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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Supporting quotations
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.
Aristotle generally acts as the customer’s service provider and processor when providing Integrity Services. It supplies check results; the customer decides whether to proceed with a user, reject them or seek more checks. The policy directs individuals to that customer’s privacy policy for their specific collection and use.
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Supporting quotations
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.
Qualifications & exceptions
Aristotle describes its processor role as general, rather than universal.
Not stated here
The customer’s separate privacy policy is not supplied here.
Data Access & Collection · Company practice
Integrity uses internal, government and third-party data
Aristotle maintains internal databases and accesses government and other third-party databases for Integrity. Examples include names, addresses, phone numbers, birthdates, government identification, IP addresses, social-network data, financial watchlists and politically exposed person data used for KYC. These are examples of Service Information, rather than a statement that every check collects every field.
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Supporting quotations
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.
We refer to all of the above information as the “Service Information.”
Data Access & Collection · Company practice
Individuals or consenting customers supply verification data
Individuals, or customers with consent from the individual or an appropriate parent, guardian or legal representative, provide similar identifying information through data connections, email, videoconference or other means. Aristotle uses it to verify age or identity, validate people for anti-fraud, financial and legal compliance in age-restricted services, or other KYC purposes.
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Supporting quotations
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.
Qualifications & exceptions
Customer-provided information requires the stated individual or representative consent.
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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Supporting quotations
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.
Use & Processing · Company practice
Service Information supports the check and compatible fraud prevention
Aristotle uses Service Information to provide the Integrity Service for which it was collected, subject to law and the source’s contractual restrictions. Within that purpose it may perform fraud prevention, risk mitigation and similarly compatible activities. This service-specific statement does not say that every use of Aristotle website or International Services data has this same limit.
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Supporting quotations
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.
Qualifications & exceptions
Subject to law and contractual restrictions imposed by the information’s sources.
Cross-references
qualified by (model-proposed): Integrity Services require individual or representative consent — Integrity use requires the individual’s or appropriate representative’s consent, while the use-purpose card describes what Aristotle does with Service Information.
qualified by (model-proposed): Outside verification providers may receive request information — The check may involve subprocessors rather than only Aristotle’s own data; their broader business use is described for anonymized information, with the stated sharing restrictions retained.
contrast (model-proposed): The general notice discloses sales to political and marketing clients — The Integrity section limits Service Information use to the collected-for service and compatible activity, while the general section discloses sales across listed categories. The source does not allocate each sale category to a data stream, so this tension does not establish that particular Integrity check records are sold.
Use & Processing · Restriction or exception
Integrity Services require individual or representative consent
Use of Integrity Services requires consent from the person whose information is processed, or that person’s parent, guardian or other appropriate legal representative. The policy does not present consent as optional for using these services.
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Supporting quotations
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.
When a customer submits verification or validation information, Aristotle returns a code indicating a match or non-match with its records. In some cases the code distinguishes an exact from a partial match. Service Information sharing is subject to legal requirements and contractual restrictions imposed by customers and other data sources.
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Supporting quotations
Where appropriate in light of legal requirements and contractual restrictions imposed by our customers and other data sources
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.
Qualifications & exceptions
Sharing is qualified by legal requirements and customer/data-source contractual restrictions.
Outside verification providers may receive request information
Aristotle often checks its own data, but may send verification-request information to a third party to perform some or all of a check. Those subprocessors provide verification and fraud prevention for Aristotle and may use anonymized information for other valid business purposes. Sharing remains subject to the section’s legal and contractual restrictions.
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Supporting quotations
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.
Where appropriate in light of legal requirements and contractual restrictions imposed by our customers and other data sources
Qualifications & exceptions
Other business-purpose use is described for anonymized information.
Subject to legal and customer/data-source contractual restrictions.
Cross-references
qualifies (model-proposed): Service Information supports the check and compatible fraud prevention — The check may involve subprocessors rather than only Aristotle’s own data; their broader business use is described for anonymized information, with the stated sharing restrictions retained.
Integrity information may go to affiliates and business helpers
Aristotle may share Service Information with affiliates and other entities helping operate its business and provide Integrity Services. The section qualifies this permission by legal requirements and contractual restrictions imposed by customers and data sources.
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Supporting quotations
We may share Service Information with our affiliates or other entities that help us to operate our business and provide our Integrity Services.
Where appropriate in light of legal requirements and contractual restrictions imposed by our customers and other data sources
Qualifications & exceptions
Subject to legal requirements and customer/data-source contractual restrictions.
