Updated December 2023
Averro, LLC is committed to protecting and respecting your privacy.
This Privacy Policy (“Privacy Policy“), together with our Terms of Use and any other documents referred to on it, describes the privacy practices of Averro, LLC and its subsidiaries and affiliates (collectively, “Averro” or “us” or “we“) and sets out the basis on which we collect, process, and share Personal Data. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
This Privacy Policy applies to the Averro.com website (“our website”), as well as any other websites and online services controlled by us, and which display this Privacy Policy, as well as to the services we provide to our Clients. Averro primarily provides talent engagement, temporary and permanent staffing, and professional services (our “Services”) to our Clients. To fulfill these Services, and for Averro’s own legitimate business purposes, we may collect, store, process, and share Personal Data, as detailed below.
We collect Personal Data about individuals who interact with Averro through the use of our website and Services, such as Clients, job applicants, website visitors, and other individuals. This information may be used for Averro’s own business purposes, such as employment, marketing, or sales purposes, where Averro is the Controller of the information, or may be processed on behalf of our Clients, where Averro is a Processor or Service Provider.
General:
For job candidates/applicants and employees, we also collect Personal Data related to employment, including:
Types of Sensitive Personal Data
Sensitive Personal Data is information about you that requires extra care and protection in handling, due to the sensitive nature of that information.
General:
For Employment Candidates/Applicants, either with Averro or on behalf of one of our Clients:
Personal Data Provided by You
This is information about you that you give us by filling in forms on our site or by corresponding with us by phone, e-mail, web form, or otherwise. It includes Personal Data you provide when you respond to job postings on our website, when you request information about our Services, and when you report a problem with our website.
Personal Data Provided by Third Parties
In some circumstances, we may also collect, or our partners (such as marketing services providers, recruitment agencies, and Clients) may provide us with, Personal Data that you have published, made available online, or have provided to them. We may combine such Personal Data provided to us with Personal Data provided directly by you for the purposes detailed in the “How We Use Personal Data” section below.
The way in which third parties, including our Clients and partners, collect, use, and share Personal Data with us and others is outside of Averro’s control and is governed by their own privacy policies, which we encourage you to familiarize yourself with.
Cookies and Personal Data collected by Automated Means
When you visit our website, we may automatically collect some Personal Data, such as device information, technical performance, cookies and web beacons, and website analytics (“Automated Technical Information”).
Information on the types of cookies we use, and how to accept or decline specific types of cookies is presented in a banner on our website. Where cookies are enabled, our service providers and business partners, may also collect certain Automated Technical Information about your online activities when you use our websites and across third-party websites. In jurisdictions where Automated Technical Information is considered Personal Data, or if we associate Automated Technical Information with other Personal Data that we have collected from or about you, we will treat Automated Technical Information as Personal Data in accordance with this Privacy Policy.
Web browsers may also offer you the ability to disable receiving certain types of cookies. However, if cookies are disabled, some features or functionality of our website may not function correctly. To learn more about cookies and how to control them via your individual browser settings, click here.
Averro may use Personal Data it collects and receives to support its business and to provide Services to Clients and individuals. We rely on the following legal bases for processing Personal Data:
Where we have your consent, we may use Personal Data to:
In order to fulfill our contractual obligations and commitments, we may use Personal Data to:
We may use Personal Data, where necessary and reasonable, to meet legal obligations, such as:
We also may use Personal Data that we collect and are provided for Averro’s legitimate business purposes, such as:
Additionally, we may deidentify any information that we collect, such that the information no longer identifies any specific individual. We reserve the right to use, disclose, and otherwise process such deidentified information for our own legitimate business purposes, including historical and statistical analysis and business planning data, without restriction.
Averro as a Personal Data Controller
When you interact with our website, apply for employment with Averro, or engage us for Services, Averro is typically the Controller for your Personal Data. We may share your Personal Data with selected third parties, in the performance of our Services and the processing activities detailed in the “How We Use Personal Data” section above. Such third parties are subject to contractual obligations to safeguard Personal Data and to process the Personal Data only as instructed. These include:
To the extent permitted by applicable data protection law, we may also disclose your personal data to third parties:
Averro as a Processor
We use Personal Data that we collect on behalf of, or are provided by, our Clients to provide Services as directed and authorized by that Client. In these cases, Averro is acting as a Processor of your Personal Data, and we do not use this information for our own business purposes. Typically, our Clients direct and authorize us to collect and use Personal Data on their behalf to fulfill the Services they have contracted with us for, including drafting, distributing, and managing communications on behalf of the Client, providing, gathering, and analyzing results of surveys, completing pre-employment screenings, recruiting for and overseeing the placement of personnel, maintaining and performing business-, placement-, and consultative-related activities, and similar. Should you wish to further understand how our Clients may share and use your Personal Data when you interact with them and us, we encourage you to review their privacy notices and reach out directly to them, as appropriate.
Our website and Services may contain links to other websites, applications, platforms, and services maintained by third parties. The information practices of these third parties, including the social media platforms that host our branded social media pages, are governed by their privacy notices. Averro does not control, nor do we have responsibility for, the practices of these third parties and we strongly recommend that you review those notices to better understand their privacy practices. When you click through to these from our website, the third party may receive information showing that you have visited our websites. Similarly, if you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.
We may transfer Personal Data to countries other than the country in which the data was originally collected, or where you are located, for the purposes described in this Privacy Policy. For example, if you are located outside of the United States, we typically transfer your Personal Data to the United States, where Averro and many of our third-party service providers and partners are headquartered. By submitting your Personal Data to us, you acknowledge and agree to such transfers, storage, and processing of it.
