Privacy policy

Effective: October 19, 2021 | Last updated: November 2023 | Last reviewed: November 2023

Introduction

This privacy policy covers Afiniti’s (“we,” “us,” or “our”) collection, use, and disclosure of personal information through the Afiniti website (the “Site”) and in various services provided by Afiniti to its clients. This privacy policy also describes your rights and choices with respect to your personal information. If you have any questions about this privacy policy, please contact us at privacy@afiniti.com.

For the purposes of data protection laws and regulations, Afiniti may be a controller (or joint controller) of the “Personal Data” or “Personal Information” (as defined below) we hold about you (i.e., Afiniti is responsible for, and controls the processing of your Personal Data) or a processor or service provider, depending on the service, data, or how Afiniti is situated with respect to its clients and you. This privacy policy does not apply where we are a processor or service provider. Where that is the case, each of our clients would be the controller and their respective privacy policies will apply.

If you are a resident of the state of California, please see the California Privacy Disclosures section below for additional California-specific privacy disclosures.

Information Collection

Under data protection laws and regulations, some of the information processed by Afiniti is defined as “Personal Data,” or “Personal Information,” which means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The categories of information we may collect include:

• Personal Information about website visitors and prospective clients or partners. We collect Personal Information from website visitors and prospective clients or partners who contact us through our Site. In this context, we may collect your first and last name, phone number, email address, and any other information that you voluntarily submit to us through our “Contact Us” form, Afiniti Link Interest Form, or other means of communication.
• Personal Information about prospective employees. We collect information about prospective employees when they submit a job application form on our Site. For example, we may collect an applicant’s first and last name, phone number, email address, city and country of residence, and any other information that the applicant voluntarily submits to us, such as information contained in a cover letter, resume, or curriculum vitae.
• Personal Information about the employees of our clients or partners when you contact us for customer support, for example, if you are having any technical issues when using our services. We collect information about our clients’ and partners’ employees such as their e-mail address, employee ID, as well as details of interactions with us through Afiniti’s service desk (the “Service Desk”). The Service Desk offers 24/7 telephone support should you encounter any issues with our services.
• Information about the original or current provider of your telephone number. We receive information about the original or current provider of your telephone number from third parties for the following purposes: to (i) build, evaluate and improve Afiniti’s models and algorithms for optimizing call routing; (ii) analyze the effectiveness of Afiniti’s services; and (iii) generate and analyze trends in the aggregate.
• Other information collected via passive collection and tracking technologies. Like most websites, in addition to the information described above, we also gather certain other information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, general location, and/or clickstream data. We and our third-party service providers may collect such information using the following technologies:
  • Server Logs. When you use the Site, we automatically receive and record certain information from your computer (or another device) and your web browser. To collect such information, we may use server logs or applications that recognize your computer and gather information about its online activity.
  • Cookies and similar technologies. Afiniti and our service providers use cookies and similar technologies to provide our Site and ensure it works for you, analyze trends, administer the Site, track users’ movements around the Site, and gather information about our user base as a whole. Please see the table in the ‘Cookies’ section below which further describes the cookies we enable on the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete existing cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.

Analytics Provided by Others

We partner with certain third parties to engage in analytics, auditing, research, and reporting. These third parties may use server logs or pixel tags, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics and Cloudflare Web Analytics to help collect and analyze certain information for analytics purposes. You may opt out of the use of cookies by Google Analytics here. These companies and others may use cookies, pixel tags, or similar technologies in order to analyze and track data, determine the popularity of content, and better understand your activity.

We may combine the information that we collect with additional information that we or third parties collect in other contexts, such as our communications with you via email or phone, or your customer service records. In those circumstances, we will treat the combined information in accordance with this privacy policy. We may also derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your approximate location based on your IP address.