Service Information may be disclosed for legal and protection purposes
Aristotle may disclose Service Information to comply in good faith with laws, rules, regulations, government requests, court orders or subpoenas, including national security and law enforcement. It may also disclose to enforce agreements or protect anyone’s rights, property or safety, within the sharing section’s legal and contractual restrictions.
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Supporting quotations
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.
Where appropriate in light of legal requirements and contractual restrictions imposed by our customers and other data sources
Qualifications & exceptions
Sharing remains qualified by legal and customer/data-source contractual restrictions.
Business transactions can involve Service Information
Aristotle may disclose Service Information in a sale, merger, consolidation, investment, change in control, substantial asset transfer, reorganization or liquidation, including anticipatory due diligence. This permission remains qualified by legal requirements and customer/data-source contractual restrictions.
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Supporting quotations
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).
Where appropriate in light of legal requirements and contractual restrictions imposed by our customers and other data sources
Qualifications & exceptions
Includes steps taken in anticipation of a transaction.
Subject to the section’s legal and contractual restrictions.
The banner and cookie icon let visitors choose cookie types
On a first website visit Aristotle says it presents a banner offering acceptance or rejection of different types of cookies or tracking technologies. Visitors can later change preferences through the cookie icon at the bottom left of this or other Aristotle webpages. This describes the policy’s controls, rather than a live test of them.
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Supporting quotations
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.
contrast (model-proposed): Aristotle websites do not respond to Do Not Track signals — The websites do not respond to Do Not Track signals, yet the policy offers explicit cookie choices. The controls are different mechanisms, and no promise about other browser signals follows.
Data Access & Collection · User right or choice
Blocking cookies can affect website access
A browser can be set to refuse some or all cookies. Aristotle warns that blocking all cookies, including essential ones, may prevent access to all or parts of its websites. It points to AboutCookies.org and allaboutcookies.org for further management information; those external instructions are not supplied.
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Supporting quotations
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
Qualifications & exceptions
Blocking essential cookies may impair website access.
Not stated here
The linked cookie-management guides are not supplied.
Data Access & Collection · User right or choice
Google’s settings offer a cookie opt-out route
The policy directs users to Google’s adssettings.google.com instructions to opt out of Google-set cookies. The described opt-out mechanisms apply to the browser or device where exercised, so users need to act on each browser and device they use. The Google instructions themselves are outside this source.
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Supporting quotations
You can opt out of Cookies set by Google by following the instructions found here:
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.
Qualifications & exceptions
Opt-outs must be exercised on each browser and device.
Not stated here
The linked Google instructions are not supplied; their detailed effect is unknown here.
Aristotle points to the Network Advertising Initiative and Digital Advertising Alliance for identifying entities enabling cookies and opting out of some of them, plus NAI’s Mobile Choices resources. These mechanisms are device/browser-specific and must be repeated for each one. This is not a promise that every cookie or advertisement can be stopped.
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Supporting quotations
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.
Qualifications & exceptions
Only some cookies are covered; each browser and device needs its own opt-out.
Not stated here
The linked industry and mobile-choice instructions are not supplied.
Google Analytics receives and stores website activity information
Aristotle uses Google Analytics to analyze website/service interaction, produce activity reports and related services. Google’s technologies may collect IP address, visit time, returning-visitor status and referring site. Generated information is transmitted to and stored by Google under its own privacy policies. Aristotle links information about Google partner services and analytics opt-outs without supplying those external terms.
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Supporting quotations
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.
Not stated here
Google’s linked privacy policies and detailed analytics opt-out instructions are not supplied.
Security & Safeguards · Company practice
reCAPTCHA sends technical and behavioral information to Google
Aristotle uses Google reCAPTCHA against spam and abuse. Depending on the version it may ask for a checkbox or detect abusive traffic without interaction. It transmits information such as referrer URL, IP address, visitor behavior, operating system, browser, visit length, cookies and mouse movements to Google. Its use is subject to Google’s linked Privacy Policy and Terms of Service, whose contents are not supplied here.
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Supporting quotations
We use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Websites from spam and abuse.
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.
How reCAPTCHA works depends on the version deployed.
Not stated here
The deployed reCAPTCHA version and linked Google policy/terms are not supplied.
Data Access & Collection · Company practice
Aristotle websites do not respond to Do Not Track signals
Because Aristotle says browsers lack a uniform way to communicate Do Not Track, its websites do not currently interpret those signals, respond to them or change practices on receipt. This statement addresses Do Not Track and does not establish how other signals are handled. The policy separately offers cookie controls.
