Aristotle Privacy Policy

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Aristotle, Inc. Privacy Policy For Integrity and Aristotle’s International Services

Introduction

Aristotle, Inc. (“Aristotle,” “we,” “our,” or “us”) provides this Privacy Policy, which applies to both Integrity and to Aristotle’s International Services (“Privacy Policy”) to explain our handling of three categories of personal information:

  • Information we receive in connection with the Integrity services we provide to our customers (“Integrity Services”). Our privacy practices with respect to this information are described in Section 1 below. Integrity customers are businesses seeking to verify the identity or age of individuals seeking to open accounts or to participate in age-regulated activities.
  • Information we receive from visitors to aiintegrity.wpenginepowered.com or any other Aristotle website on which this Privacy Policy is posted, other than information collected through login-protected product portals on any site (collectively, the “Websites”). Our privacy practices with respect to this information are described in Section 2 below.
  • Information we receive in connection with our International Services. Our privacy practices and your choices with respect to this information can be found in Section 3 below. Section 3 also applies to the other two categories of information described above.

Section 3 below contains details relevant to our handling of both types of information.

Table of Contents

This Privacy Policy contains the following topics:

  • PRIVACY PRACTICES FOR OUR INTEGRITY SERVICES
  • Information Collected in Connection with Our Integrity Services
  • How We Use the Information Collected Through the Integrity Services
  • How We Share Information We Collect Through the Integrity Services
  • PRIVACY PRACTICES FOR OUR WEBSITES
  • Information We Collect Through Our Websites
  • How We Use Information We Collect Through Our Websites
  • How We Share Information We Collect Through Our Websites
  • Cookies and Other Tracking Technologies
  • “Do Not Track” Signals
  • Children’s Privacy
  • GENERAL INFORMATION ABOUT OUR PRIVACY PRACTICES
  • Your Rights and Choices
  • Data Retention
  • Users From Outside the United States
  • EU-U.S. and Swiss-U.S. Data Privacy Framework
  • Data Security
  • Third-Party Websites and Apps
  • Notice to California Residents
  • Notice to Nevada Residents
  • Your State Privacy Rights and Additional Disclosures
  • Changes to This Privacy Policy
  • Accessibility
  • Contacting Us

PRIVACY PRACTICES FOR OUR INTEGRITY SERVICES

When we provide Integrity Services to our customers, we are generally acting on their behalf as their service provider and processor. Our Integrity Services provide check results to our customers who decide how to proceed with the user, this may be to proceed, to reject the user, or to ask for further checks. For additional information about how your specific data is being collected and used, please review the privacy policy of our customer who is using our Integrity Services with you.

Information Collected in Connection with Our Integrity Services

To operate the Integrity Services, we maintain internal databases (and have access to databases provided by governments and other third parties) containing personal information, such as names, addresses, telephone numbers, birthdates, and government-issued identification data, IP addresses, social network data, as well as details relevant to Know-Your-Customer (“KYC”) requirements, such financial watch list and Politically Exposed Person data.

During use of our Integrity Services, the relevant individuals (or our customers, with the consent of such individuals or their parents, guardians, or other appropriate legal representatives) provide us with similar information (via data connection, email, videoconference or other means) for verifying the relevant individuals’ age or identity, to otherwise validate the individuals for anti-fraud, financial and legal compliance for age-restricted services, or for other KYC purposes.

Certain data we provide for some of our Integrity Services may include information obtained from the Death Master File (DMF) made available by the US Department of Commerce National Technical Information Service (NTIS) and subject to regulations found at 15 CFR Part 1110. All Aristotle customers are required to comply with all applicable laws and, if a client is granted access to DMF data, the client certifies compliance with 15 CFR Part 1110. The client’s failure to comply with 15 CFR Part 1110 may subject the client to penalties under 15 CFR 1110.200 of $1,000 for each disclosure or use, up to a maximum of $250,000 in penalties per calendar year.

We refer to all of the above information as the “Service Information.”

How We Use the Information Collected Through the Integrity Services

We use the Service Information to provide the Integrity Service for which it was collected, in compliance with law and with contractual restrictions imposed by the relevant sources of the Service Information. As part of this, we may use the information to engage in fraud prevention, risk mitigation, and similarly compatible activities.

Use of our Integrity Services requires the consent of (i) the individual whose personal information is being processed or (ii) that individual’s parent, guardian or other appropriate legal representative.

How We Share Information We Collect Through the Integrity Services

Where appropriate in light of legal requirements and contractual restrictions imposed by our customers and other data sources, we may share Service Information as follows:

  • When a customer submits information to us for verification or validation through our Integrity Services, we send the customer a code indicating whether the information submitted regarding an individual matches or does not match information in our records. In some cases we may send a code indicating whether the match between the information submitted by a customer and our database is exact or only partial.
  • In many cases, we perform our Integrity Services by reference to data that we hold. In some cases, however, we may pass information received as part of a verification or validation request to a third party to perform all or a portion of the verification or validation for us. These third-party subprocessors use the information to perform verification and fraud prevention services for us and may use anonymized information for other valid business purposes.
  • We may share Service Information with our affiliates or other entities that help us to operate our business and provide our Integrity Services.
  • We may disclose Service Information to (1) comply in good faith with applicable laws, rules, regulations, governmental requests, court orders, or subpoenas, including for purposes of national security and law enforcement; (2) enforce our agreements; or (3) protect the rights, property, or safety of our users or any other person or entity.
  • We may disclose Service Information as part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization, or liquidation, or in connection with steps taken in anticipation of such an event (e.g., due diligence).