Cookies

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Information Use

Afiniti uses the information that it collects for a variety of purposes, including to:

• Contact our clients and partners or prospective clients and partners, respond to requests for information about Afiniti, and send marketing emails;
• Communicate with you regarding changes to our policies, other terms and other administrative information such as reminders and technical updates;
• Process and evaluate job applications that we receive from prospective employees;
• Administer the Site, conduct internal auditing, and troubleshoot technical or user issues on the Site;
• Count and recognize visitors and users of the Site and analyze how individuals use our services;
• Improve our existing products and services or create new products and services;
• Assist you with your customer support queries should you encounter any problems when using our services, for example, when you liaise with the Service Desk. Please note that we may record your interactions with the Service Desk for the purposes of quality assurance and for training purposes. However, we will make reasonable efforts to notify you before any recording takes place;
• Prevent and detect fraud and other activities that may violate Afiniti’s policies in order to protect the security of Afiniti, our property or the property or physical safety of any person or third party;
• Generate and analyze trends in the aggregate; and
• Comply with legal and/or regulatory requirements.

For the purposes of UK and EU data privacy laws, our lawful basis for the above purposes is generally that these purposes are necessary for our legitimate interests in one or more of the following: business administration, ensuring you and your business are duly provided with our services, responding to your queries and resolving any issues you may have regarding the Site or our services, ensuring the quality of our services, making sure our staff are well-trained, making you aware of any changes to our policies, terms and other such technical updates, providing you with information you have requested, generating and developing our business, informing our marketing strategy, maintaining security and preventing fraud, improving the Site to ensure that content is presented in the most effective manner for you and protecting Afiniti, its staff, its property, third parties or members of the public.

From time to time, we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services. You can opt out of receiving marketing messages at any time by clicking on the unsubscribe link at the bottom of our marketing emails.

We may aggregate any of the information we collect (so that it does not directly identify you). We may use aggregated information for purposes that include testing our IT systems, research, data analysis, improving the Site and developing new products and features. When we do this, we will not seek to re-identify such information. We may also share such aggregated information with others.

Information Disclosure

Afiniti may disclose the information that it collects to third parties for a variety of purposes, such as:

• Affiliates. We may share Personal Information with our corporate affiliates for the purposes described in this privacy policy.
• Third-party service providers and business partners. We may use third-party service providers engage our business partners to help us provide our services, such as managing and maintaining our information systems.
• Legal purposes. We may use or disclose your Personal Information to third parties when we believe, in our sole discretion, that doing so is necessary:
  • To comply with applicable laws or a court order, subpoena, request from government or law enforcement, or other legal process;
• To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
• To establish, protect, or exercise our legal rights or defend against legal claims; or
• To facilitate a merger, acquisition, or sale of all or a portion of Afiniti’s assets. Where appropriate, you will be notified via email or a prominent notice on our website of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.
• De-identified or aggregated information. Afiniti also may share de-identified and/or aggregated information about users of our services, such as by publishing a report on trends in the usage of the Sites.
• With your consent. We may disclose your information to any other third party with your prior consent.

Your Rights and Choices

Depending on where you live, you may have the following rights in respect of your Personal Information that we hold. If you wish to exercise one of these rights, please contact us at privacy@afiniti.com with “Consumer Rights Request” in the subject line or, if you reside in the United States, you can also call 1-866-467-8688 and enter the Service Code 1144. For your protection, we might only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. Further, please note that if the exercise of these rights limits our ability to process Personal Information (such as in the case of a deletion request), we may no longer be able to provide you our products and services or engage with you in the same manner.

a) Right of access. The right to obtain certain information about and obtain access to your Personal Information.

b) Right to rectification/correction. The right to obtain rectification or request correction of your Personal Information where that Personal Information is inaccurate or incomplete.

c) Right to erasure/deletion. The right, in certain circumstances, to obtain the erasure or request deletion of your Personal Information.

d) Right to portability. The right to portability, where it applies, allows you to move, copy or transfer Personal Information easily from one organization to another.

e) Right to restriction. The right, in some circumstances, to require us to limit the purposes for which we process your Personal Information.

f) Right to object. The right to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the unsubscribe link set out in any marketing communication you receive.

g) Right to withdraw consent. If you have provided consent to any processing of your Personal Information, you have a right to withdraw that consent.

h) Right to nondiscrimination. We will not discriminate against you for exercising your privacy rights.

Data Retention

Afiniti will retain information for as long as reasonably necessary to accomplish the purposes described in this privacy policy.

