DATA PRIVACY AND PROTECTION POLICY
Group Avant is fully committed to protecting the privacy of all information we collect from our clients, research participants and visitors to our website. We have developed this Data Privacy and Protection Policy for you to understand how we collect, use, store, share, transmit, transfer, delete or otherwise process (collectively “process”) your personally identifiable information or “PII”.

​​Our policy applies to all PII that we collect or use in the course of conducting our business, and covers all information and data housed at Group Avant or stored on our network and data servers. By accessing or browsing our website, participating in any of our surveys, contacting us or otherwise providing your data to us, you confirm that you have read and understood the entirety of this privacy policy.

Group Avant complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. Group Avant has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), Group Avant commits to resolve complaints about our collection or use of your personal information transferred to the U.S. pursuant to the EU-U.S. DPF. EU individuals with inquiries or complaints should first contact Group Avant at info@groupoavant.com.

Group Avant has further committed to refer unresolved DPF Principles-related complaints to a U.S.-based independent dispute resolution mechanism, BBB NATIONAL PROGRAMS. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbbprograms.org/dpf-complaints for more information and to file a complaint. This service is provided free of charge to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See  https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf  

With respect to personal data received or transferred pursuant to the Data Privacy Frameworks, Group Avant is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. 

LAWFULNESS, FAIRNESS AND TRANSPARENCY
​We do not collect or process PII without having a lawful reason to do so. This Data Privacy and Protection Policy outlines the reasons we may collect personal information to ensure transparent collection and processing of PII.
 
​We operate in compliance with the Children’s Online Privacy Protection Act (“COPPA”), governed by the US Federal Trade Commission (“FTC”). We do not collect, use or disclose information from children under the age of 13 online without a statement of permission from a parent or guardian. For more information on COPPA, please visit http://www.ftc.gov/ogc/coppa1.htm.
 
​LEGITIMATE PURPOSE, LIMITATION AND DATA MINIMIZATION
Our website offers informational services only, we do not collect or store any user information from our website. We will, during the course of business communications with clients or prospective clients, directly collect certain basic information to facilitate communication and conduct business with our clients. This information could includes Contact Information (Names, email addresses, phone numbers, and business addresses), Correspondence, including records of emails, phone conversations, or other communications containing details relevant to conducting business, and Client-Provided Information which includes any additional data that you or your organization directly provides to us to support the execution of our services. All information as described above is stored in our encrypted and secure servers and is never available outside of Group Avant.
 
Group Avant will, during the course of its normal business operations and marketing studies, engage with 3rd party vendors who will execute surveys. Group Avant never receives PII data back from these surveys, only anonymized information and data such as yes/no answers to questions about preferences. Group Avant’s survey vendors are highly trained and widely used in the industry and all conform to the highest standards of data privacy and protection. We ensure that any PII is collected for specified, explicit and legitimate purposes.

The information collected by surveys  is voluntarily disclosed to us in connection with our research studies. Only a very small portion of data collected would be considered personally identifiable information or “PII”. We do not collect PII without the affirmative consent of the research participant. We collect data for research purposes only, and our use of that information is limited to that purpose. In most cases, this information is shared with the client commissioning the study pursuant to our contract with that client. 
 
We ensure that any PII processed is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

DATA ACCURACY AND STORAGE LIMITATION
Group Avant will ensure that PII that is processed is accurate to the best of our knowledge and abilities.

 We keep PII for no longer than necessary for the purposes for which the PII is collected or processed. The length of time we retain PII depends on the purposes for which we collect and use it and/or as required to comply with applicable laws and to establish, exercise or defend our legal rights.

SECURITY OF YOUR PERSONAL DATA
We maintain physical, electronic, and procedural security measures to help safeguard and keep secure PII which are consistent with industry standards and practice and in compliance with applicable law.
 
DISCLOSURE OF YOUR PERSONAL DATA
We will not share your PII with other parties unless you request it or have given us prior approval to do so. We may be obliged to disclose personal data to regulatory authorities, courts, and government agencies where required by law, regulation, or legal process but these instances are limited.

ONWARD TRANSFER LIABILITY
Group Avant’s accountability for personal data that it receives in the United States under the Data Privacy Frameworks and subsequently transfers to a third party is described in the Data Privacy Framework Principles. In particular, Group Avant remains responsible and liable under the Data Privacy Framework Principles if third-party agents that it engages to process personal data on its behalf do so in a manner inconsistent with the Data Privacy Framework Principles, unless Group Avant proves that it is not responsible for the event giving rise to the damage.

​YOUR RIGHTS
​Group Avant is committed to ensuring the protection of your rights under applicable laws. These only apply in the very limited circumstances where we may have access to PII. We take measures to avoid collecting any PII and only do so if it is absolutely necessary for the purposes of the research.
​
Here we summarize your different rights:
​
Right to be informed
You have the right to be informed about how Group Avant collects and uses your PII, including the purpose for collecting PII, our retention period of that PII, and who it will be shared with. Refer to previous sections of this Data Protection and Privacy policy for more detail on these topics.
​
Right of access to PII
You have the right to ask us for copies of your PII which may be provided where technically feasible.
​
Right to rectification of PII
You can request the correction of your PII held by Group Avant to the extent that it is inaccurate or incomplete in certain circumstances.
​
Right to erasure of PII
You have the right to ask us to erase your PII in certain circumstances.
​
Right to restrict processing
You have the right to ask us to restrict the processing of your PII in certain circumstances.
​
Right to object to processing
You have the right to object to the processing of your PII in certain circumstances. We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your 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. To request to limit the use and disclosure of your personal information, please submit a written request to info@groupavant.com

​Right to data portability
You have the right to ask that we transfer the personally identifiable information you gave us to you or to another organization, in certain circumstances (where technically feasible).
​
Right to object to automated decision making (including profiling)
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has a legal affect upon you or significantly affects you.
​
​POLICY UPDATES
We may update this Data Privacy & Protection Policy from time to time by posting an amended version of the statement on one or more of our websites. Please refer to this policy regularly.

CONTACT US
If you have questions about the collection and the processing of your PII by Group Avant, you can send your questions or complaints through email to the Data Protection Officer at the following email address: info@groupavant.com or by writing to the Group Data Protection Officer at:
 
Group Avant, LLC
108 Wild Basin Road, Suite 250 PMB #6135
Austin, TX 78746