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Supporting quotations
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.
Not stated here
Treatment of other browser signals is not established by this passage.
Cross-references
contrast (model-proposed): The banner and cookie icon let visitors choose cookie types — The websites do not respond to Do Not Track signals, yet the policy offers explicit cookie choices. The controls are different mechanisms, and no promise about other browser signals follows.
Data Access & Collection · Company commitment
The websites are not intended for children under 16
Aristotle says its websites are not intended for children under 16 and that it does not knowingly collect, use or disclose their personal information. This appears in the website section; it does not eliminate the Integrity Services provision allowing an appropriate parent or guardian to consent to processing.
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Supporting quotations
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.
Qualifications & exceptions
The noncollection statement is qualified by knowledge.
The statement concerns websites; Integrity consent rules are separate.
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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Supporting quotations
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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Supporting quotations
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.
Security & Safeguards · Company commitment
Commercially reasonable safeguards do not guarantee absolute security
Aristotle maintains commercially reasonable measures aimed at protecting collected/stored personal information against loss, misuse and unauthorized access, disclosure, alteration or destruction. It expressly says no measure is perfect and does not guarantee absolute security.
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Supporting quotations
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.
Qualifications & exceptions
No guarantee of absolute security.
Security & Safeguards · Restriction or exception
Users bear responsibility for credential secrecy and use
The policy makes users responsible for keeping secret credentials that access Aristotle accounts or services and assigns sole responsibility to them for actions taken using those credentials. It does not state an exception here for unauthorized use of credentials.
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Supporting quotations
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.
Not stated here
This passage does not state exceptions to its credential-use responsibility rule.
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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Supporting quotations
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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Supporting quotations
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.
Sharing & Disclosure · User right or choice
Nevada residents can record an opt-out for future sales
The policy says Aristotle does not currently sell personal information as defined by Nevada law, describing that definition as monetary exchange of certain information subject to exceptions. Nevada residents can nevertheless submit a verified sale opt-out through the listed do-not-sell form; Aristotle says it will record and incorporate the instructions if its policy changes. The Nevada-specific no-sale statement does not establish that Aristotle never sells information under other definitions.
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Supporting quotations
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.
Qualifications & exceptions
The no-sale statement is limited to the Nevada-law definition.
A verified Nevada request is recorded for future use if the policy changes.
Not stated here
The external form’s contents are not supplied.
Cross-references
contrast (model-proposed): The general notice discloses sales to political and marketing clients — The general section discloses data sales, while the Nevada provision says there are no current sales under Nevada’s specific definition. The statements use different scope/definitions; neither cancels the other.
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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Supporting quotations
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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Supporting quotations
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.
Applicable state rights include advertising, sale and profiling opt-outs
Depending on state and applicability, the policy lists opt-outs for targeted advertising, sale as defined by applicable law, and profiling that furthers decisions with legal or similarly significant effects. Aristotle also states it does not use data for that significant-effects profiling. It supplies a sale/profiling form and cookie controls for targeted advertising; legally required requests are subject to identity verification. The list does not make every form of profiling prohibited.
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Supporting quotations
The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
We do not use personal data for profiling in furtherance of “decisions that produce legal or similarly significant effects” concerning individuals.
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
Rights depend on state and applicable law; California has a separate notice.
Profiling wording is limited to decisions with legal or similarly significant effects.
Not stated here
The linked opt-out form’s contents are not supplied.
Cross-references
qualifies (model-proposed): The general notice discloses sales to political and marketing clients — Applicable state rights may allow sale opt-outs. Rights depend on residence, applicable law and verification, rather than an unconditional ability to stop every listed disclosure.
Required consent for sensitive-data processing can be withdrawn
In the state-rights list for non-California residents, the policy gives a right to withdraw sensitive-data processing consent if applicable law requires Aristotle to obtain that consent. Availability depends on state and applicability; the general withdrawal provision says such actions typically have no retroactive effect.
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Supporting quotations
If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
though such actions typically will not have retroactive effect.
Qualifications & exceptions
Applies where law requires consent to sensitive-data processing.
Rights vary by state; withdrawal typically is not retroactive.
Cross-references
qualifies (model-proposed): Sensitive-data sales require consent in specified states — The state-rights list offers withdrawal where applicable law requires sensitive-data processing consent. This does not create a universal consent rule for every sale or make withdrawal retroactive.
