Aristotle, Inc. Integrity Privacy Policy

Aristotle, Inc. (“Aristotle”) provides this Integrity Privacy Policy to explain our handling of two categories of personal information:

  1. Information we receive in connection with Aristotle, Inc.’s Integrity services (the “Integrity Services” or the “Services”). Our privacy practices with respect to this information are described in Section 1 below.
  2. Information we receive from visitors to integrity.aristotle.com or any other Aristotle website on which this Policy is posted, other than information collected through login-protected product portals on any site (collectively, the “Websites”). Our privacy practices with respect to this information are described in Section 2 below.

Section 3 below contains details relevant to our handling of both types of information.

  1. PRIVACY PRACTICES FOR OUR INTEGRITY SERVICES
  2. Information Collected in Connection with our Integrity Services

To operate the Services, we maintain internal databases (and have access to databases provided by governments and other third parties) containing personal information, such as names, addresses, telephone numbers, birthdates, and government-issued identification data, IP addresses, social network data, as well as details relevant to Know-Your-Customer (“KYC”) requirements, such financial watch list and Politically Exposed Person data.

During use of our Services, the relevant individuals (or our customers, with the consent of such individuals or their parents, guardians or other appropriate legal representatives) provide us with similar information (via data connection, email, videoconference or other means) for verifying the relevant individuals’ age or identity, to otherwise validate the individuals for anti-fraud, financial and legal compliance for age-restricted services, or for other KYC purposes.

Certain data provided by Aristotle for some of our Services may include information obtained from the Death Master File (DMF) made available by the US Department of Commerce National Technical Information Service (NTIS) and subject to regulations found at 15 CFR Part 1110. All Aristotle clients are required to comply with all applicable laws and, if a client is granted access to DMF data, the client certifies compliance with 15 CFR Part 1110. The client’s failure to comply with 15 CFR Part 1110 may subject the client to penalties under 15 CFR 1110.200 of $1,000 for each disclosure or use, up to a maximum of $250,000 in penalties per calendar year.

We refer to all of the above information as the “Service Information.”

b. How We Use the Information Collected Through the Aristotle Services

We use the Service Information to provide the Service for which it was collected, in compliance with law and with contractual restrictions imposed by the relevant sources of the Service Information. As part of this, we may use the information to engage in fraud prevention, risk mitigation, and similarly compatible activities.

Use of our Services requires the consent of (i) the individual whose personal information is being processed or (ii) that individual’s parent, guardian or other appropriate legal representative.

c. How We Share Information We Collect Through the Aristotle Services

Where appropriate in light of legal requirements and contractual restrictions imposed by our customers and other data sources, we may share Service Information as follows:

  • When a customer submits information to us for verification or validation through our Services, we provide verification information to that customer.
  • In many cases, we perform our Services by reference to data that we hold. In some cases, however, we may pass information received as part of a verification or validation request to a third party to perform all or a portion of the verification or validation for us.
  • We may share information with our affiliates or other entities that help us to operate our business and provide our Service.
  • We may disclose information to (1) comply in good faith with applicable laws, rules, regulations, governmental requests, court orders, or subpoenas, including for purposes of national security and law enforcement; (2) enforce our agreements; or (3) protect the rights, property, or safety of our users or any other person or entity.
  • We may disclose information as part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization or liquidation, or in connection with steps taken in anticipation of such an event (e.g., due diligence).

2. PRIVACY PRACTICES FOR OUR WEBSITES

a. Information We Collect Through the Aristotle Websites

  • Information You Disclose to Us

Website visitors may choose to provide their contact information, such as part of a registration or order form. Visitors may also provide payment information.

  • Automatically Collected Information

On our Websites, we or third parties may collect certain information by automated means such as cookies, Web beacons and JavaScript. This information may include unique browser identifiers, IP address, browser and operating system information, device information, Internet connection information, as well as details about individuals’ interactions with websites.

We and third parties may use automated means to read or write information to users’ devices, such as in various types of cookies and other browser-based or plugin-based local storage. Cookies are files that contain data, such as unique identifiers, that we or a third party may transfer to or read from a user’s device for purposes such as recognizing the device, service provision, record-keeping, analytics and marketing. You may choose to set your web browser to refuse certain types of cookies, or to alert you when certain types of cookies are being sent. However, if you block or otherwise reject our cookies, certain websites (including our own website and some of our clients’ websites) may not function properly.

In some cases, we facilitate the collection of information by advertising services administered by third parties. The ad services may track users’ online activities over time by collecting information through automated means such as cookies, and they may use this information to show users advertisements that are tailored to their individual interests or characteristics and/or based on prior visits to certain sites or apps, or other information we know, infer or have collected from the users. For example, we and the third-party vendors may use first-party cookies and third-party cookies together, as well as other automated means and other data (such as the data described above) (i) to recognize users and their devices, (ii) to inform, optimize, and serve ads and (iii) to report on our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services (including how they are related to visits to specific sites or apps). To learn more about interest-based advertising generally, including how to opt out from the targeting of interest-based ads by some of our current ad service partners, click here. For controls specific to advertising and analytics services offered by Google, click here, here and here. If you replace, change or upgrade your browser, or delete your cookies, you may need to use these opt-out tools again.

b. How We Use Information We Collect Through the Aristotle Websites

In addition to the uses described elsewhere in this Policy, we use the information we collect through the Aristotle Websites to provide, market, improve, and operate the Aristotle Websites, Aristotle Services, and any other products or services we have or may develop. This includes use of the information to:

