Privacy Policy

Last updated: July 3, 2019


AVSecure LLC

AVSecure LLC is responsible for your information (collectively referred to as "AVSecure LLC", "we", "us" or "our" in this privacy policy.

If you have any questions about this privacy policy or our privacy practices, please contact us at: AVSecure LLC, 1097 Jupiter Park Lane Suite 3, Jupiter, Florida, USA, 33458 or via our website contact form.

We keep our privacy policy under regular review and reserve the right to revise, amend, or modify this policy, providing any notice required by applicable law.

Our privacy policy

This privacy policy aims to give you information on what information (if any) AVSecure LLC collects and processes:

  • online, via www.avsecure.com (desktop and mobile versions) (Website); and
  • offline, via all channels of communication including post, phone or otherwise.

Other privacy policies, as notified to you, may apply to you if you use other products or services we provide.

Your consent

Please read this privacy policy carefully before using this Website. By using this Website, you are consenting to the collection, use and sharing of your personal information as set forth in this policy. If you do not agree to any of the terms of this privacy policy, then you may not access or use this Website. For European users, by using this Website, you acknowledge our collection, use and sharing of your personal information as set forth in the relevant sections of this privacy policy.

Who this policy applies to

This privacy policy applies to anyone who visits or uses our Website. The personal information we collect depends on what type of user you are:

  • “Website Visitors” are visitors who access and browse the Website.
  • “Business Users” are users at businesses operating websites which include age-restricted content and who request or inquire about our age verification services.

Our services and products are intended for adults. Children under the age of eighteen are not permitted to use the Website or register for or use our services or products. We do not knowingly collect information from children under eighteen.

Information we collect and why

For Website Visitors:

Information we collect
Feedback and correspondence, such as information you provide if you correspond with us.

Why we collect it

  • To respond to your inquiries and fulfil your requests.
  • For legal compliance and fraud prevention.
    Legal basis (EU only)
  • To comply with our legal obligations.
  • Our legitimate interests, including fulfilling our legal and contractual duties, complying with regulations that apply to us, and operating our business.

For Business Users:

  • Information we collect
  • Contact data, including name, company, email address, telephone number.
  • Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with the services, receive customer support or otherwise correspond with us.
  • Technical data, including your web address.

Why we collect it

  • To provide our services.
  • To respond to your inquiries and fulfil your requests.
  • To send you marketing communications (in accordance with your preferences).
  • To communicate service updates.
  • For legal compliance and fraud prevention.
  • To improve our services (including the Website) and develop new services.
  • For operating and expanding our business.

Legal basis (EU only)

  • To provide the services to you or to take steps at your request prior to providing our services.
  • Your consent (in relation to marketing only).
  • To comply with our legal obligations.
  • Our legitimate interests, including fulfilling our legal and contractual duties, complying with regulations that apply to us, ensuring the safety and security of our services, preventing fraud, and developing our services and expanding our business.

Sharing information

We may share personal information with third parties as follows:

  • Our group of companies: We may share it within our group of companies, including AV Card LLC, to the extent necessary to deal with the matter.
  • Our service providers and professional advisors: Our servers are hosted on Amazon Web Services in the UK. We also use other service providers who provide IT and system administration services. We may use professional advisors (e.g. lawyers, accountants, auditors etc.) and we may share information with regulators or other governmental or legal authorities where required.
  • Business transfers: If we sell, transfer or merge parts of our business or our assets, we share information with the purchaser of that business/those assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use any information in the same way as set out in this privacy policy.
  • Compliance with laws and the protection of our rights and the rights of others: We may share your information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of the Website; to enforce or apply our online terms of use or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. The recipients of this type of disclosure include law enforcement, court and regulatory authorities, government agencies (including tax authorities) and professional advisors.

Retaining information

We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying legal, accounting, or reporting requirements. To determine the appropriate retention period for the personal information we collect from you, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure of the data, the purposes for which we process the data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

Securing Information

AVSecure has implemented appropriate technical and organizational measures designed to protect your personal information but cannot guarantee that this information will never be disclosed in a manner inconsistent with this privacy policy (for example, because of unauthorized acts by third parties that violate applicable law).

