Protecting Your Privacy


At Advarra, Inc. (“Advarra” or “we”), we are committed to protecting data and information that we gather from our customers, potential customers, prospects, and other end users of our online sites and services, including (collectively, all the websites to which this is posted, the “site”).

To make sure that your personal information is safe and secure, Advarra keeps and maintains privacy and security policies. We communicate our policies to our employees and contractors and strictly enforce our privacy safeguards within the company.

In general

This privacy policy (this “policy”) describes the information that we gather on or through the site, how we use and disclose such information, and the steps we take to ensure the protection of that information. This policy also applies to any information or communications made by individuals selling bitcoins through or to the site including by email (our “services”).

This policy is not intended to cover the access to, or use or protection of, information and data stored in Advarra’s licensed software products, including OnCore, Allegro, Advarra EDC, Insights, eReg, Payments, Benchmarks or EVAL, which are subject to the agreement between Advarra Tornado Cash and its customers. If you have any questions about whether this policy applies, you should contact your Advarra sales or support representative.

By using the site or our services, you accept the privacy practices described in this policy.

What information we collect and store about our end users of our online tools

As part of providing you useful tools, functionality, and information through the site and our services, we may collect different types of information. We collect, process, and store this information primarily for the purpose of providing you our services in accordance with the site terms of use , and which is further described in the “How we use your information” section of this policy.

In addition to information that we may collect with your consent, we collect the following sort of information in connection with the site and our services as described below:

User-supplied information.

By using our services or visiting the site, you may provide and we may collect personally-identifiable information.  Personally-identifiable information includes any information that can be reasonably used to identify a person, including names, address, phone numbers, or billing information. For example, if you sign up for our mailing list or online webinar through the site or our services, you may be asked to provide that information.

In addition, we may collect and store information that you voluntarily contribute to the site or services, such as when you reply to an email mailing list, post to one of the community forums, interact with other users of the site or our services, register for an account, or submit data or feedback to Advarra.

Automatically-collected information.

We may automatically record certain information you or your device using various types of technologies, including cookies, when you use our services or visit the site. This automatically-collected information may include IP address, web browser and/or device type, the webpages or sites visited (including referral information), and dates and times of when you accessed our services or visited the site. Automatically-collected information also includes information that is made available from third party platforms, such as Google and Facebook, who are authorized to provide that information. In general, the automatically-collected information is gathered from all visitors to the site or users of our services.

Information from third parties.

From time to time, we use software from third parties who may gather information from you in order to fulfill their purpose. These third parties may vary over time but include social networks and services providers. For instance, we may use third party companies to collect event registration information, accept payments online, and gather survey information. These services may have their own privacy policies and you should consult them. However, if we receive your information from them, then we will treat the received information in accordance with this policy.

We may keep any of the foregoing information for so long as we view it necessary and appropriate for our business purposes, which may be indefinitely. For personally-identifiable information, you may request that we update or delete that information as described in “Advarra as Information Controller/Processor” section.

How we use your information

We use the information we collect in a variety of ways. In general, we use information we collect in ways that we feel are necessary and appropriate in order to provide you our services, operate the site, and conduct our business, including the following ways:

Our business operations.

We use the information to operate, maintain, improve, deliver, and provide the features, functionality and information of the site and our services that you access, request or use. We use information to improve our products and personalize your experience with the site and our services. In addition, we may use the information to respond to your questions, address support concerns about the site or our services, and notify you of information concerning the site and our services.


We use the information we collect to communicate with you about the site, our services, or other Advarra products or product offerings. For example, you can subscribe to Advarra’s email mailing lists in order to receive information about upcoming webinars, educational materials, or Advarra products and services.

Personalization and analytics.

We use the automatically-collected information from cookies and similar technologies to enable many features of modern websites including to personalize the site and our services, keep you logged into the site or our services, provide customized content and information, monitor and analyze the performance of the site and our services, and improve the site and our services.

We may also use information from common web analytics platforms, such as Google Analytics, to measure and evaluate access to and traffic on the site. These analytics platforms, including Google, keep and maintain their own privacy policies, which we encourage you to review. Visit the following site for more information about Google’s privacy practices: Google Privacy Policy.

When you consent.

In addition to the foregoing, we may also use your information for the reasons that you have provided it to us. For example, if you submit your personal information in order to apply for a job with Advarra, we may use the information to evaluate you for employment with Advarra. If you have completed an online survey, we may use the information you submit for the purpose for which the survey was created.  If you contribute content to a forum or mailing list, we may post that information to the forum or mailing list.

If you submit personally-identifiable information to Advarra and consent to Advarra’s use, you may later withdraw that consent by contacting us, and we will attempt to comply if reasonable to do so.

