Privacy Statement
Overview
At Aristotle, we are committed to
maintaining the confidentiality and security of any personal information about
our users. Your privacy is always at the top of our priorities. This Privacy
Statement explains who we are and spells out how we collect, use, and disclose
personal information from or about you and how to exercise your privacy rights.
If you have any questions or concerns about our use of your personal
information, please contact us using the details provided at the bottom of this
Privacy Statement.
Quick links
We recommend that you read this
Privacy Statement in full to ensure you are fully informed. However, if you
only want to access a particular section of this Privacy Statement, then you
can click on the relevant link (to the left) to jump to that section.
About Us
Aristotle is headquartered in San Francisco,
CA.
If you are a resident in the
European Economic Area (“EEA”), UK or Switzerland, the controller of
your personal information is Aristotle HQ Inc.
What Does this Privacy Statement Cover?
This Privacy Statement applies to
our collection, use and disclosure of personal information that we collect from
you or that you provide when you engage with Aristotle, our website "AristotleHQ.com"
(the “Website”) or the customer engagement platform service at sight.AristotleHQ.com,
AristotleHQ.com ("Aristotle Service") (together the “Services”). Aristotle
Users can access the Aristotle Service via our website AristotleHQ.com,
sight.AristotleHQ.com, applications on Devices, APIs, and third-parties.
This Privacy Statement only applies
where we are processing personal information for our own purposes. It does not
cover the personal information Aristotle collects, uses and discloses on behalf
of its Clients (“Client Data”) in connection with the Aristotle Service
and we invite you to contact the relevant company or organization if you have
any questions about their privacy practices.
The Information We Collect
The personal information we collect
broadly falls within the following categories:
Information you provide voluntarily
Certain parts of our Website or Aristotle
Service ask you to provide certain information voluntarily. This typically
includes:
Information we collect
automatically
Like most companies that offer
online services, we may automatically collect certain information from your
computer or device, about your use of the Aristotle Service or our Website. We
use this information to provide our Services, ensure the security of our
Services, help improve our Services and promote our Services to you. This
typically includes:
Information we obtain from
third-party sources
From time to time, we may receive
personal information about you from third party sources but only when these
third parties have confirmed to us that they either have your consent or are
otherwise legally permitted or required to disclose this information to us.
This typically includes:
Client Data
Please note that as explained
above, we also receive personal information about you, in the form of Client
Data from our Client. We use such personal information to provide the Aristotle
Service to our Clients and only as instructed by the Clients. Under these
circumstances, we process your information as a processor on our Clients'
behalf and it is our Clients, as the controllers of the information, that
determine what information we process about you and how we use it. If you have
any privacy-related questions or concerns about one of our Client's privacy
practices, or the choices a Client has made to share your information with us,
you should contact that company or organization directly. We are not
responsible for the privacy or security practices of our Clients, which may
differ from those described in this Privacy Statement.
How We Use Personal Information
We use personal information about
you for the purposes detailed below. In some regions, such as the European
Economic Area, the United Kingdom and Switzerland, we need a lawful basis to
collect, use and disclose your personal information. Our lawful basis will
depend on the information concerned and the context in which it is processed
and this is also detailed here.
In general, we will use the
personal information we collect only for the purposes described in this Privacy
Statement or for purposes that we explain to you at the time we collect your
personal information. However, we may also use your personal information for
other purposes that are not incompatible with the purposes we have disclosed to
you if and where this is permitted by applicable data protection laws.
Disclosure of Your Personal Information
We may disclose your personal
information to the following categories of recipients:
Vendors, service providers and
partners.We may use certain trusted third-party vendors, service providers and
partners who provide data processing services to us (including but not limited
to data storage, maintenance services, database management, web analytics,
payment processing, and improvement of the Service’s features). These third
parties will only process your information for the purposes described in this
Privacy Statement or that are notified to you when we collect your information.
Third-Party Applications. Our
Website includes links to other websites whose privacy practices may differ
from those of Aristotle. For example, our website includes social media
features, such as the Facebook Like button and widgets, such as the "Share
This" button for Twitter and LinkedIn. These features allow you to share
information about your activities on our Services through social media
networks. This Privacy Statement does not apply to your use of any such third
party plug-ins and applications and we are not responsible for how those third
parties use and disclose your information. Your interactions with these
features are governed by the privacy policy of the company providing it.
Compliance with Laws and Law
Enforcement Requests; Protection of Aristotle's Rights
We may disclose to any competent
law enforcement body, regulatory, government agency, court or other third party
data stored in your Aristotle account and information about you that we process
only when we have a good faith belief that disclosure is reasonably necessary
to (a) comply with a law, regulation, or compulsory legal request, such as to
comply with a subpoena; (b) protect the safety of any person from death or
serious bodily injury; (c) prevent fraud or abuse of Aristotle or its users; or
(d) to protect Aristotle's rights. If we provide any data stored in your Aristotle
account to a law enforcement agency, we will remove Aristotle's encryption from
the information before providing it to law enforcement. However, Aristotle will
not be able to decrypt anything that you encrypted prior to uploading it to Aristotle.
Business Transfers
Your information may be transferred
to potential or actual buyers (and their agents and advisers) in connection
with a merger, acquisition, or sale of all or a portion of our assets, provided
that we inform the buyer it must use your personal information only for the
purposes disclosed in this Privacy Statement.
Consent. We may share your
information with others where you have given your consent to the disclosure.
International Data Transfers
Aristotle is a US company and our
service providers are located in the US and other countries.This means that
your personal information may be transferred to, and processed in, countries
other than the country in which you are located. These countries may have data
protection laws that are different to the laws of your country (and, in some
cases, may not be as protective).
However, we take appropriate
safeguards to ensure that your information remains protected in accordance with
this Privacy Statement and applicable data protection laws. If you are located
in the European Economic Area, United Kingdom or Switzerland these safeguards
include transferring your information to a country that the relevant
authorities have determined provide an adequate level of protection for
personal information, or by implementing standard contractual clauses with our
customers, third party service providers and partners.
Data Protection Rights
You can access and control the
personal information that we process about you as follows:
Account information. If
you are a Client Representative and are registered with us, you may review,
update, correct, or delete certain personal information provided in your
registration or account profile by changing your account settings.
Account closure. If
you no longer desire to use our Aristotle Service, you may delete your account
by making the change in your account settings, although (in some cases) we may
retain copies of your information if required by law, to protect our rights, or
if it is not technically reasonably feasible to remove it.
