Legal Agreements

Privacy and Data Processing Policy

Updated and effective: March 10, 2020

This Privacy and Data Processing Policy reflects our Aventiv Technologies global privacy practices and standards as of the effective date.

I want to know about:

Who we are

Aventiv Technologies is a diversified technology company that provides innovative solutions to customers in the corrections and government services sectors. Aventiv Technologies is the parent company of Securus Technologies, JPay and AllPaid, leading providers of innovative products and services. The collective power of these unified organizations delivers superior value and service to all of our customers nationwide. This privacy notice applies to Aventiv Technologies and all its subsidiaries. For sake of simplicity, Aventiv Technologies and its subsidiaries are simply called Aventiv for the rest of this notice.

Policy Questions or Individual Rights Management Requests?

If you have a privacy question or wish to exercise your individual rights, you may contact the Aventiv privacy team and our Chief Compliance Officer any time at privacy@securustechnologies.com or privacy@aventiv.com, by calling 800-524-5547 or by using the Policy Questions button on this page. We appreciate the opportunity to address your questions and concerns.

Our Data Values

At Aventiv Technologies, protecting your privacy is fundamental to the way our company and its subsidiaries conduct our business.

Embedding privacy and security. We strive to embed privacy and security into our strategy and operations.
Responsible use. We strive to promote responsible data use and stewardship among all our employees, contractors, subsidiaries and suppliers.
Purpose driven. We only collect, use, and share the information we need to provide and operate our solutions for our customers.
Always improving. We process data about the way we operate our own business in order to help us better understand the needs of our customers, prospects, and other stakeholders, and to continue to improve user experience, features, and functionality of our solutions.

Your Rights

If certain privacy and data protection laws apply to the personal information we process about you, you may make any of the requests listed below related to your personal information. You do not have to pay a fee, and we will aim to respond to your request within 45 days. If you make any of these requests, we will not discriminate against you. We will honor the requests you make related to your rights as the law allows and requires. This means in some cases there may be legal or other official reasons that we may not be able to address the specific request you make related to your rights. You may:

request access to the personal information we process about you;
request that we correct inaccurate or incomplete personal information about you;
request deletion of personal information about you;
request restrictions, temporarily or permanently, on our processing of some or all personal information about you;
request that we transfer personal information we process about you to you or a third party; and
request opt-out or object to our use of personal information about you where our use is based on your consent or our legitimate interests.

Unless otherwise addressed by applicable law or regulations, your use of our site constitutes your consent to our use of cookies (discussed below), and the collection, processing and transfer of your personal information as described in this Policy.

What personal information do we collect?

The data we process about you depends on who you are and how we interact with you. Personal information is data, which identifies you or makes you identifiable. It includes data that could be used to identify, locate, track or contact you.

If you open an account, create a profile or register for online account access:

Accessing our services: You may be asked, by a live agent, computer, telephone, mobile device or otherwise, to provide us with identifiers, such as your name, date of birth, social security number, e-mail address, mailing address and phone number. You may be asked to provide a driver’s license and financial account information, such as a credit card number and associated information for certain services. We may also collect audio/video and biometric data when you purchase or use our products or services, including your voice and video data. We may record your biometric data such as your voice and your video image.

We maintain and update this information as we continue to engage with you and use it as described under the Legitimate Interests processing purposes described below.

Using our services: If you are a user of our services, we may record your actions while you are using our services, such as phone number, your conversation with one of our representatives, email address, computer or device IP address and MAC address, time and length of call, PIN number of inmate who connects to call, credit or debit card information and tickets filed on your behalf related to our service platform.

Payment Information: if you are using our services to make payments, we are required to collect identification and financial information like your name, address, drivers’ license number, social security number, type of payment you are making, or information related to the purpose of the payment. We may need to run background checks on anyone involved in the transaction to satisfy our legal requirements.

Receiving marketing, sales-related and business development communications from us: If our marketing team or a member of our sales or business development teams sends communications to you, we process your name, phone number, email address, postal address, job title, job function, organization name, IP address, device type, email view information including IP address and associated city, and information about which of our solutions you use or which may be of interest to you.

Market research and surveys: If you participate in our market research and surveys, we process identification, professional and commercial information such as email address, job title, phone number, survey responses, organization name, job function, state, country, and any comments you provide.

Third party sources: if you use our services, we may obtain information from third parties about the billing name and address associated with your phone number.

