Averon US, Inc. (“Averon”) is committed to respecting and protecting your privacy. We value your trust and want you to understand how we protect, collect, use and disclose the personal information you share with us. This privacy statement applies to personal information we obtain anytime you interact with Averon such as when you visit our websites (www.averon.com, www.getluxmo.com, www.luxmo.us, www.httpsi.org) or social sites, contact Averon support, or use any application or product that accesses or uses Averon’s authentication services, mobile identification services, or related mobile services (collectively, the “Averon Services”). We want to ensure you are aware of our practices for collecting and processing personal information, which is information about a person that can be used to identify that person.

What We Collect

In connection with Averon Services, we may collect personal information to process verifications and related transactions, provide services, and to administer our business. The type of personal information we collect when via the Averon Services may include contact information such as mobile number, wireless network, transaction type, billing amount and related merchant(s) or such other information we may collect with your consent or as permitted or required by law.

Averon may provide services to merchant customers that may have a need for identify verification, fraud avoidance, and related purposes or who may desire to use Averon Services to auto-fill online or mobile forms within customer applications. To provide such services, Averon utilizes data or information obtained from mobile carriers and/or other data sources.

In connection with Averon Services, your use of applications or services that utilize Averon Services may require your mobile carrier or other data sources to disclose your consumer information, including your name, address, mobile phone attributes, and mobile phone location, to the application provider or some other third party that contracts with Averon for use of that information. By providing your consent, you authorize your mobile carrier and such data sources to disclose your information to these third parties to enable Averon Services and the application or service in connection with which the Averon Services are used. Check the applications or Averon customers terms of use and policies for more information about how the application or Averon customers may collect, access, use or disclose your information. The terms of use and other policies are normally available on the application providers or Averon customers website. If you are not comfortable with the application providers or Averon customers terms or policies, do not use the application or consent to use of your data in connection with Averon Services.

How We Use It

In connection with Averon Services, we use personal information in a number of ways such as to complete your transaction, administer any problems that may arise in effecting the transaction, to better understand and manage our ongoing relationship with you, to assure good service, to prevent fraud and abuse, for purposes of verification and risk management and otherwise with consent or as permitted or required by law. In our ongoing relationship with you, including via email, newsletter, social media, and other communications between you and Averon, we may store personal information on databases for the purposes of such interactions and the administration of our business, including market research and, only with your consent, for direct marketing purposes. As permitted by applicable law, we may merge personal information with public information or other information received from reputable vendors to update contact information or to enhance demographic profiles.

In connection with Averon Services, we and/or merchant customers that contract with Averon for Averon Services may use the information for identity verification, fraud avoidance, to auto-fill on-line or mobile application forms, to process transactions, and for similar purposes.

Who We Share It With

We may share all of the information, as described above, with our affiliates, merchants, and our agents in connection with goods and services these parties perform for, or with, Averon for the uses described in “How we use it” and for other purposes as permitted or required by law. In particular, use of your personal information for marketing purposes by Averon and/or our agents will always be made with your consent and in compliance with the applicable law regarding customer consent. Disclosures permitted or required by law may include cooperation with criminal or government investigations, fraud prevention and detection, and responses to a court order or subpoena. Averon agents are bound by appropriate data safeguarding obligations. Averon may disclose some or all of the personal information to service providers, data sources and participating mobile carriers for the purposes of processing requested transactions, verifying your identity, providing mobile identification services, Averon Services, or to perform business support functions on our behalf.

Averon does not sell, rent, trade or share personally identifiable information with third parties for their promotional purposes. Our agreements with these service providers and participating mobile carriers will contain confidentiality provisions and restrictions on using this information for any other purpose. If Averon becomes involved in a merger, acquisition or any form of sale of some or all its assets, we may disclose personal information to third parties in connection with the evaluation of the transaction. The surviving company, or the acquiring company in the case of a sale of assets, would have access to personal information that would continue to be subject to this privacy statement.

