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Avature

(Last update: June 27, 2024)

Scope of this Privacy Policy

This Privacy Policy describes how Avature Limited collects and processes information relating to identified or identifiable individuals (“Personal Data”) through our channels, websites or mobile applications (collectively, “Websites”) and/or how the relevant Avature legal entity (as listed below) processes your Personal Data in the course of the provision of its products or services.

A reference to “Avature,” “we” or “us” is a reference to Avature Limited and its relevant affiliates involved in the processing of your Personal Data as required for the provision of the requested Avature services and/or products. A list of Avature’s affiliates can be found in Appendix 1.

This Privacy Policy does not apply to the extent we process Personal Data in the role of processor on behalf of our customer as part of our business activity as described below. If your information is being processed by Avature on behalf of one of our customers, such customer’s privacy policy applies to the processing. Further information in this regard is provided in the corresponding section below.

Description of our business activity

Avature develops and provides software application services, which include data processing activities and hosting activities. Avature’s customers primarily use our hosted services for Recruiting, Recruitment Marketing and Communication, and Talent Management activities. Avature’s customers upload their data (including Personal Data of prospective job candidates and employees) to the Avature hosted environment. Depending on our agreement with the respective customer, this data may be stored in the United States of America, the Netherlands, Germany, Australia, Japan, China or Singapore, and Avature may transfer it to other countries where we have operations. Once the data is stored, our customers access our solution and their data for recruitment purposes. Individuals involved in these recruitment and staffing activities interact directly with Avature’s customers, rather than with Avature. Avature is a processor for our customers, who operate as controllers of Personal Data.

Avature does not collect Personal Data for resale, sell Personal Data it has collected, or sell access to Personal Data.

What Personal Data do we collect?

We will collect Personal Data about you from a variety of sources, including information we collect from you directly (e.g. when you reach out to us through the online “Contact Us” forms), and information we collect about you from other sources, as described below:

1. Personal Data we collect directly from you

The categories of Personal Data we collect directly from you include:

  • Personal details (e.g. first and last name);
  • Contact details (e.g. phone number, postal address or e-mail address);
  • Professional details (e.g. job title, company and company details, and professional contact details);
  • Content of enquiries (including your expressed interests) explicitly provided by you, including through the chatbot functionality; and
  • Information we collect automatically from you (e.g. data collected using cookies or other similar technologies (“Cookies”)) regarding your use of the Websites. Further information about our use of Cookies is available in the Cookies Section below and our Cookie Notice.

When you are acting as an employee, representative and/or agent of our customers, suppliers, providers, partners, business associates, advisors or prospects, we may also collect the following information about you:

  • Contractual data, such as purchase orders, invoices, contracts and other agreements between your company (or your employer) and Avature, that may include your contact information and signature;
  • Financial and payment information such as bank account and credit card details;
  • IT related data, such as your user ID, passwords and logs about your usage (including profile details) of our Websites or portals specifically created to provide a service to our customers such as the Training, Sales and Resourcecenter portals; and
  • Other details about our professional relationship, including our communications.

If you are a user of our mobile app (available for IOS and Android devices), we also collect the following information:

  • Data resulting from our access to your camera and/or photo library (provided you have expressly authorized such access); and
  • Other information you may provide that is useful for the future development of the app and for support purposes.

If you give us Personal Data about somebody else, such as a spouse or work colleague, we will assume that you have their permission to do so.

2. Personal Data we collect from other sources

We also collect some of the Personal Data listed above directly from publicly available sources (which would only include personal, professional and contact details), from third parties that may provide us with Personal Data to improve and enhance our services, or from your employer in the case of candidates for employment with Avature.

We neither intend nor try to collect information on minors (16 years of age or younger). Considering that we cannot tell the age of online visitors, if a minor provides Personal Data to us without the consent of his or her parents or guardian, his or her parents or guardian may request us to remove the information we have about him or her.

How do we use your Personal Data and on what legal bases?

In general, Avature may retain Personal Data as controller about several different types of individuals, including (i) visitors of our Websites; and (ii) employees, representatives and/ or agents of customers, suppliers, providers, partners, business associates, advisors or prospects. Avature may also access Personal Data regarding end users of its services on behalf of its customers as processor, as further specified below. Avature’s practices with respect to each of these types of individual data subjects are described below.

