Last Updated: [December 23, 2019]
Data Privacy is Important to Us
Please be assured that your privacy is of utmost importance to us. AVI-SPL, Inc., including its affiliates (“AVI-SPL”, “we”, “us”, “our”), is committed to protecting your privacy while visiting our websites and purchasing our products and services.
What Personal Data We Collect
The following lists the ways in which we collect Personal Data from our users and the type of information collected:
Information you provide voluntarily:
- Connect with Us: If you wish to learn more about our company and the products and services we offer, 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 products and obtain other services offered on the Website, a user has 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 products or services online if you are not a registered online user.
- Supplier Application: To become an authorized supplier 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 of AVI-SPL.
Information we collect automatically:
- Website Traffic Information: We collect certain website traffic information from visitors to our Website such as internet protocol (IP) addresses and preferences. AVI- SPL uses Google Analytics to analyze trends, administer the Website, 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.
How We Use Personal Data
Our Company uses personal data for the following purposes:
- Providing products and services to our business customers: AVI-SPL collects and processes the business contact information of the individuals working for our business customers so that we can enter into and perform contracts with our business customers in order to provide our products and services.
- Working with our suppliers. AVI-SPL collects and processes the business contact information of the individuals working for our suppliers so that we can enter into and perform contracts with our suppliers.
- Making our Website more useful for our visitors.
- Communications: In addition, AVI-SPL may also use users’ contact details for the following purposes in accordance with the user’s communication preferences: (i) for internal surveys to obtain feedback on our products or services, our Website, or on other areas of our business that impact you as a customer, (ii) to notify users of new products or services we think may be of interest to them, and (iii) to send promotional materials.
Interaction with Children
We do not collect personal data of and our websites do not target or provide content to children under the age of 16.
We use the following cookies:
- Session cookies, which are automatically deleted after every visit.
- Persistent cookies that will remain in place during multiple visits to the site.
- Third party cookies, which are used by partner websites that are embedded within our site or that we link to.
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.
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 data as part of this process.
3rd Party cookies
When you visit our site 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.
Managing cookies to enable or disable 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.
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.
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.
Data Subject Rights of EU Residents
Residents of the European Union (EU) have the following rights regarding their Personal Data:
- Right of Access: You have the right to obtain confirmation from AVI-SPL as to whether Personal Data concerning you is being processed and how, what when, why and for how long your Personal Data is processed and to whom it is disclosed.
- Right to Rectification: You have the right to request AVI-SPL to correct inaccurate Personal Data and to complete incomplete Personal Data.
- Right to Erasure (Right to be Forgotten): You have the right to request AVI-SPL to erase Personal Data concerning you where your Personal Data is no longer needed for the purposes for which it was collected or processed or has otherwise been improperly processed.
- Right to Object: You have the right to object to the processing of your Personal Data if the processing is based upon AVI-SPL’s legitimate interest or for the performance of a task carried out in the public interest, including any profiling based on such processing, or if the processing is for direct marketing.
- Right to Restrict Processing: You have the right to request AVI-SPL to restrict the processing of your Personal Data while your data subject rights requests are being investigated and answered.
- Right to Portability: You have the right to receive Personal Data that you have provided to AVI-SPL and transmit such Personal Data to another entity where the processing of such Personal Data is based on consent and is processed by automated means. Additionally, you have the right to require AVI-SPL to transmit such Personal Data directly to another entity, where technically feasible.
- Right Not to be Subject to Automated Decision-Making, Including Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.
To make a subject access request, you should send the request to email@example.com. We normally will respond to a request within a period of one (1) month from the date it is received. In some cases, such as where AVI-SPL processes large amounts of an individual’s Personal Data, we may need up to three (3) months of the date the request is received in order to respond. We will write to you within one (1) month of receiving the original request to tell you if this is the case.
International data transfers
AVI-SPL has certified that it complies with the EU-U.S. Privacy Shield (Privacy Shield) as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred to the U.S. from the EU. This certification covers the following AVI-SPL entities:
• Audio Visual Innovations, Inc.
