Published February 17, 2021
Protecting Your Personal Information is Important
This Policy explains how the Company collects and uses information (to the extent applicable, this also includes “Personal Information” we collect as defined below). In particular, this Policy describes the basis upon which and for what purposes we process your information, as well as your privacy rights under certain privacy laws including, where applicable, under US privacy laws and the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), and how we protect your personal information.
By using the Company’s website and/or other web or cloud based services you agree to the terms and conditions of this Policy. If you do not agree to the terms of this Policy, do not visit the Company’s website or submit any personal information to the Company.
We reserve the right to modify or amend this Policy at any time by posting the updated version on our website and changing the date listed at the top of this Policy. Any material changes in how we use or share the information we collect will only affect information collected after the posting of the updated Policy, unless otherwise expressly stated. You are bound by any revisions to this Policy and are encouraged to review this Policy periodically for updates.
In particular, this Policy describes the basis upon which and for what purposes we process your personal information, as well as your privacy rights under certain privacy laws including, where applicable, under US privacy laws and the European Union’s (“EU”) General Data Protection Regulation (“GDPR”), and how we protect your personal information.
To affirm our continued commitment to the proper use of client information and protecting your privacy, we have set forth the following privacy policies.
By visiting this Site, you are accepting the practices described in this Policy. If you do not agree to this Policy, please do not use this Site.
Changes to this Policy
This Policy may change from time to time and should be reviewed periodically. Such changes shall be effective immediately upon posting. The current version of this Policy can be accessed from the link on the bottom of our homepage, or at the bottom of our other Site pages. By accessing our Site after we have posted changes to this Policy, you are agreeing to the terms of the Policy as modified.
How We Collect Information
The Company intends to give you as much control as possible over your personal information. In general, you can visit us on the web without directly telling us who you are. However, in order to use certain services offered by us, there are times when we may need personal information from you.
“Personal Information” is information that identifies or could be used to identify you and that is either collected by our website automatically or is otherwise submitted to us by you.
We collect Personal Information in order to provide you with our Company’s Services. For further details, please see the “Use of your Personal Information” section below.
You will voluntarily provide most of your Personal Information directly to us. We may also obtain Personal Information from other sources or persons. We collect Personal Information from the following sources:
Information Collected Directly from You: We collect information you voluntarily give to us such as your first and last name, e-mail address, company name, physical address, telephone number, username, password, data or any other information you choose to give to us when you set up an account, participate in a survey, submit content or feedback, sign up to receive information about the Company, or otherwise provide information to us. When you contact us online, we may keep a record of that correspondence. When you use our services we may also collect information about the services you use and how you use them.
Public Information: information about you or your business, which is publicly available, for example on your employers’ website, public professional social networking sites, the press, and relevant electronic data sources.
Information Collected Through Our Site: When you visit our site and use our “Contact Us” form, certain information may be collected. Among the types of information that may be collected are:
- domain names of visitors to our Site;
- your name, address, e-mail address and any additional information you provide in the “Contact Us” form;
- “navigational information” regarding the traffic patterns of our Site, including the number of visits to a particular page and user-specific information on which pages a guest visits, average length of time spent on the Site and similar Site usage data;
- any information that you may choose to submit in connection with any e-mail messages, on-site surveys, and the like; and
- cookies that track your IP address and certain other information from you when you visit our Site. For further details, please see the “Do We Use “Cookies” or Obtain Personal Information by Automated Means?” section below.
Information Collected through Our IT Systems and Network: Our IT systems and network automatically filter email and other electronic communications for viruses and compliance with our internal policies. Usage of our IT systems (and access to secure office areas) is also automatically logged. Where appropriate and local law permits us to, we will monitor such communications and logs to ensure compliance with applicable rules and law and our internal policies, and for business continuity purposes.
The Types of Information We Collect
The type of Personal Information we collect and how we process it will vary depending on the relationship we have with you and the context for collecting the Personal Information. Generally, this information can include:
- personally identifying information such as name, title, role, company, telephone, mailing address, and fax number;
- digital footprint data such as e-mail, login information, and IP addresses;
- employment data such as job position and business contact information.
Lawful Basis for Processing
The Avoca Group may have one or more of the following lawful bases to process your Personal Information:
- Consent: your freely, informed, and voluntary consent to process your Personal Information in connection to our Company’s Services.
- Contract: processing your Personal Information is necessary in order to fulfill a contract.
- Legal Obligation: processing is necessary to comply with applicable rules, laws, and regulations.
- Legitimate Interests: processing is necessary to the legitimate interests of our firm and/or a third party.
How We Use the Information We Collect
Collectively, this information is used to provide a more customized and enjoyable experience for you and to allow us to fulfill visitor requests. We also use this information:
- to communicate with you about services and programs;
- to respond to your inquiries and requests for information;
- to deliver and process data based on information you input;
- to send you personalized promotions, advertisements and special offers;
- to maintain and improve our site and services we offer;
- to detect, prevent, or investigate security breaches or fraud;
- to maintain appropriate records; and
- to internally to compile data regarding website traffic.
