Independent Contractor Privacy Policy

Effective Date: 26 September 2025

This Independent Contractor Privacy Policy (“Contractor Policy”) applies to California and international independent contractors’ personal information collected by Checkr, Inc. and its family of companies (“Checkr,” “us,” “we,” or “our”). Although laws differ in how they define “personal information,” we use the term here to mean information that identifies or reasonably could identify you. Examples could include your name, email, and phone number.

If you are offered and accept a position with Checkr as an employee, the use of this personal information will be governed by our internal Employee Privacy Policy and employee handbook. At that point, this Contractor Policy will no longer apply.

If you are an independent contractor based outside the United States, please review our International Independent Contractor Privacy Policy. That policy supplements this Contractor Policy and provides additional details required by certain non-US jurisdictions, such as the European Union and the Philippines.

1. Where We Collect Personal Information

We may collect personal information from the following sources:

Information you provide to us directly, such as information you provide when invoicing Checkr;
Information we collect or receive from others, such as referrals or feedback from customers; and
Publicly available sources, such as LinkedIn.
Information we infer from security systems, such as firewall or intrusion-detection logs collected when logged into the company network.

2. Personal Information We Collect

We may collect (and may have collected in the 12 months before this Contractor Policy was last updated) the following categories of personal information.

Personal Information Categories	Examples of Personal Information We Collect
Identifiers and associated information	Name Date of birth Address Phone number Email Social security number Electronic signature Photograph Country Call transcripts Insurance policy number Tax information, such as W-9 and W-8BEN information IP address
Personal information under the California Customer Records Act	Name Date of birth Address Phone number Email Tax information, such as W-9 and W-8BEN information Social security number Electronic signature Photograph Country Insurance policy number Bank name Bank code Branch number Routing number Account number Account type BIC code/SWIFT code
Protected characteristics	Age if your provide your date of birth Gender if you voluntarily disclose your pronouns in, for example, your Slack profile
Biometric information	Facial measurements for those working at a Checkr office
Internet activity	IP addresses Login credentials User and device identity, including IP addresses Device type Device information Browsing history Connection details Firewall and security logs Physical location VPN client logs Timestamps and similar information
Precise Geolocation	IP address, WiFi access points, and other information that is used to infer geographic location when you are logged into Checkr’s network using an unmanaged device.
Audio, visual, or similar information	Call recordings for certain activities, such as customer support Video conference recordings CCTV footage Screen recordings for certain activities, such as candidate support
Professional and employment-related information	Occupation Title Vendor with whom you are employed Licenses Professional memberships Business background check report information
Inferences	Suspicious network behavior Excessive downloading patterns Anomalous login pattern Productivity metrics for agents
Sensitive personal information	Facial measurements for those working at a Checkr office Social security number

3. Purposes for Collecting Personal Information

We may use personal information for the following purposes.

Personal Information Categories	Why We Collect and How We Use Personal Information
Identifiers and associated information	Creating and maintaining your independent contractor account Fulfilling requests and obligations related to our partnership Contract lifecycle management, invoice management, and payment to independent contractors Auditing and monitoring of transactions and engagement Workplace safety, fraud prevention, security, and protection of property Business analyses, such as analytics, projections, identifying areas for operational improvement Improving and developing our products and services Research, development, and training opportunities Complying with applicable laws and regulatory guidance
Personal information under the California Customer Records Act	Creating and maintaining your independent contractor account Fulfilling requests and obligations related to our partnership Contract lifecycle management, invoice management, and payment to independent contractors Auditing and monitoring of transactions and engagement Workplace safety, fraud prevention, security, and protection of property Business analyses, such as analytics, projections, identifying areas for operational improvement Research, development, and training opportunities Improving and developing our products and services Complying with our contractual obligations with third parties, such as providing certain independent contractors’ certificates of insurance to landlords Complying with applicable laws and regulatory guidance
Protected characteristics	Creating and maintaining your independent contractor account Auditing and monitoring of transactions and engagement Workplace safety, fraud prevention, security, and protection of property Business analyses, such as analytics, projections, identifying areas for operational improvement Research, development, and training opportunities Complying with applicable laws and regulatory guidance
Biometric information	Workplace safety, fraud prevention, security, and protection of property
Internet activity	Auditing and monitoring of transactions and engagement Workplace safety, fraud prevention, security, and protection of property Complying with applicable laws and regulatory guidance
Precise Geolocation	Workplace safety, cybersecurity, fraud prevention, and protection of property Workplace management Enforcing workplace policies
Audio, visual, or similar information	Auditing and monitoring of transactions and engagement Workplace safety, fraud prevention, security, and protection of property Business analyses, such as analytics, projections, identifying areas for operational improvement
Professional and employment-related information	Auditing and monitoring of transactions and engagement Workplace safety, fraud prevention, security, and protection of property Business analyses, such as analytics, projections, identifying areas for operational improvement Improving and developing our products and services Research, development, and training opportunities Complying with applicable laws and regulatory guidance
Inferences	Auditing and monitoring of transactions and engagement Workplace safety, fraud prevention, security, and protection of property Complying with applicable laws and regulatory guidance
Sensitive personal information	Workplace safety, fraud prevention, security, and protection of property Complying with applicable laws and regulatory guidance

4. Disclosure of Personal Information

We may disclose (and may have disclosed in the 12 months before this Contractor Policy was last updated) personal information to the following entities.

