Introduction

This privacy policy covers Afiniti’s (“we,” “us,” or “our”) collection, use, and disclosure of personal information through the Afiniti website (the “Site”) and in various services provided by Afiniti to its clients. This privacy policy also describes your rights and choices with respect to your personal information. If you have any questions about this privacy policy, please contact us at privacy@afiniti.com.

Our Site may include links to other websites whose privacy practices may differ from those of Afiniti. If you submit information to any of those third-party websites, your information is governed by their privacy statements. We encourage you to carefully read the privacy statement of any website you visit.

For the purposes of data protection laws and regulations, Afiniti may be a controller, joint controller, or co-controller of the Personal Data (as defined below) we hold about you (i.e., Afiniti is responsible for, and controls the processing of your Personal Data) or a processor, depending on the service, data, or how Afiniti is situated with respect to its clients and you.

If you are a resident of the state of California, please click here for additional California-specific privacy disclosures.

Information Collection

Under data protection laws and regulations, some of the information processed by Afiniti is defined as “Personal Data”, which means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. The categories of information we may collect include:

• Personal information about website visitors and prospective clients or partners. We collect personal information from website visitors and prospective clients or partners who contact us through our Site. In this context, we may collect your first and last name, phone number, email address, and any other information that you voluntarily submit to us through our “Contact Us” form, Afiniti Link Interest Form, or other means of communication.
• Personal information about prospective employees. We collect information about prospective employees when they submit a job application form on our Site. For example, we may collect an applicant’s first and last name, phone number, email address, city and country of residence, and any other personal information that the applicant voluntarily submits to us, such as information contained in a cover letter, resume, or curriculum vitae.
• Personal information about the employees of our clients or partners when you contact us for customer support, for example, if you are having any technical issues when using our services. We collect information about our clients' and partners’ employees such as your e-mail address, your employee ID as well as details of your interactions with us through Afiniti's service desk (the "Service Desk"). The Service Desk offers 24/7 telephone support should you encounter any issues with our services.
• Information about the original or current provider of your telephone number. We receive information about the original or current provider of your telephone number from third parties for the following purposes: to (i) build, evaluate and improve Afiniti’s models and algorithms for optimizing call routing; (ii) analyze the effectiveness of Afiniti’s services; and (iii) generate and analyze trends in the aggregate.
• Other information collected via passive collection and tracking technologies. Like most websites, in addition to the personal information described above, we also gather certain other information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, general location, and/or clickstream data. We and our third-party service providers may collect such information using the following technologies:
  • Server Logs. When you use the Site, we automatically receive and record certain information from your computer (or another device) and your web browser. To collect such information, we may use server logs or applications that recognize your computer and gather information about its online activity.
  • Cookies and similar technologies. Afiniti and our service providers use cookies and similar technologies to analyze trends, administer the Site, track users’ movements around the Site, and gather information about our user base as a whole. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete existing cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.

We partner with certain third parties to collect other information to engage in analytics, auditing, research, and reporting. These third parties may use server logs or pixel tags, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for analytics purposes. You may opt out of the use of cookies by Google Analytics here.

We also embed videos or other media hosted by a third party on our Site. The third party may use cookies, pixel tags, or similar technologies in order to provide you advertising based upon your browsing activities over time and across unaffiliated websites, as well as your inferred commercial interests. If you wish to learn more or opt out of interest-based advertising, visit http://optout.aboutads.info, and http://optout.networkadvertising.org, or visit https://www.youronlinechoices.eu/ if you are located in the European Union. Please note you may continue to receive generic ads.

We may combine the information that we collect with additional information that we or third parties collect in other contexts, such as our communications with you via email or phone, or your customer service records. In those circumstances, we will treat the combined information in accordance with this privacy policy.

Information Use

Afiniti uses the information that it collects for a variety of purposes, including to:

• Contact our clients and partners or prospective clients and partners, respond to requests for information about Afiniti, and send marketing emails, which include clear and conspicuous instructions to unsubscribe from future marketing emails;
• Process and evaluate job applications that we receive from prospective employees;
• Administer the Site, conduct internal auditing, and troubleshoot technical or user issues on the Site;
• Count and recognize visitors and users of the Site and analyze how individuals use our services;
• Improve our existing products and services or create new products and services;
• Assist you with your customer support queries should you encounter any problems when using our services, for example, when you liaise with the Service Desk. Please note that we may record your interactions with the Service Desk for the purposes of quality assurance and for training purposes. However, we will make reasonable efforts to notify you before any recording takes place;
• Build, evaluate and improve Afiniti’s models and algorithms for optimizing call routing;
• Analyze the effectiveness of Afiniti’s services;
• Prevent and detect fraud and other activities that may violate Afiniti’s policies in order to protect the security of Afiniti, our property or the property or physical safety of any person or third party;
• Generate and analyze trends in the aggregate; and
• Comply with legal and/or regulatory requirements.