To Provide Company’s Services
Where it is necessary to communicate with and perform our contract with our clients or to take steps at our client’s request to enter into the contract, The Avoca Group may collect or generate additional details about you during the course of such engagement in order to provide you with our Company’s Services.
Where permitted by applicable law, The Avoca Group may record and/or monitor telephone calls made and received and electronic communications sent to or received by the firm’s networks in order to protect our business and verify compliance with our policies and relevant legal requirements. Any such recording and/or monitoring will be carried out for lawful business purposes and in accordance with applicable laws and regulations. This may include the following purposes:
- recording facts (including converting voice messages into text);
- establishing compliance with the firm’s policies and procedures;
- complying with applicable laws and regulations;
- for crime prevention and detection;
- to monitor the effective use and operation of the firm’s networks and systems.
In order to communicate efficiently, correspondence and documents may be sent by unencrypted email. You will be aware that this is not guaranteed as a secure method of communication, nor are there any service standards for delivery. If you would prefer us not to use unencrypted email, please speak to your contact at the firm.
For Client Development
We may use Personal Information in order to respond to, prepare for and present pitches and other proposals, and identify potential business opportunities. Largely, this involves our collection and use of non-personal business information about current, former and prospective corporate clients. However, we may also process limited Personal Information about individuals (name, current and former company, current and former title, contact information and similar information).
If you attend an event that is run by or in association with our firm, we will collect contact details as part of event registration. This information may include dietary requirements and details of any health issues or disabilities which may impact upon your attendance at or participation in the event.
Where an event is sponsored in association with a partner organization or hosted at an external venue (“Co-Sponsored”), we may need to share your personal details with the partner, event organizer or venue. Only the minimum information will be shared as necessary for the purposes of running the event.
Should you choose to register or submit your information to any events where The Avoca Group co-sponsors with a third party, The Avoca Group will have no control over the third party sponsors’ use of this information, and this Policy will not apply.
The Avoca Group uses this information to help us develop and improve our Site to better meet your needs. We may use your name or e-mail address to contact you or respond to your inquiries. We also use this information to help us diagnose technical issues relating to the performance of our Site.
Analytics and Improvement
To better understand how users access and use the Site, our other services and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations and to develop services and features.
To Comply with Another Party’s Legitimate Interests and our Legal and Regulatory Obligations
As part of your business or other commercial dealings with our firm, we may collect or generate details about you in connection to maintain our relationship with you and maintain contractual relations and applicable legal and/or regulatory obligations.
Prevent Misconduct, Abuse and Misuse
Subject to our professional and ethical duties, we use Personal Information where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our terms of engagement. We also use Personal Information to protect and secure the Site and our information systems and networks.
In the event that we use Personal Information we collect for other purposes not identified above where direct client consent is required under applicable rules, laws and/or regulations we will provide specific notice at the time we collect such Personal Information.
Do We Use “Cookies” or Obtain Personal Information by Automated Means?
There are various technologies, including “cookies” and “pixel tags”, that can be used to provide you with tailored information from a website. A cookie is an element of data that a website can send to your browser, which may then store it on your system. A pixel tag is a type of technology placed on a website or within the body of an email for the purpose of tracking activity on websites, or when emails are opened or accessed, and is often used in combination with cookies. Some of our pages may use these technologies or other technologies so that we can better serve you when you return to our site.
Amending internet browser settings to disable cookies. You can configure your browser to send accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies that have already been set. Each browser is different, so check the “Help” menu of your browser to learn how to change your cookie preferences. You can also visit https://optout.networkadvertising.org/#!/ to opt out of targeted advertising. Some cookies may be required in order to allow you to access and use our systems. You are free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on our Site. By completely disabling cookies, you may not be able to access some or all of the features we offer. In addition, a number of companies offer utilities designed to help you visit websites anonymously.
For more information about cookies and how to disable them please visit www.allaboutcookies.org, or you may consult the vendor documentation for your specific software.
How do We Respond to Do Not Track Signals?
We do not track users across time or over multiple websites, we do not receive, or respond to, browser do-not-track signals or other similar mechanisms. However, as noted above, some third party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you.
Amending your internet browser’s Do Not Track signal: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers and is a way for users to inform a particular website that they do not want certain information about their webpage visits collected over time and across websites or online services.
To learn more about setting up a Do Not Track signal, please visit https://allaboutdnt.com/.
Providing Information to Third Parties
Your information may be shared with our affiliates and with vendors that help us to manage and process the information. We do not currently sell personally identifiable information to third parties. If we become involved with a merger or a situation involving the transfer of some or all of our business assets, we may share your information with business entities or individuals involved in that process. We may also share your information as required by or permitted by law, including sharing your information with law enforcement agencies or other governmental entities, with third parties in response to subpoenas or other court orders, or to exercise our legal rights or defend against legal claims against us.
