This Policy is effective as of April 28, 2023.
This Policy applies to users or visitors who:
- Access and use Our Website,
- Complete a form on Our Website,
- Apply for a job on Our Website,
- Request a demo from Our Website.
We may amend this Policy from time to time. We encourage you to review this Policy periodically, as changes will be posted on this page. If we make any material changes to this Policy, We will provide a prominent notice. Your continued use of this Website after We make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates. If you do not agree with this Policy, you should not use Our Website.
This Policy covers:
- The Personal Information We Collect and How
- How We Use That Personal Information
- The Legal Basis for Collecting Your Information
- How We Share Your Information
- How Long We Retain Your Information
- Your Rights
- Rights for EU Residents
- Rights for California Residents
- International Data Transfers
- Children’s Privacy
- Sensitive Information
- How to Communicate with Us
What Personal Information We Collect and How
We collect various types of information depending on how you interact with Us and Our Website. The following are the categories of Personal Information We collect:
Personal Information You Provide to Us
If you fill out a form on Our Website that requires contact information, such as submitting a request for a white paper, demo, or any other form to be willingly filled out, then We will collect and process that information to provide you with the Services.
These types of Personal Information may include:
- First and Last Name,
- Work email address,
- Company Name,
- Job Title,
- Job Department,
- Phone Number.
Personal Information Automatically Collected When You Visit Our Website
We may automatically collect from you:
- Session ID,
- Date and time stamp,
- Geolocation or other location information,
- Click or touch stream data, movement, scroll, and keystroke activity,
- Device information, like operating systems and screen resolution, and
- Internet activity, like your web browser.
Unless otherwise noted in this Policy, We act as the “controller” of personal data that We collect and process from Our Website.
How We Use Your Information
In general, We will only use the information you provide to Us for the purpose for which such information was provided. We may also use this information to deliver to you information about Aware and promotional material. Your information may also be used to contact you when necessary and may be shared with other companies consistent with your stated preferences. You may manage email communications by clicking “Manage Preferences” at the bottom of the email received. You may entirely opt-out of receiving future mailings from Aware by clicking the “unsubscribe” button at the bottom of the email received.
Non-personal demographic and profile data is used to tailor your experience at Our Website, showing you content We think you might be interested in. This information may also be shared with advertisers on an aggregate non-personal basis. At any time, you may disable the sharing of this information by clicking on the Cookie Widget in the bottom right-hand corner of Our Website.
We process your Personal Information for the following purposes:
- To remember your preferences and interactions,
- To respond to your requests for information,
- To contact you with updates about Our Services,
- To market and advertise Our Services, including sending marketing communications, with your consent,
- To analyze and improve Our Website and Services.
The Legal Basis for Collecting and Processing Information
We use the following legal bases for collecting Personal Information:
- We may collect or process information with your consent, such as when you fill out a form or request information regarding Our Services.
- We may collect or process information to fulfill a legal obligation.
- We may collect information when we have a legitimate interest to do so, such as for marketing, as long as Our legitimate interests are not outweighed by your rights.
- We may collect or process information if necessary to protect the vital interests of the user or another individual.
- We may share Personal Information in response to a legal summons or subpoena, or if required by law enforcement agencies.
How We Share Information
We share Personal Information with Our service providers and vendors, as needed to provide Our Services. We share Personal Information with service providers such as customer relationship management systems and other vendors We use to operate Our Website and provide Our Services.
Our vendors and service providers are not permitted to use your Personal Information for any other purpose than to provide contracted services. Vendors are not permitted to use your personal information for their own marketing and are not allowed to share your information for marketing purposes.
How Long We Retain Your Information
How long we keep Personal Information that we have collected depends on the type of information and the purpose for which it was collected. After a reasonable period of time or the completion of the purpose for which it was collected, we will either delete or anonymize Personal Information.
We retain Personal Information where We have an ongoing legitimate business purpose to do so; for example, to resolve disputes or to comply with ongoing legal obligations.
We retain your Personal Information for as long as it is needed to provide Our Services to you and to fulfill Our legal obligations and for a reasonable period of time after such Services are completed.
