AVI-SPL Privacy Policy

1. Personal Information that You Provide to Us

“Personal information” is information that can be used to identify, locate, or contact an individual, and includes other information that may be associated with personal information.

“Privacy and Data Protection Laws” means any and/or all laws, rules, directives and regulations, on any local, provincial, state, federal or national level, pertaining to data privacy, data security and/or the protection of Personal Data including, but not limited to: (a) the General Data Protection Regulation (GDPR) and each European Union Member States’ national implementation thereof; (b) the Canadian Personal Information Protection and Electronic Documents Act, SC 2000, c 5 (PIPEDA); (c) the Personal Data Protection Act 2012 of Singapore (PDPA); (d) the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020; (e) additional privacy and data protection laws applicable to a data subject’s location; and (f) any successor legislation or regulations applicable thereto.

When you interact with our sites and services, depending on the site or service, we may collect the following personal information directly from you:

• Connect with Us: If you wish to learn more about our company and our sites and services, you may use the “Contact Us” or “Live Chat” features on our website. We request you provide the following information: (i) full name, (ii) work e-mail, (iii) company name, (iv) phone number, and (v) state/region. The provision of full name and work e-mail is mandatory; the other fields are optional.
• Global Help Desk Support: When you choose to submit a support ticket to our Global Help Desk using our online form, we request the following information: (i) company name, (ii) full name, (iii) phone number, (iv) e-mail address, and (v) street address for location in need of service. The provision of this information is mandatory in order for us to provide support.
• Account Creation: To purchase services offered on our sites, a user may be required to register an account by completing a form online. Through the completion of the form by a user we typically collect the following information: (i) full name, (ii) address, (iii) e-mail address, (iv) credit card information, (v) password, and (vi) username. All users can access the Website without being a registered user. However, you will not be able to access certain areas or purchase our services online if you are not a registered online user.
• Supplier and Subcontractor Application: To become an authorized supplier or subcontractor of AVI-SPL, a user must complete an online application. Through this online application, we collect information such as (i) the user’s full name, (ii) e-mail address, (iii) phone number, (iv) company name, and (v) company address. The provision of this information is mandatory for users who want to become authorized suppliers or subcontractors of AVI-SPL.

2. Other Information We Automatically Collect through Cookies and Other Technologies

2.1 Website Traffic Information

We collect certain website traffic information from visitors to our sites such as internet protocol (IP) addresses and preferences. AVI-SPL uses Google Analytics to analyze trends, administer the sites, and gather demographic information about

our user base as a whole. This tool does not create individual profiles for users. Unlike some tracking services, Google Analytics does not have a database of individual profiles for each visitor – they only collect aggregate data.

2.2 Cookies and Other Tracking Technologies

We use the following cookies:

• Session cookies, which are automatically deleted after every visit.
  • These enable you to perform essential functions on the site, such as remembering a repeat form field item within a browsing session. In addition, they help by limiting the need to transfer information across the Internet. They are not stored on your computer and will expire when you terminate your browser session.
• Persistent cookies, which will remain in place during multiple visits to the site.
  •  These enable us to recognize anonymous repeat visitors to the site. By matching an anonymous, randomly generated identifier, a record can be taken of specific browsing information such as how you arrive at the site, the pages you view, options you select, and the path taken through the site. By monitoring this information, we’re able to make improvements to the site, including the fixing of errors and the enhancement of content.
  • We use Google Analytics software to analyze page use, page interactions and the routes taken through our sites. These are known as ‘website metrics’ or ‘analytics’. We do not record any personal information as part of this process.
• Third party cookies, which are used by partner websites that are embedded within our site or to which we link.
  • When you visit our sites you may notice some cookies that are not related to AVI-SPL. If you go on to a web page that contains embedded content, for example from Facebook or YouTube, you may be sent cookies from these websites. We do not control the generation of these cookies, so we suggest that you check the individual third-party websites for more information about their cookies and how to manage them.

2.3 Enabling or Disabling Cookies

If you do not know the type and version of the web browser you use to access the Internet, click on ‘Help’ at the top of your browser window, then click ‘About’. The relevant information you require will then be shown.

