NOTICE AT COLLECTION
Notice at Collection by Language:
Last Updated: January 15, 2023
1. What personal data does Avetta collect and for what purposes?
Avetta, LLC and its affiliates and subsidiaries (collectively, “Avetta,” “we,” or “us”) collect your personal data to support our business operations, including for the business purposes listed in the table below.
| Personal Data Category | Collected [YES/NO] | Business Purpose |
|---|---|---|
| A. Identifiers (examples: a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) | Admin users/agents of a Client or a Supplier (collectively, “Admin Users”): Yes (business contact data).
Individual workers (“Workers”): Yes (such as name, contact data, and identification data).
Client’s visitors (“Client Visitors”): Yes (such as name and contact data).
Business contact of potential customers (“Business Prospects”): Yes (such as name, contact data, online identifier).
|
Admin Users: To fulfill our contracts and manage our relationship with our customers.
Workers/Client Visitors: To fulfill our contracts with our customers.
Business Prospects: To generate sales leads.
|
| B. Personal data in a nature similar to the personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) (examples: name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information) | Admin Users: Yes (to the extent the business contact data falls under this category).
Workers: Yes (to the extent the data is required by the Worker’s employer).
Client Visitors: Yes (to the extent the data is required by the Client).
Business Prospects: Yes (to the extent the business contact data falls under this category).
|
Admin Users: To fulfill our contracts and manage our relationship with our customers.
Workers/Client Visitors: To fulfill our contracts with our customers.
Business Prospects: To generate sales leads.
|
| C. Protected classification characteristics under California or US federal law (examples: age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information)) | Admin Users: No.
Workers: Yes (to the extent the data is required by the Worker’s employer).
Client Visitors: Yes (to the extent the data is required by the Client).
Business Prospects: No.
|
Admin Users: N/A
Workers/Client Visitors: To fulfill our contracts with our customers.
Business Prospects: N/A
|
| D. Commercial information (examples: records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | Admin Users: No (unless personal data is contained in the business transaction data).
Workers: No (unless personal data is contained in the business transaction data).
Client Visitors: No (unless personal data is contained in the business transaction data).
Business Prospects: No (unless personal data is contained in the business transaction data).
|
Admin Users: To fulfill our contracts and manage our relationship with our customers.
Workers/Client Visitors: To fulfill our contracts with our customers.
Business Prospects: To generate sales leads.
|
| E. Biometric information (examples: genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data) | Admin Users: No.
Workers: No.
Client Visitors: No.
Business Prospects: No.
|
N/A |
| F. Internet or other similar network activity (examples: technical data, usage data, search history, information on a user’s interaction with a website, application, or advertisement) | Admin Users: Yes.
Workers: Yes.
Client Visitors: Yes.
Business Prospects: Yes.
|
Admin Users/Workers/Client Visitors: To fulfill our contracts with our customers and to improve and develop our products and services.
Business Prospects: To generate sales leads.
|
| G. Geolocation data (examples: physical location or movements) | Admin Users: Yes (IP address).
Workers: Yes (IP address, and work site locations if required by the Worker’s employer).
Client Visitors: Yes (IP address).
Business Prospects: Yes (such as IP address or the location of the event in which the Business Prospect participated).
|
Admin Users/Workers/Client Visitors: To fulfill our contracts with our customers and to improve, maintain, and develop our products and services.
Business Prospects: To generate sales leads.
|
| H. Sensory data (examples: audio, electronic, visual, thermal, olfactory, or similar information) | Admin Users: No (unless the Admin User participates in recorded meetings/calls).
Workers: No.
Client Visitors: No.
Business Prospects: No (unless the Business Prospect participates in recorded meetings/calls).
|
Admin Users: To fulfill our contracts with our customers.
Workers/Client Visitors: N/A
Business Prospects: To generate sales leads.
|
| I. Professional or employment-related information (examples: current or past job history or performance evaluations) | Admin Users: Yes (role with the business subscriber).
Workers: Yes (to the extent required by the Worker’s employer).
Client Visitors: Yes (to the extent required by the Client).
Business Prospects: Yes (business contact person’s role).
|
Admin Users: To fulfill our contracts and manage our relationship with our customers.
Workers/Client Visitors: To fulfill our contracts with our customers.
Business Prospects: To generate sales leads.
|
| J. Non-public education information (examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records) | Admin Users: No.
Workers: No.
Client Visitors: No.
Business Prospects: No.
|
N/A |
| K. Inferences drawn from other personal information (examples: profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes) | Admin Users: No.
Workers: No.
Client Visitors: No.
Business Prospects: Yes (inferences related to the business contact person’s role).
|
Admin Users/Workers/Client Visitors: N/A
Business Prospects: To generate sales leads.
|
| L. Sensitive personal data/special categories of personal data (examples: government identifiers (social security, driver's license, state identification card, or passport number); complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password); precise geolocation; racial or ethnic origin; religious or philosophical beliefs; union membership; genetic data; mail, email, or text messages contents; unique identifying biometric information; health, sex life, or sexual orientation information) | Admin Users: No.
Workers: Yes (to the extent required by the Worker’s employer).
Client Visitors: Yes (to the extent required by the Client).
Business Prospects: No.
|
Admin Users/Business Prospects: N/A
Workers/Client Visitors: To fulfill our contracts with our customers.
|
In addition to the business purposes set forth above, we may use the personal data for our legitimate interests such as to prevent and detect security threats, fraud, or other malicious activity, to prepare or implement reorganization, or sale of assets or shares, and to comply with our legal obligations, and for other purposes permitted under the applicable data protection laws.
Please note that any sensitive personal data/special categories of personal data we collect from Workers is strictly used to fulfill our contracts with our customers that the Workers are working for and for purposes permitted under the data protection laws. We do not process any sensitive personal data/special categories of personal data to infer characteristics about any individuals.
We may also aggregate the data in order to anonymize it for data analysis, audits, developing new products, enhancing the services, identifying usage trends and determining the effectiveness of our promotional campaigns.
2. How long does Avetta retain the personal data?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
3. Does Avetta sell any personal data or share any personal data with third parties for cross-context behavioral advertising?
We do not sell any personal data for monetary consideration, and we do not engage in any cross-context behavioral advertising towards consumers.
We use B2B marketing strategies (such as account-based marketing) to generate sales leads; however, such use, based on our analysis, does not qualify as a “sell” or “share” under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020.
4. Further information
To view our full privacy policy, visit https://www.avetta.com/privacy-policy.
If you have any questions about this notice or need to access it in an alternative format due to having a disability, please contact [email protected].