PRIVACY PRACTICES FOR OUR WEBSITES

Information We Collect Through Our Websites

Information You Provide

Website visitors may choose to provide their contact information (e.g., name, organization, email, phone number), such as part of a registration or order form. Visitors may also provide payment information. We will share any payment information you provide with our payment processors, NCR and StripeStripe. You may view NCR’s privacy policy here: https://www.ncr.com/privacy. You may view Stripe’s privacy policy here: https://stripe.com/privacy.

Information as You Navigate Our Websites

We automatically collect certain personal information through your use of the Websites, such as the following:

How We Use Information We Collect Through Our Websites

In addition to the uses described elsewhere in this Privacy Policy, we use the personal information we collect through our Websites to provide, market, improve, and operate the Websites, Integrity Services, and any other products or services we have or may develop. This includes use of the personal information to:

How We Share Information We Collect Through Our Websites

We may share the personal information we collect through the Websites in the following situations:

  • With your consent, including through this Privacy Policy;
  • With our affiliates or other entities that help us to operate our business and provide our Integrity Services;
  • With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, targeted marketing, analysis, etc.). We use services offered by ZoomInfo for marketing purposes and may provide this vendor with the personal data we collect from you as you navigate our websites, including your IP address. You may view ZoomInfo’s privacy policy here;
  • To (1) comply in good faith with applicable laws, rules, regulations, governmental requests, court orders, or subpoenas, including for purposes of national security and law enforcement; (2) enforce our agreements; or (3) protect the rights, property, or safety of our users or any other person or entity; or
  • As part of a business sale, merger, consolidation, investment, change in control, transfer of substantial assets, reorganization or liquidation, or in connection with steps taken in anticipation of such an event (e.g., due diligence).

With respect to aggregated or de-identified information, we may share such information without restriction.

Cookies and Other Tracking Technologies

How We Use Cookies

Like many other companies, we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”). Cookies are small files of information that are stored by your web browser software on your computer hard drive, mobile or other devices (e.g., smartphones or tablets).

We use Cookies to:

We set some Cookies ourselves, while separate entities set other Cookies. We use Cookies other entities set to provide us with useful information, to help us improve our Websites and Integrity Services, to conduct advertising, and to analyze the effectiveness of advertising. For example, we use Cookies from GoogleGoogle, FacebookFacebook, and other similar companies.

How You Can Opt Out of Cookies

Your Preferences

When you first visit our Websites, we will present you with a banner which offers you choices about whether to accept or reject cookies or tracking technologies of different types. If you wish to change your preferences, you can do so by clicking the cookie icon at the bottom left of this webpage or other Aristotle webpages.

Browser Settings

You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Website(s).

You can find out more about Cookies and how to manage them by visiting www.AboutCookies.org or www.allaboutcookies.org.

Platform Controls

You can opt out of Cookies set by Google by following the instructions found here: https://adssettings.google.com

Advertising Industry Resources

You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.

Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.

Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses Cookies or other tracking technologies to help us analyze how users interact with the Websites and Services, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

Google reCAPTCHA

We use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Websites from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. More information as to Google reCAPTCHA and how it works is available here.

“Do Not Track” Signals

Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, our Websites do not currently interpret, respond to or alter their practices when they receive “Do Not Track” signals.

Children’s Privacy

Our Websites are not intended for children under 16 years of age. We do not knowingly collect, use, or disclose personal information from children under 16.

GENERAL INFORMATION ABOUT OUR PRIVACY PRACTICES

The following subsections apply to the following categories of personal information: (1) information collected in connection with our Integrity Services, (2) information collected through our Websites, and (3) information collected through our International Services.

Your Rights and Choices

Some individuals (including those whose information we collect under the EU-U.S. Data Privacy Framework) have certain legal rights with regard to the data that we collect. To exercise those rights, they may contact us at support@aristotle.com or the address at the end of this Privacy Policy. Except where prohibited by law, we will charge a reasonable fee to respond to these requests.

Depending on what country you live in, you may have the right to:

Individuals may also use the contact information below to object to our uses or disclosures of personal information, to withdraw consent, or to otherwise fulfill their digital privacy rights, though such actions typically will not have retroactive effect. Your rights will differ depending on the country or legal jurisdiction that you live in.

Data Retention

Generally speaking, we retain the information collected from the Websites or in connection with our Integrity and International Services for as long as necessary to achieve our objectives as detailed in this Privacy Policy, and for legally permissible, compatible purposes, such as compliance with law, resolution of disputes, auditing, and enforcement of our agreements.