Legal and compliance.

We may use any information you disclose in order to comply with our legal and regulatory obligations. As discussed below, we may be required to disclose that information as a result of legal or law enforcement processes.

To whom we share information

We do not sell your personally-identifiable data or information to any third parties.

And, except as described in this policy, we will not knowingly disclose any personally-identifiable information that we collect or store in connection with the site or our services to any third parties without your consent.

Public spaces.

If you post information, including personally-identifiable information, to an area accessible to other users or visitors of the website or which is addressed to mailing lists received by other users of the site or our services, that information will be available to other users of that service or visitor of that site who has access to it.

Service providers.

We use various third-party service providers to provide different services in order to enable the site or our services, including hosting and maintenance of the site or our services. These service providers may also be used to enable other features like online payment, event registration and email and marketing management. We attempt to limit these service providers to information and data reasonably required to perform their functions and fulfill their obligations to us.

Law enforcement.

We may disclose information to third parties if required to do so by law; if served or presented with a court order, subpoena, warrant, or similar governmental order; or if we have a good faith belief such disclosure is required in order to cooperate with law enforcement or other governmental agency. We may also disclose information to law enforcement or governmental authorities to extent we reasonably believe necessary to protect against undue risk or liability; protect against fraud, abuse or unlawful activities; protect the safety and security of the site or our services; to defend against any third-party claims; and/or protect Advarra’s rights or property or the rights and property of others.

Business partners.

We may share certain automatically-collected information and/or non-personally identifiable information with third parties for various business purposes including business and marketing, market and business analytics consulting, and compliance obligations.

The Advarra corporate family.

We may share information that we collect within our corporate family, including to our subsidiaries and parent companies, under the same conditions provided in this policy.

A change in ownership.

We may also share information we collect with any acquirer, successor or assignee of the Advarra as a result of any merger, acquisition, sale of assets or similar transactions or as the result of any bankruptcy or receivership.  In such case, the recipient of the information will be responsible for compliance with the terms of this policy.

Third party sites and services

The site and our services may link to third party websites and other services. Information that you provide to these third-party sites and services is provided to the owners and operators of those sites and services, not to Advarra, and will be subject to the terms of use and privacy policies of those sites and services.

Protection of personally identifiable information

We are concerned about the safety, security, and integrity of personally-identifiable information we collect and store. We have implemented, and maintain, commercially-reasonable and industry-standard administrative, technical and physical safeguards to protect your personally-identifiable information against unauthorized use and disclosure including: firewalls, SSL technology to encrypt data during transmission, and password protection and other authentication controls.

When personally-identifiable information is stored by Advarra, we keep the information on computer systems we own or manage that are protected in one or more of the following ways: the systems have limited access, the information is protected by passwords, or the information stored on encrypted disks.

However, we cannot guarantee the protection or secrecy of any information you post to open areas of the site or our services, like forums or email lists, which are accessible by other users and visitors. You should take care to guard private and personal details when using these features.

Advarra as Information Controller / Processor

Except as set out in this policy, Advarra is the “Processor” and “Controller” (as defined in the EU General Data Protection Regulation) of personally-identifiable information collected from the site and our services. The personally-identifiable information we collect is processed and stored on systems and servers operated in the United States that are owned, operated, or controlled by Advarra.

For information we control and process, you may contact us to request that (i) we provide you with a copy of your personally-identifiable information; (ii) we update, rectify, or correct your personally-identifiable information; and/or (iii) we delete copies of your personally-identifiable information. Within a reasonable time after that request, we will take reasonable steps to comply with your request to the extent feasible.

Required California privacy disclosures

Direct marketing.

We do not knowingly share personally-identifiable information with third-parties for direct marketing purposes.

Do Not Track.

We do not track visitors or users of the site or our services over time or across third party websites for the purposes of targeted advertising.  Therefore, we do not respond to do-not-track (DNT) signals.


We do not believe that the site or our services are directed to children under the age of 18 and we do not knowingly collect personally-identifiable information from children. If you are under 18 years of age, please do not use the site or our services. If we become aware of any personally identifiable information of a user under the age of 18, we will take reasonable steps to delete this information.


If you have any questions or concerns regarding Advarra’s collection, use or disclosure of information under this policy; or if you would like to make a complaint about, or notify Advarra of, a possible breach of local privacy laws, please contact us. You can always contact Advarra at 608-826-6000 or 1200 John Q. Hammons Dr., Madison, WI 53593.


We may update this policy from time to time. When we change the policy in a material way, we will post a notice to our website along with a link to the new policy.


Last modified November 9, 2020