Freedom USA, Inc. dba AVADirect Custom Computers (“AVADirect”) respects your privacy and is committed to protecting it through compliance with this policy. This policy describes the types of information AVADirect may collect from you or that you may provide when you visit the website, https://www.avadirect.com (the “Website”), and AVADirect’s practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information AVADirect collects:
- On the Website.
- In email, text, and other electronic messages between you and the Website.
- When you interact with AVADirect’s advertising and applications on third-party websites and services, if those applications or advertising include links to this policy
It does not apply to information collected by:
- AVADirect offline or through any other means, including on any other website operated by AVADirect or any third party; or
- any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.
Children Under the Age of 13
The Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Website. AVADirect does not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on the Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of the Website or provide any information about yourself to AVADirect, including your name, address, telephone number, email address, or any screen name or user name you may use. If AVADirect learns it has collected or received personal information from a child under 13 without verification of parental consent, AVADirect will delete that information. If you believe AVADirect might have any information from or about a child under 13, please click here to contact AVADirect.
Information AVADirect Collects About You and How It Collects It
AVADirect collects several types of information from and about users of the Website, including information:
- by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
- that is about you but individually does not identify you; and/or
- about your internet connection, the equipment you use to access the Website and usage details.
AVADirect collects this information:
- Directly from you when you provide it to AVADirect.
- Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Information You Provide to AVADirect
The information AVADirect collects on or through the Website may include:
- Information that you provide by filling in forms on the Website. This includes information provided at the time of registering to use the Website, subscribing to AVADirect’s service(s), posting material, or requesting further services. AVADirect may also ask you for information when you enter a contest or promotion sponsored by AVADirect, and when you report a problem with the Website.
- Records and copies of your correspondence (including email addresses), if you contact AVADirect.
- Your responses to surveys that AVADirect might ask you to complete for research purposes.
- Details of transactions you carry out through the Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Website.
- Your search queries on the Website.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although AVADirect may limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, AVADirect cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, AVADirect cannot and does not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information AVADirect Collects Through Automatic Data Collection Technologies
As you navigate through and interact with the Website, AVADirect may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
AVADirect also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information AVADirect collects automatically is statistical data and may include personal information, but AVADirect may maintain it or associate it with personal information it collects in other ways or receive from third parties. It helps us to improve the Website and to deliver a better and more personalized service, including by enabling AVADirect to:
- Estimate audience size and usage patterns.
- Store information about your preferences, allowing us to customize the Website according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Website.
The technologies we use for this automatic data collection may include:
- Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of the Website and AVADirect’s e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit AVADirect, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
AVADirect does not collect personal information automatically, but it may tie this information to personal information about you that it collects from other sources or you provide to AVADirect.
AVADirect does not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How AVADirect Uses Your Information
AVADirect uses information that it collects about you or that you provide to AVADirect, including any personal information:
- To present the Website and its contents to you
- To provide you with information, products, or services that you request from AVADirect.
- To fulfill any other purpose for which you provide it.
- To carry out AVADirect’s obligations and enforce AVADirect’s rights arising from any contracts entered into between you and AVADirect, including for billing and collection.
- To notify you about changes to the Website or any products or services AVADirect offers or provides though it.
- To allow you to participate in interactive features on the Website.
- In any other way AVADirect may describe when you provide the information.
- For any other purpose with your consent.
AVADirect may also use your information to contact you about goods and services that may be of interest to you. If you do not want AVADirect to use your information in this way, please check the relevant box located on the order form.
AVADirect may use the information it has collected from you to enable AVADirect to display advertisements to AVADirect’s advertisers’ target audiences. Even though AVADirect does not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
AVADirect may disclose aggregated information about its users, and information that does not identify any individual, without restriction.
- To AVADirect’s subsidiaries and affiliates.
- To contractors, service providers, and other third parties AVADirect uses to support its business.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of AVADirect’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by AVADirect about the Website users is among the assets transferred.
- To third parties to market their products or services to you if you have not opted out of these disclosures.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by AVADirect when you provide the information.
- With your consent.
AVADirect may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If AVADirect believes disclosure is necessary or appropriate to protect the rights, property, or safety of AVADirect, AVADirect’s customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How AVADirect Uses and Discloses Your Information
AVADirect strives to provide you with choices regarding the personal information you provide to AVADirect. AVADirect has created mechanisms to provide you with the following control over your information:
- Disclosure of Your Information for Third-Party Advertising. If you do not want AVADirect to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending AVADirect a request. Please click here to contact AVADirect.