The countries to which we transfer personal information may not have the same data protection laws as the country in which you initially provided the information. When we transfer Personal Data across borders, we will take all reasonable steps to ensure that it is treated securely and in accordance with this Privacy Policy. Where deemed legally necessary we will also enter into Data Protection Agreements/Addenda and EU Standard Contractual Clauses with our Clients, service providers, and partners.
We maintain commercially reasonable administrative, technical, and organizational measures to prevent the unauthorized access, modification, alteration, disclosure, or destruction of Personal Data that we process or use. While we follow generally accepted standards to protect your Personal Data, no method of storage or transmission via the internet is 100% secure and we cannot guarantee absolute security of the data transmitted to or through our site. Any transmission of your Personal Data, including via email and web form, is at your own risk. Averro is not responsible for any circumvention of the safeguards we may offer and employ.
The safety and security of your Personal Data is also your responsibility. Where you have been provided the option to create any account, login, or password with our website or Services, you are responsible for keeping such credentials secure and private at all times. We also strongly advise you to use extreme care in providing any Personal Data in public areas or forums, message or discussion boards, comments, or feedback sections, as these may be viewable to other visitors to and users of that website or service.
We only retain Personal Data so long as necessary to perform the processing activities for which it was collected, and to meet our contractual and legal obligations. In most cases, the retention period for Personal Data will not exceed five (5) years, plus any additional time required to comply with applicable laws and regulations, or as needed to exercise or defend our legal rights. Personal Data is destroyed or deleted when no longer required for these purposes.
Our website and Services are not intended for individuals under 18 years of age (“Minors”), and individuals must be at least 18 years of age to enter into the Terms of Use or to register with our website. We do not knowingly collect Personal Data from Minors. If you believe we have mistakenly or unintentionally collected Personal Data of a Minor, please contact us via using the information in the “How to Contact Us” section below, and we will take steps delete their information from our systems.
For information about the rights and choices users have with respect to cookies and online tracking, please see the “Cookies and Other Information Collected by Automated Means” section of this Privacy Policy.
If you are a resident within the European Economic Area, or a US State with certain privacy legislations such as California, you may also have certain rights regarding the use, sharing, access to, and deletion of, your Personal Data.
If you are a resident of one of these regions and you, or where permissible, an authorized agent on your behalf, would like to exercise any of your rights, please see the “How to Contact Us” section below for details on submitting your request. We will make every effort to respond to valid requests within 30 days. We may refuse baseless or repetitive requests and may reject or limit requests, as permitted by applicable law. If we refuse, reject, or limit your request, we will notify you of the reasons for such action. You will not receive discriminatory treatment or retaliation if you or your authorized agent exercise your rights.
Individuals whose Personal Data Averro processes on behalf of a Client (such as a job applicant or consultant working for that Client) should contact that Client directly to exercise the rights and choices described in this section.
Please note that if the exercise of these rights limits Averro’s ability to process your Personal Data, we may be precluded from providing our Services to you, or from otherwise engaging with you in the future.
Access to, Correction of, and Portability of your Personal Data
You may request access to the Personal Data that we maintain about you. If we grant your request, we will provide you with a copy of the Personal Data we maintain about you in the ordinary course of business, in a commonly used, machine readable format.
You may request to correct any errors in your Personal Data. We may request additional verification of your identity or of the information you wish to correct to ensure accuracy.
Deleting and Restricting the Processing of your Personal Data
To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your Personal Data. In some circumstances, you may request that Averro delete your Personal Data.
Where Averro has a legal obligation to retain or process your Personal Data we may refuse, or only partially fulfill, a deletion or restriction request and in such cases, we will notify you with explanation. Please also be advised that withdrawing your consent to Averro’s use or disclosure of your Personal Data may mean that Averro will not be able to provide Services to you or to otherwise engage with you.
You may have the right to file a complaint if you believe that we have inaccurately or inappropriately processed your Personal Data. In such case, you should contact the appropriate supervisory authority for your region of residency.
Averro does not “sell” Personal Data for monetary gain, “share” Personal Data to third parties for their direct marketing purposes, or otherwise disclose Personal Data in any manner that may be considered a “Sale of Personal Information” under the California Consumer Protection Act (CCPA). Nonetheless, if you are a resident of California or certain other US states, you have the right to opt-out of any sale of your Personal Data where applicable. To exercise such right, please contact us via the methods described in the “How to Contact Us” section of this Policy.
Averro reserves the right to change this Privacy Policy at any time. When we make material updates to this Privacy Policy, we will make a copy of the previous version available on our website for at least 30 days.
You may contact us with questions, comments, or concerns about this Privacy Policy or our privacy practices, via our contact information below.
Averro, LLC
ATTN: Privacy & General Counsel
If you have questions about, or wish to exercise any rights that you may be afforded in the “Privacy Rights and Preferences” section of this Privacy Policy please contact us via the mailing address or at the toll free phone number listed above, or via email at privacy@averro.com, with the subject line “Data Subject Request.”
In order to verify the identity of the individual initiating any such request and to ensure that we only provide Personal Data to the individual whom it pertains to, or to their authorized agent, we may require you to verify Personal Data that we already hold about you before releasing any information. The type(s) of Personal Data that we may require to complete verification is dependent on your prior interactions with us and the sensitivity of the request.
If you are a California resident, you may designate an authorized agent to exercise your rights on your behalf, if:
