Privacy Policy

EU-U.S. Privacy Framework Principles / Swiss-U.S. Data Privacy Framework Principles

Introduction

The Verify Group of Companies (Verify, Inc., Vendor Surveillance Corporation (VSC), VTR Inc., Verify Europe Ltd., VTR (UK) Staffing Ltd., Verify Canada Ltd., Verify Asia, and Verify Deutschland) (“Company”, “we”, “us”, or “our”) complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework program (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce.  Verify, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF.  [INSERT your organization name] has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework program Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Verify, Inc. complies with the EU-U.S. Data Privacy Framework program (EU-U.S. DPF) as set forth by the U.S. Department of Commerce. Verify, Inc. has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework program Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF.  If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Scope

This Data Privacy Framework Program applies to all Personally Identifiable Information (PII) collected by Verify subsidiaries; including Vendor Surveillance Corporation, VTR, Inc., Logistech, its contractors, customers, and other business partners located in the European Economic Area (the EEA), United Kingdom (UK) and Switzerland, which is then transferred to Verify in the United States.  This includes, but is not limited to, transmission of data over phone lines, computer networks, and hard copy and includes such material as payroll or remittance records, telephone and contact records, business information, interviews and performance evaluations, contact details, results of permitted background and medical checks, resumes/CVs, bank accounts, and any material that identifies a particular individual employee, contractor, customer, or business partner in support of Verify service activities.

Responsibilities and Contact

In implementing this policy, Verify will annually certify to the US Department of Commerce that it agrees to adhere to the Data Privacy Framework Program.  Verify further acknowledges that its failure to provide an annual self-certification to the US Department of Commerce will result in the removal of Verify from the list of participants.

Questions regarding the transmission of PII from the EEA, UK or Switzerland to the United States or any other non-EEA country, or any further transmission of the PII once received in the United States, should be referred to Verify’s Quality, Compliance and Administration department, at:

  • Phone: +1-949-335-9120
  • Mail: Verify – Quality, Compliance and Administration
    3100 Bristol Street, Suite 200 Costa Mesa, CA  92626
  • E-mail: compliance@vscnet.com

Policy

Verify’s Privacy Policy is based on the principles of notice, choice, onward transfer, access, security, data integrity and enforcement with respect to PII and other sensitive data transferred out of the EEA or Switzerland to the United States or any other location.

  • Verify will notify employees, contractors, customers and other business partners in the EEA/UK/Switzerland about type(s) and purpose(s) for which personal data will be collected and used.  Information will be provided on how individuals can contact Verify with inquiries or complaints regarding personal data.  Verify will notify employees, contractors, customers, and other business partners of any third parties to which it discloses PII, and restrictions that limit the use and disclosure of such information.
  • Choice. Prior to using PII for any purpose incompatible with the purpose for which it was originally collected or subsequently authorized or transferred to a third party exercising independent control over the data, Verify will give an individual employee, contractor, customer or business partner the opportunity to decline to have their data so used or transferred.  In the event that the PII used for a new purpose or transferred to the control of a third party are sensitive personal data, the individual’s explicit consent will be obtained prior to the use or transfer of the PII.
  • Onward Transfer. Prior to transferring PII to any third party (excluding other members of the Verify group of companies), Verify will apply the Notice and Choice principles described above and will ensure that the third party recipient also subscribes to Data Privacy Framework.  Verify will further enter into a written agreement with such third party requiring that the third party provide at least the same level of PII protection as is maintained by Verify.

In cases of onward transfer to third parties of data of EU, UK or Swiss individuals received pursuant to the Data Privacy Framework, Verify, Inc. is potentially liable.

