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Date: September 28, 2016

Avetta, LLC and Avetta Subsidiary Holdings, LLC (together, “AVETTA”) comply with the EU-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the transfer of personal data from the EU to the US (“Personal Data”). “Personal Data” is data about an identified or identifiable individual that are within the scope of EU Directive 95/46/EC, received by an organization in the US from the EU, and recorded in any form. AVETTA has self-certified to the US Department of Commerce and declared its commitment to adhere to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability (the “Principles”).

You can learn more about Privacy Shield at and see our Privacy Shield self-certification at AVETTA’s self-certification to the Privacy Shield is subject to the investigatory and enforcement authority of the Federal Trade Commission.

Information We Process. In accordance with the Privacy Shield Principles, we collect the categories of information described in Section 2 (Collection of Information) of our Privacy Policy. We process this information for the purposes described in Section 3 (Use of Your Personal Data) of our Privacy Policy. The information we process may include Personal Data.

Accessing Personal Data. The Privacy Shield Principles provide individuals located in the EU whose Personal Data we process the right to access their Personal Data and to review, correct, amend, or delete their Personal Data. EU individuals who would like to access their Personal Data may contact us at [email protected]

Transfers to Third Parties and Your Choices. As described in Section 4 (Sharing or Disclosing Your Personal Data) of our Privacy Policy, we may transfer Personal Data to third parties. We contractually require those third parties to provide the same level of protections to Personal Data as required under the Principles. AVETTA currently does not transfer Personal Data to a third party for its own use; if in the future it does, individuals may choose to opt out of this type of transfer by emailing us at [email protected] AVETTA will remain liable under the Principles if a third party processes Personal Data in a manner inconsistent with the Principles, unless AVETTA proves that it is not responsible for the event giving rise to the damage.

In accordance with our legal obligations, we may also transfer, subject to a lawful request, Personal Data to public authorities for law enforcement or national security purposes.

Contacting Us, Complaints and Dispute Resolution. We encourage EU individuals who have questions or complaints about how we process their Personal Data under Privacy Shield to contact us as described in Section 11 (Contacting Us) of our Privacy Policy. 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

If you are an EU individual and unable to resolve any complaints through any of the above methods, you may invoke binding arbitration in accordance with the Privacy Shield Framework at

Internal Dispute Resolution. In compliance with the Privacy Shield Principles, Avetta commits to resolve complaints about our collection or use of your personal information.  EU individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Avetta at: 

[email protected]

Avetta has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship.

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