Websites visitors

Avature processes Personal Data about you (as listed in section above) while you visit and browse our Websites (e.g. via Cookies), communicate with us through the Websites (e.g. via “Contact Us” forms) and make use of other functions or services offered in our Websites. We process such Personal Data for the following purposes and on the basis of the lawful bases identified below:

a) We process your Personal Data on the basis of our legitimate interest to provide you with the requested Websites and services, for the following purposes:

  • Develop and provide you with our online features and content;
  • Manage our Websites;
  • Deal with your inquiries and requests;
  • Provide you with the required support;
  • Ensure the security and/or integrity or our Websites and IT infrastructure;
  • To understand how you use our services and to enable us to improve and further develop the features, performance and support available on our Websites, which may entail the provision of anonymous statistical information about our visitors (however, without it being used to identify any individual user); and
  • To carry out the disclosures of your Personal Data further specified in section “How do we disclose your Personal Data and with whom?” below when those do not specify another applicable lawful basis or do not require one at all (i.e. disclosures to service providers acting as processors).

Where we process Personal Data in fulfillment of our own legitimate interests, we carry out a balancing test (available upon request) to verify that said legitimate interest is not overridden by your interests or rights.

b) We process your Personal Data for the following purposes, provided you have granted your prior consent:

  • To send you personalized commercial communications (such as e-newsletters) via electronic and non-electronic means, in relation to offers regarding our own products or services and those of our affiliates. You are free to choose whether or not to have your information used in this way. You will be provided with an unsubscribe link in all marketing communication we send you and you can also revoke this consent at any time by contacting us here; and
  • For any other purpose disclosed to you at the time you provide us with your Personal Data, to the extent that you have granted us your prior consent to that particular processing. For example, we will obtain your consent to collect and use certain types of Personal Data when we are required to do so by law (e.g. in relation to certain types of Cookies).

c) We will also process your Personal Data in order to ensure an optimum level of compliance with the applicable legal obligations to which Avature is subject,and cooperate with regulators and law enforcement bodies where necessary, in line with section “How do we disclose your Personal Data and with whom?” below (e.g. to disclose your Personal Data and other complementary information subject to requests received from authorities and/or bodies with compelling power, as required by the applicable laws or by law enforcement officers invested with such powers).

If you choose to provide some Personal Data via our Websites, we will use that information for the purpose for which you provided it and in accordance with this Privacy Policy.

Employees, representatives and/or agents of customers, suppliers, providers, partners, business associates, advisors or Prospects

Avature processes Personal Data (as listed in section above) about employees, representatives, agents and/or other data subjects that have a relationship with our customers, suppliers, providers, partners, business associates, advisors or prospects. We process such Personal Data for the following purposes and on the basis of the lawful bases identified below:

a) We process your Personal Data on the basis of our legitimate interest, for the following purposes:

  • Perform our contracts with our customers, suppliers, providers, partners, business associates, advisors or prospects and/or in order to take steps to enter into such a contract and/or to comply with our record retention obligations (i.e. for business purposes, including delivering products or services; establishing, renewing, maintaining or terminating client and business relationships; providing access to Internet-based activities; performing invoicing, collection, payment and related accounting functions);
  • To send you commercial communications (such as invitations to participate in Avature-hosted events) via electronic and non-electronic means, in relation to offers regarding our own products or services and that of our affiliates similar to those initially purchased/contracted by your employer under the agreement it has in place with us;
  • to improve, enhance and further develop the features of our services;
  • in case you incidentally provide any personal data in chatbots or other free texts not designed to collect personal data, we will only store that data until deletion (without carrying out any further processing) in the interest of the well functioning of chatbots;
  • All other purposes identified above for processing Website visitors’ Personal Data on the basis of Avature’s legitimate interest.

b) We process your Personal Data for the following purposes, provided you have granted your prior consent:

  • To send you personalized commercial communications (such as e-newsletters) via electronic and non-electronic means, in relation to offers regarding our own products or services and those of our affiliates. You are free to choose whether or not to have your information used in this way. You will be provided with an unsubscribe link in all marketing communication we send you and you can also revoke this consent at any time by contacting us here; and
  • For any other purpose disclosed to you at the time you provide us with your Personal Data, to the extent that you have granted us your prior consent to that particular processing. For example, we will obtain your consent to collect and use certain types of Personal Data when we are required to do so by law (e.g. in relation to certain types of Cookies).

c) We will also process your Personal Data in order to ensure an optimum level of compliance with the applicable legal obligations to which Avature is subject and cooperate with regulators and law enforcement bodies where necessary, in line with section, “How do we disclose your Personal Data and with whom?” below (g. to disclose your Personal Data and other complementary information subject to requests received from authorities and/or bodies with compelling power, as required by the applicable laws or by law enforcement officers invested with such powers).