Direct marketing. You
can opt-out from marketing communications that we send. including our
newsletter, at any time. You can do this by clicking on the
"unsubscribe" or "opt-out" link in the marketing
communications we send, by accessing the email preferences in your account
settings page, or by contacting us at hello@AristotleHQ.com or by using the
details provided below.
Privacy rights. Depending
on your location and applicable data protection laws, you may also have certain
rights with regard to the personal information we control about you.
We respond to all requests we
receive from individuals wishing to exercise their privacy rights in accordance
with applicable data protection laws. If you would like to exercise any of the
rights which are available to you under applicable data protection laws, please
contact us at hello@AristotleHQ.com or by using the details provided below.
Please note that we may need to verify your identity before we can respond to
your request.
Additional Information for Europe
Under European laws (including the
GDPR) you may have the following rights:
Additional Information for California
If you are a California resident
and the processing of personal information about you is subject to the
California Consumer Privacy Act (“CCPA”), the following information also
applies to you and supplements the information contained in this Privacy
Statement.
Information We Collect and Sources
of Information
Our Privacy Statement already describes
the information we collect and the sources of information – see the above
sections "The Information We Collect” and “How We Use Personal
Information". This section organizes that information around the personal
information categories set out in the CCPA.
In the past 12 months, we have
collected the following information for the following purposes:
How We Share your Personal
Information:
We do not share your personal
information except as approved by you or as otherwise described in this Privacy
Statement. In the preceding 12 months, we have disclosed the following
categories of personal information described above for the business purposes
described in this Privacy Statement:
Under the CCPA, a "sale"
is defined very broadly and includes a wide array of data sharing. As the term
is defined by the CCPA, we “sold” the following categories of personal
information in the last 12 months: identifiers/contact information, Internet or
other electronic network activity information, and inferences drawn from the
above. We “sold” such information to advertising networks and data analytics
providers. The business purposes of “selling” personal information is for
third-party companies to perform services on our behalf, such as marketing,
advertising, and audience measurement. We do not have any actual knowledge that
we "sell" personal information of consumers under 16 years of age.
Most modern web browsers give you
the option to send a Do Not Track signal to the sites you visit, indicating
that you do not wish to be tracked. However, there is no accepted standard for
how a site should respond to this signal, and we do not take any action in
response to this signal.
If you are a California resident
our default cookie settings may constitute a sale of personal information. You
can change your cookie settings using our cookie consent management tool.
California Privacy Rights
If you are a California resident,
you may have the following consumer privacy rights:
You may designate, in writing or
through a power of attorney, an authorized agent to make requests on your
behalf to exercise your rights under the CCPA. Before accepting such a request
from an agent, we will require the agent to provide proof you have authorized
it to act on your behalf, and we may need you to verify your identity directly
with us.
Further, to provide or delete
specific pieces of personal information we will need to verify your identity to
the degree of certainty required by law.
For more information regarding data
rights requests, refer to the Contacting Us section below.
Data Retention
Aristotle will retain personal data
we process about Aristotle Users for as long as we have a legitimate business
purpose to do so. If you wish to cancel your account or request that we no
longer use your information to provide you Services, you may delete your
account. Please note that Aristotle may retain your personal data for longer
where there is a legal, tax or accounting obligation, contractual, or
legitimate interest, including resolving disputes and enforcing our agreements
and rights. When we no longer have an ongoing legitimate business need to
process your personal information, we will either delete or anonymize it or, if
this is not possible (for example, because your information has been stored in
backup archives), then we will securely store your information and isolate it
from any further processing until deletion is possible.
Please note that Aristotle will
retain Client Data that we process on behalf of our Clients for as long as
needed to provide services to our Clients and in accordance with our agreements
with our Clients.
Blogs
If the personal information we
process about you is subject to EU data protection law, we rely on one or more
of the following EU lawful legal bases:
Personal information is or may be used
for the following purposes:
If you no longer wish to receive
communications from us that are not required for the Service, please follow the
"unsubscribe" instructions provided in any of those communications or
update your account settings information.
Security
Aristotle stresses its privacy and
security standards. Although no one can guarantee absolute security, we
regularly re-evaluate our privacy and security policies in order to adapt to
new challenges. We follow generally accepted standards to protect the
information submitted to us, both during transmission and once we receive it.
Changes to our Privacy Statement
We may update this Privacy
Statement from time to time. If we make a material change to this Privacy
Statement, we will provide you with notice (for example, by email, a sign-in
notification, or some other means) and obtain your consent if and where this is
required by applicable data protection law prior to the change becoming
effective. You can see when this Privacy Statement was last updated by checking
the "last updated" date at the top of this Privacy Statement.
Contacting Us
If you have any questions about our
use of personal data, please contact us at hello@AristotleHQ.com.
Privacy Shield
Although the EU-U.S. and Swiss-U.S.
Privacy Shield Frameworks have been ruled invalid for transfer of data from the
EU and Switzerland to the U.S., while government discussions regarding possible
replacement mechanisms proceed, we will continue to protect European data
according to the standards of the Privacy Shield and applicable European law
and will implement other methods for transferring data to the extent those are
available (as explained under the “International Data Transfers” above). To
learn more about the Privacy Shield Frameworks, visit the U.S. Department of
Commerce’s Privacy Shield program
site.
Aristotle is responsible for the
processing of personal data it receives, under the Privacy Shield Frameworks,
and subsequently transfers to a third party acting as an agent on its behalf. Aristotle
complies with the Privacy Shield Principles for all onward transfers of
personal data from the EEA, UK or Switzerland, including the onward transfer liability
provisions.
With respect to personal data
received or transferred pursuant to the Privacy Shield Framework, Aristotle is
subject to the regulatory enforcement powers of the U.S. Federal Trade
Commission. In certain situations, Aristotle may be required to disclose
personal data in response to lawful requests by public authorities, including
to meet national security or law enforcement requirements.
If you have an unresolved privacy
or data use concern that we have not addressed satisfactorily, please contact
our U.S.-based third party dispute resolution provider (free of charge)
at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more
fully described on the Privacy Shield website,
you may be entitled to invoke binding arbitration when other dispute resolution
procedures have been exhausted.
Overview
At Aristotle, we are committed to
maintaining the confidentiality and security of any personal information about
our users. Your privacy is always at the top of our priorities. This Privacy
Statement explains who we are and spells out how we collect, use, and disclose
personal information from or about you and how to exercise your privacy rights.