If you visit our websites or access our Apps:

Our websites and Apps: We process personal information about you that we collect either directly, through forms or data entry fields on our website or Apps, or through passive collection by cookies and other data collection technologies. The types of personal data we process in each of these contexts is further explained in the following categories:

Contact us and registration forms: We process identification, commercial and professional information such as your name, email address, organization where you work, phone number, job function, job title, address, and any comments you provide.
Consumer opinion surveys: We process your survey responses.
Cookies and other data collection technologies when using a browser: We use browser session cookies, which are temporary cookies, which are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, generally after one year, unless you delete them before that time. We group browser cookies on our site into these categories:

Required cookies: These cookies are necessary to enable the basic features of this site to function, such as allowing images to load or allowing you to select your cookie preferences.
Functional cookies: These cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remembering your log-in details or providing us information about how our site is used.

Server log files: We automatically gather server log file information when you visit our websites. This includes Internet activity, such as IP address, browser type, referring and exit web pages, and your operating system.
Individual Rights Manager: When you submit a request related to our processing of personal information about you, we process your name, email address, type of request, the individual type you select on the form, and any comments you provide.

If you are an employee, contractor, job applicant, or former employee:

Applying to work at Aventiv: If you apply to work at Aventiv, we process personal identification information about you and your professional experience, education and training such as your application, your name (and any former names), postal address, email address, phone number, universities attended, academic degrees obtained, grades, professional certifications and licenses, employment history, and curriculum vitae or resume. In many cases as an applicant, you may provide information through our recruiting service providers, which are only authorized to collect, process and store your information as necessary and as directed by us.

Offer of employment or contractor position: After making an offer of employment or a contracted position we collect personal information to conduct background and professional reference checks in accordance with applicable laws. We will collect personal information about the position to which you have been appointed, your job title at Aventiv, the compensation or project-based contracted rate we offer to you, whether you accept the offer, your signature, and your starting compensation or project-based contracted rate, and your start date at Aventiv.

Employment-Related Background checks: Prior to commencement of your employment with us, we engage service providers to conduct background checks that involve the necessary personal information processing as permitted by the laws in the location in which you reside and/or work. More details are provided to you in the context of our request to you to complete these checks.

As an employee or contractor of Aventiv: We may process personal identifying and employment information about your benefits, nationality, residency status, email address, office or other workplace location, work phone number, mobile phone number, photographs, passport, visas, marital status, disability status, beneficiaries, emergency contact details, financial account information, social security number or other government-issued identification number, holiday and paid time off days, salary, incentive compensation, assigned projects, performance against your assigned goals, training completed, any performance improvement plans, any disciplinary actions taken, system accounts, technology and physical assets provided to you, your role and actions taken in connection with Aventiv projects and processes. You may also be required to provide personal information to government authorities for regulatory filings and background checks.

If your employment with Aventiv ends, we process personal information necessary to offboard you from Aventiv, including deactivation of your access to our systems, fulfilling our financial, benefits, and related obligations with respect to the end of your employment with Aventiv.

Why do we process personal information?

The reasons that we process about you depend on who you are and how we interact with you.

If you use our services:

We use the personal information we collect from you to fulfill the purpose for which you provide it. We may use your personal information:

To process transactions, manage your account and administer our services and website. We will not sell or give your personal information to any other commercial company without your consent, except as is necessary to provide you with the products or services requested or as otherwise stated in this Privacy Policy;
To send you periodic e-mails pertaining to your order, as well as occasional Aventiv news, updates, and related product or service information;
To personalize your experience and better respond to your individual needs; and
To improve customer service, our website and services and assess our services.

Where permitted by law, we may share your information with our affiliates, service providers, and vendors for the above purposes.

Our legitimate interests – We process personal information about you based on our legitimate business interests for the following purposes, to which you may exercise Your Rights to object as described above:

To fund accounts and provide resources for use of our communications services based on our legitimate business interest of collecting funds for services;
To provide additional solutions you request based on our legitimate business interest to respond to your reasonable requests and to retain you as a customer or partner;
To better understand the needs of the users of our services, we analyze our interactions with you online and offline and store that information in a quantitative way. This helps us continue to improve how we provide information and engage specifically with you, including to help us determine when you might be ready to make a purchase based on repeated interactions with Aventiv. We do not make any automated decisions about you that would result in legal or other similarly significant effects on you;
To determine whether, when, and the IP address and associated city of, a marketing, sales, or business development email communication we sent was viewed based on our legitimate interest to effectively manage and improve upon such communications with you;
To understand the agency or organization that you work for and your prior experience based on our legitimate interest to tailor our communications with you to improve our engagement with you;
To understand your communication needs based on our legitimate interest to develop and enhance our solutions to address your needs and to make them more relevant to you;
To meet contractual obligations with our Facility customers and provide them with the ability to monitor and analyze transactions and communications; and
To manage our legal, financial, policy and regulatory compliance responsibilities and to demonstrate our compliance upon request.