Cookies and Other Tracking Technologies
If you would like to opt-out of cookies, you may change the settings on your web browser to reject or delete cookies. You may also change the settings on the Cookie Widget provided in the bottom right corner of Our Website. You may also find more information about cookies, including how to opt-out of interest-based advertising, at www.cookiesandyou.com.
Your Rights Regarding Access to and Control over Personal Information
Consistent with applicable law, you may exercise the rights described in this section. Please note that some of the rights may vary depending on your country, province, or state of residence.
Accessing, Updating, Correcting, and Deleting Personal Information
You may have the right to request access to and receive details about the Personal Information We maintain about you and how We have processed it, update and correct inaccuracies, get a copy of, or delete your Personal Information. You may also have the right to withdraw your consent to our processing of your Personal Information. These rights may be limited in some circumstances by applicable law.
Access and Deletion
You can submit a request to access or delete your Personal Information, or withdraw consent, by:
- Emailing at firstname.lastname@example.org.
Updates and Corrections
You can submit a request to update and correct your Personal Information by:
- Emailing at email@example.com.
Managing Communication Preferences
You can stop receiving promotional e-mails at any time by:
- Clicking on the “unsubscribe” link at the bottom of any promotional email that you receive from Us.
Information for EU/EEA Residents
Aware, which processes the personal data of individuals in the European Union, European Economic Area and/or UK, in either the role of “data controller” or “data processor”, has appointed DataRep as its Data Protection Representative for the purposes of GDPR in the EU/EEA and The Data Protection Act 2018 (as amended) in the UK.
If Aware has processed or is processing your personal data, you may be entitled to exercise your rights under GDPR in respect of that personal data. For more details on the rights you have in respect of your personal data, please refer to the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en) or the national Data Protection Authority in your country (https://edpb.europa.eu/about-edpb/about-edpb/members_en).
Aware takes the protection of personal data seriously and has appointed DataRep as Our Data Protection Representative in the European Union so you can contact them directly in your home country. DataRep has locations in each 27 EU countries, the UK, and Norway & Iceland in the European Economic Area (EEA), so users may always raise any concerns or questions.
If you reside in the EU/EEA, you may have the following rights with regard to your Personal Information:
- Right of information and access - You have the right to access your Personal Information We have about you and to be provided with a copy of your Personal Information.
- Right to rectification - You have the right to correct or update your inaccurate or out of date Personal Information.
- Right of erasure - You have the right to request that your Personal Information be permanently erased/deleted.
- Right to restrict processing - You have the right to restrict the processing of your Personal Information.
- Right to object to processing - You have the right to object to specific types of processing of your Personal Information.
- Right to portability - You may ask to receive a portable copy of your Personal Information in a format that may be transferred to another organization.
- Right not to be subject to decisions based solely on Automated Decision Making - You have the right not to be subject to decisions based solely on automated processing.
- Right to complain to a data protection authority - You have the right to complain to a supervisory authority in the country in which you reside, details of which can be provided by the EU Data Protection Authorities at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
- Right to withdraw consent - If you have given Us consent to collect or process your Personal Information, you may withdraw that consent at any time.
- The Right to Non-Discrimination - We may not discriminate against you if you exercise your privacy rights.
If you wish to raise a question or otherwise exercise your rights in respect of your personal data, you may do so by:
- Sending an email to DataRep at Aware@datarep.com
- Contacting DataRep on their website at www.datarep.com/data-request, or
- Mailing your inquiry to DataRep at the most convenient address for you by requesting such address at firstname.lastname@example.org.
Please Note: when mailing inquiries, it is essential that you mark your letters for “DataRep” and not “Aware”. Please refer clearly to “Aware” in your correspondence. Upon receipt, Aware is likely to request evidence of your identity to ensure your personal data and information connected with it is not provided to anyone other than you.
We may charge a reasonable fee if your request is not valid under applicable law, repetitive or excessive. We may also request additional information from you in order to verify your identity before processing your request.
Information for California Residents
The California Consumer Privacy Act (CCPA) applies to information collected from California residents.
