Last Updated: August 25, 2017
Effective: August 25, 2017
Our overarching mission is to build trusted connections online. Respect for people’s privacy and the protection of their data is a crucial pillar of trust building. This policy represents our commitment to your privacy and the respectful use of your data. That’s why it’s important to us that you understand how we collect, use and - in limited cases - share your personal data.
While we’ve tried to make this policy easy to follow and read, we understand that you may still have questions. If you do, you can contact us at firstname.lastname@example.org. We’re here to help.
- What This Policy Covers
- Our Data Collection Practices
- Your Privacy Choices
Other Privacy Information
- Data Security and Retention
- California’s ‘Do Not Track’ Law
- California Personal Information Disclosure: United States or Overseas
- California Information-Sharing Disclosure
- Children’s Information
- Our Privacy Commitment To Individuals In The EU and Switzerland
- Changes to this Policy
- Contact Information
What This Policy Covers
We offer a wide range of Services to employers, businesses, and individuals, including background check and identity verification services. For example, we provide:
- Criminal record, education, motor vehicle record, and credit screening services to employers for current and prospective employee background checks.
- Services for individuals to run employment background checks on themselves.
- Non-employment background checks and identity verification services for businesses that want to screen current or prospective users.
Depending on the Service you use, we may collect different information about you, and additional privacy terms, notices, and/or disclosures may apply to your use of the Services. This policy does not cover data collected by or through third-party websites or services.
Our Data Collection Practices
Information We Collect
In order to provide the Services, we collect personal information directly from our users, from our customers as part of providing our Services, from visitors to our Services, and from public records.
Collection Directly from Our Users
We collect information about users who create accounts with us:
- Creating an account. If you create an account, we ask you to provide some basic registration information such as your name and email address. If you're registering on behalf of a company, we may also ask you to provide some details about that company as well.
- Making a purchase. If you choose to make a purchase from us, we ask you to provide billing details such as credit card or ACH information.
- Commenting on a blog or report. If you leave a comment on a blog post, that comment will be publicly visible. If you choose to add annotations to your personal background report, your comment will be made available to anyone that you authorize to receive a copy of that report.
- Contacting us. If you contact our customer service team, we will collect your contact information, such as phone number or email address, as well as the contents of your communication. We may also collect additional information to help us better assist you, such as technical information about your browser or information about your account with us.
Collection When We Provide Services to Our Business Customers
We may need to collect personal information from you in order to provide Services to our business customers. For example, if you are the subject of a background check, or if a business customer requests that you verify your identity with us, we may collect some identifying information about you to make sure we're providing the right Services to you.
- Authorizing a background check. When you authorize one of our business customers to run a background check on you, we ask for your legal name, date of birth, and other identifying details such as your Social Security number, residential address, or past employment or educational history (depending on the type of background check requested). If the background check is authorized electronically, we also collect your email address and/or phone number.
- Verifying your identity. To run an identity verification check on you for an Inflection Risk Solutions business customer, we collect personal information from you so that we can confirm that you are who you say you are. This personal information could include your legal name, address, phone number, email address, Social Security number, financial or utility account information, or a government-issued photo ID document.
Collection from Third Party Sources
If you authorize us to create a background report about you, we'll collect public records and other information from reliable third-party sources to assemble the report. We may also verify information you provide us against authoritative government databases or information providers. If you are a business customer, we may also use reputable data providers like Salesforce, HubSpot, and LinkedIn to supplement the information you provide to us.
Collection When You Visit Our Websites
Inflection Risk Solutions makes use of tools such as cookies to collect various types of information about your activity and computer while you use the website of a Service. This information is only used to deliver and market the Services.
- If you visit our website, we will collect technical information from your browser, whether you have an account with us or not. This includes log data, which is automatically generated by your browser every time you request a webpage, and includes your IP address, browser User Agent, Referer, and the requested webpage. We might also request analytics data, which include cookies and third-party analytics tools like Google Analytics.
- We use tools by services such as Google Analytics and MixPanel to learn about how people discover, use, and interact with our website.
How We Use The Information We Collect From You
Your information is used to provide and improve the Services. That includes operating the website, remembering your preferences, conducting in-house research and development, preventing fraud or abuse, marketing products or services offered by us, our parent company, or by selected partners to you, and to communicate with you about your use of the Services and address your concerns.
When We Share Your Information
In limited circumstances, we share the information we collect from you.
- With your consent. We may share your information when you give us permission - for example, if you authorize us to share your background report with a platform or employer.
- De-identified and aggregated data. We may share or disclose information we collect after de-identifying and aggregating it so it cannot be linked back to an individual person. We contractually require third parties to respect this practice.
- Fraud and abuse prevention. We partner with certain third party vendors to prevent fraud and abuse. When you make a purchase, we analyze your payment information and unique device identifiers (including, but not limited to, IP address, MAC address, geographical location, browser and operating system settings) to identify suspected fraudulent activity and block it. We may share information associated with activity flagged as fraudulent (including, but not limited to, payment information, email addresses, and unique device identifiers) with our security partners or law enforcement.
- For legal process and emergency situations. We may be required to disclose or preserve for future disclosure your personal information if we believe, after due consideration, that doing so is reasonably necessary to protect Inflection’s rights or property or to comply with a law, regulation, valid legal process, or to prevent imminent and serious bodily harm to a person, and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you are a law enforcement officer seeking information from Inflection about one of our users, please reference our Law Enforcement Guidelines for further information.