  • Fulfill your requests;
  • Send information about our products and services, including marketing communications;
  • Respond to your questions, concerns, or customer service inquiries;
  • To create aggregate or de-identified information;
  • Comply with law and engage in fraud prevention, risk mitigation, and similar purposes;
  • Understand usage trends and preferences;
  • Otherwise analyze, improve, and provide products and services;
  • Customize the content and advertising you see on the Aristotle Websites, across the Internet, and elsewhere; and/or
  • Other purposes for which the individual provided it.

a. How We Share Information We Collect Through the Aristotle Websites

We may share the information we collect through the Aristotle Websites in the following situations:

  • With your consent, including through this Policy;
  • With our affiliates or other entities that help us to operate our business and provide our Service;
  • To (1) comply in good faith with applicable laws, rules, regulations, governmental requests, court orders, or subpoenas, including for purposes of national security and law enforcement; (2) enforce our agreements; or (3) protect the rights, property, or safety of our users or any other person or entity; or
  • As part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization or liquidation, or in connection with steps taken in anticipation of such an event (e.g., due diligence).

With respect to aggregated or de-identified information, we may share such information without restriction.

3. GENERAL INFORMATION ABOUT PRIVACY PRACTICES

The following subsections apply to both categories of personal information described above: (1) information collected in connection with our Services, and (2) information collected through our Websites.

a. YOUR RIGHTS AND CHOICES

Some individuals (including those whose information we collect under the EU-U.S. Privacy Shield) have certain legal rights to obtain confirmation of whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment or deletion in appropriate circumstances. To exercise those rights, they may contact us at integrity@aristotle.com or the address at the end of this Policy. Except where prohibited by law, we will charge a reasonable fee to respond to these requests.

Individuals may also use the contact information below to object to our uses or disclosures of personal information or to withdraw consent, though such actions typically will not have retroactive effect.

b. DATA RETENTION

Generally speaking, we retain the information collected from the Aristotle Websites or in connection with our Services for as long as necessary to achieve our objectives as detailed in this Privacy Policy, and for legally permissible, compatible purposes, such as compliance with law, resolution of disputes, auditing, and enforcement of our agreements.

c. USERS FROM OUTSIDE THE UNITED STATES

The Aristotle Websites and Services are provided from, supported and hosted primarily in the United States. If you are using the Aristotle Websites or Aristotle Services from outside the United States, be aware that your information may be transferred to, stored and processed in the United States and other countries outside of yours. The privacy laws of the United States might not be as comprehensive or protective as those in your country. By using the Aristotle Websites or Aristotle Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy.

d. EU-U.S. PRIVACY SHIELD

As a business subject to the investigatory and enforcement authority of the Federal Trade Commission, Aristotle complies with the EU-U.S. Privacy Shield framework regarding the collection, use, and retention of PII from participating European countries. Aristotle has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability, effective as of the date our certification is posted at https://www.privacyshield.gov/list. If there is any conflict between this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern with respect to the information we receive in reliance on the Privacy Shield. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov.

When Aristotle receives personal information under the Privacy Shield and then transfers it to a third-party service provider acting as an agent on Aristotle’s behalf, Aristotle has certain liability under the Privacy Shield if both (i) the agent processes the information in a manner inconsistent with the Privacy Shield and (ii) Aristotle is responsible for the event giving rise to the damage.

Covered European residents should direct any questions, concerns or complaints regarding Aristotle’s handling of personal information or compliance with the Privacy Shield to Aristotle at integrity@aristotle.com or the address listed at the bottom of this Policy. Aristotle will attempt to answer your questions and satisfy your concerns in a timely and complete manner as soon as possible. Aristotle has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Also, note that if your complaint still is not resolved through these channels, under limited circumstances, an additional binding arbitration option may be available before a Privacy Shield Panel created by the European Commission in coordination with the U.S. Department of Commerce.

e. DATA SECURITY

We maintain security measures with the goal of protecting our information from loss, misuse and unauthorized access, disclosure, alteration and destruction. However, no security measure is perfect, and we cannot guarantee the security of your information.

To assist with data security, you understand that you are responsible for maintaining the secrecy of any credentials that can be used to access any account or service with Aristotle. Any actions taken using your access credentials are your sole responsibility.

f. THIRD-PARTY WEBSITES AND APPS

We are not responsible for the privacy practices or disclosures of third parties that access or use the Aristotle Websites or Aristotle Services. When you access the Aristotle Websites, you may be directed to other websites that are also beyond our control. We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, as well as those of the tools that we have referenced in this Privacy Policy (such as in the “Automatically Collected Information” section above). This Privacy Policy applies only to Aristotle’s Websites and Services.

g. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy to reflect changes to our privacy practices. The amended Privacy Policy will be displayed on or accessible from our Websites. Please check our Privacy Policy regularly to ensure you have read the latest version and to stay informed of our privacy practices. Your continued access to or use of the Aristotle Websites or Aristotle Services constitutes your acceptance of this Privacy Policy and any updates.

h. CONTACTING US

If you have any questions regarding this Policy, or to exercise your rights or file a complaint, please contact us at integrity@aristotle.com or at;

Integrity
205 Pennsylvania Avenue, SE
Washington, DC 20003
United States