Users From Outside the United States

The Websites and Integrity Services are provided from, supported, and hosted primarily in the United States. However, data on individuals residing in Europe or the UK is generally stored and accessed only in the UK. If you are using the Websites or Integrity Services from outside the United States, be aware that your information may be transferred to, stored, and processed in the United States and other countries outside of yours. The privacy laws of the United States might not be as comprehensive or protective as those in your country. Your personal information can be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States.

For any transfers of personal information from the European Economic Area (EEA), Switzerland, or the United Kingdom that we make to other entities as described in this Privacy Policy, we use appropriate safeguards to ensure for the lawful processing and transfer of the personal information, including, when appropriate, the use of standard contractual clauses approved by the European Commission. To obtain a copy of the safeguards, contact us at Integrity@Aristotle.com.

EU-U.S. and Swiss-U.S. Data Privacy Framework

As a business subject to the investigatory and enforcement authority of the Federal Trade Commission, Aristotle complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Aristotle 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 and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Aristotle has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-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/

When Aristotle receives personal information under the DPF and then transfers it to a third-party service provider acting as an agent on Aristotle’s behalf, Aristotle has certain liability under the DPF if both (i) the agent processes the information in a manner inconsistent with the DPF and (ii) Aristotle is responsible for the event giving rise to the damage.

Covered European, UK, and Swiss residents should direct any questions, concerns or complaints regarding Aristotle’s handling of personal information or compliance with the Data Privacy Framework to Aristotle at integrity@aristotle.com or the address listed at the bottom of this Privacy Policy. Aristotle will attempt to answer your questions and satisfy your concerns in a timely and complete manner as soon as possible. In compliance with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF), Aristotle 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, the UK extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. EU, UK, and Swiss individuals with inquiries or complaints should first contact Aristotle at integrity@aristotle.com.

Aristotle 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/framework-article/ANNEX-I-introduction

Data Security

We maintain commercially reasonable security measures with the goal of protecting the personal information we collect and store from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, no security measure is perfect, and we cannot guarantee absolute security of your personal information.

To assist with data security, you understand that you are responsible for maintaining the secrecy of any credentials that can be used to access any account or service with Aristotle. Any actions taken using your access credentials are your sole responsibility.

Third-Party Websites and Apps

We are not responsible for the privacy practices or disclosures of third parties that access or use our Websites or Integrity Services. When you access our Websites, you may be directed to other websites that are also beyond our control. We encourage you to read the applicable privacy policies and terms and conditions of such third parties and websites, as well as those of the tools that we have referenced in this Privacy Policy (such as in the “How You Can Opt Out of Cookies” section above). This Privacy Policy applies only to personal information that is acquired by us through our Websites and Integrity Services. We accept no responsibility or liability for these other websites.

Notice to California Residents

If you are a California resident, please see our Notice to California Residents for more information about our online and offline practices regarding the collection, use, disclosure, sale, sharing, and retention of your personal information and the rights you have regarding your personal information.

Notice to Nevada Residents

Nevada law allows Nevada residents to opt out of the sale of certain types of personal information. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal information for monetary consideration to another person. We do not currently sell personal information as defined in the Nevada law. However, if you are a Nevada resident, you still may submit a verified request to opt out of sales and we will record your instructions and incorporate them in the future if our policy changes. You may send opt-out requests to https://www.aristotle.com/privacy/do-not-sell-my-personal-info/.

Your State Privacy Rights and Additional Disclosures

The Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our “NOTICE TO CALIFORNIA RESIDENTS” section above. For other state residents, your privacy rights may include (if applicable):

NOTICE: We may sell your sensitive personal data. We do not sell sensitive personal data (as defined in applicable laws) of individuals residing in states where such sales are prohibited without affirmative consent unless we have the affirmative consent of the data subject. We sell the following categories of personal data to our clients (i.e., political organizations, candidates, and organizations which undertake political activities, as well as third-party advertisers, marketing providers, and data analytics companies:

We do not use personal data for profiling in furtherance of “decisions that produce legal or similarly significant effects” concerning individuals. To exercise your rights to confirm whether we have your personal data, to correct inaccuracies, or to obtain a copy of your personal data, please submit a request through this webform. If you wish to opt out of profiling or the sale of your personal data, please use this webform. If you want us to delete your personal data, please use this webform. If you would like to opt out of targeted advertising, you may alter your cookie preferences by clicking on the cookie icon at the bottom left of this or other Aristotle webpages. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision by replying to the email denying your request.

Changes to This Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes to our privacy practices. If we do, the amended Privacy Policy will be displayed on or accessible from our Websites. Please check our Privacy Policy regularly to ensure you have read the latest version and to stay informed of our privacy practices. Your continued access to or use of the Websites or Services constitutes your acknowledgement of this Privacy Policy and any updates.

Accessibility

We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.

Contacting Us

If you have any questions regarding this Privacy Policy, or wish to exercise your rights or file a complaint, please contact us at integrity@aristotle.com,support@aristotle.com or at:

Integrity 205 Pennsylvania Avenue, SE Washington, DC 20003 United States

Effective Date: August 28th, 2024

Last Updated Date: November 11th, 2025