Unless prohibited from doing so by law or court order, we will do our best to provide subjects – including candidates and applicants - of law enforcement requests with advance notice before we disclose their information to law enforcement, if we have contact information for that customer. We reserve the right to withhold advance notice where it would impede an investigation of identity theft, or in situations involving imminent physical harm or harm to minors.
Your Privacy Choices
Personal information and preferences can change. We understand that. That’s why we make it possible for you to update certain types of personal information we have about you.
Access, Update and Correct Your Information
You have the right to access your personal information. You may use your account to access, correct, or change any personal information that is associated with your account. You may also email our Privacy Team at email@example.com. if you have provided personal information to us but do not have an account, or if you wish to delete your account entirely. We will do our best to respond to your request within a reasonable timeframe.
Your Opt-Out and Communication Choices
We may send you information about our products, notices regarding your account, and other messages related to Inflection services, including marketing emails. You can unsubscribe by clicking on the unsubscribe link in those emails, emailing firstname.lastname@example.org with the email address you wish to unsubscribe, or calling 1-888-797-0104. Please note that you may still receive account and billing notices from us, if applicable.
Other Privacy Information
We follow industry-standard best practices to keep your data safe and secure. Inflection does not collect information from children under the age of 13, and does not share your information with third parties for their own marketing purposes. We also abide by Privacy Shield principles for transferring data to and from the EU, and Switzerland.
Data Security and Retention
Inflection retains all of the information we collect or that you submit for as long as your account is active, or is needed to provide you services, or for purposes including fraud prevention, legal compliance, dispute resolution, as well as for the enforcement of our agreements.
Your information is stored on secure servers in the United States. While we use acceptable industry-standard practices to protect your information, we cannot and do not guarantee that your information will be absolutely secure. Here are a few other steps we take to protect your information:
- We implement technical measures to prevent unauthorized access, and keep security patches and software up-to-date
- Employee access to your information is restricted and audited
- Sensitive personal information is stored in encrypted form
- All personal information is encrypted during transfer
California’s ‘Do Not Track’ Law
When you browse our website, we may use trusted third-party tools to analyze website usage, monitor performance, and prevent fraud. This website does not currently respond to browser settings such as Do Not Track. Third parties, such as our fraud prevention tools, may also collect personally identifiable information from you.
California Personal Information Disclosure: United States or Overseas
We do not transfer personal information to third parties outside of the United States or its territories during the preparation or processing of consumer reports, except to the extent that queries for public records are submitted to non-US government agencies and data providers.
California Information-Sharing Disclosure
We do not share your personal information with third parties for direct marketing purposes without your permission.
Our Services are not directed to individuals under the age of 18 and we do not knowingly collect personal information from children under the age of 13. If we discover that we have collected personal information on a child under the age of 13 via the Services, we will promptly remove it from our systems.
Our Privacy Commitment To Individuals In The EU and Switzerland
Inflection Risk Solutions, LLC
Attn: Privacy Team
P.O. Box 391403
Omaha, NE 68139
Inflection Risk Solutions, LLC has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint.
Under certain limited conditions, individuals may invoke binding arbitration before the Privacy Shield Panel, to be created by the U.S. Department of Commerce and the European Commission.
Data Collection And Sharing By Inflection
Your information is only used to provide the Services for you and others, which includes operating the website, remembering your preferences, conducting in-house research, preventing fraud or abuse, marketing products or services offered by us or by selected partners to you, and to communicate with you and address your concerns.
|Data That Inflection May Collect from You||Why Inflection Collects This Data||The Third Parties Inflection May Share Your Data With and Why|
Date of Birth
|To create your account on our website||Our service providers, but only to the extent necessary to provide services to you|
|Government-issued photo identification (e.g., a passport)||To verify your identity||Our identification verification service providers to prove you are who you say you are|
|Log Data (including your IP address, the type of browser you use, your device ID, and operating system)||To better understand how visitors use our website so that we can make improvements||Analytics Companies (such as Google Analytics and Mixpanel) for analytics purposes|
|Advertising Information||To help us decide how to buy ads elsewhere on the web||Advertising companies, to enhance advertising by Inflection (such as Google AdWords and DoubleClick)|
|Technical and Analytical Information||To learn about how people discover, use, and interact with our website||Analytics Companies (such as Google Analytics and Mixpanel) for analytics purposes|
Onward Transfer Of Data
We 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.
In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-U.S. Privacy Shield or Swiss-U.S. Privacy Shield, Inflection is potentially liable.
Inflection is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
Access And Choice
You have the right to access your data. Upon request, we will provide you with information about whether we hold any of your personal information. To access your data, please contact us at the information below, we will provide you with instructions on how you can go about doing so.
If you seek to access, or to correct, amend, or delete inaccurate data, please direct your query to Elizabeth McLean using the contact information below. If you request for us to remove your data, we will respond to you within a reasonable timeframe.
EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield Point of Contact
Elizabeth McLean, Compliance Counsel
Changes to this Policy
If you have any questions about this Policy, please contact us at 1-888-797-0104, email@example.com, or at the following mailing address:
Inflection Risk Solutions, LLC
Attn: Privacy Team
P.O. Box 391403
Omaha, NE 68139