You may contact your regular point of contact within Avature if any of your Personal Data changes, or if you would like to exercise any of your data protection rights with regard to your Personal Data that we maintain. In any event, you can also contact Avature’s Data Protection Officer here.

End users of Avature’s services provided to our customers such as the Hosted Application Service (including candidates for employment with our customers)

In cases where we act as a processor on behalf of our customers, such as when we act as an application service provider that delivers Human Resources software, we conduct such activities strictly in accordance with our customer’s instructions and pursuant to our contractual arrangements with them.

It remains the responsibility of our customers to inform the individuals of the purposes for which they collect and use Personal Data, about the choices and means, and any ways that the individuals may limit the use or disclosure of their information. In this instance, the software would be clearly identified as belonging to our customer and would be branded with their logos and company information.

If you are a candidate with one of our customers through this software, or an end user of this software with an existing relationship with one of our customers, you should refer to the customer’s website or their human resources manager to understand the privacy practices that apply to Personal Data that we may maintain about you on our customer’s behalf. Moreover, if you would like to exercise any of your data protection rights with regard to your Personal Data, you should contact our customer (your potential or existing employer) with any such requests. We will cooperate as appropriate with requests from our customers to assist with such responses.

How do we disclose your Personal Data and with whom?

Avature will disclose your Personal Data to third parties under the following circumstances:

a) Other members of the Avature Group. Avature works closely with other businesses and companies that fall under the Avature group family. We will share certain information about you with other Avature group companies for internal administrative purposes, and insofar as it is reasonably necessary for the purposes stated in this Privacy Policy and relying on the corresponding legal basis. You may find a list of Avature entities in Appendix 1 to this Privacy Policy.

b) Service providers. We will allow our service providers to access your Personal Data in order to carry out the data processing activities for the purposes described in this Privacy Policy to the extent applicable. Before any access is granted to such third parties, we enter into a written agreement that requires them to refrain from making any further unauthorized disclosures of the Personal Data, to use such data only for the purposes of providing the specific services and according to the instructions received from Avature, to only retain the Personal Data as required to fulfill such purposes of protect our interests, and to have in place adequate and appropriate security measures.
Additionally, we may disclose your Personal Data to third parties pursuant to our good faith belief that disclosure is necessary to the establishment of legal claims or defenses, to obtain legal advice, to exercise and defend our legal rights, to protect our rights and/or property and those of our affiliates, or to protect the life, body or property of an individual.

c) Asset purchasers. We will also disclose your Personal Data with any third party that purchases, or to which we transfer, all or part of our assets and business. In these situations, Avature will require the recipient of the data to protect the data in accordance with the relevant principles under the applicable data protection regulations and takes steps to ensure that Personal Data is appropriately protected.

d) Customers, suppliers, providers, partners, business associates, advisors and prospects. We will disclose your Personal Data with these recipients as necessary in connection with the performance of requested services or solutions or as otherwise reasonably necessary for the purposes stated in this Privacy Policy, and relying on the corresponding legal basis. In particular, we may disclose the following Personal Data to the following people:

  • Personal Data about employees, representatives and/or agents of a customer to prospects in case you explicitly give us your permission to mention you as our reference.
  • Personal Data about employees, representatives and/or agents of our suppliers, providers, partners, business associates and/or advisors to our customers and prospects in case it is needed in the context of offering and/or providing our services.
  • Personal Data about employees, representatives and/or agents of our prospects to our suppliers, providers, partners, business associates and advisors in case it is needed to adequately offer and negotiate the provision of our services.

e) Law enforcement agency, court, regulator, government authority or other third party with compelling authority. Please be aware that in certain circumstances, it is possible that Personal Data may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders or if required by applicable laws and regulations.

Where Avature becomes aware that a third party is using or disclosing Personal Data in a manner contrary to this policy, Avature will take reasonable steps to prevent or stop the use or disclosure.

Our worldwide practices and international transfers of data

Avature is a global organization, with legal entities, business processes, management structures, and technical systems that cross borders. Therefore, the recipients referred to in section above can be located outside the jurisdiction in which you are located (or in which we provide the services), including third countries outside the European Union (“EU“).