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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Supporting quotations
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.
The general notice discloses sales to political and marketing clients
Aristotle’s general state-disclosures section says it sells personal data to political organizations, candidates and other political actors, advertisers, marketing providers and analytics companies. Listed data includes contact details, cookies, sex/gender, age, marital/military/veteran status, education, employment, political affiliations, race/ethnicity, religion, health/diagnosis, citizenship, consumer health data and crime-victim status, the last group in accordance with state/local law. The sensitive-sale notice requires affirmative consent where a state prohibits such sales without it. Separately, Aristotle says it does not currently sell under Nevada’s definition. The general section covers three data streams but does not allocate each sale category among them; this does not establish that every Integrity verification record is sold.
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Supporting quotations
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:
Contact information
Information from cookies
Personal characteristics (sex/gender, age, marital status, military or veteran status)
Education information
Professional or employment-related information
Political affiliations
Data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, and citizenship status; Consumer health data; and Data concerning consumer’s status as a victim of crime, in accordance with state and local laws.
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 do not currently sell personal information as defined in the Nevada law.
Qualifications & exceptions
Affirmative consent is required where the stated state-law restriction applies to sensitive sales.
The Nevada-defined no-sale statement remains separate; sensitive categories are subject to state/local law.
Not stated here
The source does not identify which listed sale categories come from Integrity, websites or International Services, or say that every verification record is sold.
Cross-references
contrast (model-proposed): Service Information supports the check and compatible fraud prevention — The Integrity section limits Service Information use to the collected-for service and compatible activity, while the general section discloses sales across listed categories. The source does not allocate each sale category to a data stream, so this tension does not establish that particular Integrity check records are sold.
contrast (model-proposed): Nevada residents can record an opt-out for future sales — The general section discloses data sales, while the Nevada provision says there are no current sales under Nevada’s specific definition. The statements use different scope/definitions; neither cancels the other.
qualified by (model-proposed): Sensitive-data sales require consent in specified states — Sensitive-data sales are constrained by affirmative-consent requirements in states that prohibit such sales without consent; the sales card preserves this state-dependent condition.
Sharing & Disclosure · Restriction or exception
Sensitive-data sales require consent in specified states
Aristotle warns that it may sell sensitive personal data. It says it does not sell sensitive data, as defined by applicable law, about people in states that prohibit those sales without affirmative consent unless it has the person’s affirmative consent. This is a state-dependent limitation, not a promise to seek affirmative consent for every data sale everywhere. Applicable sale opt-out rights are listed separately.
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Supporting quotations
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.
The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
Qualifications & exceptions
Sensitive data follows applicable-law definitions; the consent limitation applies in states imposing that restriction.
Cross-references
qualifies (model-proposed): The general notice discloses sales to political and marketing clients — Sensitive-data sales are constrained by affirmative-consent requirements in states that prohibit such sales without consent; the sales card preserves this state-dependent condition.
qualified by (model-proposed): Required consent for sensitive-data processing can be withdrawn — The state-rights list offers withdrawal where applicable law requires sensitive-data processing consent. This does not create a universal consent rule for every sale or make withdrawal retroactive.
Aristotle says it does not profile for significant-effect decisions
The state-disclosures section says Aristotle does not use personal data for profiling in furtherance of decisions producing legal or similarly significant effects about individuals. It also supplies a profiling/sale opt-out form. The statement concerns that decision-related profiling; it does not rule out all analytics, customization or advertising.
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Supporting quotations
We do not use personal data for profiling in furtherance of “decisions that produce legal or similarly significant effects” concerning individuals.
Qualifications & exceptions
Limited to profiling for decisions with legal or similarly significant effects.
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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Supporting quotations
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.
Rights requests are verified against existing records
Aristotle says it will comply with a request if legally required after verifying the requester’s identity and, where applicable, the identity of the person represented. It asks for verification of data points based on its records. Someone acting for another person should use the same contact methods. This is not a promise that any request will be granted regardless of applicable law.
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Supporting quotations
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.
Qualifications & exceptions
Fulfillment is conditional on legal requirements and identity verification.
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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Supporting quotations
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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Supporting quotations
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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Supporting quotations
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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Supporting quotations
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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Supporting quotations
Effective Date: August 28th, 2024
Last Updated Date: November 11th, 2025
Data Access & Collection · Company practice
Website visitors can supply contact and payment details
Visitors may choose to provide a name, organization, email address and phone number, for example in registration or order forms. They may also provide payment information; Aristotle says it will share that payment information with NCR and Stripe. Their privacy policies are linked but their contents are outside this source.