  • Access. Verify acknowledges the individual’s right to access their data to review, edit, correct, or delete it.  Employees, contractors, customers and business partners covered under this Policy will have access to PII about them that Verify holds and will be able to correct, amend or delete information if it is inaccurate, excepting cases wherein the burden or expense of providing access would be disproportionate to the risks of the individual privacy in the case in question or the rights of persons other than the individual would be compromised or violated.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct their query to the contact information listed above.
  • Security. Verify will take reasonable and appropriate administrative, technical and physical precautions to protect the confidentiality, integrity, and availability of PII, whether in electronic or tangible, hard copy form.  Access to PII of EU/UK/Swiss employees, contractors, customers and business partners will be limited to those users who require such access in the course of doing business.
  • Data Integrity. Verify limits the collection, usage, and retention of information to that which is germane for the intended purposes for which it was collected, and takes reasonable steps to ensure that all PII is reliable, accurate, complete and current.
  • Enforcement. To ensure compliance with these Data Privacy Framework principles, Verify will:
    • Commit to cooperate with the Data Protection Authorities (DPAs) of the EU/UK/Switzerland in the investigation and resolution of complaints and will comply with any advice given by the DPAs;
    • Employ a procedure for verifying that the commitment the company has made to adhere to the Data Privacy Framework principles has been implemented;
    • Remedy issues arising out of any failure to comply with the principles;
    • Subject to any investigatory and enforcement powers enacted by the Federal Trade Commission (FTC);
    • Conduct compliance audits of its relevant privacy and security practices to verify adherence to this Policy;
    • Subject any employee determined to be in violation of this policy to disciplinary action, up to and including termination of employment.

Dispute Resolution

The Verify Quality, Compliance and Administration department will be the internal organization and mechanism for ensuring compliance with the Data Privacy Framework principles and facilitating the internal compliance audits referenced above.  Any questions or concerns regarding the use or disclosure of PII should be directed to the Quality, Compliance and Administration organization at the contact address, phone number, or website provided above.  Verify will investigate and attempt to resolve complaints and disputes regarding use and disclosure of PII by reference to the principles contained in this Policy.  For complaints that cannot be resolved between Verify and the complainant, Verify will participate in the following dispute resolution procedures:

  • In compliance with the EU-US Data Privacy Framework Principles, Verify, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to the DPF Principles.  European Union, Swiss and United Kingdom individuals with DPF inquiries or complaints should first contact the following:
  • Verify, Inc. has further committed to refer unresolved privacy complaints under the DPF Principles to an independent dispute resolution mechanism, Data Privacy Framework Services, operated by BBB National Programs. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/programs/all-programs/dpf-consumers/ProcessForConsumers  for more information and to file a complaint. This service is provided free of charge to you.
  • If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms.  See https://www.dataprivacyframework.gov/s/article/G-Arbitration-Procedures-dpf?tabset-35584=2
  • In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Verify, Inc. commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.

Limitation of Application of Principles

Verify adheres to these privacy principles except (a) as required or allowed by law; (b) to meet legal, governmental, law enforcement or national security obligations; or (c) to protect the health and safety of an individual.

NOTE:  Verify, Inc. may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Changes

This policy may be changed from time to time.  When updates are made, the “Last Updated” date at the bottom of this document will be updated appropriately.  This Policy will be posted on Verify’s website (www.verifyglobal.com) and remain publicly available at all times.

General Data Protection Regulation (GDPR)

Thank you for choosing to be part of our community at The Verify Group of Companies (Verify, Inc., Vendor Surveillance Corporation (VSC), VTR Inc., Verify Europe Ltd., VTR (UK) Staffing Ltd., Verify Canada Ltd., Verify Asia, and Verify Deutschland) (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at compliance@vscnet.com.

When you visit and use our website www.verifyglobal.com, you trust us with your personal information. We are committed to your privacy. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website (such as www.verifyglobal.com), and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the “Sites”).

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us. 

WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when registering at the Sites expressing an interest in obtaining information about us or our products and services, when participating in activities on the Sites or otherwise contacting us.

The personal information that we collect depends on the contact of your interaction with us and the Sites, the choices you make and the product and features you use. The personal information we collect can include the following:

Name and Contact Data

We collect your first and last name, email address, postal address, phone number, and other similar contact data.

Credentials

We collect your passwords, password hints, and similar security information used for authentication and account access.