If you have any questions or concerns about our use of your personal
information, please contact us using the details provided at the bottom of this
Privacy Statement.
Quick links
We recommend that you read this
Privacy Statement in full to ensure you are fully informed. However, if you
only want to access a particular section of this Privacy Statement, then you
can click on the relevant link (to the left) to jump to that section.
About Us
Aristotle is headquartered in San Francisco,
CA.
If you are a resident in the
European Economic Area (“EEA”), UK or Switzerland, the controller of
your personal information is Aristotle HQ Inc.
What Does this Privacy Statement Cover?
This Privacy Statement applies to
our collection, use and disclosure of personal information that we collect from
you or that you provide when you engage with Aristotle, our website "AristotleHQ.com"
(the “Website”) or the customer engagement platform service at sight.AristotleHQ.com,
AristotleHQ.com ("Aristotle Service") (together the “Services”). Aristotle
Users can access the Aristotle Service via our website AristotleHQ.com,
sight.AristotleHQ.com, applications on Devices, APIs, and third-parties.
This Privacy Statement only applies
where we are processing personal information for our own purposes. It does not
cover the personal information Aristotle collects, uses and discloses on behalf
of its Clients (“Client Data”) in connection with the Aristotle Service
and we invite you to contact the relevant company or organization if you have
any questions about their privacy practices.
The Information We Collect
The personal information we collect
broadly falls within the following categories:
Information you provide voluntarily
Certain parts of our Website or Aristotle
Service ask you to provide certain information voluntarily. This typically
includes:
Information we collect
automatically
Like most companies that offer
online services, we may automatically collect certain information from your
computer or device, about your use of the Aristotle Service or our Website. We
use this information to provide our Services, ensure the security of our
Services, help improve our Services and promote our Services to you. This
typically includes:
Information we obtain from
third-party sources
From time to time, we may receive
personal information about you from third party sources but only when these
third parties have confirmed to us that they either have your consent or are
otherwise legally permitted or required to disclose this information to us.
This typically includes:
Client Data
Please note that as explained
above, we also receive personal information about you, in the form of Client
Data from our Client. We use such personal information to provide the Aristotle
Service to our Clients and only as instructed by the Clients. Under these
circumstances, we process your information as a processor on our Clients'
behalf and it is our Clients, as the controllers of the information, that
determine what information we process about you and how we use it. If you have
any privacy-related questions or concerns about one of our Client's privacy
practices, or the choices a Client has made to share your information with us,
you should contact that company or organization directly. We are not
responsible for the privacy or security practices of our Clients, which may
differ from those described in this Privacy Statement.
How We Use Personal Information
We use personal information about
you for the purposes detailed below. In some regions, such as the European
Economic Area, the United Kingdom and Switzerland, we need a lawful basis to
collect, use and disclose your personal information. Our lawful basis will
depend on the information concerned and the context in which it is processed
and this is also detailed here.
In general, we will use the
personal information we collect only for the purposes described in this Privacy
Statement or for purposes that we explain to you at the time we collect your
personal information. However, we may also use your personal information for
other purposes that are not incompatible with the purposes we have disclosed to
you if and where this is permitted by applicable data protection laws.
Disclosure of Your Personal Information
We may disclose your personal
information to the following categories of recipients:
Vendors, service providers and
partners.We may use certain trusted third-party vendors, service providers and
partners who provide data processing services to us (including but not limited
to data storage, maintenance services, database management, web analytics,
payment processing, and improvement of the Service’s features). These third
parties will only process your information for the purposes described in this
Privacy Statement or that are notified to you when we collect your information.
Third-Party Applications. Our
Website includes links to other websites whose privacy practices may differ
from those of Aristotle. For example, our website includes social media
features, such as the Facebook Like button and widgets, such as the "Share
This" button for Twitter and LinkedIn. These features allow you to share
information about your activities on our Services through social media
networks. This Privacy Statement does not apply to your use of any such third
party plug-ins and applications and we are not responsible for how those third
parties use and disclose your information. Your interactions with these
features are governed by the privacy policy of the company providing it.
Compliance with Laws and Law
Enforcement Requests; Protection of Aristotle's Rights
We may disclose to any competent
law enforcement body, regulatory, government agency, court or other third party
data stored in your Aristotle account and information about you that we process
only when we have a good faith belief that disclosure is reasonably necessary
to (a) comply with a law, regulation, or compulsory legal request, such as to
comply with a subpoena; (b) protect the safety of any person from death or
serious bodily injury; (c) prevent fraud or abuse of Aristotle or its users; or
(d) to protect Aristotle's rights. If we provide any data stored in your Aristotle
account to a law enforcement agency, we will remove Aristotle's encryption from
the information before providing it to law enforcement. However, Aristotle will
not be able to decrypt anything that you encrypted prior to uploading it to Aristotle.
Business Transfers
Your information may be transferred
to potential or actual buyers (and their agents and advisers) in connection
with a merger, acquisition, or sale of all or a portion of our assets, provided
that we inform the buyer it must use your personal information only for the
purposes disclosed in this Privacy Statement.
Consent. We may share your
information with others where you have given your consent to the disclosure.
International Data Transfers
Aristotle is a US company and our
service providers are located in the US and other countries.This means that
your personal information may be transferred to, and processed in, countries
other than the country in which you are located. These countries may have data
protection laws that are different to the laws of your country (and, in some
cases, may not be as protective).
However, we take appropriate
safeguards to ensure that your information remains protected in accordance with
this Privacy Statement and applicable data protection laws. If you are located
in the European Economic Area, United Kingdom or Switzerland these safeguards
include transferring your information to a country that the relevant
authorities have determined provide an adequate level of protection for
personal information, or by implementing standard contractual clauses with our
customers, third party service providers and partners.
Data Protection Rights
You can access and control the
personal information that we process about you as follows:
Account information. If
you are a Client Representative and are registered with us, you may review,
update, correct, or delete certain personal information provided in your
registration or account profile by changing your account settings.
Account closure. If
you no longer desire to use our Aristotle Service, you may delete your account
by making the change in your account settings, although (in some cases) we may
retain copies of your information if required by law, to protect our rights, or
if it is not technically reasonably feasible to remove it.
Direct marketing. You
can opt-out from marketing communications that we send. including our
newsletter, at any time. You can do this by clicking on the
"unsubscribe" or "opt-out" link in the marketing
communications we send, by accessing the email preferences in your account
settings page, or by contacting us at hello@AristotleHQ.com or by using the
details provided below.
