Last Updated:  September 30, 2016

Our Commitment

Avention, Inc. (“Avention” or “We”) is committed to protecting the privacy of visitors to the Avention website (“Website”) and users of Avention products and services (collectively, the “Products”). We are providing this privacy policy (“Policy”) to you because we take privacy issues seriously. We think you should know how we may be collecting and using information about you through the Website and in connection with your use of the Products, as well as information we receive from the European Union (which is addressed in “EU-US Privacy Shield Compliance” below). This Policy does not apply to information collected by third-party websites that may link to or be accessible from the Website or to Avention’s privacy practices associated with offline activities or websites other than the Website.

This Policy describes the personal information we collect about you, why we collect it, how we use it, and when we share it with third parties. In addition, this Policy describes your choices with respect to how we collect and use your information. You may exercise your choices about how we collect and use your information consistent with this Policy at any time. Your continued use of the Website or the Products, or your participation in our contests and promotions, constitutes your acceptance of this Policy and any updates thereto.

The Website is intended for adult audiences only, and neither Avention nor any of our agents or service providers, acting on our behalf, knowingly collects any personal information from anyone under 13 years of age, nor do we benefit from allowing another to collect personal information from anyone under the age of 13 on our behalf.  If you are under age 13, please do not attempt to register for any portion of the Website that requires registration (including, without limitation, the “Live Chat” feature, the “Contact Us” form, or the “Request a Free Trial” option) or otherwise provide any personal information about yourself to us. If we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible.  If you believe that we might have any personal information from a child under the age of 13, please contact us immediately.

Avention shall separately address the handling of any personal information you disclose in connection with your use or access of, purchase or subscription to, any Product in the appropriate contract and otherwise in separate Product terms and conditions. To the extent that this Policy conflicts with any executed contract between you and Avention with respect to a Product, the terms of such executed contract shall govern.

EU-US Privacy Shield Compliance

As part of our commitment to protecting your privacy, Avention complies with the EU-U.S. Privacy Shield Framework as set forth by the United States Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Avention has certified to the Department of Commerce that it and the entities it lists in its certification adhere to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. Additional information about the Privacy Shield Principles can be obtained, and our certification may be viewed, at https://www.privacyshield.gov.

To the extent that visitors to the Website and users of the Products are located in the European Union, such individuals’ information is collected and used in accordance with the other sections of this Policy.  In addition, Avention receives the following personal information from the European Union: (1) customer/prospect contact information, which information Avention uses in the scope of its sales efforts and marketing activities; and (2) executive and business contact information contained within the data supplied to Avention by its third party information providers and/or compiled by Avention through its own collection and research efforts, which information Avention includes in its various business information Products and makes available to customers, prospects, vendors, agents and service providers.

In compliance with the Privacy Shield Principles, Avention commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with questions, complaints, access requests, and any other issues arising under the Privacy Shield should first contact Avention at:

Avention, Inc.
300 Baker Avenue
Concord, Massachusetts 01742
Telephone: 1-978-318-4300
Facsimile: 1-978-318-4690
Email: privacy@avention.com

Avention has further committed to refer unresolved Privacy Shield complaints to the American Arbitration Association, an alternative dispute resolution provider located in the United States.  If you do not receive timely acknowledgement of your complaint from us, or if we have not resolved your complaint, please contact the American Arbitration Association as follows:

American Arbitration Association
120 Broadway
21st Floor
New York, NY 10271
www.adr.org

The services of the American Arbitration Association are provided at no cost to you.  Under certain limited conditions, an individual can invoke “last resort” binding arbitration for complaints regarding Privacy Shield compliance that have not been resolved by any other Privacy Shield mechanism. For more information on this option, visit https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

The Federal Trade Commission has jurisdiction over Avention’s compliance with the Privacy Shield.

Information We Collect About You

Automatic Information Collected Through Computer Tracking

Avention may track and retain information about the computing environment you use to access the Website and Products, such as your IP address, browser type, or operating system. We collect and analyze this information for the continued improvement of the Products, Website, and our business. For example, tracking the computing environments most frequently used by our customers can help us to accommodate the most appropriate browser types and versions. Additionally, our record of IP addresses that access the Products and Website allows us to determine the source or cause of error messages that may appear in the Products or on the Website at any given time, or to assist customers who may be experiencing technical difficulties while accessing the Products or Website.