Transferring information

AVSecure LLC is based in the United States and has affiliates and service providers in other countries. Personal information may be transferred to the United States, the UK, or other locations outside of your state, province, country or other governmental jurisdiction where privacy laws may not be as protective as those in your country. We will process your personal information in accordance with this privacy policy regardless of where your personal information is stored or accessed.

For Website Visitors and Business Users in the EU (including UK)
If you provide us with your personal information, we may share it with our personnel in the United States and within our group of companies, including AV Card LLC, to the extent necessary to deal with the matter. We are certified to the Privacy Shield, which gives personal information the same protection it has in Europe. Please see below.

To the extent our service providers are based outside the EEA and receive personal information, we ensure the transfer is either (a) to a country deemed to provide an adequate level of protection by the European Commission, (b) pursuant to specific contracts approved by the European Commission, or (c) for transfers to the US, pursuant to that third party’s certification to the Privacy Shield.

AVSecure Privacy Shield
This section provides additional information on how AVSecure LLC and its subsidiaries and affiliates in the United States (US) collect, use, and disclose certain personally identifiable information that we receive in the US from the European Economic Area (EEA) and the United Kingdom (UK).

To provide adequate protection for certain personal information about consumers, corporate customers, suppliers, business partners received in the US from the EEA and the UK, AVSecure LLC has elected to self-certify to the EU-US Privacy Shield Framework administered by the US Department of Commerce (Privacy Shield). AVSecure LLC adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability.

AVSecure LLC is subject to the investigatory and enforcement authority of the US Federal Trade Commission. For more information about the Privacy Shield, see the US Department of Commerce's Privacy Shield website located at: privacyshield.gov. To review our representation on the Privacy Shield list, see the US Department of Commerce's Privacy Shield self-certification list located at: privacyshield.gov/list.

Please see above for the information we may collect and use. Where required by the Privacy Shield, we enter into written agreements with any relevant third-party agents and service providers requiring them to provide the same level of protection the Privacy Shield requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps to ensure that third-party agents and service providers process any personal information in accordance with our Privacy Shield obligations and to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of any personal information that we transfer to them.

Under certain circumstances, we may be required to disclose your personal information in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

AVSecure LLC maintains reasonable and appropriate security measures to protect information from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the Privacy Shield.

For any unresolved complaints, we have agreed to cooperate with the ICDR-AAA EU-U.S. Privacy Shield Independent Recourse Mechanism. If you are unsatisfied with the resolution of your complaint, you may contact the ICDR-AAA.

You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with us and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).

Your rights

We will comply with any rights provided to you under applicable law.

For Website Visitors and Business Users in the EU (including UK)

Under certain circumstances, you have rights under data protection laws in relation to any personal information we have about you. We try to respond to all legitimate requests within one month, although we will notify you if it will take longer.

  • Request access to your personal information.
  • Request correction of your personal information.
  • Request erasure of your personal information.
  • Object to processing of your personal information.
  • Request restriction of processing your personal information.
  • Request transfer of your personal information.
  • Right to withdraw consent (where we rely on your consent as our basis for processing).

You have the right to make a complaint at any time to your supervisory authority for data protection issues.

Marketing

In relation to marketing communications, we will provide you with an “opt in” or “opt out” mechanism depending on where you are located when we collect your personal information. An “opt in” mechanism will provide you the opportunity to positively indicate that you would like or do not object to our sending you such further communications and we will not send you any unless you have “opted in”. An “opt out” mechanism (e.g., “unsubscribe”) will provide you the opportunity to indicate that you do not want us to send you such further communications, and if you “opt out” we will not send you any.

You may opt out of marketing-related emails by clicking on a link at the bottom of each such email, or by contacting us using the information above. You may continue to receive service-related and other non-marketing emails for which you have not opted out.

Third party links

AVSecure.com contains links to other websites. This privacy policy only applies to AVSecure.com and doesn’t cover other services and transactions that we link to. These services have their own terms and conditions and privacy policies. If you go to another website from this one, read the privacy policy on that website to find out what it does with your information. If you come to AVSecure.com from another website, we may receive information from the other website. We don’t use this data. You should read the privacy policy of the website you came from to find out more about this.

Changes to this privacy policy

AVSecure may update this privacy policy from time to time and will provide appropriate online notice of any significant changes. You may be provided other privacy-related information in connection with your use of specific AVSecure offerings, special features and services not described in this policy, or products and services that may be introduced in the future.