CD Arevon USA, Inc. Privacy Policy

Effective Date: 10/09/2020

Last Updated: 10/09/2020

This Privacy Policy (the “Policy”) applies to the websites, applications, and electronic communications on which it appears (the “Platform”).  The Policy describes how CD Arevon USA, Inc. as well as our affiliates and subsidiaries (collectively “Arevon” or “we” or “us” or “our”) use the Personal Information that we collect, receive, maintain, and store about you.  Please read this Privacy Policy carefully, by interacting with us through the Platform you consent to this Policy.

1. Types of Personal Information Collected

We collect a range of Personal Information.  “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with or linked to an individual.  When we combine Personal Information with other information (i.e. information that does not, on its own, identify you), we treat the combined information as Personal Information.  

Contact and Demographic Information – If you sign up for our newsletter, submit an inquiry, or register for a webinar we may collect your contact and mailing information.  This may include your email name, address and phone number.  

Employment Information – If you apply for employment with Arevon, we will collect your employment and work history, as well as personal information related to your potential employment.  This may include your education and employment history, address and contact information, demographic information, and any other information included in your resume or application.  

Location Data – While navigating our Platform your mobile device or browser may share you’re your location data, both through WiFi and GPS.  Arevon will collect this information based on the settings of your phone and browser.  

Usage Information – We may also collect usage and device information when you visit our Platform.  This may include information about the browser, operating system, and/or device identifier for the device you are using, your ISP and IP information, your navigation activity on the Platform, as well as the websites that you came from and the site you visit when you leave.

2. Method of Information Collection

We collect personal information in a variety of ways.  We collect information directly from you; for example, when you submit an inquiry or job application, or correspond with us through the Platform.  

We also collect information from third parties.  For example we work with business partners, subcontractors in technical and delivery services, advertising networks, analytics providers, and search information providers.  

We also collect information from you passively.  Our Platform uses tracking tools like cookies, pixels, and we beacons.  We do this both on our Platform and in emails that we send to you.  Through these tools we collect information about users over time when you use our Platform.  This collection includes usage and browser information.  We may also have third parties collect Personal Information in this way.  For more information about the trackers that we use, please see Section 6 of this Policy.  Additionally, if you enable location data on your device, this data will be collected passively based on the location settings on your device. 

3. Combining Information

We may combine Personal Information we obtain.  For example we may combine information that we have collected online with information that we have collected offline, for instance during calls between you and our support team.  We may also combine information that we have collected across other third party sites or from other third parties with information we already have.  Finally, we combine information across devices.

4. How We Use Personal Information

We will use your Personal Information to fulfill your purchases and offer our services, respond to your requests and inquiries, as well as to send you communications.  We also use your Personal Information to communicate with you for transactional purposes.  For example, we might contact you about this Policy or our Terms of Use. 

We may also use your Personal Information to improve our Platform, products, and services.  This may include using your information to customize your experience with us.   We may also use your Personal Information for the security of the Platform and our company, our customers, and other third parties. We may also use your Personal Information to protect against fraud and other malicious activity.

We may also your information for marketing purposes.  For example, we may send you information about new features on the Platform, new services we offer, and special offers.  When legally permitted, this may also include using your information to serve you ads and to tell you about products or offers available through third parties we think you might find interesting.  These might be our own offers, or third party offers, or products we thing you might find interesting.

Finally we may use your information for other purposes, as permitted by law.  

5. Sharing Personal Information

We may share your Personal Information in the following circumstances:

  • Within Arevon – We may share your Personal Information within our family of companies. 
  • Service providers – When we hire a service provider to help operate the Platform or our business, we may give access to Personal Information as necessary to perform the service for Arevon.  This may include service providers that operate our website or send our communications. 
  • Legal obligation or protection from harm – When Arevon has a good faith belief that access, use, preservation or disclosure of the Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Arevon, its users, or the public against harm.
  • Merger or sale – If and when Arevon is involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business.  Where legally required we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer. 
  • Purposes described to you – We may share your Personal Information for other purposes, as we describe to you. 

We do not share information to third parties for their marketing purposes. 

6. Cookies and Other Technologies

We collect information about users over time on the Platform by using several common types of cookies and other tracking technologies including web beacons, pixels, and flash cookies.  We also have third parties that collect information in this way on our behalf and for their own purposes.  Cookies are small files that download when you access certain websites.  For more information about cookies visit: http://www.allaboutcookies.org/.  Web beacons, pixels, and other tracking technologies operate independent of cookies. 

To assist us with analyzing our website traffic through cookies and similar technologies, we use analytics services such as Google Analytics.  For more information on Google Analytics’ processing of your information, please see “How Google uses data when you use our partners’ Platforms or apps.”  You can opt out of Google Analytics by installing Google’s opt-out browser add-on.

These cookies may be ones placed by us (first-party) or by a third party.  These cookies may also be Flash Cookies.  To learn how to manage privacy and storage settings for Flash cookies click here.  We may use cookies that are session-based or persistent.  Session cookies expire when you close your browser or turn off your device.  Persistent cookies remain on your device after you close your browser or turn off device.  

