AWARE, INC.

DATA SECURITY & PRIVACY POLICY

I. Privacy Policy

Your privacy is important to Aware, Inc. (“Aware”), a provider of fingerprint recognition, facial recognition, and iris recognition towards biometric identification and authentication applications (the “Service”). This Privacy Policy describes the information practices for Aware websites and applications, including what type of information is gathered and tracked, how the information is used, and with whom the information is shared. As described below, this policy also applies to your offline interactions with Aware, such as when you license software subject to an End-User License Agreement or enter into Terms of Service for an Aware offering, or provide information to Aware at a trade show or other event.

II. What Information We Collect

We have implemented this Privacy Policy because your privacy, and the privacy of other Service users, is important to us. This Privacy Policy applies to websites operated in the United States and we provide this Privacy Policy explaining our online information practices and the choices you can make about the way Personal Information is collected and used in connection with the Service. “Personal Information” means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, a personal profile, an email address or other contact information.

We operate in accordance with applicable data protection legislation. We recognize the importance of protecting the privacy of individual-specific information (“Personal Information”) collected about our users (referred to as “users,” “you” or “your”). This Privacy Policy discloses what Personal Information we gather, how we use it, and how you can correct or change it. It is our intention to give you as much control over your Personal Information as possible to preserve your privacy, while still allowing us to utilize that Personal Information in the course of our business to provide you a valuable service.

Consent and Modification. By using the Service, you consent to the terms of this Privacy Policy and to our processing of Personal Information for the purposes set forth herein. If you do not agree to this Privacy Policy, please do not use the Service. We reserve the right, at our discretion, to change this Privacy Policy at any time, which change will be effective ten (10) days following posting the revised Privacy Policy on the Site. Your continued use of the Service ten (10) days following such posting means you accept those changes.

Receipt and Collection of Information. We occasionally collect Personal Information from users. In each case, you will only be required to provide the Personal Information that we need in order to be able to provide the services you have requested. You may be entitled under data protection laws to access and review the Personal Information that we hold on you, if you provide the necessary consent and background information and pay any mandated fee. All such communications regarding access to your personal data should be addressed to: privacy@aware.com. Such enquiries should clearly be marked as data protection queries and as being time sensitive.

In particular, we receive and/or collect Personal Information from you in the following ways: This Privacy Policy applies to all information collected by or submitted to Aware (or carefully selected third parties acting on Aware’s behalf), including Personal Information. “Personal Information” is data that reasonably can be used to identify or describe an individual. You do not need to provide us Personal Information to simply browse our site.

Aware collects Personal Information when:

  • you make purchases of products or services;
  • you provide biometric information when using the Service;
  • you request support for a Aware product or service;
  • you request free software downloads;
  • you create a user account (login user name and password) on a Aware Site;
  • you register for webcasts, seminars and roundtables;
  • you request information or materials (e.g., whitepapers or newsletters);
  • you participate in surveys and evaluations;
  • you participate in promotions, contests or giveaways;
  • you apply for a job, or submit your resume to Aware;
  • you submit questions or comments to us.

Aware may also collect Personal Information from individuals (with their consent) at conventions, trade shows and expositions. The types of Personal Information collected may include (but are not limited to):

  • your first and last name;
  • your title and your company’s name;
  • your home, billing, or other physical address (including street name, name of a city or town, state/province, postal code);
  • your e-mail address;
  • your telephone number;
  • (for job applicants submitting electronic information) your educational background, employment experience, and job interest;
  • any other identifier that permits Aware to make physical or online contact with you;
  • any information that Aware collects online from you and maintains in association with your account, such as: (a) your Aware username, (b) your Aware password, and/or (c) your credit card account information.

Use of Your Personal Information: Aware collects and uses your Personal Information to operate and improve its sites and deliver the Service or carry out the transactions you have requested. These uses may include providing you with more effective customer service; making the sites or services easier to use by eliminating the need for you to repeatedly enter the same information; performing research and analysis aimed at improving our products, services and technologies; and displaying content and advertising that are customized to your interests and preferences.

We also use your Personal Information to communicate with you. We may send certain mandatory service communications such as welcome letters, billing reminders, information on technical service issues, and security announcements. We may also contact you to inform you of other products or services available from Aware and its affiliates.

Personal Information collected on Aware Sites and services may be stored and processed in the United States or any other country in which Aware or its affiliates, subsidiaries or agents maintain facilities, and by using a Aware Site or Service, you consent to any such transfer of information outside of your country. We may transfer your Personal Information to our affiliated companies for the purpose of storing or processing such information on our behalf. Such information may be transferred to other countries around the world. We require that these parties agree to process such information in compliance with our Privacy Policy. In particular, if you provide Personal Information to us it may be transferred to and processed on computers in the U.S. and other countries. Do not provide your Personal Information to us through this website if you do not want this information to be transferred outside of your country, or if the laws in your country restrict these types of transfers. Your provision of Personal Information to us will be handled in accordance with this Privacy Policy. From time to time, your Personal Information may be transferred to a country different from where you are located. Your legal rights may be different in these countries, but we will hold your Personal Information in accordance with this Privacy Policy. Your provision of Personal Information to us through this website means that you agree to the terms of this Privacy Policy.

We may transfer your Personal Information to our third party service providers (such as a server hosting provider), but only to provide our services to you. Such information may be transferred to other countries around the world. We use commercially reasonable efforts to only engage or interact with third party service providers that post a privacy policy governing their processing of Personal Information. We may disclose your Personal Information or any information you submitted via the Service if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce any applicable terms of service, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Aware, our users, yourself or the public. We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Sharing of Your Personal Information: Aware will not sell, rent or lease your Personal Information to others. Aware shares Personal Information with companies working on our behalf and Aware-owned business entities. Except as described in this statement, we will not disclose your Personal Information to third parties for their own marketing purposes unless you have provided consent.

