Updated May 2, 2017
Effective June 2, 2017
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.
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
Afiniti may disclose the information it collects to third parties in limited circumstances, such as:
- 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
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.
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 email@example.com to initiate a request for Afiniti to stop using your information to tailor your customer service experience.
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.
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 firstname.lastname@example.org.
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
Washington, DC 20006