This policy covers three Aristotle information streams
Aristotle describes Integrity customer verification data, information from visitors to websites displaying this policy, and International Services information. Website scope excludes information collected through login-protected product portals. Section 3 supplies general practices for all three streams; its rules should not be read as limited to International Services.
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applies to both Integrity and to Aristotle’s International Services
Integrity customers are businesses seeking to verify the identity or age of individuals seeking to open accounts or to participate in age-regulated activities.
other than information collected through login-protected product portals on any site
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.
Legal Rights & Agreement Rules · Restriction or exception
Death Master File access carries customer compliance requirements
Some Integrity data may come from the NTIS Death Master File. The policy requires customers to comply with applicable laws and customers granted DMF access to certify compliance with 15 CFR Part 1110. It states that noncompliance may bring $1,000 per disclosure or use, up to $250,000 per calendar year. This reports the policy’s description of an external regulation.
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Certain data we provide for some of our Integrity Services may include information obtained from the Death Master File (DMF)
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.
Qualifications & exceptions
Applies to clients granted access to DMF data.
Legal Rights & Agreement Rules · Procedure
Covered DPF complaints go first to Aristotle
Covered European, UK and Swiss residents should first contact integrity@aristotle.com or the policy’s postal address about handling of their data or DPF compliance. Aristotle says it will attempt timely, complete responses as soon as possible and commits to resolve complaints about collection/use of data transferred to the U.S. under the listed DPF routes.
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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.
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.
Qualifications & exceptions
Concerns covered EU, UK and Swiss data transferred under the relevant DPF routes.
Legal Rights & Agreement Rules · User right or choice
Unresolved DPF complaints have a free BBB route
Aristotle commits to refer unresolved DPF Principles complaints to BBB National Programs, an independent U.S. dispute-resolution mechanism. A person whose complaint is not acknowledged promptly or satisfactorily addressed can use the linked BBB complaint page. That service is free, distinct from the general fee provision for data-rights requests.
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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
This service is provided free of charge to you.
Qualifications & exceptions
Available for unresolved DPF Principles complaints, including untimely acknowledgement or unsatisfactory handling.
Not stated here
The linked BBB procedure is not supplied.
Cross-references
contrast (model-proposed): Rights requests can carry a fee where law permits — The general data-rights request provision allows a reasonable fee where lawful, while the BBB DPF complaint service is expressly free. They concern different procedures, so the fee is not applied to the free complaint route.
referred to by (model-proposed): Some residual DPF claims can proceed to binding arbitration — Conditional arbitration is a route for some residual DPF claims after the preceding complaint channels do not resolve them, including the independent complaint route.
Legal Rights & Agreement Rules · User right or choice
Some residual DPF claims can proceed to binding arbitration
If the preceding complaint channels do not resolve a DPF complaint, a person may under certain conditions invoke binding arbitration for some residual claims left unresolved by other redress mechanisms. This is a conditional remedy the person may invoke, rather than a general mandatory arbitration clause for all disputes. The policy links Annex I but does not supply its detailed conditions.
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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.
Qualifications & exceptions
Only certain residual DPF claims after other channels fail, subject to conditions.
Not stated here
The linked Annex I arbitration conditions are not supplied.
Cross-references
refers to (model-proposed): Unresolved DPF complaints have a free BBB route — Conditional arbitration is a route for some residual DPF claims after the preceding complaint channels do not resolve them, including the independent complaint route.
Legal Rights & Agreement Rules · Restriction or exception
Aristotle disclaims responsibility for third-party privacy practices
Aristotle says it is not responsible for privacy practices/disclosures of third parties accessing or using its websites or Integrity Services, or for external websites reached from its sites. It encourages reading those parties’ policies and terms, including referenced tools. Although the introduction and general section include International Services, this paragraph describes policy scope only as data acquired through websites and Integrity Services; it does not explain that narrower wording.
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We are not responsible for the privacy practices or disclosures of third parties that access or use our Websites or Integrity Services.
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.
Not stated here
Third-party policies are not supplied.
The narrower scope wording here is not reconciled with the policy’s express International Services coverage.
Cross-references
contrast (model-proposed): The general provisions address all three data streams — The general section expressly includes International Services but the third-party paragraph describes policy scope only as information acquired through websites and Integrity Services. The analysis reports the narrower wording without erasing the express broader coverage or inventing its intended reconciliation.
contrast (model-proposed): Onward-transfer liability under DPF has two stated conditions — Aristotle disclaims responsibility for third-party practices and external sites, but separately acknowledges conditional DPF liability for its agents’ inconsistent processing. Agent liability is not an unconditional guarantee about every independent website.
