Privacy and Data Processing Policy
Updated and effective: May 10, 2022
About Us and This Policy
Aventiv Technologies™ (“Aventiv”) is a diversified technology company that provides innovative solutions to customers in the corrections and government services sectors. Aventiv® is the parent company of Securus Technologies®, JPay® and AllPaid®, which are leading providers of innovative products and services. The collective power of these unified organizations delivers superior value and service to all of our customers nationwide. This Privacy and Data Processing Policy applies to Aventiv and all its subsidiaries and reflects our global privacy practices and standards as of the effective date.
Your use of our websites, products, services, or other online activities constitutes your consent to these practices.
Our Data Values
Aventiv understands that you entrust us with your personal information with the expectation that it will be used only for specific purposes. We respect your expectation and place a high priority on protecting this information by limiting its use. At Aventiv, protecting your privacy is fundamental to the way our company and its subsidiaries conduct our business.
- Embedding privacy and security. We strive to embed privacy and security into our strategy and operations.
- Responsible use. We strive to promote responsible data use and stewardship among all our employees, contractors, subsidiaries and suppliers.
- Purpose driven. We only collect, use, and share the information we need to provide, improve, and operate our solutions for our customers.
- Always improving. We process data to help us better understand the needs of our customers, prospects, and other stakeholders, and to continue to improve the user experience, features, and functionality of our solutions.
Contact Us
If you have any questions regarding this Policy, there are several ways you may contact the Aventiv Privacy Team and our Chief Integrity and Risk Officer.
You can fill out a request form (click here), send us an email at [email protected] or call us using our toll-free number 800-524-5547. We appreciate the opportunity to address your questions and concerns.
Personal Information We Collect from You and Its Use
We collect information from you when you use our products and services, visit our websites, when you provide your information to us, and from our correctional facility partners. Some of this information may be considered personal information. We consider information that identifies you as a specific, identified individual to be personal information (such as your name, email, date of birth, postal address).
Types of Personal Information We Collect and How We Use It
The types of personal information we process and why is further explained in the table listed below:
| Collection Sources | Types of Personal Information Collected | Purpose and Use of Personal Information |
|
When you set up an account to use our products or services and when you contact our Customer Care Team |
Personal Identifiers, such as your name, date of birth, social security number, e-mail address, driver’s license or government ID, postal address and/or phone number Customer records information, such as your phone number, credit card information, and other financial information Characteristics,such as your age and your gender Biometric information, such as your voice during call recording with our service representatives |
You provide this information to us when you register for our products and services on our website or with a live agent over the phone. We use this information to:
|
|
When an individual becomes incarcerated at a correctional facility and uses our products or services |
Personal Identifiers, such as name and incarcerated individual ID Customer records information, such as phone number, projected release date, and court appearance dates Characteristics, such as age and gender |
We process data on behalf of correctional facilities to:
|
|
When Friends and Families use our products and services to communicate with incarcerated individuals |
Personal Identifiers, such as PIN number of the incarcerated individual, names and postal address Customer Proprietary Network Information, such as time stamp, call length and phone numbers Biometric information, such as image, voice and voice patterns Commercial records, such as the content of their communications, products and services purchased, financial information, for example bank account or credit card information Internet or other electronic network activity information, such as IP address and MAC address computer, time and length of call |
We process data on behalf of correctional facilities as part of our services to:
|
|
When using our money transfer and payment products |
Personal Identifiers, such as your name, social security number, driver’s license number and postal address Customer record information, such as your phone number, financial information, for example bank account or credit card information, type of payment and purpose of payment |
You provide this information while using our services to allow us to:
|
|
When you access our websites or use our mobile applications |
Internet or other electronic network activity information,such as IP or MAC addresses, cookies, and server log files |
This information is automatically collected through our website and mobile applications to allow us to:
|
|
When filling out a Contact Us and/or registration form |
Personal Identifiers such as your name, e-mail address, postal address and phone number Professional or employment-related informationsuch as where you work, phone number, job function, job title, and work address |
You provide this information when filling out the form to allow us to:
|
|
When responding to a consumer opinion survey |
Personal Identifiers such as your name, job title and phone number Commercial records such as your survey responses and your organization name |
You provide this information when responding to our surveys to allow us to:
|
|
When submitting a request through the Individual Rights Manager |