Statistical and research purposes: We may further analyze use of our solutions, and characteristics of those who use our solutions to help us understand and make decisions about customer and market needs, to improve our solutions, to design new solutions, and to inform partnership and business development decisions.

If you visit the websites and online properties we provide:

We process personal information about you to:

Share your name or contact information in order to verify your identity for purposes of addressing privacy-related requests or complaints; however, please be aware that if we cannot share this information, then we may not be able to address your requests.
Respond to your individual rights requests.
Manage your consent preferences.
Deliver the resources and information you have requested online.
Send direct email marketing communications about our solutions, events and related resources that may be of interest to you.
Use cookies and other data collection technologies to help you navigate our website or technical solutions, personalize and provide a more convenient experience to you, analyze which pages you visit, which features you use in our solutions, and provide features such as social sharing widgets and videos, measure advertising and promotional effectiveness, assess which areas of our site you visit to remarket to you after you visit our site, and to provide content to you from our third party content partners.

Unless an email is required to process services for you, you may withdraw your consent to our emails at any time by clicking the “unsubscribe” link in the email communications we send to you.

You may also withdraw consent by exercising Your Rights as described above, including through our Individual Rights Manager.

To investigate requests or concerns based on our legitimate interest to ensure that such requests or concerns are addressed appropriately;
To send optional customer satisfaction surveys once your request or concern has been resolved based on our legitimate interest to continue to improve our processes;
To evaluate the characteristics and needs of our customers based on our legitimate interest in improving the solutions we offer and provide;
To communicate with you about Aventiv events, industry or services-related news based on our legitimate interest in engaging with you as a user of our services;
To conduct online consumer surveys to learn about your views on our services based on our legitimate interest in better understanding the communications and technology market and to improve our solutions; we do not directly collect any personal information about you when we conduct these surveys, however cookies and data collection technologies may be used to manage the delivery of the surveys; and
To administer our website and our technical solutions and to understand how our website visitors navigate through our websites and technical solutions based on our legitimate interest to continuously improve the experience for our users.

Statistical and research purposes: We may further analyze information we gather online to improve the online experience, resources and tools we provide to our users.

If you are an employee, contractor, job applicant, or former employee:

If you have a contract or other agreement with us, we process personal information about you to fulfill the specific obligations we have to you under the applicable contract or agreement such as:

Payment of project fees to contractors; and
Managing performance obligations under employment contracts, where applicable.
Complying with industry procedures and government regulations to verify your identity, the identify of your ownership or control persons, and confirm other details of your identity.

Our legitimate interests – we process personal information about you based on our legitimate interests to establish and manage our relationship with and responsibilities to you, to industry oversight bodies and governmental agencies and for effective operation of our business, such as to:

Recruit new talent to join Aventiv;
Onboard employees and contractors to Aventiv;
Activate customers for certain Aventiv services;
Grant and ensure appropriate access to Aventiv systems and facilities;
Ensure the security and safety of the workplace and the tangible and intangible assets for which we are responsible;
Assign roles and responsibilities;
Manage team and cross-functional communications and collaboration;
Promote a positive workplace culture;
Administer payroll, benefits administration, award and pay incentive compensation;
Invoice payments;
Manage Aventiv projects and processes;
Maintain corporate, financial and other essential business records and reporting;
Evaluate financial and operational performance; and
Manage compliance, including, but not limited to our privacy, security, accounting, labor and employment, Office of Foreign Assets Control Specially Designated Nationals List, and other legal and regulatory obligations.

Statistical and research purposes: We may further analyze information to evaluate and understand employee engagement and to develop plans to continuously improve our workplace culture.

How do we share data about you?

At Aventiv, we only share personal information in ways that we tell you about. We do not sell or rent personal information to businesses for commercial purposes and we do not share personal information with third parties that are not owned by us or under our control or direction except as described in this Policy. The personal information we share may identify you or may include professional, employment, audio/video or biometric data about you.

Service providers. We share personal information with service providers that help us with our business activities. They only are authorized to process that information as necessary and as directed by us.

Required by law. We may be required to disclose personal information in response to lawful requests by government authorities, including requests from national security agencies or law enforcement.

Safety, fraud prevention, government requests and protection of our rights are all reasons where we may share personal information where we believe in good faith it is necessary.