Personal Information You Provide Through The Website

The personal information you provide to Avention through the Website allows us to determine if you are an authorized user of one or more of the Products, for which you or your organization has paid a fee. We need to know your personal information in order to provide you with all the benefits you are entitled to receive as an authorized user of the Products. For instance, you may be asked to provide us with your physical and online contact information (e.g., name, address, email address, etc.), particularly if you seek customer support from our Help Desk. In addition, we may ask for work-related identifying information (e.g., employer, job title, etc.) in order to inform you of Product updates. Avention may retain the personal information you provide to us in order to more easily assist you with customer service or technical support of the Products and to continue to forward new Product information.

Personal Information Collected In The Scope Of Marketing Activities

In order to improve our Products and facilitate their delivery to you, Avention may collect both personal and non-personal information about you within the scope of our marketing activities on and through the Website.  For example, Avention may collect contact information about you that would include information like your name, address, telephone number, social media handle, and email address when it conducts webinars, demand generation campaigns, contests or trials, when it disseminates white papers, ebooks or similar content, when you click on landing pages, in the course of Pay-Per-Click campaigns, and similar events and methods.

In addition, when you enter Avention contests and participate in other Avention promotions, you provide us with various personal details (e.g., name, company, job title, telephone number, social media handle, and email address), which we may retain and use in furtherance of our marketing activities in accordance with this Policy and specific Avention Contest Rules and Conditions.

When you register as a user of the Products, you have the option to allow us to contact you about our Products. In order to evaluate your use of the Products, Avention may track which functions of the Products you use most frequently. This information will help us provide you with only the most relevant and useful information about the Products, as well as suggestions that could enhance your use of the Products.

How We Use Collected Information

Aggregation Of User Data

Avention may aggregate the information you provide with similar information collected from other visitors to the Website and users of the Products, in order to evaluate or enhance the Website or Products. Specifically, Avention may use the aggregated data to determine the usage patterns or interests of visitors to the Website and users of the Products, or for purposes related to the technical support or security of the Website, Products, and our computer systems. The aggregated data that we evaluate contains no personal information or other information that could identify an individual.  We may, however, associate such aggregated data with personal information or other information separately stored by Avention (e.g., email address, UserID, etc.) that could identify an individual user of a Product as described in “Usage Tracking Within The Avention Products” below.

Usage Tracking Within The Avention Products

We may track usage information within the Products based upon the number of reports, types of reports, and functions that are accessed by a particular UserID. We do this to monitor authorized usage of the Products, respond to questions from the user or its organization, for market research, and to improve the design and functionality of the Products.  Avention customers can also track the total number of reports in the Product that are accessed at the user level or accessed by all users within their organization for administrative purposes.

We may also aggregate corporate or industry information accessed by all of our clients. We do this in order to appreciate the types of companies and industries for which our customers require information, which in turn improves the quality of the Products. Avention does not correlate the accessed corporate or industry information to a specific user or to a particular organization.

User Information To Certain Third Parties

Avention may engage third party providers to collect and use certain information in the manner described in this Policy, in order to enable Avention to provide you with opportunities for additional products and/or services based upon your interests. As a Privacy Shield organization, we have a responsibility for the processing of personal information we receive under the Privacy Shield and subsequently transfer to a third party acting as an agent on our behalf.  As such, Avention will remain liable under the Privacy Shield Principles if our agents process such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to damage.  Avention may also, on occasion, provide some general usage information from the Products to our information providers for royalty-related, usage report, or similar purposes. Any information that we may provide to our information providers contains no personal details about individual users. Additionally, no information that we collect from your use of the Website or Products or that you provide to us is ever sold to third parties. When appropriate or required, we may disclose information, including personal information, collected from your use of the Website or Products to protect our legal rights or in response to a court order or a lawful request by public authorities (including, without limitation, to meet national security or law enforcement requirements), or in connection with a sale or merger of Avention or its assets. Avention will endeavor to make such disclosures subject to protective orders or confidentiality agreements.

With respect to information collected in the course of our marketing activities on or through the Website, Avention may exchange business leads with our affiliates from time to time, including Avention UK Limited and other affiliates. In addition, we may share personal information we collect from contest entrants with our affiliates, including Avention UK Limited and other affiliates. As such, information collected from contest entrants may be shared outside of Avention US. In order to properly conduct Avention contests, Avention UK Limited and other affiliates may, on occasion, contact contest entrants directly.

Additionally, we may, on limited occasions, share your personal information with third party marketing partners. These partners generally consist of persons or entities with whom we maintain a relationship and which offer certain complementary products and services to those Products and services that we offer. We will take commercially reasonable efforts to make sure that such third parties safeguard your personal information. Further, you are permitted at any time to request that we refrain from sharing your personal information with such third parties, or that we disclose who we shared your personal information with. In order to make such requests, please follow the instructions set forth below with regard to requests made in connection with your personal information.