For transfers to the United States of America, Avature has certified itself under the Data Privacy Framework to provide an adequate level of protection to the Personal Data.

For transfers to other jurisdictions that are not regarded as providing an adequate level of protection of Personal Data, we have put in place additional appropriate safeguards (such as contractual commitments) in accordance with applicable laws and regulations to ensure that your Personal Data is adequately protected, on the basis of the relevant sets of standard contractual clauses approved by the European Commission available for consultation here. For more information on the appropriate safeguards in place, please contact us at the details below.

How long do we store your Personal Data?

We will keep your Personal Data for as long as we have a relationship with you and insofar as the agreement with your employer is in force. Conversations from chatbots will be retained for a maximum of two years. Afterward, we will retain your Personal Data for a period of time that enables us to defend ourselves against potential legal and contractual actions (during their expiration period) or as otherwise required under the relevant local laws. Finally, once these actions expire, we will proceed to delete your information.

What rights do you have over your Personal Data?

You have certain data protection rights regarding your Personal Data. Including the following rights:

  • To know how Avature processes your Personal Data and to access the Personal Data we hold about you;
  • To request the rectification of inaccurate or incomplete Personal data;
  • To request the erasure of your Personal Data when, among others, such data is no longer necessary for the initial purposes for which it was initially collected, in accordance with applicable laws;
  • To restrict our processing of your Personal Data, under certain circumstances (in which case we will only retain your Personal data for the exercise and/or defense of Avature’s rights);
  • To object to our processing of your Personal Data, having regard to the given circumstances and for reasons related to your particular situation (in which case we will only retain the Personal Data for imperative legitimate reasons or the exercise and/or defense of Avature’s rights);
  • To request the portability of your Personal Data, which will allow you to obtain and reuse the Personal Data in a usable electronic format for your own purposes and across different services without hindrance to usability, including its transmission to another third party;
  • To withdraw the consent you may have granted to a specific processing, at any time; and
  • To make a complaint to the competent supervisory authority.

You may exercise the rights specified above by writing to your regular Avature point of contact and/or by sending an email to our Privacy Officer.

Please note that if you send your request and we confirm that your request refers to the data held by Avature as a processor, we are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Policy. However, we may be under contractual obligation to notify your request to our customer(s) as appropriate. In such cases, they will contact you to respond to your request. We may also respond to your request based on the information we find in our own databases.

Please note that, in case you are an employee, representative and/or agent of an Avature customer, supplier, provider, partner, business associate, advisor or prospect, Avature’s use of your Personal Data may be required to comply with Avature’s agreement with your employer or representative, so you should discuss with them the consequences of restricting Avature’s use of your Personal Data and, eventually, provide an alternate point of contact. Any failure to do so may result in an impossibility on Avature to comply with our contractual obligations.

Posting to Public Areas of Avature Website

Please remember that if you post any of your Personal Data in public areas of our Websites, such as in online forums or chat rooms, in the Avature blog or on Avature’s pages on social media, such information may be collected and used by others over whom we have no control. We are not responsible for the use made by third parties of information you post or otherwise make available in public areas of our Websites. In addition, each participant’s opinion on a forum or chat room is his or her own and should not be considered as reflecting the opinion of Avature.

Links in Avature’s Website

Our Websites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Avature has no responsibility or liability for what the owners of such websites may do. Please check these policies before you submit any Personal Data to these websites.

How do we protect your Personal Data?

We intend to protect your Personal Data and maintain its quality. We implement appropriate measures and processes, such as using encryption when transmitting certain sensitive information, to help us keep your information secure and maintain its quality.

Data Security

Avature has global hosting centers that store and process Personal Data in the United States, the Netherlands, Argentina, Germany, China, Australia, Japan and Singapore. Avature takes reasonable precautions to protect Personal Data in these data centers from loss, misuse and unauthorized access, disclosure, alteration, and destruction.

Data Integrity

Avature will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Avature will take reasonable steps to keep Personal Data accurate, current, complete and available for its intended use.

Enforcement

Avature will conduct compliance audits of its relevant privacy practices to verify adherence to this Privacy Policy. Any employee that Avature determines is in violation of this Privacy Policy will be subject to disciplinary action up to and including termination of employment.

Cookies

We collect information regarding your use of our Websites through the use of Cookies. For example, we keep track of the domains from which people visit and we also measure visitor activity. Avature may use this data to analyze trends and statistics and to help us provide better service.