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Supporting quotations
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 Stripe.
Qualifications & exceptions
Concerns visitors to covered Aristotle websites, excluding login-protected product-portal collection.
Not stated here
The linked payment-processor policies are not supplied.
Data Access & Collection · Company practice
Website browsing yields usage, device and regional location data
Aristotle automatically collects website information including pages visited, frequency and clicks; hardware model, operating system, application version and browser; aggregated mobile/tablet access, device type and carrier; and city-regional location. The stated location category does not establish precise location collection.
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Supporting quotations
We automatically collect certain personal information through your use of the Websites
Usage Information. For example, the pages on the Websites you access, the frequency of access, and what you click on while on the Websites.
Device Information. For example, hardware model, operating system, application version number, and browser.
Mobile Device Information. Aggregated information about whether the Website is accessed via a mobile device or tablet, the device type, and the carrier.
Location Information. Location information from Website visitors on a city-regional basis.
Qualifications & exceptions
Mobile device information is described as aggregated; location is city-regional.
Use & Processing · Company practice
Website data supports existing and future products
Besides uses described elsewhere in the policy, Aristotle uses website personal information to provide, market, improve and operate its websites, Integrity Services and other products or services it has or may develop. It also uses information for other purposes for which the person supplied it. The narrower Integrity check-purpose statement does not describe this website-data provision.
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Supporting quotations
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.
Other purposes for which the individual provided it.
Use & Processing · Company practice
Website information supports requests and customer service
Aristotle uses website personal information to fulfill requests and respond to questions, concerns and customer service inquiries.
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Supporting quotations
Fulfill your requests;
Respond to your questions, concerns, or customer service inquiries;
Use & Processing · Company practice
Website data supports marketing messages and personalized advertising
Aristotle uses website personal information to send product and service information, including marketing messages, and customize content and advertising on its websites, across the Internet and elsewhere. Applicable state rights and cookie choices are described separately; this paragraph does not promise that every visitor receives the same rights.
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Supporting quotations
Send information about our products and services, including marketing communications;
Customize the content and advertising you see on our Websites, across the Internet, and elsewhere; and/or
Use & Processing · Company practice
Website information is analyzed and can be de-identified
Aristotle uses website personal information to understand usage trends and preferences, analyze and improve products and services, and create aggregate or de-identified information.
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Supporting quotations
To create aggregate or de-identified information;
Understand usage trends and preferences;
Otherwise analyze, improve, and provide products and services;
Security & Safeguards · Company practice
Website information also supports compliance and fraud prevention
Aristotle uses website personal information to comply with law and for fraud prevention, risk mitigation and similar purposes.
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Supporting quotations
Comply with law and engage in fraud prevention, risk mitigation, and similar purposes;
Sharing & Disclosure · Permission or license
Website information may be shared with consent
Aristotle lists consent, including consent through this privacy policy, as one situation in which it may share website personal information. Other listed situations have their own grounds; the policy does not say that each disclosure requires a new consent request.
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Supporting quotations
We may share the personal information we collect through the Websites in the following situations:
With your consent, including through this Privacy Policy;
Not stated here
Any separate consent terms are not supplied here; the wording refers to this Privacy Policy, so the card cannot describe an independent consent instrument.
Sharing & Disclosure · Permission or license
Affiliates and business helpers may receive website information
Website personal information may be shared with Aristotle affiliates and other entities helping operate its business and provide Integrity Services.
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Supporting quotations
With our affiliates or other entities that help us to operate our business and provide our Integrity Services;
Sharing & Disclosure · Permission or license
Website vendors include ZoomInfo for marketing
Aristotle may share website personal information with vendors supplying email, hosting, maintenance, backup, targeted marketing, analysis and other data or site services. It specifically says ZoomInfo is used for marketing and may receive data collected as visitors navigate the websites, including IP addresses. ZoomInfo’s linked policy is not supplied.
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Supporting quotations
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.
Not stated here
ZoomInfo’s separate privacy-policy terms are outside this source.
Sharing & Disclosure · Permission or license
Website information may be disclosed for law and protection
Aristotle may disclose website personal information for good-faith compliance with laws, regulations, government requests, court orders and subpoenas, including national security and law enforcement. It also lists enforcement of agreements and protection of users’ or others’ rights, property and safety.