Personal Identifiers such as your name, postal address and email address |
You provide this information through the Individual Rights Form on our website to allow us to:
|
|
When using our Stalker Alert Mobile App |
Personal Identifiers, such as your name, e-mail address, postal address and/or phone number Internet or other electronic network activity information, such as IP or MAC addresses, cookies, and server log files Geolocation Data, precise geolocation data |
You provide the Personal Identifiers information when you elect to download the Stalker Alert Mobile App. The Internet or other electronic network activity information and geolocation data are collected through the Stalker Alert Mobile App to allow us to:
Note that the Stalker Alert Mobile App does NOT provide your geolocation data to the program participant, nor does it provide you with the program participant geolocation data. |
Use of Cookies
We process personal information about you that we collect either directly, through forms or data entry fields on our websites or applications, or through passive collection by cookies and other data collection technologies. Cookies are small pieces of text sent to your browser by our website that may be stored by your computer. It helps the website remember information about your visit, which can make it easier to visit our websites again and make our websites more useful to you. We use this information to improve your online experience, fulfill a service request or a request to exercise your privacy rights.
We use browser session cookies, which are temporary cookies, which are erased from your device’s memory when you close your Internet browser or turn your computer off, and persistent cookies, which are stored on your device until they expire, generally after one year, unless you delete them before that time. We group browser cookies on our site into these categories:
- Required cookies: These cookies are necessary to enable the basic features of this site to function, such as allowing images to load or allowing you to select your cookie preferences.
- Functional cookies: These cookies allow us to analyze your use of the site to evaluate and improve our performance. They may also be used to provide a better customer experience on this site. For example, remembering your log-in details or providing us information about how our site is used.
Unless otherwise addressed by applicable law or regulations, your use of our site constitutes your consent to our use of cookies, and the collection, processing and transfer of your personal information as described in this Policy.
Sharing of Personal Information
At Aventiv, we only share personal information in ways that we tell you about as described throughout this Policy. We do not sell or rent personal information to businesses for commercial purposes and we do not share personal information with third parties that are not owned by us or under our control or direction except as described in this Policy. The personal information we share includes the personal information described above. Attorneys should also review the “Attorney Calls” below.
| Sharing Categories | Purpose and Use of Sharing Personal Information |
|
Service Providers |
To support the services, we offer to you, we share personal information with service providers that help us with our business activities. The service providers are only authorized to process the information as necessary and as directed by us. |
|
Government Authorities |
To respond to lawful requests, we may be required to disclose personal information in response to lawful requests by government authorities, including requests from national security agencies or law enforcement. |
|
Law Enforcement |
To support law enforcement activities, under appropriate circumstances, we share your information with law enforcement personnel and/or correctional facilities and certain third parties for use in connection with and in support of law enforcement activities. Any calls or visits using our services may be monitored or recorded in accordance with applicable law, and with your explicit consent, as required. All of this data may be stored, monitored, searched, analyzed and transferred amongst law enforcement agencies for law enforcement purposes. |
|
Correctional Facilities |
To fulfill our contractual service obligations with correctional facilities to allow them to offer you our products and services which enable you to communicate with incarcerated individuals. When you use our services to communicate with or process a transaction on behalf of an incarcerated individual housed within a correction facility, we process personal information for the facility and the facility staff are able to access your personal information in order to operate these facilities, conduct investigations, and/or to verify transactions. Facility staff have access to friends and family information including: your name, postal address, zip code, phone number, and email; the incarcerated individual ID you are communicating with; payment transactions; your transaction history as well as any content transmitted to and from the incarcerated individual and/or the facility in connection with your use of our products and services. |
|
Mergers and Acquisitions |
Merger, Acquisitions, Divestitures, or Asset Sales may involve sharing your personal information, but only if the acquiring organization agrees to this Policy’s protections. |
|
Safety, Fraud and Government Requests |
We may share your personal information to support safety, fraud prevention, government requests and protection of our rights where we believe in good faith it is necessary. |
Your Choices and Rights
Choices about Marketing
Unless an email is required to process services for you, you may withdraw your consent to our emails at any time by clicking the “unsubscribe” link in the email communications we send to you. You may withdraw your consent to any text notifications at any time by replying “Stop”; by updating your notification settings online via our website; or by contacting Customer Care at 1-800-844-6591.