Privacy rights. Depending
on your location and applicable data protection laws, you may also have certain
rights with regard to the personal information we control about you.
We respond to all requests we
receive from individuals wishing to exercise their privacy rights in accordance
with applicable data protection laws. If you would like to exercise any of the
rights which are available to you under applicable data protection laws, please
contact us at hello@AristotleHQ.com or by using the details provided below.
Please note that we may need to verify your identity before we can respond to
your request.
Additional Information for Europe
Under European laws (including the
GDPR) you may have the following rights:
Additional Information for California
If you are a California resident
and the processing of personal information about you is subject to the
California Consumer Privacy Act (“CCPA”), the following information also
applies to you and supplements the information contained in this Privacy
Statement.
Information We Collect and Sources
of Information
Our Privacy Statement already
describes the information we collect and the sources of information – see the
above sections "The Information We Collect” and “How We Use Personal
Information". This section organizes that information around the personal
information categories set out in the CCPA.
In the past 12 months, we have
collected the following information for the following purposes:
How We Share your Personal
Information:
We do not share your personal
information except as approved by you or as otherwise described in this Privacy
Statement. In the preceding 12 months, we have disclosed the following
categories of personal information described above for the business purposes
described in this Privacy Statement:
Under the CCPA, a "sale"
is defined very broadly and includes a wide array of data sharing. As the term
is defined by the CCPA, we “sold” the following categories of personal
information in the last 12 months: identifiers/contact information, Internet or
other electronic network activity information, and inferences drawn from the
above. We “sold” such information to advertising networks and data analytics
providers. The business purposes of “selling” personal information is for
third-party companies to perform services on our behalf, such as marketing,
advertising, and audience measurement. We do not have any actual knowledge that
we "sell" personal information of consumers under 16 years of age.
Most modern web browsers give you
the option to send a Do Not Track signal to the sites you visit, indicating
that you do not wish to be tracked. However, there is no accepted standard for
how a site should respond to this signal, and we do not take any action in
response to this signal.
If you are a California resident
our default cookie settings may constitute a sale of personal information. You
can change your cookie settings using our cookie consent management tool.
California Privacy Rights
If you are a California resident,
you may have the following consumer privacy rights:
You may designate, in writing or
through a power of attorney, an authorized agent to make requests on your
behalf to exercise your rights under the CCPA. Before accepting such a request
from an agent, we will require the agent to provide proof you have authorized
it to act on your behalf, and we may need you to verify your identity directly
with us.
Further, to provide or delete
specific pieces of personal information we will need to verify your identity to
the degree of certainty required by law.
For more information regarding data
rights requests, refer to the Contacting Us section below.
Data Retention
Aristotle will retain personal data
we process about Aristotle Users for as long as we have a legitimate business
purpose to do so. If you wish to cancel your account or request that we no
longer use your information to provide you Services, you may delete your
account. Please note that Aristotle may retain your personal data for longer
where there is a legal, tax or accounting obligation, contractual, or
legitimate interest, including resolving disputes and enforcing our agreements
and rights. When we no longer have an ongoing legitimate business need to
process your personal information, we will either delete or anonymize it or, if
this is not possible (for example, because your information has been stored in
backup archives), then we will securely store your information and isolate it
from any further processing until deletion is possible.
Please note that Aristotle will
retain Client Data that we process on behalf of our Clients for as long as
needed to provide services to our Clients and in accordance with our agreements
with our Clients.
Blogs
If the personal information we
process about you is subject to EU data protection law, we rely on one or more
of the following EU lawful legal bases:
Personal information is or may be
used for the following purposes:
If you no longer wish to receive
communications from us that are not required for the Service, please follow the
"unsubscribe" instructions provided in any of those communications or
update your account settings information.
Google API Statement
Access and Usage of Google User
Data: Aristotle ensures that access to Google user data is contingent upon
explicit consent granted by the user. Upon connecting their Google account to Aristotle,
users authorize the application to access their data through Google
authentication. This access enables Aristotle to utilize Google's robust
application programming interface (API) for specific functionalities such as
composing, sending, and reading emails. It is important to note that Aristotle's
usage of the Google API is solely limited to facilitating enhanced email
management services within the Aristotle application.
Data Storage, Security, and
Confidentiality: Aristotle prioritizes the security and confidentiality of
Google user data. Once acquired, the data is stored on secure servers with
stringent measures in place to protect against unauthorized access, employing
industry-standard security practices. Aristotle adheres to data protection laws
and regulations to ensure the privacy of user data. Importantly, Aristotle does
not share or sell any Google user data with third parties. The acquired data is
strictly utilized within the Aristotle application, enhancing email management
functionality and delivering an optimized user experience.
Security
Aristotle stresses its privacy and
security standards. Although no one can guarantee absolute security, we
regularly re-evaluate our privacy and security policies in order to adapt to
new challenges. We follow generally accepted standards to protect the
information submitted to us, both during transmission and once we receive it.
Changes to our Privacy Statement
We may update this Privacy
Statement from time to time. If we make a material change to this Privacy
Statement, we will provide you with notice (for example, by email, a sign-in
notification, or some other means) and obtain your consent if and where this is
required by applicable data protection law prior to the change becoming
effective. You can see when this Privacy Statement was last updated by checking
the "last updated" date at the top of this Privacy Statement.
Contacting Us
If you have any questions about our
use of personal data, please contact us at hello@AristotleHQ.com.
Privacy Shield
Although the EU-U.S. and Swiss-U.S.
Privacy Shield Frameworks have been ruled invalid for transfer of data from the
EU and Switzerland to the U.S., while government discussions regarding possible
replacement mechanisms proceed, we will continue to protect European data
according to the standards of the Privacy Shield and applicable European law
and will implement other methods for transferring data to the extent those are
available (as explained under the “International Data Transfers” above). To
learn more about the Privacy Shield Frameworks, visit the U.S. Department of
Commerce’s Privacy Shield program
site.
Aristotle is responsible for the
processing of personal data it receives, under the Privacy Shield Frameworks,
and subsequently transfers to a third party acting as an agent on its behalf. Aristotle
complies with the Privacy Shield Principles for all onward transfers of
personal data from the EEA, UK or Switzerland, including the onward transfer
liability provisions.