We may use a variety of cookies:

Type of CookiesDescription
Required Required cookies are essential for the Platform to function properly and for you to navigate our Site and use its features, such as accessing secure areas of the Platform and using our services.
Performance These cookies collect information about how you use the Platform, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how the Platform functions and performs.
Functionality Functionality cookies allow the Platform to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Platform after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize.
Targeting or Advertising From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit the Platform. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited the Platform. The information provided to third parties does not include Personal Data, but this information may be re-associated with Personal Data after we receive it.By way of example, as you visit the Platform, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with the Platform.We also contract with third-party advertising networks and similar partners that collect IP addresses and other information on our Platform, from emails, and on third-party sites. Ad networks follow your online activities over time by collecting Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts.Third parties, with whom we partner to provide certain features on the Platform or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.

You can control cookies and tracking tools.  Some browsers have a “do not track” feature that prevents a website from tracking you, as well as additional cookie settings.  Our Platform does not currently respond to these signals.  If you choose to block cookies and other trackers, certain features of the Platform may not work.  Blocking or rejecting cookies will not stop all of the tracking described in this Policy.  These features and options are browser and device specific and are not uniform. You can usually find these settings in the options or preferences menu of your browser. To understand these settings, the following links for commonly used browsers may be helpful, or you can use the help option in your browser for more details:

  • Cookie settings in Internet Explorer
  • Cookie settings in Firefox
  • Cookie settings in Chrome
  • Cookie settings in Safari web and iOS.

To find out more on how to manage and delete cookies, visit aboutcookies.org. For more details on your choices regarding use of your web browsing activity for interest-based advertising you may visit the following sites:

  • networkadvertising.org
  • optout.aboutads.info 
  • youradchoices.com
  • youronlinechoices.eu

On a mobile device, you may also be to adjust your settings to limit ad tracking.

7. Your Choices

You have certain choices about how we use your Personal Information.  You can opt out-out of certain marketing.  To opt-out of marketing communications, please email us at info@arevonenergy.com or by following the instructions included in the email or text correspondence.  Please note that, even if you unsubscribe from certain correspondences, we may still need to contact you with important transactional or administrative information, as permitted by law.

8. Children Under the Age of 13

The Platform is meant for adults and we will not knowingly collect personally identifiable information from any person under the age of 13 without permission from a parent or guardian. The Platform is not designed to attract the attention of persons under the age of 13.  If you are a parent or legal guardian and think your child has given us information you can email us at info@arevonenergy.com.  You can also write to us at the address listed in the “Contact Us” section of this Policy.  Please mark your inquiries “COPPA Inquiry.”

9. Information for Individuals in the EU

In accordance with the GDPR, individuals in the EU have additional rights relating to the collection and processing of personal information.  If you need more information or would like to exercise your rights under the GDPR, you may contact us at enquiries@arevonenergy.com.

a. Basis for Processing

Our legal basis for collecting and using the Personal Information described in this Privacy Policy will depend on the Personal Information concerned and the context in which we collect it.  We collect Personal Information from you:

  • where we need it to perform a contract with you;
  • where the processing is in our legitimate interests (including the purposes described, above, in How We Use Personal Information); or
  • if we otherwise have your consent.

b. Your Privacy Rights

Depending on applicable law, you may have the right to:

  • Request access to Personal Information about you.  
  • Request correction of the Personal Information that we hold about you.
  • Request erasure of Personal Information about you. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of Personal Information about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. 
  • Request restriction of processing of Personal Information about you. You can ask us to suspend the processing of Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of Personal Information to you or to a third party.
  • Withdraw consent at any time where we are relying on consent to process Personal Information about you.

If you wish to exercise any of these applicable rights, please contact us at info@arevonenergy.com.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Information.  We encourage you to first reach out to us at info@arevonenergy.com, so we have an opportunity to address your concerns directly before you do so.

10. Storage, Security and Retention of Information

Arevon has taken reasonable steps to protect the information users share with us, including, but not limited to, setup of processes, equipment and software to avoid unauthorized access or disclosure of this information. No transmission of information via the Internet can be entirely secure, however, so please always use caution when submitting Personal Information.  We will retain your Personal Information in compliance with the uses described in this Policy, as well as to comply with our legal, financial reporting, or compliance obligations.

Arevon is a multinational business and serves individuals that operate globally.  We use cloud servers based in different geographic regions to facilitate compliance with local data protection laws and regulations.  Where possible, we endeavor to minimize the transfer of Personal Data outside the geographic territory in which it originated. 

In the event that we must transfer Personal Data across international borders, we take steps to help maintain a consistent level of data protection in accordance with the most stringent applicable law.  For example, we implement intra-company standard contractual clauses (where required by law) between our affiliated entities.

11. Links to Third Parties and their Sites

Our Platform may include third party content and links to third party websites and services that collect Personal Information.  We do not control these third parties and this Policy does not apply to their privacy practices.  We are not responsible for the practices of these third parties or how they use information you provide to them.  Please read the third parties’ privacy policies carefully. 

12. Contacting Averon

If you have any questions about this Policy, or the privacy practices of Averon, please email us at info@arevonenergy.com write to us at:

Arevon Energy
Attn: Privacy Policy
8800 N. Gainey Center Dr., Suite 250
Scottsdale, AZ 85258
USA

13. Updates

Please note that this policy may be amended from time to time. Unless otherwise indicated, any changes to this Policy will apply immediately upon posting to the Platform so please check our site periodically for updates.  You can see when this Policy was last updated by reviewing the “Last Updated” legend at the top of this page.  We will provide notice of material changes by updating the Policy here, and communicating with you in the manner and format in which we typically communicate with you in our regular course of business, as required by applicable law.