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