• Signal Perfection, Ltd.
To learn more about the EU-U.S. Privacy Shield programs, please visit http://www.privacyshield.gov. To view AVI-SPL’s certification under Privacy Shield, please visit http://www.privacyshield.gov/list.
You will be offered a clear, conspicuous, and readily available mechanism to choose (opt out) whether their Personal Data is (1) to be disclosed to a third party (other than a third party acting as an agent to perform tasks on behalf of and under the instruction of AVI-SPL or (2) to be used for a purpose that is materially different than or incompatible with the purpose for which it was originally utilized or subsequently authorized by the individual.
Additionally, you will be offered a similar choice mechanism to give affirmative or explicit (opt in) choice whether their Personal Data is to be disclosed to a third party or used for a purpose other than the purposes for which it was originally collected or subsequently authorized by the individual by opt-in choice. However, explicit (opt in) choice is not required when the disclosure of the Personal Data is (1) in the vital interests of the individual or another person; (2) necessary for the establishment of legal claims or defenses; (3) required to provide medical care or diagnosis; (4) necessary to carry out the organization’s obligations in the field of employment law, or (5) related to personal data that is manifestly made public by the individual.
Transfer of Personal Data from the EU to Processors in the U.S.
AVI-SPL’s EU entities may transfer Personal Data to a processor in the United States solely for processing purposes. A “processor” is a third party who processes Personal Data on behalf of and in accordance with the instructions of AVI-SPL’s EU entities.
When Personal Data is transferred from the EU to the United States solely for processing purposes, AVI-SPL’s EU and/or Swiss entities will comply with the applicable data protection laws including the EU General Data Protection Regulation (GDPR) and enter into a contract with the processor to ensure that the processor (1) acts only on instructions of AVI-SPL’s EU entities; (2) provides appropriate technical and organizational measures to protect the Personal Data against unlawful destruction or accidental loss, alteration, unauthorized disclosure or access; (3) understands whether onward transfers are allowed; and (4) assists AVI-SPL’s EU entities in responding to individuals exercising their rights under the Privacy Shield principles, taking into account the nature of the processing.
Onward Transfers to Third-Party Agents
After Personal Data is transferred from the EU to AVI-SPL entities in the United States, AVI-SPL may thereafter transfer the Personal Data to third parties acting as controllers. A “controller” is a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data. Examples of third-party controllers may include banks and healthcare providers, or management personnel in other AVI-SPL offices outside of the U.S. When the Company makes such onward transfers to third-party controllers, the Company will comply with the Privacy Shield notice and choice principles and enter into a contract with the third-party controller that provides that (1) such Personal Data may be processed only for limited and specified purposes consistent with the consent provided by the individual; (2) the third-party controller will provide the same level of protections as the Privacy Shield principles; (3) the third-party controller will notify the Company if the third-party can no longer meet its obligation to provide the same level of protection for the Personal Data as required by the Privacy Shield principles; and (4) upon such notice by the third-party controller, the third-party controller will cease processing the Personal Data and/or take reasonable and appropriate steps to remediate any unauthorized processing.
Lawful Requests By Public Authorities
AVI-SPL may be required from time to time to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
AVI-SPL has verified and will verify annually through self-assessment that the attestations and assertions made about its Privacy Shield privacy practices are true and that those privacy practices have been implemented as represented and in accordance with the Privacy Shield principles. This verification has been and will be signed by an officer of AVI-SPL or other authorized representative of AVI-SPL at least once a year and is available upon request by individuals or in the context of an investigation or a complaint about non-compliance. The verification includes the following:
- That the Policy is accurate, comprehensive, prominently displayed, completely implemented and accessible;
- That the Policy conforms to the Privacy Shield Principles;
- That individuals are informed of any in-house arrangements for handling complaints and of the independent mechanisms through which they may pursue complaints;
- That it has in place procedures for training employees in the implementation of this Policy and disciplining them for failure to follow it;
- That it has in place internal procedures for periodically conducting objective reviews of compliance with the above.