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Supporting quotations
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
Sharing & Disclosure · Permission or license
Website information may be disclosed in business transactions
Website personal information may be disclosed in a sale, merger, consolidation, investment, change in control, substantial asset transfer, reorganization or liquidation. The permission includes steps anticipating such a transaction, such as due diligence.
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Supporting quotations
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).
Qualifications & exceptions
Includes anticipatory due diligence.
Sharing & Disclosure · Permission or license
Aggregate or de-identified information may be shared without restriction
The website-sharing section says Aristotle may share aggregated or de-identified information without restriction. The statement concerns those forms of information, rather than an unrestricted permission for all identifiable website data.
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Supporting quotations
With respect to aggregated or de-identified information, we may share such information without restriction.
Data Access & Collection · Company practice
Cookies support measurement, customization and advertising
Aristotle’s term Cookies includes cookies, pixels and web beacons. It uses them to estimate audience size and usage, save preferences and customize websites and Integrity Services, advertise relevant new content, track ads and search results, improve the site using aggregate traffic/interactions, and recognize returning visitors. A first-visit banner offers accept/reject choices for different types; preferences can be changed through the bottom-left cookie icon.
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Supporting quotations
we use cookies and other tracking technologies (such as pixels and web beacons) (collectively, “Cookies”).
We use Cookies to:
Estimate audience size and usage patterns;
Understand and save your preferences for future visits, allowing us to customize our Websites and Integrity Services to your individual needs;
Advertise new content and services that relate to your interests;
Keep track of advertisements and search engine results;
Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
Recognize when you return to the Websites.
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.
Qualifications & exceptions
The policy offers choices by cookie or tracking-technology type through the banner and cookie icon.
Google, Facebook and others set cookies Aristotle uses
Aristotle sets some cookies itself and uses cookies set by other entities, including Google and Facebook, for useful information, website and Integrity Service improvements, advertising and measuring advertising effectiveness. The policy’s cookie choices apply; this does not establish what every particular cookie does.
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Supporting quotations
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 Google, Facebook, and other similar companies.
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.
Qualifications & exceptions
Users are offered cookie-type choices and can change preferences using the cookie icon.
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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Supporting quotations
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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Supporting quotations
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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Supporting quotations
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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Supporting quotations
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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Supporting quotations
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.
Use & Processing · User right or choice
Consent withdrawal usually has no retroactive effect
Individuals may use the policy’s contact details to object to uses or disclosures, withdraw consent or exercise other digital privacy rights. The policy says these actions typically do not have retroactive effect, and rights differ by country or legal jurisdiction. It does not say withdrawal reverses past processing.
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Supporting quotations
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.
Qualifications & exceptions
Typically no retroactive effect; rights differ by country or jurisdiction.
Retention follows policy objectives and compatible legal purposes
Aristotle generally retains website, Integrity and International Services information as long as necessary for policy objectives and legally permissible compatible purposes. Examples include legal compliance, dispute resolution, auditing and agreement enforcement. The policy gives a purpose-based standard rather than a fixed retention period.
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Supporting quotations
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.
Qualifications & exceptions
Retention includes legally permissible compatible purposes beyond the initial objective.
Not stated here
No fixed number of days or years is stated here.
Sharing & Disclosure · Company practice
Overseas transfers are possible despite the usual UK storage rule
Websites and Integrity Services are primarily provided, supported and hosted in the U.S. The policy says Europe/UK residents’ data is generally stored and accessed only in the UK, while warning outside-U.S. users that data may be transferred, stored and processed in the U.S. and other countries. It warns U.S. protections may be less comprehensive and U.S. authorities may request access under U.S. law. The general UK statement is not an absolute no-transfer promise.
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Supporting quotations
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.
Qualifications & exceptions
Europe/UK resident data is described as generally stored and accessed only in the UK.
Outside-U.S. users are still warned of U.S. and other-country processing.
Not stated here
The policy does not specify every circumstance departing from the general UK storage/access practice.
Sharing & Disclosure · Company commitment
EEA, Swiss and UK transfers use safeguards
For transfers from the EEA, Switzerland or UK to other entities described in this policy, Aristotle says it uses appropriate safeguards, including European Commission standard contractual clauses when appropriate. Users may request a copy at Integrity@Aristotle.com. The policy does not say every transfer relies on those clauses.
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Supporting quotations
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.
Qualifications & exceptions
Covers the described transfers from the EEA, Switzerland or UK; standard clauses are used when appropriate.
Not stated here
The safeguard documents themselves are not supplied.
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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Supporting quotations
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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Supporting quotations
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.