Legal Rights & Agreement Rules · Context
California residents are referred to a separate notice
California residents are directed to Aristotle’s Notice to California Residents for more information on online/offline collection, use, disclosure, sale, sharing, retention and privacy rights. That linked notice is not supplied in this assigned source, so this card does not describe its additional rules or assume they match the other-state list.
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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.
Not stated here
The linked California notice is not supplied; its additional practices, rights and limitations are unknown here.
Legal Rights & Agreement Rules · User right or choice
State rights may include access and portable copies
For residents of states other than California, depending on state and applicability, rights may include confirmation of processing and access to personal data. A portable, readily usable copy may also be available to the extent technically feasible where processing is automated, allowing transmission to another controller without hindrance. Aristotle says legally required requests are fulfilled after identity verification; California residents are referred to a separate notice.
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For other state residents, your privacy rights may include (if applicable):
The right to confirm whether or not we are processing your personal data and to access such personal data;
The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
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.
Qualifications & exceptions
Depends on state and applicable law; California has a separate notice.
Portability concerns automated processing and technical feasibility; identity verification applies.
Legal Rights & Agreement Rules · User right or choice
Applicable state rights can include deletion and correction
Depending on residence and applicability, non-California state residents may delete personal data collected from/about them and correct inaccurate personal data Aristotle maintains. Both rights are subject to exceptions. Legally required requests are fulfilled after verification of the requester and, where applicable, the represented individual. California is directed to a separate notice.
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The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
For other state residents, your privacy rights may include (if applicable):
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.
Qualifications & exceptions
State-dependent; deletion and correction each have exceptions.
Identity verification applies to legally required requests.
Legal Rights & Agreement Rules · User right or choice
Applicable state rights include freedom from discriminatory treatment
The policy’s state-rights list includes a right not to receive discriminatory treatment from Aristotle for exercising privacy rights. This appears in the non-California state list whose availability depends on residence and applicable law; California residents are referred to their separate notice.
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The right not to receive discriminatory treatment by us for the exercise of your privacy rights.
For other state residents, your privacy rights may include (if applicable):
Qualifications & exceptions
Within the state-dependent rights list; California has a separate notice.
Different requests use different forms and advertising uses cookie settings
The policy directs confirmation, correction and copy requests to its linked personal-data request form; sale/profiling opt-outs to its do-not-sell form; and deletion requests to its deletion form. Targeted-advertising opt-outs use the bottom-left cookie icon. Rights depend on applicable law, and legally required requests are fulfilled after identity verification. The forms are routes named by this policy; their separate contents are not supplied.
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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.
Qualifications & exceptions
Legally required fulfillment follows identity verification; underlying rights depend on applicable law.
Not stated here
The linked webforms are not supplied and have not been tested here.
Cross-references
qualified by (model-proposed): Rights requests are verified against existing records — Legally required fulfillment follows verification against existing records, including the represented individual’s identity where applicable.
Legal Rights & Agreement Rules · User right or choice
A refusal can be appealed by replying to the denial email
If Aristotle refuses to act on a rights request, the policy says the requester may appeal by replying to the denial email. This passage does not provide a response deadline or guarantee that an appeal succeeds.
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If we refuse to take action regarding your request, you may appeal our decision by replying to the email denying your request.
Qualifications & exceptions
Applies after refusal to act on the request.
Not stated here
No appeal-response deadline or result is specified in this passage.
Updated policies appear on the websites and continued use acknowledges them
Aristotle may update the policy as its practices change and display or make the amended version accessible on its websites. It asks users to check regularly. Continued access to or use of websites or services constitutes acknowledgement of the policy and updates; the text says acknowledgement, without describing a separate advance-notice promise here.
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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.
Not stated here
This passage does not specify advance notice or an individual notification channel.
Legal Rights & Agreement Rules · User right or choice
An alternative policy format can be requested
Aristotle commits to making the policy accessible to people with disabilities and invites requests for an alternative format using the policy’s contact methods.
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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.
Legal Rights & Agreement Rules · Procedure
Privacy questions, rights and complaints have email and postal routes
The policy lists integrity@aristotle.com and support@aristotle.com for privacy questions, rights requests and complaints. Its postal contact is Integrity, 205 Pennsylvania Avenue, SE, Washington, DC 20003, United States. These general routes sit alongside the specific webforms and DPF complaint process.
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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
Legal Rights & Agreement Rules · Context
The stored policy states 2024 effectiveness and a 2025 update
The source states an effective date of August 28, 2024 and a last-updated date of November 11, 2025. These are the publisher’s dates printed in the stored document, separate from acquisition and analysis times; they do not establish that the publisher still serves identical text today.