In addition to cookies in the strict sense of the word, our Websites may also contain electronic images known as Web beacons (sometimes called single-pixel gifs) that allow us to count users who have visited those pages and deliver co-branded services.

On occasion, we may also personalize and customize our Websites for certain visitors. If you visit one of these Websites, you may find it customized with references to products and/or services or career opportunities that we believe may be of interest to you based on your previous interactions with Avature and the information you have provided to us. While you are visiting these Websites, we may collect information about your visit to better tailor the site to your interests. An invitation to visit one of these Websites is usually presented as a personalized URL in an e-mail, a notice on a website registration page, or as a response to you logging on to a certain website.

If you choose to visit one of these Websites, you are agreeing to let Avature collect information about your visits and also to its association with other information about you and your relationship with Avature as further described in the terms and conditions that apply to such pages. If you do not wish your information to be used in this way, do not accept the invitation to visit these sites.

For further information about the Cookies we use in our Websites please refer to our Cookie Notice here.

Data Privacy Framework

Avature LLC and Avature Limited (Avature’s affiliates established in the United States of America) comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and, as applicable the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union, the United Kingdom and/or Switzerland to the United States, respectively. The Data Privacy Framework list of adhered members may be accessed here. Avature LLC and Avature Limited have certified to the Department of Commerce that they adhere to the Data Privacy Framework Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Data Privacy Framework Principles, the Data Privacy Framework Principles shall govern.

For more information about the Data Privacy Framework Principles and to view the certification for Avature’s companies, visit the Data Privacy Framework website at https://www.dataprivacyframework.gov/. You may also contact us directly at (+1) 212-380-4160 to learn more about this certification.

With respect to Personal Data received or transferred pursuant to the Data Privacy Framework, Avature is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In some cases, Avature is potentially liable if its agents process your Personal Data in a manner that is inconsistent with the Data Privacy Framework Principles, including in cases of onward transfers to third parties.

Avature may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Additional Specific Provisions Applying to Personal Data Collected in California

If you are located in California, the following provisions apply to any Personal Data we collect about you.

The categories of personal information collected may be the following:

  • Identifiers such as a real name, signature, alias, unique personal identifier, online identifier, internet protocol address, account name, social security number, driver’s license number, passport number, state identification card number, or other similar identifiers.
  • Contact details such as postal address, email address, telephone number and mobile number.
  • Commercial information, including records of products or services purchased, obtained, or considered by you or your employer, or other purchasing or consuming histories or tendencies.
  • Bank account number, credit card number, debit card number, or any other financial information needed to charge you or your employer for services provided by Avature or required to pay you for services rendered to Avature.
  • Biometric information.
  • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with Avature’s websites, applications, or advertisements.
  • Geolocation data.
  • Professional or employment-related information.
  • Education information.
  • Inferences drawn from any of the information above described.

You may find the business purposes for which we shall use your information in the chapter titled “How do we use your Personal Data and on what legal basis?”

The main sources from which we collect personal information are the individuals themselves, the Avature websites, the cookies and web beacons we placed in them, our customers, suppliers, providers, partners, business associates, advisors and prospects and their employees, agents and representatives, Discover.org, the organizers of events we sponsor, the internet and/or reputable providers of professional profiles/CVs.

You may find Avature’s business and/or commercial purpose for collecting personal information in the chapter titled “How do we use your Personal Data and on what legal basis?”

You may find the categories of third parties with whom Avature shares personal information in the chapter titled, “How do we disclose your Personal Data and with whom?”

You may have the right to ask Avature to:

  • disclose the categories and specific pieces of information we have collected about you;
  • access the personal information we have collected about you.
  • delete the personal information we collected about you;
  • disclose the sources from which the personal information is collected;
  • opt out of the sale or sharing of personal information
  • limit the use or disclosure of sensitive personal information
  • disclose the business or commercial purpose for collecting or selling personal information;
  • disclose the categories of third parties with whom Avature shares personal information; and
  • disclose the categories of personal information that Avature disclosed about you for a business purpose.
  • not to receive discriminatory treatment for exercising these rights.

You may submit your request as specified in the chapter titled “Questions”. Additionally, you may call our toll-free number: 1-888-696-6246, or you may submit your request through the contact form.

Note that in the previous 12 months, we have collected and disclosed all of the categories of personal information we collect, as explained in the “How do we disclose your Personal Data and with whom?” section of this Privacy Notice, to third parties for a business purpose.