With respect to personal data
received or transferred pursuant to the Privacy Shield Framework, Aristotle is
subject to the regulatory enforcement powers of the U.S. Federal Trade
Commission. In certain situations, Aristotle may be required to disclose
personal data in response to lawful requests by public authorities, including
to meet national security or law enforcement requirements.
If you have an unresolved privacy
or data use concern that we have not addressed satisfactorily, please contact
our U.S.-based third party dispute resolution provider (free of charge)
at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more
fully described on the Privacy Shield website,
you may be entitled to invoke binding arbitration when other dispute resolution
procedures have been exhausted.
Overview
At Aristotle, we are committed to
maintaining the confidentiality and security of any personal information about
our users. Your privacy is always at the top of our priorities. This Privacy
Statement explains who we are and spells out how we collect, use, and disclose
personal information from or about you and how to exercise your privacy rights.
If you have any questions or concerns about our use of your personal
information, please contact us using the details provided at the bottom of this
Privacy Statement.
Quick links
We recommend that you read this
Privacy Statement in full to ensure you are fully informed. However, if you
only want to access a particular section of this Privacy Statement, then you
can click on the relevant link (to the left) to jump to that section.
About Us
Aristotle is headquartered in San Francisco,
CA.
If you are a resident in the
European Economic Area (“EEA”), UK or Switzerland, the controller of
your personal information is Aristotle HQ Inc.
What Does this Privacy Statement Cover?
This Privacy Statement applies to
our collection, use and disclosure of personal information that we collect from
you or that you provide when you engage with Aristotle, our website "AristotleHQ.com"
(the “Website”) or the customer engagement platform service at sight.AristotleHQ.com,
AristotleHQ.com ("Aristotle Service") (together the “Services”). Aristotle
Users can access the Aristotle Service via our website AristotleHQ.com,
sight.AristotleHQ.com, applications on Devices, APIs, and third-parties.
This Privacy Statement only applies
where we are processing personal information for our own purposes. It does not
cover the personal information Aristotle collects, uses and discloses on behalf
of its Clients (“Client Data”) in connection with the Aristotle Service
and we invite you to contact the relevant company or organization if you have
any questions about their privacy practices.
The Information We Collect
The personal information we collect
broadly falls within the following categories:
Information you provide voluntarily
Certain parts of our Website or Aristotle
Service ask you to provide certain information voluntarily. This typically
includes:
Information we collect
automatically
Like most companies that offer
online services, we may automatically collect certain information from your
computer or device, about your use of the Aristotle Service or our Website. We
use this information to provide our Services, ensure the security of our
Services, help improve our Services and promote our Services to you. This
typically includes:
Information we obtain from
third-party sources
From time to time, we may receive
personal information about you from third party sources but only when these
third parties have confirmed to us that they either have your consent or are
otherwise legally permitted or required to disclose this information to us.
This typically includes:
Client Data
Please note that as explained
above, we also receive personal information about you, in the form of Client
Data from our Client. We use such personal information to provide the Aristotle
Service to our Clients and only as instructed by the Clients. Under these
circumstances, we process your information as a processor on our Clients'
behalf and it is our Clients, as the controllers of the information, that
determine what information we process about you and how we use it. If you have
any privacy-related questions or concerns about one of our Client's privacy
practices, or the choices a Client has made to share your information with us,
you should contact that company or organization directly. We are not
responsible for the privacy or security practices of our Clients, which may
differ from those described in this Privacy Statement.
How We Use Personal Information
We use personal information about
you for the purposes detailed below. In some regions, such as the European
Economic Area, the United Kingdom and Switzerland, we need a lawful basis to
collect, use and disclose your personal information. Our lawful basis will
depend on the information concerned and the context in which it is processed
and this is also detailed here.
In general, we will use the
personal information we collect only for the purposes described in this Privacy
Statement or for purposes that we explain to you at the time we collect your
personal information. However, we may also use your personal information for
other purposes that are not incompatible with the purposes we have disclosed to
you if and where this is permitted by applicable data protection laws.
Disclosure of Your Personal Information
We may disclose your personal
information to the following categories of recipients:
Vendors, service providers and
partners.We may use certain trusted third-party vendors, service providers and
partners who provide data processing services to us (including but not limited
to data storage, maintenance services, database management, web analytics,
payment processing, and improvement of the Service’s features). These third
parties will only process your information for the purposes described in this
Privacy Statement or that are notified to you when we collect your information.
Third-Party Applications. Our
Website includes links to other websites whose privacy practices may differ
from those of Aristotle. For example, our website includes social media
features, such as the Facebook Like button and widgets, such as the "Share
This" button for Twitter and LinkedIn. These features allow you to share
information about your activities on our Services through social media
networks. This Privacy Statement does not apply to your use of any such third
party plug-ins and applications and we are not responsible for how those third
parties use and disclose your information. Your interactions with these
features are governed by the privacy policy of the company providing it.
Compliance with Laws and Law
Enforcement Requests; Protection of Aristotle's Rights
We may disclose to any competent
law enforcement body, regulatory, government agency, court or other third party
data stored in your Aristotle account and information about you that we process
only when we have a good faith belief that disclosure is reasonably necessary
to (a) comply with a law, regulation, or compulsory legal request, such as to
comply with a subpoena; (b) protect the safety of any person from death or
serious bodily injury; (c) prevent fraud or abuse of Aristotle or its users; or
(d) to protect Aristotle's rights. If we provide any data stored in your Aristotle
account to a law enforcement agency, we will remove Aristotle's encryption from
the information before providing it to law enforcement. However, Aristotle will
not be able to decrypt anything that you encrypted prior to uploading it to Aristotle.
Business Transfers
Your information may be transferred
to potential or actual buyers (and their agents and advisers) in connection
with a merger, acquisition, or sale of all or a portion of our assets, provided
that we inform the buyer it must use your personal information only for the
purposes disclosed in this Privacy Statement.
Consent. We may share your
information with others where you have given your consent to the disclosure.
International Data Transfers
Aristotle is a US company and our
service providers are located in the US and other countries.This means that
your personal information may be transferred to, and processed in, countries
other than the country in which you are located. These countries may have data
protection laws that are different to the laws of your country (and, in some
cases, may not be as protective).
However, we take appropriate
safeguards to ensure that your information remains protected in accordance with
this Privacy Statement and applicable data protection laws. If you are located
in the European Economic Area, United Kingdom or Switzerland these safeguards
include transferring your information to a country that the relevant
authorities have determined provide an adequate level of protection for
personal information, or by implementing standard contractual clauses with our
customers, third party service providers and partners.