Support of law enforcement activities. Under appropriate circumstances, we may share your contact information, account information and history, call details, financial transactions and your voice and video records with law enforcement personnel and/or correctional facilities and certain third parties for use in connection with and in support of law enforcement activities. Any calls or visits using our services may be monitored or recorded. All of this data may be stored, monitored, searched, analyzed and transferred among law enforcement agencies for law enforcement purposes.

Correctional Facilities. When you use our services to communicate with or process a transaction on behalf of an inmate housed in a Correction Facility, Facility staff may access your personal information in order to operate these Facilities, conduct investigations, and/or to verify transactions. The information accessible to Facility staff includes transaction information such as your name, address, zip code, phone number, and email; the inmate ID of the recipient; the transaction amount; and your transaction history as well as any content transmitted to and from the inmate and/or the Facility in connection with your use of our services.

Mergers, acquisitions, divestitures, or asset sales may involve sharing your personal information, but only if the acquiring organization agrees to this Policy’s protections.

Keeping and Securing Your Data

Except as we describe below, we will keep personal information about you for as long as we provide solutions to you, as long as you work for or with us, or as long as we are addressing a concern, question, complaint, or request you have made to us, as applicable to our interactions with you. If we have a contract or other agreement that applies to your personal information, we will follow the retention obligations of that agreement.

We may keep data longer if we have a legal or contractual obligation to keep it or to maintain necessary records for legal, financial, compliance, or other reporting obligations, and to enforce our rights and agreements. We also may keep data about you for statistical analysis or research purposes. Upon completion of a transaction, your private information (e.g., credit cards or debit card number, bank routing or checking account numbers) will not be stored on our servers.

We take appropriate security measures to protect personal information against loss, misuse, and unauthorized access, alteration, disclosure or destruction. We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information and will restore the availability and access to data in a timely manner in the event of a physical or technical incident.

Children’s Privacy

Our websites, products and services are not directed to children. We do not knowingly seek or collect personal information from children under the age of 18 without verifiable parental consent or authorized orders from courts or governmental agencies. When we provide services related to support payments for a child, a child’s parent provides us with information that allows us to process the requested services, including personal information about the child.

If we learn that we have collected personal information from a child 17 years old or younger without verified parental consent or authorized order, we will delete that information as quickly as possible. If you learn that a child’s information has been provided to us without parental consent or authorized order, please contact us as soon as possible as directed above.

Compliance with Other Laws

In order to comply with the Financial Modernization Act of 1999, also known as the Gramm-Leach-Bliley Act, JPay maintains a customer privacy program designed to ensure the security, integrity, and confidentiality of non-public customer information.

Moreover, JPay ensures compliance with US Government regulations implementing the Unlawful Internet Gambling Enforcement Act (UIGEA). UIGEA prohibits businesses from processing restricted transactions. A restricted transaction involves knowingly accepting a transmittal of any credit, funds, instrument, or proceeds in connection with the participation of another person in unlawful internet gambling. In the event that JPay receives knowledge that a customer in engaged in illegal internet gambling, JPay will close the customer's account and cancel the transactions.

Organizational Information and Links to Other Sites

Organizational information – In the course of using our solutions, we may ask you to provide information related to the organization where you work. This may include information about your organization’s practices, policies, processes, technology, finances, and supporting documentation. This information is stored on Aventiv systems or files, and we use it to provide solutions to you or utilize the products and services you provide to us and in accordance with the terms and conditions of agreements between Aventiv and your company,

Links to other websites – This Policy applies only to Aventiv practices, technologies, and services. Our online properties may include links to websites and online services that are operated by other companies not under the control or direction of Aventiv. If you provide or submit personal information to those websites or online services, the privacy policies on those websites or online services apply to your personal information. We encourage you to carefully read the privacy policies of any website you visit.

Changes to this Policy

We may make changes to this Policy from time to time based on changes to applicable laws and regulations or other requirements applicable to us, changes in technology, or changes to our business. Any changes we make to the Policy in the future will be posted on this page and we also will post a notice on our home page that this Policy has changed.

Appendix A: Policy Questions & Individual Rights Form

Aventiv Privacy Program Management

You may use this form, our phone number 800-524-5547 or our email privacy@securustechnologies.com or privacy@aventiv.com to submit a question about Aventiv’s Privacy Practices or to submit an Individual Rights request related to the data we process about you. If you contact us to exercise your individual rights, we may have additional questions to verify your identity.

Please do not submit any sensitive information about yourself or others in the Comments box.