Section 3 below contains details relevant to our handling of both types of information.
To operate the Integrity 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 Integrity 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 we provide for some of our Integrity 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 customers 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.”
We use the Service Information to provide the Integrity 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 Integrity 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.
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:
Information You Provide
Information as You Navigate Our Websites
We automatically collect certain personal information through your use of the Websites, such as the following:
We may share the personal information we collect through the Websites in the following situations:
With respect to aggregated or de-identified information, we may share such information without restriction.
How You Can Opt Out of Cookies
When you first visit our Websites, we will present you with a banner which offers you choices about whether to accept or reject cookies or tracking technologies of different types. If you wish to change your preferences, you can do so by clicking the cookie icon at the bottom left of this webpage or other Aristotle webpages.
You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Website(s).
You can opt out of Cookies set by Google by following the instructions found here: https://adssettings.google.com
Advertising Industry Resources
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our Websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.
Our Websites are not intended for children under 16 years of age. We do not knowingly collect, use, or disclose personal information from children under 16.
The following subsections apply to both categories of personal information described above: (1) information collected in connection with our Integrity Services, and (2) information collected through our Websites.
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.
The Websites and Integrity Services are provided from, supported, and hosted primarily in the United States. However, data on individuals residing in Europe or the UK is generally stored and accessed only in the UK. If you are using the Websites or Integrity 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. Your personal information can be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States.
When Aristotle receives personal information under the DPF and then transfers it to a third-party service provider acting as an agent on Aristotle’s behalf, Aristotle has certain liability under the DPF if both (i) the agent processes the information in a manner inconsistent with the DPF and (ii) Aristotle is responsible for the event giving rise to the damage.
Aristotle has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.
If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf
We maintain commercially reasonable security measures with the goal of protecting the personal information we collect and store from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, no security measure is perfect, and we cannot guarantee absolute security of your personal 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.
If you are a California resident, please see our Notice to California Residents for more information about our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of your personal information and the rights you have regarding your personal information.
Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to https://www.aristotle.com/privacy/do-not-sell-my-personal-info/.
The Virginia Consumer Data Protection Act (“VCDPA”) provides Virginia residents with the right to receive certain disclosures regarding the personal data we process about them. For purposes of this section, personal data means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include de-identified or publicly available information as the VCDPA defines those terms.
For a discussion of the categories of personal data we process, the purposes for our processing, the categories of personal data that we share with third parties, and the categories of third parties with whom we share personal data, please see Sections 1 and 2, above.
If you are a Virginia resident, the VCDPA grants you the right to: (1) confirm whether or not we are processing your personal data and to access such personal data; (2) correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing of your personal data; (3) delete personal data you have provided or we have obtained about you; (4) obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and (5) opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
To opt out of the sale or processing of your personal data, complete this form. To request that we delete your personal data, complete this form. To exercise your other rights, please email us at [email protected] with your name, the fact that you are a Virginia resident, and specifying the right(s) you wish to invoke. If we refuse to take action regarding your request, you may appeal our decision by emailing us at [email protected]. If you would like to opt out of targeted advertising, you may alter your cookie preferences by clicking on the cookie icon at the bottom left of this or other Aristotle webpages.
Effective Date: January 18th, 2019
Last Updated Date: June 30th, 2023