Data Protection Rights
You can access and control the
personal information that we process about you as follows:
Account information. If
you are a Client Representative and are registered with us, you may review,
update, correct, or delete certain personal information provided in your
registration or account profile by changing your account settings.
Account closure. If
you no longer desire to use our Aristotle Service, you may delete your account
by making the change in your account settings, although (in some cases) we may
retain copies of your information if required by law, to protect our rights, or
if it is not technically reasonably feasible to remove it.
Direct marketing. You
can opt-out from marketing communications that we send. including our
newsletter, at any time. You can do this by clicking on the
"unsubscribe" or "opt-out" link in the marketing
communications we send, by accessing the email preferences in your account
settings page, or by contacting us at hello@AristotleHQ.com or by using the
details provided below.
Privacy rights. Depending
on your location and applicable data protection laws, you may also have certain
rights with regard to the personal information we control about you.
We respond to all requests we
receive from individuals wishing to exercise their privacy rights in accordance
with applicable data protection laws. If you would like to exercise any of the
rights which are available to you under applicable data protection laws, please
contact us at hello@AristotleHQ.com or by using the details provided below.
Please note that we may need to verify your identity before we can respond to
your request.
Additional Information for Europe
Under European laws (including the
GDPR) you may have the following rights:
Additional Information for California
If you are a California resident
and the processing of personal information about you is subject to the
California Consumer Privacy Act (“CCPA”), the following information also
applies to you and supplements the information contained in this Privacy
Statement.
Information We Collect and Sources
of Information
Our Privacy Statement already
describes the information we collect and the sources of information – see the
above sections "The Information We Collect” and “How We Use Personal
Information". This section organizes that information around the personal
information categories set out in the CCPA.
In the past 12 months, we have
collected the following information for the following purposes:
How We Share your Personal
Information:
We do not share your personal
information except as approved by you or as otherwise described in this Privacy
Statement. In the preceding 12 months, we have disclosed the following
categories of personal information described above for the business purposes
described in this Privacy Statement:
Under the CCPA, a "sale"
is defined very broadly and includes a wide array of data sharing. As the term
is defined by the CCPA, we “sold” the following categories of personal
information in the last 12 months: identifiers/contact information, Internet or
other electronic network activity information, and inferences drawn from the
above. We “sold” such information to advertising networks and data analytics
providers. The business purposes of “selling” personal information is for
third-party companies to perform services on our behalf, such as marketing,
advertising, and audience measurement. We do not have any actual knowledge that
we "sell" personal information of consumers under 16 years of age.
Most modern web browsers give you
the option to send a Do Not Track signal to the sites you visit, indicating
that you do not wish to be tracked. However, there is no accepted standard for
how a site should respond to this signal, and we do not take any action in
response to this signal.
If you are a California resident
our default cookie settings may constitute a sale of personal information. You
can change your cookie settings using our cookie consent management tool.
California Privacy Rights
If you are a California resident,
you may have the following consumer privacy rights:
You may designate, in writing or
through a power of attorney, an authorized agent to make requests on your
behalf to exercise your rights under the CCPA. Before accepting such a request
from an agent, we will require the agent to provide proof you have authorized
it to act on your behalf, and we may need you to verify your identity directly
with us.
Further, to provide or delete
specific pieces of personal information we will need to verify your identity to
the degree of certainty required by law.
For more information regarding data
rights requests, refer to the Contacting Us section below.
Data Retention
Aristotle will retain personal data
we process about Aristotle Users for as long as we have a legitimate business
purpose to do so. If you wish to cancel your account or request that we no
longer use your information to provide you Services, you may delete your
account. Please note that Aristotle may retain your personal data for longer
where there is a legal, tax or accounting obligation, contractual, or
legitimate interest, including resolving disputes and enforcing our agreements
and rights. When we no longer have an ongoing legitimate business need to
process your personal information, we will either delete or anonymize it or, if
this is not possible (for example, because your information has been stored in
backup archives), then we will securely store your information and isolate it
from any further processing until deletion is possible.
Please note that Aristotle will
retain Client Data that we process on behalf of our Clients for as long as
needed to provide services to our Clients and in accordance with our agreements
with our Clients.
Blogs
If the personal information we
process about you is subject to EU data protection law, we rely on one or more
of the following EU lawful legal bases:
Personal information is or may be
used for the following purposes:
If you no longer wish to receive
communications from us that are not required for the Service, please follow the
"unsubscribe" instructions provided in any of those communications or
update your account settings information.
Security
Aristotle stresses its privacy and
security standards. Although no one can guarantee absolute security, we
regularly re-evaluate our privacy and security policies in order to adapt to
new challenges. We follow generally accepted standards to protect the
information submitted to us, both during transmission and once we receive it.
Changes to our Privacy Statement
We may update this Privacy
Statement from time to time. If we make a material change to this Privacy
Statement, we will provide you with notice (for example, by email, a sign-in
notification, or some other means) and obtain your consent if and where this is
required by applicable data protection law prior to the change becoming
effective. You can see when this Privacy Statement was last updated by checking
the "last updated" date at the top of this Privacy Statement.
Contacting Us
If you have any questions about our
use of personal data, please contact us at hello@AristotleHQ.com.
Privacy Shield
Although the EU-U.S. and Swiss-U.S.
Privacy Shield Frameworks have been ruled invalid for transfer of data from the
EU and Switzerland to the U.S., while government discussions regarding possible
replacement mechanisms proceed, we will continue to protect European data
according to the standards of the Privacy Shield and applicable European law
and will implement other methods for transferring data to the extent those are
available (as explained under the “International Data Transfers” above). To
learn more about the Privacy Shield Frameworks, visit the U.S. Department of
Commerce’s Privacy Shield program
site.
Aristotle is responsible for the
processing of personal data it receives, under the Privacy Shield Frameworks, and
subsequently transfers to a third party acting as an agent on its behalf. Aristotle
complies with the Privacy Shield Principles for all onward transfers of
personal data from the EEA, UK or Switzerland, including the onward transfer
liability provisions.
With respect to personal data
received or transferred pursuant to the Privacy Shield Framework, Aristotle is
subject to the regulatory enforcement powers of the U.S. Federal Trade
Commission. In certain situations, Aristotle may be required to disclose personal
data in response to lawful requests by public authorities, including to meet
national security or law enforcement requirements.