From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services. We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the unsubscribe link at the bottom of our marketing emails.

We may aggregate any of the personal information we collect (so that it does not directly identify you). We may use aggregated information for purposes that include testing our IT systems, research, data analysis, improving the Site and developing new products and features. We may also share such aggregated information with others.

Information Disclosure

Afiniti may disclose the information that it collects to third parties for a variety of purposes, such as:

• Affiliates. We may share personal 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 personal 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. For the avoidance of doubt, Afiniti does not share information about the original or current provider of your telephone number with any recipients.
• Third-party plugins. Our Site may integrate certain third-party plug-ins (such as a Facebook “Like” button and Twitter “Follow” button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.
• Legal purposes. We may use or disclose your personal information to third parties when we believe, in our sole discretion, 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. You will be notified via email or a prominent notice on our website of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
• De-identified or aggregated information. Afiniti also may share de-identified and/or aggregated information about users of our services, such as by publishing a report on trends in the usage of the Sites.
• With your consent. We may disclose your information to any other third party with your prior consent.

Legal basis for processing in the EU

If you are an EU resident, our legal basis for processing personal information, as described above, will depend on the type of information at issue and the purpose for which it is collected and used.

The purposes for which we process your personal information are:

1. the provision of personal information by you may be necessary for the performance of ay contractual relationship we have with you;
2. where it is necessary for compliance with our legal obligations laid down by EU law;
3. where in our legitimate interests except where such interests are overridden by your data protection interests or fundamental rights and freedoms such as:
   a) to contact you and respond to your requests and enquiries;
   b) for business administration, including statistical analysis;
   c) to provide the Site to you;
   d) for fraud prevention and detection;
   e) for quality assurance and training purposes; and
   f) to comply with applicable laws, regulations and codes of practice.

The table at ANNEX 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

Your Rights and Choices

You may have the following rights in respect of your personal information that we hold:

a) Right to object. YOU HAVE A RIGHT TO OBJECT TO ANY PROCESSING BASED ON OUR LEGITIMATE INTERESTS WHERE THERE ARE GROUNDS RELATING TO YOUR PARTICULAR SITUATION. YOU CAN OBJECT TO MARKETING ACTIVITIES FOR ANY REASON WHATSOEVER.

b) Right of access. The right to obtain access to your personal information.

c) Right to rectification. The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.

d) Right to erasure. The right to obtain the erasure of your personal information without undue delay in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed.

e) Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal information in certain circumstances, such as where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information.

f) Right to portability. The right to portability allows you to move, copy or transfer personal information easily from one organization to another.

If you wish to exercise one of these rights, please contact us at privacy@afiniti.com.

You may also have the right to lodge a complaint to your local data protection authority. Further information about how to contact local data protection authorities in the EU is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm and in the UK at https://ico.org.uk/make-a-complaint/.

For your protection, we might only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request.

Data Retention and Access

Afiniti will retain information for as long as reasonably necessary to accomplish the purposes described in this privacy policy. Afiniti also will retain and use information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will process personal information in a manner that is compatible with and relevant to the purpose for which it was collected or authorized by individuals. To the extent necessary for those purposes, we will take reasonable steps to ensure that personal information is accurate, complete, current and reliable for its intended use.

Security

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

Children’s Privacy

The Site is not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16. If you are under the age of 16, please do not use the Site or otherwise provide us with any personal information either directly or by other means. If a child under the age of 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems.

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 Site 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 would like to exercise your data protection rights, please contact us at privacy@afiniti.com. If you are located in the European Union, you may contact our Data Protection Officer at dpo@afiniti.com.

For questions regarding our privacy policies or practices, please visit our contact page or write to us at:

Privacy @ Afiniti
1701 Pennsylvania Avenue NW,
Suite 600
Washington, DC 20006

ANNEX 1