Securing Your Information
Aventiv takes safeguarding your personal information seriously. We have implemented commercially reasonable technical and organizational security measures designed to protect personal information against loss, misuse, and unauthorized access, alteration, disclosure or destruction. We also have implemented measures to maintain the ongoing confidentiality, integrity and availability of the systems and services that process personal information and will endeavor to restore the availability and access to data in a timely manner in the event of a physical or technical incident.
When you make a payment through an Aventiv company using your credit card or debit card, we use methods designed to keep your payment card information secure that comply with Payment Card Industry Data Security Standards (PCI DSS), at the highest security level. This applies to all card information an Aventiv company possesses or otherwise stores, processes, or transmits on your behalf. We also require the companies providing services to us that store, possess, process, transmit, or otherwise handle card information in their data environment to acknowledge their responsibility for card data security. PCI DSS compliance is mandatory for ALL Aventiv associates, contractors, vendors, and business associates with roles involving an Aventiv data environment that is subject to PCI DSS. An independent PCI DSS examiner reviews and certifies our compliance annually.
Aventiv understands that, while we have implemented security measures, there is no such thing as perfect security. Although we strive to protect your information, we cannot guarantee your information will never be disclosed in a manner inconsistent with this Policy. If a breach of your personal information were to occur, we will notify you promptly, as required by applicable law.
Monitoring and Retention
To help protect you and others, we may monitor use of the Aventiv products and services, and use your personal information and other information we collect, in order to: identify fraudulent activities and transactions; prevent abuse of and investigate and/or seek prosecution for any potential threats to or misuse of the products and services; ensure compliance with the applicable terms of service and this Privacy Policy; investigate violations of or enforce these agreements; and otherwise to protect the rights and property of us, our partners, and customers. Monitoring performed by correctional facilities using our products and services includes the collection, recording, live monitoring and analysis of online activity or communications. Call and video recordings are the property of the correctional facilities and used at their discretion. Standard practice, and at the discretion of the correctional facility, is to exempt juvenile activity and communications from monitoring. If you do not consent to these conditions, you must discontinue your use of the products and services.
We retain information about you for as long as it is necessary for us to fulfill the purposes outlined in this Privacy Policy and within our internal company policies. Unless we need to keep your information to comply with applicable legal, regulatory, contractual or other obligations, or the information is required for business reasons (such as to resolve disputes, provide service and enforce agreements), when Aventiv no longer needs to use your information, we will take steps to securely remove it from our active systems. Even if we delete your information from active databases, the information may remain on backup or storage media to the extent allowed by applicable law.
Attorney Calls
An attorney may register their number as a Private Number at an incarceration facility, which means that calls to that number from that facility will not be recorded and cannot be monitored. If calls occur before a number is designated by a facility as a Private Number, calls to that attorney’s number from an incarcerated person are recorded and may be monitored. Only incarceration facilities may designate which numbers are Private Numbers and are excluded from recording and monitoring. Each incarceration facility maintains its own list of Private Numbers. Having a number designated as a Private Number at one facility does not necessarily mean that number will be treated as a Private Number at other facilities, even if those facilities are under the same agency or Department of Corrections. If an attorney wants to designate their number as a Private Number for incarcerated clients in different facilities, they must register their number as Private at each of those incarcerated facilities. If a phone number is not designated as a Private Number, it will be recorded and may be monitored.