California Shine the Light
Customers who are residents of California may request information concerning the categories of Personal Information (if any) We share with service providers or vendors for their direct marketing purposes. If you would like more information, please submit a request to Us by:
- Emailing at email@example.com, or
- Mailing a request to Nullable, Inc., 455 S. Ludlow Street, Columbus, OH 43215
Categories of Personal Information We Collect and Our Purposes for Collection and Use
You can find a list of the categories of Personal Information that We collect and how We collect such information in the “What Personal Information We Collect” section above. We collect and use Personal Information for the business or commercial purposes described in the “How We Use Your Personal Information” section above.
Categories of Personal Information Disclosed and Categories of Recipients
We disclose the following categories of Personal Information for business or commercial purposes to the categories of recipients listed below:
- We share Basic Identifying Information with: service providers, vendors, and advertising networks.
- We share Device Information and Other Unique Identifiers with: service providers, vendors, and advertising networks.
- We share Internet or Other Network Activity with: service providers, vendors, and advertising networks.
- We share Geolocation Data with: service Providers and vendors.
- We share Inferences with: service Providers who help administer marketing and personalization.
For more information on how your information is shared, please see the “How We Share Your Personal Information" section, which provides more detail on Our service providers and vendors. We may also need to share any of the above categories of information pursuant to Legal Process or as a result of a Business Transfer as described in the “How We Share Your Personal Information” section.
Your Rights as a California Resident:
- The Right to Know and Access Information: The categories of Personal Information We collect is described above in the section entitled “The Personal Information We Collect and How”. California residents may submit a verifiable request regarding the information collected, the types of sources from which personal Information is collected, the purposes for which information is collected, and the specific Personal Information collected about them.
- The Right to Have Personal Information Deleted
- The Right to Portability: California residents may request a copy of their Personal Information in a format that can be transferred to another person or entity.
- The Right to Non-Discrimination: We may not discriminate against you if you exercise your privacy rights.
You may be asked for more information in order for Us to verify your identity when you make a request. You may exercise your rights by sending Us an email at firstname.lastname@example.org.
Sale of Personal Information and the Right to Opt-Out
Categories of Personal Information disclosed that may be considered a “sale” under California law: Basic Identifying Information, Device Information and Other Unique Identifiers, Internet or Other Network Activity, Geolocation Data, and Commercial Data.
Categories of third parties to whom Personal Information was disclosed that may be considered a “sale” under California law: Advertisers and marketing partners, data analytics providers, and social media networks.
International Data Transfers
Personal Information may be transferred from users residing in the European Union to Our service providers or vendors located in the United States and other non-EU countries where there may not be an adequacy opinion issued with respect to that country. We have taken appropriate safeguards to ensure that Personal Information remains protected wherever it is transferred. When we transfer Personal Information of individuals in the European Economic Area (“EEA”), Switzerland or the United Kingdom (“UK”) to the United States, We make use of the Standard Contractual Clauses, as well as additional safeguards where appropriate. To obtain a copy of Our Standard Contractual Clauses, please contact Us at email@example.com.
We take all reasonable steps to protect the information We receive from you from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. We have put in place appropriate physical, technical, and administrative measures to safeguard and secure your information, but no security measures are perfect; the risk of a data breach is possible. To learn more about Our security measures, please email firstname.lastname@example.org.
Our website is not intended for or directed to children under the age of 13. We do not knowingly collect Personal Information directly from children under the age of 13 without parental consent. If We find a child under the age of 13 has provided Us with Personal Information, We will delete the information from Our records.
For California consumers: We will not sell the Personal Information of California consumers who are 16 years old or younger unless We have prior parental authorization. If a California consumer is under the age of 13, a parent or guardian must consent to the sale of such minor’s Personal Information. If the California consumer is between the ages of 13 and 16 years old, the minor may consent on an opt-in basis to the sale of their Personal Information. Our sites directed toward children will ask for age verification and will require appropriate consent.
For EU residents: We do not collect or process Personal Information of data subjects in the EU under the age of 16 without explicit consent from a parent or guardian. Our sites directed toward children will ask for age verification and will require appropriate consent.
Unless specifically requested, We ask that you not send Us, and you not disclose on or through Our Websites or otherwise to sensitive Personal Information unless specifically requested by Us or required by law.