Choice

Averon will not use or share your personal information in ways incompatible with the ones described above or as contemplated by your consent to use without providing you a choice. You must opt-out of any sharing of personal information you have authorized or consented to as described above. However, to the extent that applicable law requires express consent or “opt-in” for the collection and use of personal information, Averon will maintain processes and procedures to ensure such information is collected with express consent. Personal information will not be used to directly market Averon services unless that possible use of the information has been disclosed and a choice provided. Users have the opportunity to opt-out of receiving communications from us or to remove your information from our database at any time by emailing info@averon.com with your specific request.

Mobile Carriers

The Averon Services, and the applications through which you may access other services and applications that use the Averon Services, are not applications of the mobile carriers or data sources. Your use of applications or services that utilize Averon Services may require your mobile carrier to disclose your consumer information, including your mobile phone location, to the application provider or some other third party. By providing your consent, you authorize your mobile carrier to disclose your information to third parties to enable Averon Services and the application or service in connection with which Averon Services are used. Check the applications or Averon customers terms of use and policies for more information about how the application or Averon customer will collect, access, use or disclose your information. The terms of use and other policies are normally available on the application providers or Averon customers website. If you are not comfortable with the application providers or Averon customers terms or policies, do not use the application or consent to use of your data in connection with Averon Services. You acknowledge and agree that (1) your relationship with the application provider or Averon customer is separate from your relationship with your mobile carrier; (2) your mobile carrier and Averon are not responsible for the application, product or service you are using from the application provider or Averon customer; and (3) you will hold harmless your mobile carrier and Averon and their respective subsidiaries, affiliates, officers, employees, agents, successors and assigns from any judgments, claims, actions, lossess, liabilities or expenses arising out of or attributable to the application, product or service or the acts or omissions or the application provider or Averon customer.

Location Information

Averon may engage in product demonstrations of its Averon Services. In connection with these demonstrations, you will be asked for consent to access and use your consumer information, possibly including your mobile phone location, obtained from your mobile carrier.

Location Terms & Conditions

Mobile phone user privacy is extremely important to us. Location coordinates for your mobile device are only gathered after the mobile phone user has explicitly consented to use of location information. Location coordinates (longitude, latitude, and radius) will be obtained only when we have proper authorization from the user. The information obtained, including location information, is used solely for the one-time purpose of performing the product demonstration. After such use, the data and information is deleted from Averon’s systems.

Limitations

The location service is available only on certain mobile carriers. The location service will not likely be available if the phone is roaming or is turned off. 

Opt-In/Opt-Out

If you agree to the terms and conditions in any demonstration, you are asked to click “continue” to opt-in to the demonstration. To cancel the demonstration and further use, you simply close the demo application. For support or further assistance, you may contact Averon at the address provided below.

Privacy

All customer data will be used only by Averon. to provide these services for demonstration purposes. We will not pass-on or re-sell your data to any third party. Location coordinate data is transmitted via Secure Socket Layer (SSL) technology into password-protected servers. This information is accessible only by Averon.

Contacting Us

If there are any questions regarding these terms or Averons demo service or any other service related to Averon Services, you may contact us using the information provided below under the heading Contacting Averon.

Accuracy & Access

Averon is committed to ensuring that the information we obtain and use about you is accurate for its intended purpose. You can contact us at info@averon.com at any time to review, update, delete or correct (for future use) your personally identifiable information maintained by Averon. We will reply to your request within sixty (60) days of submission. You can help us maintain accurate records by informing us of changes or modifications to your personal information.

Data Security

Averon utilizes physical, electronic and procedural security measures to protect against loss, misuse, and alteration of information under our control. Averon offers industry standard practices and security measures to safeguard and secure the personal information we collect. Access to personal information is restricted to employees, service providers and mobile carriers who need to have access to that information as described in this privacy statement. Averon requires its service providers to observe standards with respect to the security, collection, use and sharing of personal information, and to comply with applicable law. We make reasonable efforts to ensure security on our systems. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. When you enter sensitive information such as your mobile number, we encrypt that information using secure socket layer technology (SSL). If Averon learns of a security systems breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using Averon Services, you agree that Averon may communicate with you electronically or via short messaging service (SMS). Averon may post a notice on the Averon website if a security breach occurs. Averon may also send you an email to you at the email address, if any, you have provided to us or send you an SMS to the mobile number you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice of a security breach) you should notify us at info@averon.com.

