclose personal information with third parties through the Services in a way that may be considered a “sale” under the CCPA or other similar laws (e.g., for cross-context behavioral advertising purposes where no money is exchanged). As explained in the Do Not Sell or Share my Personal Information section of this CA Notice, you may opt out of such disclosures of your personal information.
The categories of third parties to whom we sell or disclose your personal information for a business purpose may include: (i) other brands and affiliates in our family of companies; (ii) our service providers and advisors; (iii) marketing and strategic partners; and (iv) analytics providers.
IN THE PREVIOUS 12 MONTHS, WE HAVE NOT SOLD ANY PERSONAL INFORMATION.
In the last 12 months, we have collected the following categories of sensitive personal information:
Account log-in or credentials in combination with any required security or access code, password, or credentials allowing access to your Aventiv account.
Aventiv uses or discloses sensitive personal information for the following purposes, where such use or disclosure is necessary and proportionate for those purposes: for performing services you have requested, operation of our website, for detecting security incidents, fraud and other illegal actions, to perform services on behalf of the business (where the sensitive information is reasonably necessary and proportionate for this purpose).
We do not use or disclose sensitive personal information to infer characteristics or for purposes that require offering the ‘Right to Limit.’ If our practices change, we will provide a ‘Limit the Use of My Sensitive Personal Information’ link.
As a resident of California as well as other states that have adopted privacy laws and regulations to which Aventiv is subject, you can exercise the following rights in relation to the personal information that we have collected about you (subject to certain limitations at law):
The Right to Know
You have the right to confirm whether we are processing personal information about you, including:
Please note that we have provided much of this information to you in this Privacy Statement.
Right to Notice
You have a right to receive notice of our personal information collection, use, retention, and disclosure practices at or before collection of personal information.
The Right to Access
Right to access the personal information collected by a business about you, in a portable and usable format.
To make a request to access your personal information, please submit requests as described in the How to Exercise Your Consumer Privacy Rights section below.
The Right to Request Deletion
You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.
The Right to Opt Out of the Sale or Sharing of Personal Information
You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future, or “share” your personal information to third parties for cross-context behavioral advertising purposes.
Please see the “Do Not Sell or Share My Personal Information” Section for more details on our personal information practices regarding the sale or sharing for cross context behavioral advertising. You can find out more about how to opt out in the section titled “How to Exercise Your Rights”.
If you are under the age of 16, you have the right to opt in, or to have a parent or guardian opt in on your behalf, to such sales.
We do not knowingly sell or share the personal information of minors under 16 years of age.
The Right to Request Correction / Rectification
You have the right to request that we correct / rectify inaccuracies in your personal information, taking into account the information's nature and processing purpose.
Right to Limit Use and Disclosure of Sensitive Personal Information
You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law.
Note that we do not use sensitive personal information for any such additional purposes.
Right to Non-Discrimination
You have a right to not be discriminated against for exercising your privacy rights.
“Shine the Light”
California residents who have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code §1798.83).
We do not disclose a customer’s personal information to third parties for the third parties’ direct marketing purposes unless the customer first affirmatively agrees to such disclosure.
Right to Opt-Out from and Access Automated Decision Making Tools
You have the right to opt-out from our use of “automated decision-making tools” (or “ADMT”) when we use ADMT to make a significant decision, subject to certain exceptions, including providing a right to appeal to a human reviewer. When we use ADMT for significant decisions, you also have the right to request access to information about our use of ADMT for significant decisions. Please note, at this time we do not use ADMT to make significant decisions.
Please note, we do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer.
Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. Please submit all appeals requests by replying to the communication resolving your original request or emailing us at privacy@aventiv.com. If we deny your appeal, we will provide you with information about how to contact your state’s attorney general or other applicable regulatory authority to file a complaint, as required by applicable U.S. state privacy laws.
To Exercise Your Right to Access, Right to Know, Right to Deletion, or Right to Correction of Your Personal Information
To exercise your Right to Access, Right to Know, your Right to Request Deletion or Correction, please submit a DSAR to us by completing the form linked here.
Before processing your request, we will need to verify your identity and confirm your residency (e.g., state, province, country). To verify your identity, we will generally either require the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. This process may require us to request additional personal information from you, including, but not limited to, your first name, last name, email address, phone number, state/province/country of residence, and/or country. During verification, we will only request the minimum personal information necessary to correctly identify you for the purpose of fulfilling your request.
In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with your request.
