Last Updated - 11/11/2018
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
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.
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 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
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 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
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.
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.
4. Do Not Track Disclosure
Our Services do not respond to Do Not Track signals. For more information about Do Not Track signals, please
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
- 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.
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
In addition, if you are located in the EU, you may have the following additional rights as of May 25, 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 defense 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 directly provided to us,
you can return to the webpage or application where you originally submitted your personal data and follow
the instructions on that webpage 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
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
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
the transfer of personal data to countries outside your country of residence consistent with the terms of
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–U.S. Privacy
Shield Framework and the Swiss-U.S. Privacy Shield Framework. Our Privacy Shield Notice is available here.