If you have an unresolved privacy
or data use concern that we have not addressed satisfactorily, please contact
our U.S.-based third party dispute resolution provider (free of charge)
at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more
fully described on the Privacy Shield website,
you may be entitled to invoke binding arbitration when other dispute resolution
procedures have been exhausted.
Overview
At Aristotle,
we are committed to maintaining the confidentiality and security of any
personal information about our users. Your privacy is always at the top of our
priorities. This Privacy Statement explains who we are and spells out how we
collect, use, and disclose personal information from or about you and how to
exercise your privacy rights. If you have any questions or concerns about our
use of your personal information, please contact us using the details provided
at the bottom of this Privacy Statement.
Quick
links
We recommend
that you read this Privacy Statement in full to ensure you are fully informed.
However, if you only want to access a particular section of this Privacy
Statement, then you can click on the relevant link (to the left) to jump to
that section.
About Us
Aristotle is
headquartered in San Francisco, CA.
If you are a
resident in the European Economic Area (“EEA”), UK or Switzerland, the
controller of your personal information is Aristotle HQ Inc.
What Does this Privacy Statement
Cover?
This Privacy
Statement applies to our collection, use and disclosure of personal information
that we collect from you or that you provide when you engage with Aristotle,
our website "AristotleHQ.com" (the “Website”) or the customer
engagement platform service at sight.AristotleHQ.com, AristotleHQ.com ("Aristotle
Service") (together the “Services”). Aristotle Users can
access the Aristotle Service via our website AristotleHQ.com, sight.AristotleHQ.com,
applications on Devices, APIs, and third-parties.
This Privacy
Statement only applies where we are processing personal information for our own
purposes. It does not cover the personal information Aristotle collects, uses
and discloses on behalf of its Clients (“Client Data”) in connection
with the Aristotle Service and we invite you to contact the relevant company or
organization if you have any questions about their privacy practices.
The Information We Collect
The personal
information we collect broadly falls within the following categories:
Information
you provide voluntarily
Certain parts
of our Website or Aristotle Service ask you to provide certain information
voluntarily. This typically includes:
Information we
collect automatically
Like most
companies that offer online services, we may automatically collect certain
information from your computer or device, about your use of the Aristotle
Service or our Website. We use this information to provide our Services, ensure
the security of our Services, help improve our Services and promote our
Services to you. This typically includes:
Information we
obtain from third-party sources
From time to
time, we may receive personal information about you from third party sources
but only when these third parties have confirmed to us that they either have
your consent or are otherwise legally permitted or required to disclose this information
to us. This typically includes:
Client Data
Please note
that as explained above, we also receive personal information about you, in the
form of Client Data from our Client. We use such personal information to
provide the Aristotle Service to our Clients and only as instructed by the
Clients. Under these circumstances, we process your information as a processor
on our Clients' behalf and it is our Clients, as the controllers of the
information, that determine what information we process about you and how we
use it. If you have any privacy-related questions or concerns about one of our
Client's privacy practices, or the choices a Client has made to share your
information with us, you should contact that company or organization directly.
We are not responsible for the privacy or security practices of our Clients,
which may differ from those described in this Privacy Statement.
How We Use Personal Information
We use
personal information about you for the purposes detailed below. In some
regions, such as the European Economic Area, the United Kingdom and
Switzerland, we need a lawful basis to collect, use and disclose your personal
information. Our lawful basis will depend on the information concerned and the
context in which it is processed and this is also detailed here.
In general, we
will use the personal information we collect only for the purposes described in
this Privacy Statement or for purposes that we explain to you at the time we
collect your personal information. However, we may also use your personal
information for other purposes that are not incompatible with the purposes we
have disclosed to you if and where this is permitted by applicable data
protection laws.
Disclosure of Your Personal
Information
We may
disclose your personal information to the following categories of recipients:
Vendors,
service providers and partners.We may use certain trusted third-party vendors,
service providers and partners who provide data processing services to us
(including but not limited to data storage, maintenance services, database
management, web analytics, payment processing, and improvement of the Service’s
features). These third parties will only process your information for the
purposes described in this Privacy Statement or that are notified to you when
we collect your information.
Third-Party
Applications. Our Website includes links to other websites whose privacy
practices may differ from those of Aristotle. For example, our website includes
social media features, such as the Facebook Like button and widgets, such as
the "Share This" button for Twitter and LinkedIn. These features
allow you to share information about your activities on our Services through
social media networks. This Privacy Statement does not apply to your use of any
such third party plug-ins and applications and we are not responsible for how
those third parties use and disclose your information. Your interactions with these
features are governed by the privacy policy of the company providing it.
Compliance
with Laws and Law Enforcement Requests; Protection of Aristotle's Rights
We may
disclose to any competent law enforcement body, regulatory, government agency,
court or other third party data stored in your Aristotle account and
information about you that we process only when we have a good faith belief
that disclosure is reasonably necessary to (a) comply with a law, regulation,
or compulsory legal request, such as to comply with a subpoena; (b) protect the
safety of any person from death or serious bodily injury; (c) prevent fraud or
abuse of Aristotle or its users; or (d) to protect Aristotle's rights. If we
provide any data stored in your Aristotle account to a law enforcement agency,
we will remove Aristotle's encryption from the information before providing it
to law enforcement. However, Aristotle will not be able to decrypt anything
that you encrypted prior to uploading it to Aristotle.
Business
Transfers
Your information
may be transferred to potential or actual buyers (and their agents and
advisers) in connection with a merger, acquisition, or sale of all or a portion
of our assets, provided that we inform the buyer it must use your personal
information only for the purposes disclosed in this Privacy Statement.
Consent. We
may share your information with others where you have given your consent to the
disclosure.
International Data Transfers
Aristotle is a
US company and our service providers are located in the US and other
countries.This means that your personal information may be transferred to, and
processed in, countries other than the country in which you are located. These
countries may have data protection laws that are different to the laws of your
country (and, in some cases, may not be as protective).
However, we
take appropriate safeguards to ensure that your information remains protected
in accordance with this Privacy Statement and applicable data protection laws.
If you are located in the European Economic Area, United Kingdom or Switzerland
these safeguards include transferring your information to a country that the
relevant authorities have determined provide an adequate level of protection
for personal information, or by implementing standard contractual clauses with
our customers, third party service providers and partners.
Data Protection Rights
You can access
and control the personal information that we process about you as follows:
Account
information. If you are a Client Representative
and are registered with us, you may review, update, correct, or delete certain
personal information provided in your registration or account profile by
changing your account settings.