To determine the appropriate retention period for Personal Information, we consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.

Afiniti may need to retain and use certain information for an extended period to comply with our legal obligations, resolve disputes, and enforce our agreements.

California Privacy Disclosures

These California Privacy Disclosures apply to you if you are a resident of the state of California. The California Consumer Privacy Act (the “CCPA”) requires us to disclose certain information regarding the categories of Personal Information we collect. For the business and commercial purposes described in the Information Disclosure section above, we disclose the following categories of Personal Information to the following categories of recipients:

We do not sell the Personal Information we collect.

Your California Rights

As a California resident, you have the right to request access to and correction or deletion of your Personal Information. Please see “Your Rights and Choices” above for more information about how to exercise your rights and how we will verify your requests. If you are submitting a rights request as an authorized agent, you are required to submit proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive Personal Information in connection with this request, such as a driver’s license or other government-issued ID. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm you have permission to submit this request. If you are an authorized agent seeking to make a request, please email privacy@afiniti.com with “Authorized Agent California Rights Request” in the subject line or call 1-866-467-8688 and enter the Service Code 1144.

Additional disclosures for individuals in the EU

Legal basis for processing

If you are an EU resident, our legal basis for processing Personal Information, as described above, will depend on the type of information at issue and the purpose for which it is collected and used.

The lawful bases for which we process your Personal Information are:

1. the provision of Personal Information by you may be necessary for the performance of any contractual relationship we have with you;
2. where it is necessary for compliance with our legal obligations;
3. where it is necessary to pursue our legitimate interests except where such interests are overridden by your data protection interests or fundamental rights and freedoms.

Further details of our legitimate interests are set out in the ‘Information Use’ section above.

In addition to the rights described above, you also have the following rights:

Right to lodge a complaint. Where UK or European data privacy laws apply, you also have the right to lodge a complaint to your local data protection authority. Further information about how to contact local data protection authorities in the EU is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm and in the UK at https://ico.org.uk/make-a-complaint/.

Third Party Sites and Content

Our Site may include links to other websites and embedded content such as videos provided by third parties or social media plugins. Those parties’ privacy practices may differ from those of Afiniti. If you engage with any of those third-party providers, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

International Data Transfers

In providing our service to clients, it may be necessary for us to transfer your Personal Information outside of the country in which it was collected, or your country of residence, when transferring it to other entities or offices within Afiniti and our service providers and business partners located in other countries. If you are based in the UK or European Economic Area (“EEA”), your Personal Information may be transferred to or accessed from territories outside the UK or EEA which are not governed by data protection laws equivalent to those in force within the UK and EU respectively.

Where applicable data protection laws apply, and Personal Information is transferred by us, and/or made available, to a recipient outside the EEA or UK, we take steps to put in place appropriate safeguards to protect your Personal Information, including: transferring your Personal Information to a country, territory, sector, or international organization which the appropriate supervisory authority has determined ensures an adequate level of protection, as permitted under applicable data protection laws; or entering into standard contractual clauses in a form approved by the appropriate supervisory authority, obliging recipients to protect your Personal Information as required under applicable data protection laws.

Further details regarding the appropriate safeguards we put in place are available upon request.

Security

The security of your Personal Information is important to us. We use commercially reasonable physical, technical, organizational and administrative safeguards to protect your Personal Information against loss or unauthorized access, use, modification, or deletion. However, no security program is 100% secure, and thus we cannot guarantee the absolute security of your Personal Information. If you have any questions about the security of your Personal Information, you may contact us at privacy@afiniti.com.

Children’s Privacy

The Site is not directed to, and we do not knowingly collect or solicit Personal Information from, children under the age of 18.

Changes to this Privacy Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we may deem it appropriate to notify you by means of a notice on our Site. We nonetheless encourage you to review this page periodically for the latest information on our privacy practices.

Contact Us

If you have any questions about our privacy practices, or would like to contact our Data Protection Officer, please contact us at privacy@afiniti.com.

For questions regarding our privacy policies or practices, you can also visit our contact page or write to us at:

1701 Pennsylvania Avenue NW,

Suite 600

Washington, DC 20006