Children’s Privacy
Our websites, products and services are not directed to children and are intended for use only by individuals at least 18 years of age. If you are under age 18, you may use our products and services only with the involvement of a parent or guardian. If you are a parent or legal guardian, and you allow your child that is under the age of 18 to use our products and services then you are responsible for your child’s activity on those products and services.
Any parent or guardian with questions regarding the collection or use of personal information relating to their child can contact us using the details provided in the Contact Us section.
Links to other websites
This Policy applies only to Aventiv practices, technologies, and products and services. Our websites may include links to websites and online services that are operated by other companies not under the control or direction of Aventiv. If you provide or submit personal information to those websites or online services, the privacy policies on those websites or online services apply to your personal information. We encourage you to carefully read the privacy policies of any website you visit.
Consent to Processing
Aventiv’s products and services are operated in and intended for use in the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that information we collect will be transferred to and processed in the United States. By using the products and services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in the United States, where the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
Compliance with Other Laws
Financial Modernization Act of 1999 (Gramm-Leach Bliley Act)
Aventiv does not share Non-Public Information (NPI) with affiliates or nonaffiliated third parties except as permitted by law and described above. Aventiv maintains a customer privacy program designed to ensure the security, integrity, and confidentiality of non-public customer information. Aventiv’s practices for safeguarding your personal information are described above in “Securing Your Information”.
Unlawful Internet Gambling Enforcement Act (UIGEA)
Aventiv ensures compliance with US Government regulations implementing the Unlawful Internet Gambling Enforcement Act (UIGEA). The UIGEA prohibits businesses from processing restricted transactions. A restricted transaction involves knowingly accepting a transmittal of any credit, funds, instrument, or proceeds in connection with the participation of another person in unlawful internet gambling. In the event that Aventiv receives knowledge that a customer is engaged in illegal internet gambling, Aventiv will close the customer’s account and cancel all transactions.
California Privacy Notice
Effective December 18, 2020
If you reside in California, we are required to provide additional information to you about how we collect, use and disclose your information, and you may have additional rights with regard to how we use your information. This section of Aventiv’s Privacy Policy is the Privacy Notice statement required by the California Consumer Privacy Act (“CCPA”), which supplements, and is to be read in conjunction with, the information contained in this Privacy Policy. The information in this section applies solely to visitors, users, and others who reside in the State of California.
California Personal Information.
Consistent with what is disclosed in our privacy policy within, we may collect certain categories of information about California residents:
Collection and Use of Personal Information
We collect information from you when you use our products and services, visit our websites, when you provide your information to us and from our correctional facility partners.
Categories of Personal Information We Have Collected in the Preceding 12 Months
In the past 12 months, we have collected the following categories of personal information relating to California residents:
- Personal Identifiers, such as your name, date of birth, social security number, e-mail address, driver’s license or government ID, postal address and/or phone number;
- Customer record information, such as phone number, financial information, for example bank account or credit card information, type of payment and purpose of payment;
- Characteristics, such as your age and your gender;
- Biometric information, such as image, voice and voice patterns;
- Commercial records, such as the content of your communications, products and services purchased, credit card information, and other financial information;
- Internet or other electronic network activity information, such as IP address and MAC address computer, time and length of call; and
- Professional or employment-related information, such as where you work, phone number, job function, job title, and work address.
- Geolocation information, if you elect to use the Stalker Alert Mobile App.
Categories of Sources for the Collection of Personal Information
The categories of sources from which we collect personal information depends on our relationship or interaction with a specific California resident and the business purpose for which the personal information is collected. We may collect personal information directly from California residents through our websites, the use of our products, over the phone or from our correctional facility customers.