Account
closure. If you no longer desire to use our Aristotle
Service, you may delete your account by making the change in your account
settings, although (in some cases) we may retain copies of your information if
required by law, to protect our rights, or if it is not technically reasonably
feasible to remove it.
Direct
marketing. You can opt-out from marketing communications
that we send. including our newsletter, at any time. You can do this by
clicking on the "unsubscribe" or "opt-out" link in the
marketing communications we send, by accessing the email preferences in your
account settings page, or by contacting us at hello@AristotleHQ.com or by using
the details provided below.
Privacy
rights. Depending on your location and applicable data
protection laws, you may also have certain rights with regard to the personal
information we control about you.
We respond to
all requests we receive from individuals wishing to exercise their privacy
rights in accordance with applicable data protection laws. If you would like to
exercise any of the rights which are available to you under applicable data
protection laws, please contact us at hello@AristotleHQ.com or by using the
details provided below. Please note that we may need to verify your identity
before we can respond to your request.
Additional Information for Europe
Under European
laws (including the GDPR) you may have the following rights:
Additional Information for
California
If you are a
California resident and the processing of personal information about you is
subject to the California Consumer Privacy Act (“CCPA”), the following
information also applies to you and supplements the information contained in
this Privacy Statement.
Information
We Collect and Sources of Information
Our Privacy
Statement already describes the information we collect and the sources of
information – see the above sections "The Information We Collect” and “How
We Use Personal Information". This section organizes that information
around the personal information categories set out in the CCPA.
In the past 12
months, we have collected the following information for the following purposes:
How We Share
your Personal Information:
We do not
share your personal information except as approved by you or as otherwise
described in this Privacy Statement. In the preceding 12 months, we have
disclosed the following categories of personal information described above for
the business purposes described in this Privacy Statement:
Under the
CCPA, a "sale" is defined very broadly and includes a wide array of
data sharing. As the term is defined by the CCPA, we “sold” the following
categories of personal information in the last 12 months: identifiers/contact
information, Internet or other electronic network activity information, and
inferences drawn from the above. We “sold” such information to advertising
networks and data analytics providers. The business purposes of “selling”
personal information is for third-party companies to perform services on our
behalf, such as marketing, advertising, and audience measurement. We do not
have any actual knowledge that we "sell" personal information of
consumers under 16 years of age.
Most modern
web browsers give you the option to send a Do Not Track signal to the sites you
visit, indicating that you do not wish to be tracked. However, there is no
accepted standard for how a site should respond to this signal, and we do not
take any action in response to this signal.
If you are a
California resident our default cookie settings may constitute a sale of
personal information. You can change your cookie settings using our cookie
consent management tool.
California
Privacy Rights
If you are a
California resident, you may have the following consumer privacy rights:
You may
designate, in writing or through a power of attorney, an authorized agent to
make requests on your behalf to exercise your rights under the CCPA. Before
accepting such a request from an agent, we will require the agent to provide
proof you have authorized it to act on your behalf, and we may need you to verify
your identity directly with us.
Further, to
provide or delete specific pieces of personal information we will need to
verify your identity to the degree of certainty required by law.
For more
information regarding data rights requests, refer to the Contacting Us section
below.
Data Retention
Aristotle will
retain personal data we process about Aristotle Users for as long as we have a
legitimate business purpose to do so. If you wish to cancel your account or
request that we no longer use your information to provide you Services, you may
delete your account. Please note that Aristotle may retain your personal data
for longer where there is a legal, tax or accounting obligation, contractual,
or legitimate interest, including resolving disputes and enforcing our
agreements and rights. When we no longer have an ongoing legitimate business
need to process your personal information, we will either delete or anonymize
it or, if this is not possible (for example, because your information has been
stored in backup archives), then we will securely store your information and
isolate it from any further processing until deletion is possible.
Please note
that Aristotle will retain Client Data that we process on behalf of our Clients
for as long as needed to provide services to our Clients and in accordance with
our agreements with our Clients.
Blogs
If the
personal information we process about you is subject to EU data protection law,
we rely on one or more of the following EU lawful legal bases:
Personal
information is or may be used for the following purposes:
If you no
longer wish to receive communications from us that are not required for the
Service, please follow the "unsubscribe" instructions provided in any
of those communications or update your account settings information.
Security
Aristotle
stresses its privacy and security standards. Although no one can guarantee
absolute security, we regularly re-evaluate our privacy and security policies
in order to adapt to new challenges. We follow generally accepted standards to
protect the information submitted to us, both during transmission and once we
receive it.
Changes to our Privacy Statement
We may update
this Privacy Statement from time to time. If we make a material change to this
Privacy Statement, we will provide you with notice (for example, by email, a
sign-in notification, or some other means) and obtain your consent if and where
this is required by applicable data protection law prior to the change becoming
effective. You can see when this Privacy Statement was last updated by checking
the "last updated" date at the top of this Privacy Statement.
Contacting Us
If you have
any questions about our use of personal data, please contact us at hello@AristotleHQ.com.
Privacy Shield
Although the
EU-U.S. and Swiss-U.S. Privacy Shield Frameworks have been ruled invalid for
transfer of data from the EU and Switzerland to the U.S., while government
discussions regarding possible replacement mechanisms proceed, we will continue
to protect European data according to the standards of the Privacy Shield and
applicable European law and will implement other methods for transferring data
to the extent those are available (as explained under the “International Data
Transfers” above). To learn more about the Privacy Shield Frameworks, visit the
U.S. Department of Commerce’s Privacy Shield program
site.
Aristotle is
responsible for the processing of personal data it receives, under the Privacy
Shield Frameworks, and subsequently transfers to a third party acting as an
agent on its behalf. Aristotle complies with the Privacy Shield Principles for
all onward transfers of personal data from the EEA, UK or Switzerland,
including the onward transfer liability provisions.
With respect
to personal data received or transferred pursuant to the Privacy Shield
Framework, Aristotle is subject to the regulatory enforcement powers of the
U.S. Federal Trade Commission. In certain situations, Aristotle may be required
to disclose personal data in response to lawful requests by public authorities,
including to meet national security or law enforcement requirements.
If you have an
unresolved privacy or data use concern that we have not addressed
satisfactorily, please contact our U.S.-based third party dispute resolution
provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
Under certain
conditions, more fully described on the Privacy Shield website,
you may be entitled to invoke binding arbitration when other dispute resolution
procedures have been exhausted.
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