Some Aware services may be co-branded and offered in conjunction with another company. If you register for or use such services, both Aware and the other company may receive information collected as part of the co-branded services.

In some cases Aware uses contractors to collect, use, analyze and otherwise process information on its behalf. It is Aware’s practice to require such suppliers to handle information in a manner consistent with Aware’s policies. Aware may also allow carefully selected Aware partners to participate in limited marketing campaigns solely to promote Aware’s products and services to you.

If you request something from an Aware Site (for example, a product or service, a callback, or specific marketing materials), we will use the information you provide to fulfill your request. To help us do this, we may share information with others, such as Aware’s business partners, financial institutions, shipping companies, and postal or government authorities (e.g., Customs authorities) involved in fulfillment. As part of a transaction, we may also contact you as part of our customer satisfaction surveys or for market research purposes.

We may hire other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting websites, processing transactions, or performing statistical analysis of our services. Those companies will be permitted to obtain only the Personal Information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose.

We may access and/or disclose your Personal Information if we believe such action is necessary to: (a) comply with the law or legal process served on Aware; (b) protect and defend the rights or property of Aware (including the enforcement of our agreements); or (c) act in urgent circumstances to protect the personal safety of users of Aware services or members of the public.

You Choices: We will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. Aware provides a number of ways for you to ‘opt-in’ or ‘opt-out’ of receiving additional information from us or having us provide your Personal Information to our partners. We may offer you these choices at the time you give us your information.

If you do not wish to continue receiving certain marketing materials (e.g., e-mail messages), you can opt-out of receiving these materials by following the unsubscribe instructions provided in the materials. This option does not apply to communications primarily for the purpose of administering orders, contracts, support, product safety warnings, software updates, or other administrative and transactional notices.

Use of Anonymous Information. We may use Anonymous Information (as defined below), or disclose it to third party service providers, to provide and improve the Service. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeting advertisements. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about use of the Service.

Opting Out. You may choose not to receive future promotional, advertising, or other Service-related notifications from us by changing the notification settings on your device. If you choose not to receive notifications, you may still use the Service but you may not receive, or may be unable to use, certain services that involve our interaction with you. If we ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would provide you with an opt-out choice to limit the use and disclosure of your personal data.

Choice. At all times, you may choose whether or not to provide or disclose Personal Information. The notices that we provide on the Service in circumstances where we collect Personal Information should help you to make this choice. If you choose not to provide the Personal Information we request, you may still use the Service, but you may be unable to access certain programs and services that involve our interaction with you.

Access/Accuracy. To the extent that you do provide us with Personal Information, we wish to maintain accurate Personal Information. Aware acknowledges that EU individuals have the right to access the personal information/data that we maintain about them. An EU individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to info@aware.com. If requested to remove data, we will respond within a reasonable timeframe. Your email should include adequate details of your request.

Collection of Information by Third-Party Sites. We may use a reputable third party to present or serve advertisements that you may see on the Service. These third party ad servers may use cookies, web beacons, clear gifs or similar technologies to help present such advertisements, and to help measure and research the advertisements’ effectiveness. The use of these technologies by these third party ad servers is subject to their own privacy policies and is not covered by our Privacy Policy.

Links to Other Sites. The Service may contain links to third party websites that are not owned or controlled by us. We are not responsible for the privacy practices or the content of such other third party websites, and you visit them at your own risk.

Service Visitors from Outside the United States. We and our servers are located in the United States and are subject to the applicable local and national laws. Those who choose to access the Service do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit the Service’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. We do not represent or warrant that the Service, or any part thereof, is appropriate or available for use in any other jurisdiction. If users choose to access or use the Service, they consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.

Children’s Privacy. The Service is neither directed to nor structured to attract children under the age of 13 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years of age. We will direct potential users under 13 years of age not to use the Service. If we learn that Personal Information of persons less than 13 years of age has been collected without verifiable parental consent, then we will take the appropriate steps to delete this information. To make such a request, or if there are any questions or concerns about the Privacy Policy for the Service or its implementation, please contact us at privacy@aware.com.

Security. The security of your Personal Information is important to us. We follow generally accepted industry standards, including the use of appropriate administrative, physical and technical safeguards, to protect the Personal Information submitted to us. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Information, we cannot guarantee its absolute security or confidentiality. If you have any questions about security, you can contact us at info@aware.com.

Please be aware that certain Personal Information and other information provided by you in connection with your use of the App may be stored on your device (even if we do not collect that information). You are solely responsible for maintaining the security of your device from unauthorized access.

Merger, Sale or Bankruptcy. If we are acquired by or merged with a third party entity, or if we are subject to a bankruptcy or any comparable event, we reserve the right to transfer or assign Personal Information in connection therewith.

California Online Privacy Protection Act Notice

On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like us to disclose how we respond to “Do Not Track Signals”; and whether third parties collect personally identifiable information about users when they visit us.

(1) We do not track users, who do not interact with its sharing functionality across the web, and therefore do not use “do not track” signals.

(2) We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies without separate member consent.

California Civil Code Section 1798.83 also permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to info@aware.com. Please note that we are only required to respond to one request per customer each year.

Commitment. We are committed to protecting your privacy. If you have any comments or questions regarding our Privacy Policy, or Personal Information that we may be storing and using, please contact us at info@aware.com

Dispute Resolution

Aware commits to resolve complaints about your privacy and our collection or use of your personal information. Individuals with inquiries or complaints regarding this privacy policy should first contact Aware at:

privacy@aware.com or (781) 276-4000

Aware is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

 

Last updated: January 31, 2017