To the extent permitted by the applicable law of your jurisdiction, in relation to your Personal Information, you may request:
- to have your Personal Information corrected, for example, if it is incomplete or incorrect;
- to opt out of receiving marketing communications at any time;
- the right to file a complaint with an applicable government regulator such as a Data Protection Authority.
In addition to the foregoing, if you are located in the European Economic Area (“EEA”), to the extent permitted by applicable law, in relation to your Personal Information, you may request:
- to access the Personal Information held by us about you;
- the right to restrict or object to the processing of your Personal Information, or request that your Personal Information is erased;
- the right to receive a copy of the Personal Information which you have provided to the firm, in a structured, commonly used and machine-readable format (known as “data portability”);
- where you have provided Personal Information voluntarily, or otherwise consented to its use, the right to withdraw your consent.
to have your personal information/data deleted when retention of the information is no longer necessary for the purposes for which they were collected or when processing is based on consent that has subsequently been withdrawn. Please note, there are certain situations where we may refuse to delete Personal Information, i.e., when it is necessary to provide the service or complete a transaction; if security incident or fraud has been detected; when the Personal Information is subject to a governmental or regulatory investigation or inquiry; or for internal uses that are reasonably aligned with the expectation of the client based on the client’s relationship with The Avoca Group.
To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to your information.
To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your Personal Information that we maintain.
The Avoca Group makes every effort to protect the security of your Personal Information. We are committed to keeping Personal Information secure and we have implemented appropriate information security policies, rules and technical measures to protect the Personal Information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.
All of our employees, consultants, workers and data processors (ie, those who process your Personal Information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of Personal Information, are obligated to respect the confidentiality of such Personal Information.
Please note that no transmission over the internet is completely secure or error-free, and that the information security policies, rules and technical measures utilized and maintained by us may be subject to compromise.
Links to Third-Party Websites. As a convenience to you, The Avoca Group may provide hyperlinks to websites operated by third parties. When you select these hyperlinks, you will be leaving the Site.
The Avoca Group has no control over third party websites, their content, or security. Accordingly, when you access these third party websites it is at your own risk. We encourage you to read the associated privacy policies by such third party websites to learn more about their data privacy management practices. The Avoca Group may, in its sole discretion, block links to the third-party website and content without notice.
Updates and Your Choice to Opt-Out of the Collection and Sharing of Personal Information
We will endeavor to ensure your Personal Information is kept accurate, complete, up to date and relevant. If you feel your Personal Information is not accurate, complete or up to date, please notify us and we will take reasonable steps to ensure it is corrected. You can contact us using the details listed below.
If you are located in a jurisdiction that requires opt-in consent to receive electronic marketing messages, we will only send you such messages if you opt-in to receive them. To opt out of receiving e-mails or other direct marketing communications, such as commercial emails, please contact us using the details listed below.
The scope of your choice to opt-out will remain subject to applicable laws, rules, and regulations.
Retention of Personal Information
To the extent permitted by applicable law, we may retain your Personal Information for the period necessary to serve the purposes for which we obtained it. We may also retain your Personal Information beyond such period in accordance with applicable laws, regulations, or another lawful basis, including but not limited to, compliance with our contractual obligations, legal obligations, regulatory obligations, legal claims, or another legitimate interest.
Information about Children on Our Site
The Site is not directed to children under the age of 18 years. By using the Site, you represent and warrant that you are at least 18 years old.
If you are a parent or guardian and believe we may have collected information about a child under the age of 18, please contact us as described in the “Contact Us” section below so we can take reasonable steps to remove that information from our servers.
Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
We may transfer the Personal Information we obtain about you to recipients in countries other than the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. To the extent required by applicable law, when we transfer your information to recipients in other countries (such as the United States, United Kingdom, Ireland or Cayman Islands), we will protect that information as described in this Policy.
If you are located in the European Economic Area (“EEA”), we will comply with applicable legal requirements regarding the provision of appropriate safeguards for the transfer of Personal Information to recipients in countries for which the European Commission has not issued an adequacy decision.
As identified under applicable law, the data controller for this Site is The Avoca Group located at the address below.
California residents may request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes. To request a notice, please contact us as described in the “Contact Us” section, below. We will make every effort to promptly respond to your request. In accordance with the above, we comply with the Children’s Online Privacy Protection Act and do not knowingly collect information about individuals under the age of 13 years.
Whom can you contact at The Avoca Group?
If you have any questions, comments or concerns about this Policy and/or the Company’s practices or if you want to change your information, stop us from using your information, or opt out of receiving future promotional emails, text messages, telephone calls, and mailings from us, you can contact us via “Contact Us” on our website or write to us at: The Avoca Group, Inc., 179 Nassau St., Princeton, NJ 08542, Attn: Digital Privacy Department. You can also opt-out by following the opt-out instructions in promotional communications we send you. Please note that if you opt out of receiving promotional communications from us, we may still send you non-promotional communications, including emails about your accounts.