Payment Data

We collect data necessary to process payments, such as your payment instrument number (which may include credit card numbers and bank account numbers). All payment data is stored by our payment processor and you should review its privacy policies and contact the payment processor directly to respond to your questions.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

We automatically collect certain information when you visit or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you user our Sites and other technical information. This information is primarily needed to maintain the security and operation of our Sites, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

Information collected from other sources

We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings.

HOW DO WE USE YOUR INFORMATION?

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interest (“Business Purpose”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal relations”). We indicate processing grounds we rely on next to each purpose listed below.

We use the information we collect receive:

  • To facilitate account creating and logon process with your Consent. If you chose to link your account with us to a third party *(such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process.
  • To send you marketing and promotional communications for Business Purpose. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing email at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
  • To send administrative information to you for Business Purposes, legal Reasons and/or possible for Contractual. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions and policies.
  • Request feedback for our Business Purposes and/or with your consent. We may use your information to request feedback and to contact you about your use of our Sites.
  • To protect our Sites for Business Purposes and/or for Legal Reasons. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual.
  • To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites, products, services, marketing and your experience.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share and disclose your information in the following situations:

  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental request, a judicial proceeding, court order, or legal process, such as in response to a court order or subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
  • Vendors, Consultants and Other Third Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes.
  • We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and subsidiaries, joint venture partners or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
  • With your Consent. We may disclose your personal information for any other purpose with your consent.
  • Other Users. When you share personal information or otherwise interact with public areas of the Sites, such personal information may be viewed by all users and may be publicly distributed outside the Sites in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Sites, and view your profile.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We and our third parties automatically collect certain information through cookies and similar technologies when you visit or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you user our Sites and other technical information. This information is used to maintain the security and operation of our Sites, generate internal analytics and reporting, analyze trends, administer the Website, track users’ movements around the website, and to gather demographic information about our user base as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or services.

DO WE USE GOOGLE MAPS?

This website, mobile application, or Facebook application uses Google Maps APIs. You may find the Google Maps APIs terms of service here. To better understand Google’s privacy policy, please refer to this link.

By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

Our servers are located in United States. If you are accessing our Sites from outside United States, please be aware that your information may be transferred to, stored, and processes by us in our facilities and by those third parties with whom we may share your personal information.

If you are a resident in the European Economic Area, then these countries may not have data protection or other laws as comprehensive as those in your country. We will however take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law. No purpose in this policy will require us keeping your personal information longer than required per established regulations and contractual obligations.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.

HOW DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly solicit data from, or market to, children under 16 years of age. By using the Sites, you represent that you are at least 16 years of age or that you are the parent or guardian of such minor and consent to such minor dependents use of the Sites. If we learn that personal information from users less than 16 years of age has been collected we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 16, please, contact us at compliance@vscnet.com

WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with the applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are a resident in the European Economic area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log into your account setting and update your user account
  • Contact us using the contact information provided

Upon your request to terminate your account, we will deactivate or delete your account and information from our active database. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our terms of Use, and/or comply with legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Sites.

Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration.

  • Access your account settings and update preferences.
  • Contact us using the contact information provided.

DO WE MAKE UPDATES TO THIS POLICY?

We may update this privacy policy from time to time. The updated version will be indicated by a “Last Updated” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), by email at compliance@vscnet.com, by phone at +1 949-335-9120 or +1 888-400-3024, or by post to:

The Verify Group of Companies
3100 Bristo Street, Suite 200
Costa Mesa, CA  92626
United States

If you are a resident in the European Economic Area, the “date controller” of your personal information is The Verify Group of Companies. We have appointed a local Data Protection Officer to be its representative in the EEA. You can contact them directly regarding the processing of your information by email at compliance@vscnet.com, or by post to:

The Verify Group of Companies
25 Shirwell Crescent
Furzton, Milton Keynes
Buckinghamshire MK4 1GAD
United Kingdom

CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

Thank you for choosing to be part of our community at The Verify Group of Companies (Verify, Inc., Vendor Surveillance Corporation (VSC), VTR Inc., Verify Europe Ltd., VTR (UK) Staffing Ltd., Verify Asia, and Verify Deutschland) (“Company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices in regards to your personal information, please contact us at compliance@vscnet.com.