• Microsoft Internet Explorer 8.0+ Click on the ‘Tools’ option at the top of your browser window and select ‘Internet options’, then click on the ‘Privacy’ tab. Ensure that your Privacy level is set to Medium or below, which will then enable cookies in your browser. Settings above Medium will disable cookies.
• Google Chrome (latest version) Click on the spanner icon at the top right of your browser window and select ‘Settings’. Click ‘Show advanced settings’ at the bottom and locate the ‘Privacy’ section. Click ‘Content settings’ and within the cookies section at the top, select ‘allow local data to be set’ to enables cookies. To disable cookies please check the ‘Block sites from setting any data’, ‘Block third-party cookies and site data’ and ‘Clear cookies and other site and plug-in data when I close my browser’ options.
• Mozilla Firefox (latest version) Click on ‘Tools’ at the top of your browser window and select Options. Next, select the Privacy icon at the top of the overlay that appears. Check the ‘Accept cookies from sites’ option to enable cookies. If you wish to disable cookies, please uncheck this box.
• Safari (latest version) Click on the cog icon located top right of your browser window and select ‘Preferences’. Click on the ‘Privacy’ icon at the top of the overlay that appears. Check the option that says ‘Block third-party and advertising cookies’. If you wish to completely disable cookies, please check the ‘Never’ box.

3. Our Legal Bases for Processing

We will only collect and process personal information, including sharing it with third parties, where we have a legal basis for such collection and processing. We rely on a number of legal bases, including:

• our legitimate interests in providing and improving our sites and services;
• our legitimate interests in keeping our sites and services safe and secure;
• our third party service providers’ legitimate interests as described in Section 2 (Other Information We Automatically Collect Through Cookies and Other Technologies) above;
• your consent to the processing of your personal information, which you can revoke at any time;
• where the processing of personal information is necessary for the performance of a contract to which you are a party to;
• where the processing of your personal information is required to protect your vital interests or those of another person, such as other users of our sites and services;
• where the processing of personal information is necessary to comply with a legal obligation such as a law, regulation, search warrant, subpoena, or court order.

4. How We Use Personal Information

4.1 Personal Information that You Provide to Us

We may use the personal information that you provide in one or more of the following ways:

• to carry out our obligations arising from your purchase of, or subscription to, our services or any other contract entered into between you and us;
• to enable site features such as geographically specific pricing or logging, and retrieving and providing analysis of data;
• to send you important notices, such as communications about changes to your account, and our sites’ and services’ terms, conditions, or policies;
• to process payments and to send you emails, invoices, receipts, notices of delinquency, alerting you if we need different or updated payment card information or other communications in connection with processing and collecting payments;
• to verify the information you provide through our sites and services;
• to solicit input and feedback to improve our sites and services and customize your user experience;
• to enable you to communicate with other site or service users via private messaging or other service specific communication channels;
• to contact you via email, telephone, text or chat in a manner required by law;
• to meet contractual obligations;
• to send you reminders, technical notices, updates, security alerts, support and administrative messages, and service bulletins;
• to inform you about new services or promotional offers, or other opportunities which we feel will be of interest to you, and to provide advertisements to you through our sites, email messages, applications, or other methods of communication;
• to manage our sites’ and services’ administration, forum management, or fulfillment;
• to provide customer service and technical support;
• to administer surveys, sweepstakes, giveaways, contests, or similar promotions or events sponsored by us or our partners;
• to detect, investigate and prevent fraud, malicious activity, unsafe experiences or potentially illegal activities, address security threats, secure our services, protect public safety, and enforce our sites’ Terms of Use
• to comply with applicable law;
• for internal purposes such as auditing, data analysis, and research to improve our products, services, and communications;
• to allow you to apply for a job or sign-up for special offers from third parties through our sites and services;

In addition to the uses described above, we may use personal information that we collect for other purposes that are disclosed to you at the time we collect the information, or with your consent.

4.2 Other Information We Automatically Collect Through Cookies and Other Technologies

We may use information collected from you through cookies and other tracking technologies in one or more of the following ways:

• to remember you when you return to our sites;
• to understand and analyze trends, to monitor usage, and learn about user behavior;
• to gather demographic information about our user base as a whole;
• to customize ads, content, or offers on our sites and services; and
• to conduct market research and measurement in order to improve our sites, content, and services and to make our sites, content, and services more useful for users.

