Privacy Shield Policy

Last Updated: February 7, 2023

This Privacy Shield 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") and the United Kingdom ("UK"). This Policy supplements our Privacy Policy ("Privacy Policy") located at https://www.avetta.com/privacy-policy, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Privacy Policy.

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

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

Personal Data Collection and Use

In accordance with the Privacy Shield 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 the individual later authorizes. Before we use your Personal Data for a purpose that is materially different than the purpose we collected it for or that you later authorized, 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 Privacy Shield requires, including if we disclose your sensitive Personal Data to third parties, or before we use your sensitive Personal Data for a different purpose than we collected it for or than you later authorized.

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 Privacy Shield, we enter into written agreements with those third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield 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 Privacy Shield obligations and to stop and remediate any unauthorized 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.

Avetta currently does not transfer Personal Data to a third party for its own use; if in the future it does, we will only disclose your Personal Data where you have not opted-out of such disclosures by emailing us at [email protected], or in the case of sensitive Personal Data, where you have opted-in if the Privacy Shield requires consent. Avetta will remain liable if a third party processes Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Avetta proves that it is not responsible for the event giving rise to the damage.

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 the Privacy Shield 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, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

Access Rights and Choices about Data Processing

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 Privacy Shield. 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

In compliance with the Privacy Shield Principles, Avetta commits to resolving complaints about our collection or use of your Personal Data. Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Avetta at [email protected] We will work to resolve your issue as quickly as possible, but in any event no later than 45 days of receipt.

If you have an unresolved privacy or data use complaints that we have not addressed satisfactorily, please contact, free of charge, our US-based third party dispute resolution provider, JAMS, at https://www.jamsadr.com/file-an-eu-us-privacy-shield-claim.

If you are unable to resolve any complaints through any of the above methods, you may invoke binding arbitration in accordance with the Privacy Shield Framework at https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.

Avetta has further committed to cooperate with the panel established by the EU data protection authorities and the UK Information Commissioner with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EEA and the UK in the context of the employment relationship.

Contact Us

If you have any questions about this Policy or would like to request access to your Personal Data, please contact us at [email protected] 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 consistent with the Privacy Shield's requirements.