Data Privacy Framework Policy

This Data Privacy Framework Policy (“Policy”) describes how Avetta, LLC (“Avetta”, “we” or “us”) collects, uses and discloses certain personally identifiable information (“Personal Data”) that we receive in the US from the European Economic Area (“EEA”), the United Kingdom (“UK”) and Switzerland. This Policy supplements our Privacy Policy (“Privacy Policy”) and, unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Privacy Policy.

Avetta recognises that the EEA, the UK and Switzerland have established strict protections regarding the handling of Personal Data, including requirements to provide adequate protection for Personal Data transferred outside the EEA, the UK and Switzerland. To provide adequate protection for certain Personal Data about individuals received in the US from the EEA, the UK and Switzerland, Avetta has elected to self-certify to the EU-US Data Privacy Framework (“EU-US DPF”), the UK Extension to the EU-US Data Privacy Framework (“UK Extension to the EU-US DPF”) and the Swiss-US Data Privacy Framework (“Swiss-US DPF” – together with “EU-US DPF” and “UK Extension to the EU-US DPF”, the “DPF”) administered by the US Department of Commerce. Avetta adheres to the Data Privacy Framework Principles (“DPF Principles”) of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability.

For purposes of enforcing compliance with the DPF program, Avetta is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the DPF program, see the US Department of Commerce’s Data Privacy Framework website located at: https://www.dataprivacyframework.gov. To review Avetta’s representation on the Data Privacy Framework List, see the US Department of Commerce’s Data Privacy Framework self-certification list located at: https://www.dataprivacyframework.gov/list.

Personal Data Collection and Use

In accordance with the DPF Principles, we collect the categories of Personal Data described in Section 3 (The Data We Collect About You) of our Privacy Policy. We process the Personal Data for the purposes described in Section 5 (How We Process Your Personal Data) of our Privacy Policy.

Avetta will only process Personal Data in ways that are compatible with the purpose that Avetta collected it for, or for purposes that the individual later authorises. Before we use your Personal Data for a purpose that is materially different to the purpose we collected it for or that you later authorised, we will provide you with the opportunity to opt out. Avetta maintains reasonable procedures to help ensure that Personal Data is reliable for its intended use, accurate, complete and current.

If we collect sensitive Personal Data, we will obtain your opt-in consent where the DPF requires it, including if we disclose your sensitive Personal Data to third parties or before we use your sensitive Personal Data for a purpose that is different to the one we collected it for or that you later authorised.

Data Transfers to Third Parties

We may transfer Personal Data to our third-party agents or service providers as described in Section 6 (Disclosures of Your Personal Data) of our Privacy Policy. Where required by the DPF, we enter into written agreements with those third-party agents and service providers, requiring them to provide the same level of protection as the DPF requires and limiting their use of the data to the specified services. We take reasonable and appropriate steps to ensure that third-party agents and service providers process Personal Data in accordance with our DPF obligations and to stop and remediate any unauthorised processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers for their handling of Personal Data that we transfer to them.

Except for the purpose of fulfilling our contractual obligations to our customers, Avetta does not transfer Personal Data to any third party for their own use. In the event that such transfers occur in the future, we will only disclose your Personal Data where you have not opted out of such disclosures, or in the case of sensitive Personal Data where you have opted in if the DPF requires consent. We will also enter into written contracts with such third parties, requiring them to provide the same level of protection for Personal Data as the DPF requires. We also limit their use of your Personal Data so that it is consistent with any consent that you have provided and with the notices that you have received.

If we transfer your Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your Personal Data is protected with the same level of protection as the DPF requires.

Under certain circumstances, we may be required to disclose your Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security

Avetta maintains reasonable and appropriate security measures to protect Personal Data from loss, misuse, unauthorised access, disclosure, alteration or destruction, in accordance with the DPF.

Access Rights

You may have the right to access the Personal Data that we hold about you and to request that we correct, amend or delete it if it is inaccurate or processed in violation of the DPF. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment or deletion of your Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances, we may charge a reasonable fee for access to your information.

Complaints and Dispute Resolution

You can direct any questions or complaints about the use or disclosure of your Personal Data to us at privacy@avetta.com. We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your Personal Data within 45 days of receiving your complaint.

If you have any unresolved complaints, please contact, free of charge, the US-based independent dispute resolution provider, JAMS, at https://www.jamsadr.com/DPF-Dispute-Resolution.

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your complaint directly with Avetta and provided us with the opportunity to resolve the issue; (2) made use of the independent recourse mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see the US Department of Commerce’s Data Privacy Framework Principles Annex I: Arbitral Model.

Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us at privacy@avetta.com. Additional contact information is set forth in Section 16 (How to Contact Us) of our Privacy Policy.

Changes to This Policy

We reserve the right to amend this Policy from time to time, consistently with the DPF program’s requirements.