5. Sharing Personal Information

We may share your personal information with third parties in the following circumstances:

• when we engage third parties to perform services on our behalf, such services include maintenance, hosting, data storage, security, analytics and data analysis, payment processing, marketing, email and text message distribution, customer service, and surveys and sweepstakes;
• when you communicate with us by email, submit an online form through our sites and services, request a quote or information, purchase a product or service, or otherwise submit a request through our sites and services, the personal information you provide may be shared with third parties to process or respond to your request, provide you with the products or services you requested, or complete a transaction.
• where necessary to operate our sites and services, your personal information and the contents of all of your online communications on or through our sites and services may be accessed and monitored:
  • to satisfy any applicable laws or regulations,
  • to defend ourselves in litigation or a regulatory action,
  • in order to protect the rights or property of AVI-SPL Global LLC and our subsidiaries and corporate affiliates, including to enforce our sites’ or services’ Terms of Use,
  • when we have a good faith belief that we are required to disclose the information in response to legal process (for example, a subpoena, court order, or search warrant),
  • where we believe our sites and services are being used in the commission of a crime, including to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and risk management, and
  • when we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally;
• in the event of a merger, acquisition, debt financing, restructure, sale of AVI-SPL Global LLC’s assets by or with another company, or a similar corporate transaction, we may need to disclose and transfer all information about you, including personal information, to the successor company;
• we may share information about you with AVI-SPL Global LLC’s subsidiaries and affiliates and companies acquired by or merged with AVI-SPL Global LLC and its affiliates, including without limitation, to enable such acquired or merged companies to advertise to you products and services in which you may be interested.
• when you register to use a service co-branded by AVI-SPL and other companies with which we partner, we may share the personal information you provide with such companies; in this instance, both our privacy policy and the partner’s privacy policy will apply;

We may share personal information about you for any other purpose(s) disclosed to you at the time we collect your information or with your consent.

6. User Generated Content, Online Communities and Forums, Profiles, Surveys, Reviews and Ratings

You may choose to publicly disclose personal information about yourself and others in the course of (i) contributing user generated content (for instance articles, blogs, surveys, reviews, ratings, or podcasts), (ii) communicating with others in our online forums or communities, or (iii) posting images, photos, or videos. Be aware, information that you voluntarily disclose in any of these areas of our sites or services is unencrypted, public information and, therefore, there can be no expectation of privacy or confidentiality, except if the terms of use of the site or service specifically limit use of the content (for example, we may let you know how such survey and rating responses will be used and if anonymity is an option). Any personal information you submit in the course of interacting in these public activities can be read, collected, or used by other users. Prior to posting in these areas, we encourage you to read the specific site’s or service’s terms of use, as we are not responsible for the personal information you choose to make public in any of these areas and strongly recommend against sharing any personal health or other sensitive information that could directly or indirectly be traced to any individual, including yourself.

7. Accessing and Updating Personal Information

We encourage you to keep your personal information up-to-date and accurate. The methods for accessing, viewing, correcting, and deleting your personal information will depend on which sites or services you use and their features. You have several choices – for instance:

• to view and change the personal information that you directly provided to us, you can return to the web page on our site where you originally submitted the data and follow the instructions on that web page;
• to correct or update your account information, you can log into the site or service where you are registered and navigate to your account;
• to close your account, you can log into the site or service where you are registered and navigate to your account;
• to change your email preferences, you can visit the email preferences page for the relevant site or follow the opt-out or unsubscribe instructions included in each email (for more information about email preferences, please see “Email and Other Communications” below); or

You can also manage certain aspects of information collection and use, including disabling geo-location, by going to the settings of your mobile device and reviewing the permissions of each application. If you have questions about your options, please email dataprivacy@avispl.com. Protecting your privacy and security is important and we also take reasonable steps to verify your identity before granting access to your data.

Please be aware that certain records and information will be retained for specific purposes such as legal, payment, accounting, technical, dispute resolution, enforcement of our sites’ and services’ Terms of Use or customer service. If you have posted comments or user generated content on our site, we may not be able to delete it. Further, we take no responsibility for removing or editing any of your public activities or any submissions or content that is a result of your public activities. We may reject requests that are unreasonably repetitive or impractical, require disproportionate technical effort, or risk the privacy of others.

8. Storing Personal Information

We retain your personal information while your account is active or as needed to provide you services. Additionally, we may retain personal information even after your account has been closed if retention is reasonably necessary to comply with our legal or regulatory obligations, resolve disputes, prevent fraud and abuse, enforce our Terms of Use or any other contract entered into between you and us, or if it is not technically feasible to delete your personal information.

9. Email and Other Communications

Our sites and services may allow us or other users to communicate with you or other users through our in-product service-branded emails and other electronic communication channels.