Personal Information Categories	With Whom Might We Share This Information
Identifiers and associated information	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Personal information under the California Customer Records Act	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Protected characteristics	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Biometric information	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Internet activity	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Precise Geolocation	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Audio, visual, or similar information	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Professional and employment-related information	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Inferences	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction
Sensitive personal information	Vendors, including landlords Affiliates Advisors, such as lawyers and consultants Regulatory and legal authorities Entities relevant to legal proceedings Entities in connection with a merger, sale of assets, bankruptcy, or similar transaction

5. Retention of Personal Information

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Once the retention period expires, we securely delete or anonymize your information.

6. Your Privacy Rights

The rights you have regarding your personal information depend on where you live. If you live outside the United States, such as the EU, EEA, UK, Switzerland, or the Philippines, you can learn about what rights you might have in our International Independent Contractor Privacy Policy.

6.1 What Rights You Might Have in California

General Information

If you live in California, the CCPA can provide independent contractors the following rights, subject to some exceptions:

The right to request access to the information we hold about you, including details about how we process your personal information.
The right to request deletion of your personal information.
The right to correct your personal information.
The right to opt out of the sale or sharing of your personal information.
The right not to be discriminated against based on your exercise of any of the rights described in this Section 6.1.

Limitations

The CCPA exempts certain types of information and processing activities from its coverage, particularly publicly available information and personal information processed as part of the background check process. To learn more about these exemptions, please read Section 1.4 of our Privacy Policy.

Sensitive Information

Under the CCPA, California residents can ask businesses to limit the use and disclosure of their sensitive personal information if those businesses are using that information for purposes beyond those designated by the CCPA. Examples of such designated purposes include providing a service requested by the consumer and fraud prevention. We do not use or disclose sensitive personal information subject to the CCPA in ways that would require us to offer the right to limit. For that reason, we are not required to provide that right.

Selling and Sharing Information

Although the CCPA gives you the right to opt out of the “sale” of your personal information, we do not “sell” your personal information, as that term is defined in the CCPA. As part of our engagement of independent contractors, we do not “share” personal information for “cross-context behavioral advertising,” as those words are defined in the CCPA.

If, however, you visit our website open to the public, such as our homepage, we might share your personal information collected during your visit to those parts of the website for cross-context behavioral advertising. Such information might include your IP address, cookie IDs, and timestamps. To learn about how to opt out of that sharing, please read our Privacy Policy. There, you will also find information about how Checkr treats Global Privacy Control (GPC) signals and how to enable them from your browser.

6.2 Exercising These Rights

To the extent required by applicable law, Checkr will help you exercise the above rights for free. To exercise these rights, please contact us at dpo@checkr.com. When you make a request to exercise your rights, we will verify your identity by asking for information that matches our records. This may include your name, contact information, and details about your relationship with us.

If you would like an authorized agent to make a privacy rights request on your behalf, we may ask for written, signed permission that the agent has been authorized to act on your behalf. Once the written authorization is provided, we will review your request and respond in accordance with applicable law.

7. Protection of Personal Information

Checkr has adopted physical, technological, and administrative safeguards to help protect the security and privacy of the information we have about you. Such safeguards include encryption, multi-factor authentication, and other proactive security measures to help protect your information against unauthorized access and disclosure. That said, no system is completely secure. We therefore cannot guarantee the security of any information we process during your engagement as Checkr’s independent contractor.

8. Use of Third-Party Providers

We might provide access to third-party applications and systems necessary for you to perform services for Checkr. That said, this Contractor Policy does not apply to your use of those applications or systems. We recommend that you review their privacy policies since they might be different from ours. Checkr is not responsible for their privacy or data security practices or policies.

9. Children

Checkr does not engage children under the age of 16 as independent contractors, nor does it knowingly collect personal information from them in connection with contractor assignments.

10. Changes to This Contractor Policy

Checkr may change this Contractor Policy at any time. We will post any changes on this webpage and update the “Last Updated” date at the beginning of this Contractor Policy to reflect the date of those changes. We recommend that you review this webpage periodically to stay informed of any changes. To the extent required by applicable law, we will provide a prominent notice of material changes and the effective date of the changes before making them. For example, we might include a notice on the Site or email you about the material change.

11. Contact Information

If you have a question or complaint about Checkr’s privacy practices, you can contact us at the following:

Checkr, Inc.
Attn: Privacy Questions
1 Montgomery St
San Francisco, CA 94104
hello@checkr.com

For a faster response, we recommend contacting us at the above email rather than through other methods.

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