Business Purposes for the Collection of Personal Information
Our business purposes for using your personal information depend on who you are and how we interact with you. In the past 12 months, we have used personal information relating to California residents to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including the following:
- Establish your account with Aventiv or our subsidiaries;
- Send you communications about the services you requested, and promotional materials on our products and services;
- Fulfill customer service requests, such as troubleshooting applications;
- Process your payments for the services you requested;
- Monitor and improve our customer service;
- Conduct statistical and research analysis to understand customer and market needs, improve our solutions and inform partnership and business development decisions
- Provide our products and services to correctional facilities so that they may provide incarcerated individuals the ability to use our products and services;
- Allow friends and family to communicate with incarcerated individuals;
- Abide by correctional facility rules and support law enforcement activities;
- Transfer funds from families and friends to incarcerated individuals;
- Conduct credit checks for use of certain products;
- Improve your user experience on our websites;
- Enable the basic features of our websites to function, such as allowing images to load;
- Send you an optional customer satisfaction survey upon completing of your customer service request;
- To understand our customer base and improve our products and services; and to
- Authenticate your identity to allow us to fulfill your request for access, correction or deletion of your personal information.
Categories of Third Parties to whom we have shared Personal Information
We do not sell or rent personal information to businesses for commercial purposes and we do not share personal information with third parties that are not owned by us or under our control or direction except as described in this Policy. The personal information we share may identify you or may include professional, employment or biometric information such as images and voice recordings about you. The categories of third parties we may share your personal information with includes:
- Service Providers to support the services we offer to you;
- Government Authorities to respond to lawful requests;
- Law Enforcement to support law enforcement activities;
- Correctional facilities to fulfill contractual service obligations; and
- Other third parties to support merger, acquisitions, divestitures, or asset sales.
Do Not Sell My Personal Information
Aventiv does not “sell” personal information and has not “sold” personal information relating to California residents, including within the meaning of the CCPA within the past 12 months. For purposes of this Disclosure, “sell” or “sold” means the disclosure of personal information for monetary or other valuable consideration.
California Consumer Rights
Subject to certain exceptions, as a California resident, you may have the following rights to your CA personal information:
Right to Access: Request access to your CA personal information that we have collected, used, disclosed, or sold within the preceding 12 months; and
Right to Deletion: Request deletion of your CA personal information.
If you request deletion of your CA personal information, to the extent permitted by applicable law, we may be required to retain some of your CA personal information, and certain CA personal information is strictly necessary in order for us to fulfill the purposes described in this Privacy Policy.
Exercising Your Rights
If you are a California resident and wish to exercise any of these rights, please follow the link here or contact us at using the information in the “Contact Us” section of this Privacy Notice. You will not be charged a fee for exercising your rights and we will aim to respond within 45 days.
When submitting your request via email or phone, you must include your first and last name, email address, and zip code or postal address. You may be asked to provide additional proof of identification so that we can verify your identity, and we may require that you validate your request. Please note that you are limited by law the number of requests you may submit per year.
Authorized Agents
You have the right to designate an authorized agent to act on your behalf to exercise your rights under the CCPA. In order to do so, Aventiv must verify your identity, and your authorized agent must have written permission from you. We reserve the right to deny a request from an agent that does not submit proof that they are authorized to act on your behalf.
Non-Discrimination
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, or in connection with promotions and other offerings, based upon you exercising your rights with respect to your CA personal information.
Access Notice in Alternative Formats.
California residents who need assistance accessing the notice in an alternative format can contact us [email protected] or call us using our toll-free number 800-524-5547.
Changes to Privacy Policy
Aventiv reserves the right to change this Privacy Policy at any time and any changes will become effective immediately upon posting within Aventiv’s products and services, unless otherwise stated. Your continued use of the Aventiv product and services on or after the posted effective date will constitute acceptance of, and agreement to be bound by, those changes to the extent allowed by applicable law. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.
Appendix A:Policy Questions & Individual Rights Form
Please do not submit any sensitive information about yourself or others in the Comments box.