9.1 Opting Out of Requested Communications

Requested communications include, for instance, email newsletters and software updates that may be expressly requested by you or which you consented to receive. After you request such communications, you may “opt-out” of receiving them by using one of the following methods:

• selecting the email “opt-out” or “unsubscribe” link, or following the opt-out instructions included in each email communication;
• returning to the web page(s) where you originally registered your preferences and following the opt-out instructions; or 
• emailing dataprivacy@avispl.com

9.2 Opting Out of Transactional or Relationship Communications

Communications that are sent by or on behalf of a user are indicated as being from that user. Communications that are sent by us are indicated as being from us or one of our account or support specialists. Either type of communication may be “real time” communications or communications triggered automatically upon the occurrence of certain events or dates, such as event or meeting reminders. Email communications received from users and our administrative announcements are often transactional or relationship messages, such as event or meeting requests, reminders, and cancellations. You may not be able to opt-out of receiving certain email messages, although our services may provide a means to modify the frequency of receiving them.

9.3 Opting Out of General or Promotional Communications

General communications provide information about products, services, and/or support and may include special offers, new product information, or invitations to participate in market research. You may opt-out of receiving these general communications by using one of the following methods:

• selecting the email “opt-out” or “unsubscribe” link, or following the opt-out instructions included in each email communication; or
• emailing dataprivacy@avispl.com

10. Linked Websites and Services

Our sites and services may link to other sites or services operated by our affiliates or third parties, and may carry advertisements or offer content, functionality, newsletters, contests or sweepstakes, or applications developed and maintained by third parties. We do not exercise control over third party sites or services. We are not responsible for the privacy practices of any such third parties. Once you leave our sites or services via a link, enable a third-party service, or click an advertisement, you should check the applicable privacy policy of the third-party’s site or service. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization, or representation of our affiliation with that third party nor is it an endorsement of their privacy or information security policies or practices.

We may also provide social media features on our sites and services that enable you to share personal information with your social network(s) and to interact with our sites and services. Depending on the features, your use of these features may result in the collection or sharing of personal information about you. We encourage you to review the privacy policies and settings on the social media site(s) with which you interact.

11. Children’s Information

Children under the age of 16 are not permitted to use our sites and services. We do not knowingly collect personal information from children under the age of 16 or utilize plug-ins or ad networks that collect personal information through child-directed third-party websites or online services. If we learn that we have collected personal information from a child under 16, we will take steps to promptly delete such information.

12. International Users

AVI-SPL is a global company, and we may transfer your information to AVI-SPL subsidiaries, affiliates, representatives, or third party contractors acting on our behalf worldwide. Each AVI-SPL subsidiary and affiliate collaborates closely with AVI-SPL and any transfer of personal data between these affiliated entities will be compliant with the applicable Privacy and Data Protection Laws.

If any transfer of the personal data of residents of the European Economic Area (EEA) is made to a person or entity located in a country outside of the EEA, that is not recognized as providing an adequate level of protection, we will provide for increased information security and appropriate contractual provisions to strengthen data protection. To ensure that any such transfers of the personal data of EEA residents are compliant with the applicable Privacy and Data Protection Laws, we will either (i) conclude a data transfer agreement, based upon the EU model agreements, (ii) adopt binding corporate rules, (iii) rely on legally determined exceptions (such as requesting your explicit consent) or (iv) adopt other mechanisms which have been deemed to provide for the adequate protection of your personal data.

13. Privacy Rights and Choices

If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California or another U.S. state with an applicable privacy law, please refer to the respective dedicated sections below. Otherwise, at your request, and as required by applicable law, we will:

• Inform you of what personal data we have about you that is under our control;
• Amend or correct such personal data or any previous privacy preferences you selected, or direct you to applicable tools; and/or
• Delete such personal data or direct you to applicable tools.

In order to exercise any of your rights as to personal data controlled by AVI-SPL, please contact dataprivacy@avispl.com. Where legally permitted, we may decline to

process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others. As an account owner or authorized user under a valid account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.

14. EU Privacy Rights

FOR RESIDENTS OF THE EUROPEAN UNION ONLY. Under European data protection law, in certain circumstances, you have the right to:

• request access to your personal information;
• request correction of your personal information;
• request erasure of your personal information;
• object to processing of your personal information;
• request restriction of processing your personal information;
• request transfer of your personal information; and
• withdraw your consent.

In addition, you have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your personal information) if we intend to use your personal information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise any of these rights by sending an email to dataprivacy@avispl.com with “EU Privacy Rights” in the subject line. If you believe that we have not complied with its obligations under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority

15. California Notice at Collection

15.1 Categories of Personal Information AVI-SPL Receives

AVI-SPL may collect, or process on behalf of our customers, categories of data as described in Section 1 (Personal Information that You Provide to Us) above.