- Promotional Offers from AVADirect. If you do not wish to have your contact information used by AVADirect to promote AVADirect’s own or third parties’ products or services, you can opt-out by checking the relevant box located on the order form any other time by sending AVADirect a request. Please click here to contact AVADirect. If AVADirect has sent you a promotional email, you may send AVADirect a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to AVADirect as a result of a product purchase, warranty registration, product service experience or other transactions.
- Targeted Advertising. If you do not want AVADirect to use information that AVADirect collects or that you provide to AVADirect to deliver advertisements according to AVADirect’s advertisers’ target-audience preferences, you can opt-out by sending AVADirect a request. Please click here to contact AVADirect.
AVADirect does not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
For Website Visitors in the European Union
- Access: Please click here to contact AVADirect and request a copy of the personal data the Website currently contains.
- Withdraw Consent: At any time, you may withdraw your consent to AVADirect’s processing of your personal data through the Website by contacting AVADirect Please click here to contact AVADirect. Simply type the words “WITHDRAW CONSENT” in the body of the message and include the email address you have provided AVADirect. Upon receipt of such a withdrawal of consent, AVADirect will confirm receipt and proceed to stop processing your personal data.
- Correction: Please click here to contact AVADirect to request a correction of your personal data the Website currently contains. You may request that AVADirect correct or rectify any personal data that you have provided to us. AVADirect may not accommodate a request to change information if it believes the change would violate any law or legal requirement or cause the information to be incorrect.
- Restrict Processing: When applicable you may restrict the processing of your personal data. Please click here to contact AVADirect. In your message, please explain how you wish AVADirect restrict processing of your personal data. When such restrictions are not possible, AVADirect will advise you accordingly. You can then choose to exercise any other rights under this policy, to include withdrawing your consent to the processing of your personal data.
- Object to Processing: When applicable, you have the right to object to the processing of your personal data. Please click here to contact AVADirect. When such objections are not possible, AVADirect will advise you accordingly. You can then choose to exercise any other rights under this policy, to include withdrawing your consent to the processing of your personal data.
- Portability: Upon request, and when possible, AVADirect can provide you with copies of your personal data. Please click here to contact AVADirect. When such a request cannot be honored, AVADirect will advise you accordingly. You can then choose to exercise any other rights under this policy, to include withdrawing your consent.
- Erasure: If you should wish to cease use of the Website and have your personal data deleted from the Website, please click here to submit a request. Upon receipt of such a request for erasure, AVADirect will confirm receipt and will confirm once your personal data has been deleted.
If you have any questions about this policy or AVADirect’s data collection practices, please contact us at the following address or telephone number or click here to message or chat with AVADirect. Please specify your country of residence and the nature of your question.
ATTN: Data Controller
2045 Midway Drive
Twinsburg, Ohio 44087
AVADirect has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where AVADirect has given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. AVADirect asks you not to share your password with anyone. AVADirect urges you to be careful about giving out information in public areas of the Website like message boards. The information you share in public areas may be viewed by any user of the Website.
Unfortunately, the transmission of information via the internet is not completely secure. Although AVADirect does its best to protect your personal information, AVADirect cannot guarantee the security of your personal information transmitted to the Website. Any transmission of personal information is at your own risk. AVADirect is not responsible for circumvention of any privacy settings or security measures contained on the Website.
Privacy Notice for California Residents
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
In particular, we have collected some or all of the following categories of personal information from consumers within the last twelve (12) months:
A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
F. Internet or other similar network activity.
Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
G. Geolocation data.
Physical location or movements.
H. Sensory data.
Audio, electronic, visual, thermal, olfactory, or similar information.
I. Professional or employment-related information.
Current or past job history or performance evaluations.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
K. Inferences drawn from other personal information.
Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website users is among the assets transferred.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA prohibits third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, AVADirect has disclosed some or all of the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category D: Commercial information.
- Category E: Biometric information.
- Category F: Internet or other similar network activity.
- Category G: Geolocation data.
- Category H: Sensory data.
- Category I: Professional or employment-related information.
- Category J: Non-public education information.
- Category K: Inferences drawn from other personal information.
Sales of Personal Information
In the preceding twelve (12) months, AVADirect has not sold personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights below), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by clicking here.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights below.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by clicking here and writing “Do Not Sell My Personal Information” in the in the message body.
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by clicking here and notifying us.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” Law
California's “Shine the Light” law (Civil Code Section § 1798.83) permits visitors of the Website that are California residents and who provide personal information in obtaining products or services for personal, family, or household use to request certain information regarding AVADirect’s disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please click here to submit a request with “Request for California Privacy Information” in the body of your message. AVADirect will provide the requested information to the e-mail address provided by you.