2. What information does Avalon collect, and how is it used and shared?
|Category of Personal Information Collected||Source||Purpose for Collection||Categories of Recipients|
|Contact information: such as name, address, and phone number.||Client contacts, including employees and representatives we work with provide this information when they visit the Site, call us, or otherwise interact with us.||To communicate with and respond to our clients about the work we do for them and deliver the Client Services to them and their customers, including validation of identity or to meet legal obligations.||We may share this information with select marketing or other service providers and partners.|
|Payment information: name, card issuer and card type, credit or debit card number, expiration date, CVV code, and billing address.||From our clients and their payment card issuers.||Authorizing of credit card and other financial transactions for our clients and their customers.||Our service providers who process payments for us—they are prohibited from using personal information for any other purposes and are contractually required to comply with all applicable laws and requirements, which includes the Payment Card Industry Data Security standards.|
|Suspected crime information: details of your identity, image, name and address, suspected or alleged thefts, fraud, assault or other criminal behavior.||From crime and fraud prevention agencies, from you, witnesses, and from the police.||To protect customers, the public and our business against risks and crime.||Law enforcement and other governmental authorities in accordance with applicable law, and our professional advisors.|
Avalon will only use personal information to the extent it is necessary to deliver the Client Services and the Site. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in Sections 8 and 9. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by Avalon, including requirements that such information be maintained in a confidential and secure manner.
In Connection with Business Transfers: In the event that a division, a product or all of Avalon is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.
To Comply with Laws: Avalon may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our clients, our clients' customers or employees or others, in accordance with or as authorized by law.
Information from our Client's Customers: Avalon processes transactions or applications that are supplied and managed by our clients. As a result, although we may access certain personal information of our client's customers pursuant to the contractual relationships with have with our clients, we typically do not collect and store personal information in our own systems, with the exception of call recordings. Typically, our clients are responsible for complying with all notices, notifications and alerts to individuals whose information is entered into our systems or portals. We do not use or share that personal information except as directed by our clients.
3. What are cookies and how do we use them and other technologies?
A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer's hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities or receive a promotion tailored to you. Avalon does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.
Avalon does not currently participate in interest-based or behavioral online advertising, and information automatically collected from the Site is not used by Avalon for that purpose.
Avalon may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners.
Do Not Track (DNT): This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore Avalon and the Site do not recognize DNT.
4. How does Avalon protect personal information?
Where applicable, Avalon uses industry-standard technology in connection with our Client Services and on the Site to help protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Personal information received from our clients or others in connection with Client Services is typically stored on servers hosted by our clients or their vendors—with limited exceptions, such as call recordings required by our client contracts for quality assurance or other legitimate purposes, personal information collected by our clients is not stored on our or our service provider's services.
5. How long does Avalon retain my personal information?
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or deidentified.
6. What are my choices concerning my personal information?
Avalon depends primarily on our clients to notify and provide their customers and employees choices regarding the personal information that they provide. Our clients are therefore responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to Avalon.
In addition, as part of the Client Services, our clients may use personal information that we have collected on their behalf for their own communication and promotional purposes. Our clients are responsible for ensuring that any commercial emails sent by them to their employees or customers comply with applicable law. If we are instructed by our clients to transmit communications on their behalf, clients remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete.
We do not sell, rent, or share the personal information of our clients’ employees or their customers with third parties for their own marketing purposes.
Avalon may, subject to applicable laws, use personal information from our clients and their employees to contact them about our Site and Client Services, including to provide them with information on additional products from Avalon that may be of interest to them. Client contacts may exercise choices regarding these communications as follows:
8. What is Avalon's policy on kids' privacy?
Avalon and our Site are not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If Avalon learns that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13, please contact us using the information detailed in the "Contacting Us" section below.
9. Access, Objection, Correction and Deletion
In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal data have been or will be disclosed. You may also have the right to receive a copy of the personal data you have provided and/or request its deletion.
Our clients are responsible for managing any request made by their employees or customers regarding access to and rectification of their personal information that is transferred to us. However, if you have questions about your rights, please feel free to contact using the contact information detailed in the "Contacting Us" section below.
10. Your California Privacy Rights
If you are a California resident, California law provides you with the following rights with respect to your personal information:
When you exercise these rights and submit a request to us, we will verify your identity by asking you for your email address, telephone number, information about your company's contract with Avalon, or the last four digits of a credit or debit card used at Avalon. We also may use a third party verification provider to verify your identity.
Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
Please note: If you are a customer of one of our clients, you should contact them first concerning your California privacy rights.
11. Transfer of personal information to other countries
In some cases, personal information that we process, including information from our clients and their employees and/or customers located in various countries, including in Canada, the EU and Switzerland or relative to queries or visitors to the Site may be transferred to the United States or other countries that may not have data privacy laws that provide the same protection as the countries where you reside. You understand that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions.
12. Right to Lodge Complaints
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or in the United States. For information on how you can file a privacy complaint with the Federal Trade Commission, please visit: https://www.ftccomplaintassistant.gov/
This policy is effective October 28, 2022.
14. Contacting Us