Sources: We receive information from sources as described in Section 1 (Personal Information that You Provide to Us).

AVI-SPL’s business and commercial purposes for use: AVI-SPL uses personal data for the following business and commercial purposes: to provide AVI-SPL products and services; for product and service research and development; for marketing and promotions (AVI-SPL does not use meeting, webinar, or messaging content, or any content generated or shared as part of other collaborative features for any marketing or promotions); to detect, investigate and prevent fraud, malicious activity, unsafe experiences or potentially illegal activities, address security threats, secure our services, protect public safety, or enforce our sites’ Terms of Use; to comply with applicable law or legal process; and to communicate with you. For more information, please see Section 4 (How We Use Personal Information). Categories of third parties to whom we disclose Personal Information for business purposes are described in Section 5 (Sharing Personal Information).

AVI-SPL does not sell your personal information to third parties.

Retention: AVI-SPL retains personal data for as long as required to engage in the uses described in this Privacy Policy, unless a longer retention period is required by applicable law. Additional detail on retention criteria can be found under Section 8 (Storing Personal Information) above.

16. California & Other U.S. State Privacy Rights

Under some U.S. state laws, including the California Consumer Privacy Act of 2018 (as amended by the California Consumer Privacy Rights Act) (CCPA), residents may have a right to:

• Access the categories and specific pieces of personal data AVI-SPL has collected, the categories of sources from which the personal data is collected, the business purpose(s) for collecting the personal data, and the categories of third parties with whom AVI-SPL has shared personal data;
• Delete personal data under certain circumstances;
• Correct personal data under certain circumstances; and
• Opt out of the “sale” of personal data or “sharing” of personal data for targeted advertising purposes. We do not sell your personal data in the conventional sense. However, like many companies, we may use advertising and analytics services that are intended to analyze your interactions with our sites or applications, based on information obtained from cookies or other trackers, including for delivering advertising to you (such as interest-based, targeted, or cross-context behavioral advertising). You can get more information and opt out of the use of cookies and other trackers on our sites and applications by following the instructions in Section 2.3 (Enabling or Disabling Cookies) above. You will need to set your preferences from each device and each web browser from which you wish to opt out.
• Appeal a denial of your request. Some states provide additional rights to their residents. If we decline to process your request, you may have the right to appeal our decision. You can do so by replying directly to our denial or emailing dataprivacy@avispl.com.

AVI-SPL will not discriminate against you for exercising any of these rights, which is further in line with your rights under state law. To exercise your rights, please e-mail dataprivacy@avispl.com or call 1-800-282-6733 and request transfer to AVI-SPL’s Information Technology Department.

We will acknowledge receipt of your request within 10 business days, and provide a substantive response within 45 calendar days, or inform you of the reason and extension period (up to a total of 90 days) in writing.

These rights are not absolute, are subject to exceptions and limitations, and may not be afforded to residents of all states. In certain cases, we may decline requests to exercise these rights where permitted by law. We will need to verify your identity to process your access, deletion, and correction requests and reserve the right to confirm your state residency.

California’s Shine the Light Law

California Civil Code Section 1798.83, also known as “Shine The Light” law, permits California residents to annually request information regarding the disclosure of your personal information (if any) to third parties for the third parties’ direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for the third parties’ direct marketing purposes.

17. Contacting Us

If you have any questions or concerns about this privacy policy or our practices you can send an email to dataprivacy@avispl.com or write to us at AVI-SPL Global LLC, Data Protection Office, 6301 Benjamin Road, Suite 101, Tampa, FL 33634 U.S.A. Please be sure to identify the specific website, software, or service about which you have a question or concern and how we can contact you.

18. Changes to This Privacy Policy

We may revise this privacy policy from time to time and, if we do, we will update it on this page and modify the “Last Updated” date. If our information practices change in a significant way, you will be provided notice by means of notice on our sites or otherwise in writing. Because our privacy policy can change at any time, we encourage you to reread it periodically to see if there have been any changes that affect you. If you disagree with any changes to this privacy policy and do not wish your information to be subject to the revised privacy policy, you will need to deactivate your account or terminate your services. Your use of our sites and services following any such change constitutes your agreement that all information collected from or about you through our sites and services after the revised privacy policy is posted will be subject to the terms of the revised privacy policy.

Last Updated: March 1, 2023