To Exercise Your Right to Opt-Out of the Sale or “Sharing” of Your Personal Information
You (or an agent on your behalf) also may exercise your right to opt-out the sale of your personal information to third parties, or your right to opt-out of “sharing” your personal information with third parties for cross-context behavioral advertising, now or in the future. You do not need to create an account with us to exercise your Right to Opt-Out.
To opt out of cookies and tracking technologies on our Sites, you may send an email to privacy@aventiv.com or by visiting our homepage’s cookie banner and open the “Cookie Settings” link to visit the “Privacy Preference Center” where you can select your preferences and opt out of our use of cookie and tracking information. You can also use the Global Privacy Control setting in a web browser or browser extensions (as described more fully in our Cookie Notice ).
To learn more about online advertising and other tracking technologies and what choices you have regarding their use, you may opt out of certain interest-based advertising, across our Sites and Services and other websites on the Internet, by using the following resources:
(i) You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at privacy.daadev.org/appchoices-ccpa or use the DAA’s CCPA App-based Opt-Out Tool.
(ii) You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at optout.networkadvertising.org or visiting About Ads.
Please note that we do not maintain or control any third party opt-out mechanisms and are not responsible for their operation.
These choices are specific to the device or browser you are using. If you access our Sites and Services from other devices or browsers, take these actions from those devices or browsers to ensure your choices apply to the data collected when you use them.
If you have any issues or concerns regarding how to exercise your opt out from the sale or sharing of personal information, please contact us by sending an email to privacy@aventiv.com with the subject line, “Consumer Rights Request”
Learn more about your rights regarding sharing of your personal information via cookies and automated technologies, below under the DO NOT SELL OR SHARE MY PERSONAL INFORMATION section below and in our Cookie Notice.
To Exercise Your “Shine the Light” Rights
The California Shine the Light Law permits you the right to opt out of the disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year.
To opt out of having your information shared under Shine the Light, you may send us an email at privacy@aventiv.com to be added to our suppression list.
We respect your right to opt out of the sale of your personal information to third parties. While we generally do not engage in the sale of personal information that we obtain from you via our Services, there may be limited circumstances where we “sell” personal information or “share” personal information with third parties with third parties for cross-context behavioral advertising. (which may be considered a “sale” under the CCPA). Specifically, this sharing occurs when we permit certain third party advertising networks, social media companies, and similar businesses to collect and process your personal information (including preferences, commercial information and internet, network, and device information) directly from your browser or device through cookies or tracking technologies in use when you visit or interact with our Sites. As further discussed in our Cookie Notice, these third parties then process your personal information to provide you with relevant ads on our behalf, measure and analyze our ad campaigns, detect and report fraud to promote the security of our Services, and perform similar processing purposes, subject to the third parties’ privacy policies.
To opt out of cookies and tracking technologies on our Sites and Services, please see the Cookie Notice section in this Policy.
This Cookie Notice supplements the information contained in the Privacy Statement and explains how we and our business partners and service providers use cookies and related technologies in the course of managing and providing our online services and our electronic communication to you. It explains what these technologies are and why we use them, as well as your rights to control our use of them.
In some cases, we may use cookies and related technologies described in this Cookie Notice to collect personal information, or to collect information that becomes personal information if we combine it with other information. For more details about how we process your personal information, please review the Privacy Statement.
As is common practice among websites, our Services use cookies, which are tiny files downloaded to your device that allow us and our third-party partners to collect certain information about your interactions with our email communications, websites and other online services, and that improve your experience. We and our third-party partners and providers may also use other, related technologies to collect this information, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”).
We and our third-party partners and providers may use cookies to automatically collect certain types of usage information when you visit or interact with our email communications and Services. For example, we may collect log data about your device and its software, such as your IP address, operating system, browser type, date/time of your visit, and other similar information. Our emails may also contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. With the exclusion of some EU countries, we may also collect analytics data or use third-party analytics tools such as Google Analytics to help us measure usage and activity trends for our online services and better understand our customer base. We also may collect location data, including general geographic location based on IP address or more precise location data when a user accesses our online services through a mobile device.
We use the following types of cookies:
We use cookies for a variety of reasons outlined below:
Please note that we link some of the personal information we collect through cookies with the other personal information that we collect about you and for the purposes described in our Privacy Statement.
Browser and Platform Controls. To manage cookies on our Sites, including to opt out from targeted advertising you have several options.
Do Not Track. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the GPC, cookie controls, and advertising controls described above.
Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, and the automatic connection to the web servers that host those images.
Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to do so on each browser on each device you actively use. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
You can view the cookies used across our Services at any time in the OneTrust cookie management tool.
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