How We Use Cookies

Avention uses cookies to validate users authorized to access the Products. A cookie is a text file that is placed on your computer by a Web server. Avention does not use cookies to track any personal information about a user. For example, the UserID (log in name) and the site ID (company name) are tracked to allow Avention to determine whether or not the user is authorized (i.e. licensed) to access a specific product on the Website. Also, a machine ID is identified to ensure that only one person uses the UserID at one time. In addition, the user may, at his or her option, identify a workgroup or project that in turn establishes a cookie; this option is provided not for Avention’s purposes but to permit a user’s organization to charge back costs internally.  In addition, Avention may contract with third parties who use cookies for certain marketing purposes.

Choices About How We Use And Disclose Your Information

 

Tracking Technologies

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Website or Products may then be inaccessible or not function properly.

Marketing Activities Information

If you do not wish to have your personal information used by Avention to promote the Products in furtherance of our marketing activities or otherwise disclosed to third parties, or if you do not wish for us to share your personal information with our affiliates for the purpose of conducting contests or providing lead information, you can opt out by sending us an email stating your request to privacy@avention.com.

Moreover, you may manage your email subscriptions and opt out of receiving future marketing emails from us at http://info.avention.com/ManageEmailSubscriptions.html, which link is also available when you fill out a form on the Website.  This opt out link is also available at the bottom of each marketing email you receive from us.

Account Maintenance Option

With respect to the Products to which you subscribe, you may access your personal account information electronically for that Product through the Account Maintenance or similar option that is accessible from the shortcuts menu located in the navigation bar or similar menu and location, or by sending a request to Avention for such access at privacy@avention.com. You may change your personal information as often as you like and even print out a copy of the personal information for your records. You may also opt out of receiving communications from us associated with your account by updating your account; provided, that you may still receive certain communications from us at your request or at the request of your organization.  Further, you may elect to change your preferences with respect to your personal information at any time, in accordance with the appropriate procedures set forth herein. To access other information we hold about you, contact us at privacy@avention.com.

Opting Out

You can always choose not to provide information when you are prompted to do so. Note that if you do not provide us with certain mandatory information, then you may be unable to access certain Products or other features we offer, and such Products and features may not function as you desire.  If at any time you are uncomfortable with our use of your personal information, you may opt out by telephone, mail or email as described in “Marketing Activities Information” above, in “Account Maintenance Option” above or in “If You Have a Concern” below.  As discussed above, if you opt out, then certain features and services may be unavailable to you.

Server Security

The Avention servers are physically secure and may only be accessed by Avention’s technical or support personnel whose jobs specifically relate to maintaining the integrity of the Avention servers or supporting product-related functions. Such individuals are required to maintain the security of the servers and the confidentiality of the information contained in the servers.  Avention takes all reasonable and appropriate steps to protect your personal information, including by encrypting such information, maintaining readily accessible steps to limit access, working to detect unauthorized access, and not storing such information any longer than we need to.

Third Party Sites

As a visitor to the Website or a subscriber to the Products, you may decide to visit a third party’s website through links available on our Website or in the Products. Although the Avention branding may still be visible, you will be subject to that third party’s privacy policy, if one exists. We encourage you to review the privacy policies of third party websites you choose to visit. Avention is not responsible for how that third party may collect or use your personal information.

Governing Law

The terms of this Policy are governed by and in accordance with the laws of the Commonwealth of Massachusetts, USA. You should not provide us with any personal information, visit this Website or utilize any of the Products, unless you consent to the application of United States law and, where applicable, Massachusetts law, and to the use and disclosure of your information in accordance with the terms of this Policy.

If You Have a Concern

Should you have a concern about Avention’s collection or use of your personal information, Avention would like to hear about it. You may contact our Help Desk in the United States at 1-800-433-0287 or in the United Kingdom at +44 800 389 4265 or elsewhere at +1-978-318-4650. You may also email us at privacy@avention.com or write to Customer Service at our corporate headquarters identified below.

Who We Are

Avention, Inc. is providing this Policy to you as a registered user of one or more of the Products or as a visitor to the Website. We may change this Policy from time to time and will post those changes here to keep you up-to-date on how we may be collecting and using your personal information. Our corporate headquarters is located at 300 Baker Avenue, Concord, Massachusetts 01742 in the United States. You may reach our U.S. corporate headquarters by telephone at 1-978-318-4300 or fax 1-978-318-4690.

California Civil Code Section 1798.83 permits customers of Avention who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send us an email at privacy@avention.com.