Afiniti Services Privacy Policy

Updated May 2, 2017
Effective June 2, 2017

This privacy policy covers Afiniti’s (“we,” “us,” or “our”) collection, use, and disclosure of information in connection with the services that we provide to our clients. To learn about how Afiniti collects, uses, and discloses information through our website, the Afiniti Portal, and the Afiniti AIMS Portal, please visit the Afiniti Website and Portal Privacy Policy.

Afiniti’s services enhance customer service interactions by efficiently pairing customers with customer service representatives. As described in this privacy policy, Afiniti receives and analyzes information from internal client databases, customer service representatives, and third parties to provide a holistic view of individual customers and customer service representatives. We then use artificial intelligence algorithms to determine the optimal fit between customers and representatives and to improve interactions conducted over the phone, live chat, email, online video, and in-person applications. If you have any questions about our services or this privacy policy, please contact us at privacy@afiniti.com.


Information Collection

Afiniti does not collect information directly from our clients’ customers or individual callers. Instead, we receive and access information from our clients’ internal databases, their customer service representatives, and other third parties during the course of providing our services to each client. The types of information that Afiniti receives and accesses will vary for each client, but it may include information such as:

  • Customer relationship management (CRM) information. We access a variety of information stored in our clients’ CRM databases during the course of providing our services. This information may include, for example, an individual customer’s name, phone number, age, location, account number or other customer identifier, account history (including current account status, purchase or transaction history, and customer tenure), and customer service call history and outcomes.
  • Information from third parties. We may receive information about individuals from various third parties, including certain demographic, inferred-interest, census, or other publicly available information.
  • Performance information. We may receive information about the performance of our clients’ customer service representatives, such as information pertaining to their service history, call outcomes, transactional or sales information, and their location.
  • Survey information. We may collect information from our clients’ customer service representatives when they voluntarily submit surveys through the Afiniti AIMS Portal, as described in the Afiniti Website and Portal Privacy Policy. This information may include the representative’s first and last name, email address, username, and any information that our clients’ employees voluntarily submit to us. We use this information to provide the services to our clients, as described in the “Information Use” section below.

Afiniti also may receive or access additional information from our clients or third parties while providing the services. In those circumstances, we may combine such information with the information listed above, and we will treat the combined information in accordance with this privacy policy.


Information Use

Afiniti uses the information described above to provide the Afiniti services to our clients. For example, Afiniti may use the information that it collects to:

  • Identify individual customers’ needs, requests, habits, or preferences in real-time;
  • Assess customer service representatives’ skills, abilities, experience, or expertise in real-time;
  • Match customers and customer service representatives in real-time, based on our assessment of the optimal fit or efficiency for responding to customer service requests, and route calls to the appropriate customer service representative;
  • Build, evaluate, and improve Afiniti’s models and algorithms;
  • Analyze the effectiveness of Afiniti’s services;
  • Generate and analyze trends in the aggregate; and
  • Comply with legal and/or regulatory requirements

Information Disclosure

Afiniti may disclose the information it collects to third parties in limited circumstances, such as:

  • Affiliates. We may share information with our corporate affiliates for the purposes described in this privacy policy.
  • Third-party service providers. We may use third-party service providers to help us provide our services, such as managing and maintaining our information systems. These service providers may collect and/or use your information to assist us in carrying out the purposes discussed in this privacy policy. Transfers to subsequent third parties are covered by the provisions in this privacy policy regarding notice and choice and the service agreements with our clients.
  • Legal purposes. We may use or disclose information to third parties when we believe, in our sole discretion or in consultation with our clients, 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.

Afiniti is responsible for the processing of personal data it receives under the Privacy Shield Framework and subsequently transfers to a third party acting as an agent on its behalf. As noted below, Afiniti complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.


International Transfers, EU-U.S. Privacy Shield, and Swiss-U.S. Privacy Shield

We may transfer and process the information that we collect in connection with our services to the United States or another country outside your country of residence. Afiniti also may subcontract the processing of your information to, or otherwise share your information with, affiliates or third parties in the United States or another country. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By accepting this privacy policy, using our clients’ services, or providing information to us, you expressly consent to such transfer and processing.

Afiniti complies with the EU–U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States, respectively. Afiniti has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Afiniti is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Afiniti may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.


Access to Data Controlled by our Clients

Afiniti has no direct relationship with the individuals whose personal data we process. If you are a customer of one of our clients who seeks access, or who seeks to correct, amend, or delete inaccurate data, please contact the client (the data controller) that you interact with directly. Afiniti will respond to the client’s request to amend or delete your data within 30 business days.


Choice

We process information for our clients. If you are a customer of one of our clients and would no longer like to be contacted by one of our clients that use our service, please contact the client that you interact with directly.

We also offer individuals the opportunity to opt out of Afiniti’s services. Please send an email to privacy@afiniti.com to initiate a request for Afiniti to stop using your information to tailor your customer service experience.


Data Retention

Afiniti will retain personal data we process on behalf of our clients for as long as needed to provide services to our clients. Afiniti also will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.


Security

The security of your information is important to us. We use commercially reasonable physical, technical, and administrative safeguards to protect your 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 information. If you have any questions about the security of your information, you may contact us at privacy@afiniti.com.


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 will notify you by means of a notice on this website prior to the change becoming effective. We encourage you to review this page periodically for the latest information on our privacy practices.


Contact Us

If you are a client and would like to update or delete your Afiniti Portal account, please contact us at support@afiniti.com. We will respond to your request within a reasonable timeframe. If you have questions regarding our privacy policy or practices, please contact us at privacy@afiniti.com. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
For all other inquiries, please visit our contact page or write to us at:
Privacy @ Afiniti
1700 Pennsylvania Avenue
Suite 560
Washington, DC 20006

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