For individuals located in California, the California Consumer Privacy Act (“CCPA”) (Civil Code § 1798.100, et seq.) provides you with specific rights regarding your Personal Information depending on the nature of your relationship with us.

When you visit and use our website www.verifyglobal.com, you trust us with your personal information. We are committed to your privacy. In this privacy notice, we describe our privacy policy. We seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to it. Please carefully review this important information. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our Sites and our services.

This privacy policy applies to all information collected through our website (such as www.verifyglobal.com), and/or any related services, sales, marketing, events, or communications (we refer to them collectively in this privacy policy as the “Sites”) over the past twelve (12) months.

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.

WHAT INFORMATION DO WE COLLECT?

We collect personal information that you voluntarily provide to us when registering at the Sites expressing an interest in obtaining information about us or our services, when participating in activities on the Sites, or otherwise contacting us.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

The personal information that we collect depends on the context of your interaction with us and the Sites, the choices you make, and the services and features you use. The personal information we collect can include the following:

Name and Contact Data

We collect your full name, email address, postal address, phone number, and other similar contact data.

Credentials

We collect your username, password, password hints, IP address, general geolocation, and similar security information used for authentication and account access.

Payment Data

We collect data necessary to process payments, such as your payment instrument number (which may include credit card numbers and bank account numbers), social security number, and federal tax identification number.

Payment data is further stored by our payment processors and you should review their respective privacy policies and contact the payment processors directly to respond to your questions. You may contact The Verify Group of Companies for a list of payment processors.

Contract or Employment Data

We collect data necessary to determine eligibility and facilitate onboarding for independent contract and employment opportunities, and this can include government-issued identification (such as driver’s license, social security number, passport, certificate of naturalization, or visa), medical records (such as disability, health insurance, health providers, eye exams, or drug screening), date of birth, marital status, authorized background check, educational history, employment history, citizenship, birth certificate, certificate of naturalization, information required by the US Equal Employment Opportunity Commission (such as race, ethnicity, veteran status, or gender). 

Information automatically collected

We and our third parties automatically collect certain information through cookies and similar technologies when you visit or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you user our Sites, and other technical information. This information is used to maintain the security and operation of our Sites, generate internal analytics and reporting, analyze trends, administer the Website, track users’ movements around the website, and to gather generalized demographic information about our user community as a whole. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or services.

Information collected from other sources

We may obtain information about you from other sources, such as public databases, joint marketing partners, denied parties lists, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information, marketing leads, search results and links, and paid listings.

We do not knowingly solicit data from, or market to, children under 16 years of age. By using the Sites, you represent that you are at least 16 years of age or that you are the parent or guardian of such minor and consent to such minor dependents use of the Sites. If we learn that personal information from users less than 16 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 16, please, contact us at compliance@vscnet.com.

HOW DO WE USE YOUR INFORMATION?

We use personal information collected via our Sites for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interest (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal relations”).

We use the information we collect and receive:

  • To facilitate account creation and login with your Consent.
  • To send you marketing and promotional communications for our Business Purposes. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing email at any time.
  • To send administrative information to you for Business Purposes, legal reasons, or Contractual reasons. We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.
  • To request feedback for our Business Purposes with your consent. We may use your information to request feedback and to contact you about your use of our Sites.
  • To protect our Sites for Business Purposes and/or for Legal reasons. We may use your information as part of our efforts to keep our Sites safe and secure (for example, for fraud monitoring and prevention).
  • To enforce our terms, conditions, and policies for Business Purposes, Legal Reasons, and/or Contractual reasons.
  • To respond to legal requests and prevent harm for Legal reasons. If we receive a subpoena or other legal request, we may need to inspect the data we collect.
  • To support other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Sites, products, services, marketing, and your experience.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share and disclose your information in the following situations:

  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental request, a judicial proceeding, court order, or legal process, such as in response to a court order or subpoena (including in response to public authorities to meet national security or law enforcement requirements).
  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

Vendors, Consultants, and Other Third Party Service Providers.