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Effective Date: August 28th, 2024
Last Updated Date: November 11th, 2025
Legal Rights & Agreement Rules · Context
The general provisions address all three data streams
The general-practices section expressly covers information from Integrity Services, the websites and International Services. Its rights, retention and other general provisions therefore are not confined to website visitors or International Services alone. Specific rights still depend on the jurisdiction and conditions each provision states.
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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.
Cross-references
contrast (model-proposed): Aristotle disclaims responsibility for third-party privacy practices — The general section expressly includes International Services but the third-party paragraph describes policy scope only as information acquired through websites and Integrity Services. The analysis reports the narrower wording without erasing the express broader coverage or inventing its intended reconciliation.
Legal Rights & Agreement Rules · Procedure
Rights requests can carry a fee where law permits
Some people, including those whose data is collected under the EU-U.S. Data Privacy Framework, have legal data rights. They may contact support@aristotle.com or the policy’s postal address to exercise them. Aristotle says it will charge a reasonable response fee except where prohibited by law. This is not a statement that every person has every listed right or may legally be charged.
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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.
Qualifications & exceptions
A response fee is charged except where prohibited by law.
Rights depend on the relevant country or jurisdiction.
Cross-references
contrast (model-proposed): Unresolved DPF complaints have a free BBB route — The general data-rights request provision allows a reasonable fee where lawful, while the BBB DPF complaint service is expressly free. They concern different procedures, so the fee is not applied to the free complaint route.
Legal Rights & Agreement Rules · User right or choice
Country-dependent rights can include access and correction
Depending on the country where someone lives, they may obtain copies of personal data Aristotle has obtained about them and request correction of information they believe inaccurate or incomplete. These are conditional legal rights, rather than a universal promise; the general request procedure and lawful-fee exception apply.
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Depending on what country you live in, you may have the right to:
Access copies of your personal data that we have obtained about you;
Request that we correct any information that you believe is inaccurate or incomplete;
Qualifications & exceptions
Availability depends on country; the general request procedure and lawful-fee exception apply.
Legal Rights & Agreement Rules · User right or choice
Deletion, restriction, objection and portability depend on conditions
Depending on country and the applicable conditions, people may erase data, request restriction of processing, object to processing, or request transfer to themselves or another organization. The policy expressly makes each of these rights conditional; it does not supply an unconditional deletion or portability entitlement. The general request procedure and lawful-fee exception apply.
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Depending on what country you live in, you may have the right to:
Erase your personal data, under certain conditions;
Request that we restrict the processing of your personal data, under certain conditions;
Object to our processing of your personal data, under certain conditions;
Request that we transfer your data to another organization, or to you, under certain conditions;
Qualifications & exceptions
Depends on country and the unspecified conditions attached to each right.
Subject to the general request procedure and lawful-fee exception.
Not stated here
The legal conditions behind this deletion right are not supplied in detail; the card cannot provide a complete eligibility test.
Legal Rights & Agreement Rules · User right or choice
Some users can seek consent and recipient information
Depending on country, people may obtain information about denying consent and its consequences, and about entities with which Aristotle has shared their data. The general request procedure, including a reasonable response fee except where prohibited, applies.
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Depending on what country you live in, you may have the right to:
Obtain information about the possibility of denying consent and the consequences of such denial; or
Obtain information about entities with whom we have shared your data.
Qualifications & exceptions
Availability depends on country and the general request procedure.
Legal Rights & Agreement Rules · Company commitment
Aristotle states DPF compliance and priority of the Principles
The policy says Aristotle is subject to FTC investigatory/enforcement authority and complies with the EU-U.S. DPF, UK Extension and Swiss-U.S. DPF. It says it certified adherence to the respective Principles for EU, UK/Gibraltar and Swiss data received in reliance on those frameworks. If the policy conflicts with the applicable EU-U.S. or Swiss-U.S. Principles, the Principles govern. This reports the stored policy’s certification statement, not an independent current certification check.
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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.
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.
Qualifications & exceptions
Certification statements concern personal data received in reliance on the respective DPF routes.
Not stated here
The linked DPF Principles and certification page are not supplied.
Legal Rights & Agreement Rules · Context
Onward-transfer liability under DPF has two stated conditions
When Aristotle receives data under the DPF and transfers it to a provider acting as its agent, it says it has certain DPF liability if the agent processes inconsistently with the DPF and Aristotle is responsible for the event causing the damage. Both conditions are stated; this is not a promise of unconditional liability for every third-party event.
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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.
Qualifications & exceptions
Requires both inconsistent agent processing and Aristotle responsibility for the damaging event.
Cross-references
contrast (model-proposed): Aristotle disclaims responsibility for third-party privacy practices — Aristotle disclaims responsibility for third-party practices and external sites, but separately acknowledges conditional DPF liability for its agents’ inconsistent processing. Agent liability is not an unconditional guarantee about every independent website.