Please note that under California law, you also have the right to request us to disclose the categories of personal information that Avature may have sold about you and the categories of third parties to whom the personal information was sold or shared. However, kindly note that Avature does not sell personal information, there may be circumstances where we “share” personal information with third parties in a way that may be considered a “sale” under the CCPA or other similar laws (e.g., for cross-context behavioral advertising purposes, where no money is exchanged). Specifically, this sharing occurs when we permit certain third-party advertising networks, social media networks, and similar businesses to process your personal information through cookies or tracking technologies in use when you visit or interact with our website. To opt out of cookies and tracking technologies on our website, please visit our homepage’s cookie banner and open the “Cookie Settings” link to visit the “Privacy Preference Center,” where you can select your preferences and opt out of our use of cookies and tracking information.

Also, kindly note that Avature does not offer any financial incentives covered by section 1798.125 of the California Civil Code.

Additional Specific Provisions Applying to Personal Data Collected in China

If you are located in the People’s Republic of China (“China”, excluding Hong Kong Special Administrative Region, Macao Special Administrative Region and Taiwan) and your Personal Data is collected or processed by Avature within China, the following provisions apply to any Personal Data we collect about you.

By providing your Personal Data to us, you are consenting to this policy and our collection, use, disclosure, access, sharing, transfer, storage and processing of your Personal Data for the purposes described in this policy and we will seek your express consent as required under applicable law. If it is necessary for us to use your Personal Data beyond such scope, we will inform you in a timely manner and use it after we have obtained your renewed consent to the extent required under applicable law.

Please note that the personal data that Avature may collect from you may include:

  • your name, gender, titles, address, e-mail address, phone and fax numbers;
  • financial and payment information, and credit card details;
  • education background, work experience and skills;
  • user ID, passwords, and information collected through Internet-based activities;
  • health information necessary to provide health benefits (only from Avature employees and in accordance with the Employee Privacy Policy available on the wiki);
  • if you are a mobile app user and have agreed to provide assistance in the improvement of the app, IP address of the device where you installed the app, information about the device such as device ID, model and device type, name and version of its operating system, settings and language of the device, version and functionality of the application and, if applicable, time of the failure; and
  • our interactions with you regarding the Avature products and services and/or your employer’s provision of products or services to Avature, such as emails, registrations to webinars, downloaded documents, etc.

When we disclose your Personal Data to third parties, we will make all commercially reasonable efforts to review the data security capabilities of, and enter into confidentiality agreements with, third parties to which we disclose Personal Data, and require them to process your Personal Data in accordance with this policy and other relevant non-disclosure and security measures.

Dispute Resolution

Avature will investigate and attempt to resolve complaints and disputes regarding collection, use and disclosure of Personal Data in accordance with the principles contained in this Privacy Policy. EU, United Kingdom, Gibraltar or Swiss individuals with inquiries or complaints regarding our Data Privacy Framework policy should first contact Avature through the following Form.

Avature Limited and Avature LLC have further committed to cooperate with EU data protection authorities (DPAs), with the UK Information Commissioner’s Office (ICO) (and the Gibraltar Regulatory Authority (GRA) and with the Swiss Federal Data Protection and Information Commissioner, with regard to unresolved Data Privacy Framework complaints concerning Personal Data transferred from the EU, UK (and Gibraltar) or Switzerland, respectively. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact the EU DPAs, the ICO (and the GRA) or the Swiss Federal Data Protection and Information Commissioner as applicable for more information or to file a complaint. The services of EU DPAs, ICO (GRA) and the Swiss Federal Data Protection and Information Commissioner are provided at no cost to you.

Under certain conditions, more fully described on the Data Privacy Framework website, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

Questions

If you have any questions or comments about this Privacy Policy, or if you would like to exercise your rights with regard to the Personal Data that we maintain about you, please contact us here.

Our Data Protection Officer may also be contacted at the e-mail address above.

If you prefer to send us a letter, you may do so to the addresses provided for each of Avature’s affiliates in Appendix 1 of this Privacy Policy.

Changes to this Privacy Policy

This Privacy Policy may be amended from time to time, consistent with the requirements of applicable data protection legislation.

If we change this Privacy Policy, we will notify you of the changes. Where changes to the Privacy Policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g., among others, to object to the processing). Moreover, and to the extent that Avature relies on consent for the performance of any of its processing activities, we will make sure to request your consent where the aforementioned changes may have a substantial impact on the relevant processing before these changes are made effective.