We may share your data with third party vendors, service providers, and contractors or agents who perform services for us or on our behalf and require access to such information to perform that work for Business Purposes. Examples include name and contact data, credentials, payment data, and contract or employment data for payment processing, contract or employment screening, data analysis, email delivery, hosting services, customer service, and marketing efforts. You should review their respective privacy policies and contact them directly to respond to your questions. You may contact The Verify Group of Companies for a list of third parties.  We may allow selected third parties to use tracking technology on the Sites, which will enable them to collect data about how you interact with the Sites over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. Unless described in this Policy, we do not share, sell, rent, or trade any of your information with third parties.

  • We may share your information with our affiliates whom are subject to this privacy policy. Affiliates include our parent company and subsidiaries, joint venture partners, and other companies that we control or that are under common control with us. 
  • Business Partners. We do not sell but may share your information with our business partners to offer you certain products, services, or promotions.
  • With your Consent. We may disclose your personal information for any other purpose with your consent.
  • Other Users. When you share personal information in public areas of the Sites, through directly- linked social media sites, or otherwise interact with public areas of the Sites, such personal information may be viewed by all users and may be publicly distributed outside the Sites in perpetuity. Similarly, sharing personal information publically may allow other users to be able to view descriptions of your activity and communications and view your profile.

DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookie and similar tracking technologies (like web beacons and pixels) to access or store information as outlined in this policy.

DO WE USE GOOGLE MAPS?

The Sites use Google Maps APIs. By using our Maps API Implementation, you agree to be bound by Google’s Terms of Service. Please refer to the Google privacy policy for more information.  www.google.com/policies/privacy/partners/.

YOU HAVE THE FOLLOWING RIGHTS AS OUTLINED BELOW:

  • Right to be informed about collection, use, sale, or disclosure:  You have the right to be informed of the categories of Personal Information that we collect about you as well as the categories of sources from which the Personal Information was collected. You also have the right to be informed of the business or commercial purposes for which we use, disclose or share your Personal Information as well as the categories of third parties with whom we share that Personal Information with.
  • Right to access and obtain a copy of your Personal Information:  You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your Personal Information two times over the past twelve (12) months. Once we have verified your identity, we will provide you a copy of your personal information in a portable and readily useable format.
  • Right to delete:  You may have the right to request that your Personal Information is deleted, subject to certain exceptions.
  • Right to opt-out of the sale of Personal Information:  We do not sell personal information or those of minors for any purpose.
  • Right to not be discriminate against for exercising your privacy rights:  We will not discriminate against you when you exercise your privacy rights under the California Consumer Privacy Act.

To exercise your rights or if acting as a third party and/or agent, submit your request using any of the following available methods:

Compliance Team
3100 Bristol Street, Suite 200
Costa Mesa, CA  92626
United States

We will need to confirm your identity and California residency to process your requests to exercise your information, access, or deletion rights. We cannot process your request if you do not provide us with accurate or sufficient detail to allow us to understand and respond to it. Information requested will be dependent on the nature of the business between yourself and us, and may include your full name, email address, contact phone number, and postal address. We will compare the information you provide against the information we have on file to confirm your identity and California residency. We may contact you if the information provided does not match our files to allow us to confirm your identity and California residency.

If you have questions about this policy, you may contact us by email at compliance@vscnet.com, by phone at +1 (888) 400-3024, or by post to:

The Verify Group of Companies
Compliance Team
3100 Bristol Street, Suite 200
Costa Mesa, CA 92626
United States

This policy may be changed from time to time.  When updates are made, the “Last Updated” date at the bottom of this document will be updated appropriately.  This Policy will be posted on Verify’s website (www.verifyglobal.com) and remain publicly available at all times.

Last Updated: September 15, 2023