Recourse Mechanisms For Personal Data Transferred Under Privacy Shield
Inquiries or complaints regarding transfers of Personal Data from the EU to the U.S. pursuant to Privacy Shield should be directed to firstname.lastname@example.org. If a complaint remains unresolved, EU residents should contact the state or national data protection authority in the jurisdiction where they reside for resolution. A listing of the EU Data Protection Authorities (DPAs) is located at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection- authorities/index_en.htm.
AVI-SPL will cooperate with the DPAs and comply with the advice of the DPAs. In the event that the DPAs determine that the Company did not comply with this Policy or Privacy Shield principles, AVI-SPL will take appropriate steps to address any adverse effects and to promote future compliance, comply with any advice given by the DPAs where the DPAs have determined that AVI-SPL needs to take specific remedial or compensatory measures for the benefit of individuals affected by any non-compliance with this Policy or the Privacy Shield principles, and provide the DPAs with written confirmation that such action has be taken.
Under certain conditions specified by the Privacy Shield Privacy Principles, you may also be able to invoke binding arbitration to resolve your complaints.
AVI-SPL is also subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
In the context of an onward transfer of Personal Data, AVI-SPL has responsibility for the processing of Personal Data it receives under the Privacy Shield and subsequently transfers to a third party agent. AVI-SPL will remain liable under the Privacy Shield principles if its third party agent processes such Personal Data in a manner inconsistent with the Privacy Shield principles unless AVI-SPL proves that it is not responsible for the event giving rise to the damage.
Privacy Rights of California Residents
Pursuant to California Civil Code Section 1798.83, California residents have the right to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to email@example.com, or call us at our toll-free number 1-800-250-9122 to make the request via phone.
You can also mail your request to:
6301 Benjamin Road
Tampa, FL 33634 United States
Attn: Data Privacy
In some cases, we may need to ask for proof of identification before the request can be processed. We will inform you if we need to verify your identity and the documents we require.
Pursuant to California Civil Code Section 1798.83(c)(2), members of the AVI-SPL organization do not share guests’ personal data with other member companies or others outside of the AVI-SPL organization for those parties’ direct marketing use unless a guest elects that we do so. AVI-SPL does not and will not sell your personal data.
You have the right to request we delete some or all of your Personal Data; however, under some circumstances, applicable law may not require us to delete your Personal Data. In any event, we will give you notice of our decision in accordance with applicable law.
AVI-SPL takes the security of personal data seriously. AVI-SPL has internal policies and technical measures in place to protect Personal Data against loss, accidental destruction, misuse or disclosure. Such internal policies and technical measures include:
- The use of pseudonymization and encryption of Personal Data where appropriate;
- Procedures and controls to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
- Procedures and controls to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
- Procedures for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing; and
- Procedures to ensure that Personal Data is not accessed, except by employees in the proper performance of their duties.
AVI-SPL retains Personal Data only for the period of time necessary to meet the purposes for which it was collected, to fulfill the legitimate business interests of AVI-SPL, and to comply with any data retention laws and regulations or legal requirements.
When AVI-SPL engages third parties to process Personal Data on its behalf, such third parties are required by contract to process the Personal Data based on AVI-SPL’s written instructions, are under a duty of confidentiality, and are required to implement appropriate technical and organizational measures to ensure the security of the Personal Data.
When AVI-SPL shares personal data of EU residents with affiliated companies, vendors, and business customers located outside of the EU, such as the U.S., AVI-SPL uses appropriate safeguards such as standard contract clauses to protect the Personal Data.
Questions and Concerns
Any questions or concerns regarding how AVI-SPL processes Personal Data should be directed to our Information Technology Department at firstname.lastname@example.org. EU residents also have the right to lodge a complaint with the local or national data protection authority in the jurisdiction where they reside. A listing of the EU Data Protection Authorities is located at: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection- authorities/index_en.htm.