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:
what
are my privacy rights
| how
to ask a privacy question or exercise my
privacy
rights
| what
data you collect about
me
| why
you process data about
me
| how
you share data about
me
| how
do
you keep and secure data about
me
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.
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
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.