Preventing Identity Theft

Averon is dedicated to protecting your personal information. We will never initiate a request for personal information from you by fax or email. Please do not send confidential personal information such as social security numbers, government identification numbers, or account numbers to Averon via an unsecured email message. You may send confidential information to Averon via posted mail, phone or contact us at info@averon.com. Do not be misled by emails that appear to be from us and ask for personal information. If you receive a suspicious email requesting your personal information, please forward the email immediately to info@averon.com. To report fraud to the Internet Fraud Complaint Center, visit www.ic3.gov. This is a partnership between The FBI and the National White Collar Crime Center.

Browsing

When you browse our websites or request pages, we automatically collect certain technical information about your visit. Examples of this standard type of information include the type of Internet browser you use, your IP address, browser headers, browser types (i.e. desktop or mobile), the files you request and the domain name and country from which you request information. We use this type of technical information to make our website function correctly, to better understand how visitors use our website and to improve the website, its contents and functionality to meet your needs. As part of our efforts to protect customers from fraud, this information is also used to assist in authenticating who you are when you access the website.

Cookies

Some of our web pages may contain “cookies,” or data that is sent to your web browser and stored on your computer. The purpose of these “cookies” is to allow our server to recognize you as an Averon user if you return to the website using the same computer and browser. In the event you do not wish to receive such cookies, you usually may configure your web browser to not accept cookies or to notify you if a cookie is sent to you. You are free to decline cookies if your web browser permits, but you may not be able to use all the features and the functionality of our websites. Averon does not link the information we store in cookies to any personally identifiable information you submit while on our website.

Privacy Practices of Third Parties

Averon is not responsible for the content or information practices employed by other websites that are linked to or from our website or which use Averon Services. In most cases where links are provided, they are provided as pointers to information on services that may be useful to users. These sites and other merchant sites providing mobile services that use Averon Services are governed by their own privacy statements. You are encouraged to review the privacy statement of these other websites before providing them with personal information.

Third Party Cookies

The use of cookies by our partners, related merchants and service providers is not covered by our privacy statement. We do not have access or control over these cookies. Our partners, related merchants and service providers may use session ID cookies to make it easier for you to navigate our site.

Use By Children

Averon will not knowingly collect personal information from children under the age of 13 without the consent of a parent or guardian.

Change in Privacy Statement

At Averon, your trust is one of our most important assets. We will continually work to protect the privacy of our customers and will continually review our privacy policy. Our website will always contain the most current privacy statement. If we decide to change our privacy practices, we will post those changes to this privacy statement, and/or to our home page, and/or to other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right to modify this privacy statement at any time, so please review it frequently. If we change how we use your personally identifiable information, we will notify you here, by email, or by means of a notice on our home page or related webpage.

International Users

By using our website and providing us with data, you acknowledge and agree that due to the international dimension of Averon we may use the data collected in the course of our relationship for the purposes identified in this policy or in our other communications with you, including the transmission of information outside your resident jurisdiction. Please note that your personal information will be stored and processed on our computers in the United States. The laws on holding personal data in the United States may be less stringent than the laws of your country. If you object to your personal information being transferred or used as described in this Policy, please do not register for the Service.

California Privacy Rights

California Civil Code section 1798.83 permits customers who are California residents to request certain information regarding disclosure of personal information to third parties for their direct marketing purposes. We do not provide your personal information to any third party for their direct marketing purposes without your consent. If you would like more information with respect to your privacy rights under California law, you may contact us at the contact point below. Please reference your request as “California Disclosure Information.”

Contacting Averon

Please also feel free to contact us if you have any questions. You may contact us at info@averon.com or at our mailing address below:

Averon US, Inc.
995 Market Street
2nd Floor
San Francisco, CA
94103