CHECKR, INC PRIVACY POLICY

Effective Date: May 12, 2020

Spanish Privacy Policy: https://checkr.com/spanish-privacy-policy

This Privacy Policy (“Policy”) describes how Checkr, Inc. (“Checkr” or “we” or “our”) treats information collected or provided in connection with your visit to or use of the website located at https://checkr.com (“Website” or “Site”) and Checkr’s products and services (the “Services“). Please note that your use of the Site and Services constitutes your acceptance of and consent to this Policy.

We believe privacy policies should be transparent, accessible and help you find the information you need. Because Checkr has different types of users, the information we collect and how we use it will depend on how you interact with us. For ease of use, our Policy divides answers to questions based on the type of user. See the definitions below to determine which type of user you are:

• Consumers: Consumers are individuals Checkr has received information about for the purpose of Checkr performing requested Services. This information may come directly from the Consumer or indirectly through one of our partners or affiliates.  
• Customers: Customers are organizations or individuals that utilize the Checkr Site or Services in the course of their business.  
• Site Visitors: Individuals accessing our Website are Site Visitors. Site Visitors can be individuals who are simply browsing the Website; or Consumers or Customers who visit the Websites to seek additional information about Checkr.  

With the type of user in mind, you can navigate our Privacy Policy through the Table of Contents below.

Table of Contents

1. What information does Checkr collect through the Services?
2. How does Checkr use the collected information?
3. When does Checkr share collected information?
4. How can you access, change, or delete information about you?
5. Will you receive notices and disclosures electronically?
6. Does this Policy apply to third parties or third party links?
7. What choices do you have about online tracking, analytics, and email communications from Checkr?
8. How does Checkr protect your information?
9. International Considerations
10. Who can use the Services?
11. Changes to the Privacy Policy
12. How can you contact Checkr with more questions?

1. What information does Checkr collect through the Services?

Consumer Information
Certain information collected by Checkr relates directly to the Consumer. This includes both personal information necessary to perform the Services as well as analytics from using the Site or Services as described below:

Personal information: Certain Services require the collection of Consumers’ personal information (i.e. to perform a requested background check or perform evaluative services on behalf of Customers). This information may include:

• Identifying information, including name, date of birth, and government issued identification numbers such as Social Security number, passport number, and drivers license or permit numbers;
• Contact information, including phone number, email and postal address;
• Education and professional training information, including degrees, certifications, academic records, qualifications, skills and achievements;  
• Employment information, including previous employers, roles and employee record information;
• Financial information, including income, salary, billing rate, payments, and benefits;  
• Additional information or supporting documentation you provide in connection with the Services, including your communications with Checkr.

Personal information may also be collected by Customers and transferred to Checkr for the purpose of conducting the Services. For example, Consumers may be offered Services by Customers directly where personal information is collected and stored by the Customer pursuant to their own policies and then transferred to Checkr to facilitate Services. Checkr may also receive personal information about Consumers from third parties as described in Third Party Information below.

• Automatically Collected Information: When Consumers visit the Site or use the Services, we automatically gather certain technical and usage information, which may be associated with your account or profile. automatically.

Customer Information
Certain information collected by Checkr relates to the Customer and their use of the Services. This includes account information necessary to perform requested Services and analytics from using the Site or Services as described below:

Account Information: When Customers create accounts and request Services from Checkr, the collection of certain information is necessary to facilitate those Services:

• Contact information, including business name, address and phone number;
• Incorporation and business licensing information, including Employer Identification Number;
• Customer evaluation criteria and standards, including job titles and duties, expected salaries, work and access locations, certain evaluation standards prior and subsequent to engagement;  
• Account and user credential information, including name, email, roles and associated permissions;
• Status and instructions for requested Services, including deactivation of Consumer or user credentials;
• Payment information, including credit card and/or bank account information and billing address. Please note, we do not store the credit card or bank account numbers you may use to make payments in the Services.

Account information and user credentials may also be collected by third parties and affiliates of Checkr. For example, Checkr Services may be offered on third party marketplace platforms.

• Automatically Collected Information: When Customers visit the Site or use the Services, we automatically gather certain technical and usage information, which may be associated with your account. For more information See Automatically Collected Information below.

Third Party Information
Certain Services require the collection of information from third parties. Third party information may relate to either Consumer or Customers and includes both public and private records as described below:

• Public Records: Checkr may collect public records bearing on an individual or business entity, including civil and criminal court records and documentation, business filings, and public media articles.
  
• Private Records: Where appropriately authorized, Checkr may obtain private records, including educational, employment, financial, and health records.

Site Visitor Information
Certain information may be collected when individuals visit the Site. This includes both manually submitted and automatically collected information:

• Submitted information: Site Visitors may have opportunities to submit information directly to Checkr, including contact requests and in browser chat with Checkr agents. Site Visitors may be asked to provide Checkr with basic information including name, email address and general business information. Checkr may maintain records of communications submitted through the Site.
  
• Automatically Collected Information: We automatically gather certain technical and usage information, which may be associated with submitted information. See Automatically Collected Information below.

Automatically Collected Information
When Consumers, Customers or Site Visitors visit the Site or use the Services, we automatically gather certain technical and usage information, which may be associated with your user account. This technical and usage information (“Technical Information”) may include information on when, how often and for how long you use the Services; and server log data such as:

• IP address; 
• Browser type; 
• Device type; 
• Operating system and version, or the webpage you were visiting before you came to the Services;

Technical Information also includes “Cookies,” which are small text files containing a string of alphanumeric characters that are downloaded by your web browser when you visit a website. For more information about how Checkr uses cookies, please review our Cookie Policy.

2. How does Checkr use the collected information?

Checkr uses collected information as described below:

• To Perform Services and Provide the Site: Checkr uses collected information to perform Services for Consumers and Customers and provide the Site to all users. Checkr may transfer certain collected information to third party partners and affiliates who perform services on behalf of Checkr. For more information on transfer of information see When does Checkr share collected information?below.
• To Communicate with You: Checkr uses collected information to communicate with you about the Services, including by phone, mail, email, live in-browser chat, or SMS regarding the status of certain requested Services, to provide updates on changes or modifications to the Services, and to facilitate the delivery of information authorized or required through the Services. Where appropriate, Checkr may send you product announcements and special promotions from Checkr or our business partners, or to administer participation in special events, surveys, contests and sweepstakes. For more information see What choices do you have about online tracking, analytics and email communications from Checkr? below.
• To Administer Your Account: Checkr uses collected information to administer account settings, to process billing and payment information, manage preferences and troubleshoot problems, and personalize the content that account Consumers and Customers’ users see based on personal characteristics or preferences.
• To Meet Legal and Compliance Requirements:  Checkr may use the collected information to i) comply with any applicable procedures, laws, and regulations, subpoenas, governmental requests or legal process; ii)  in connection with a legal investigation, if in our good faith opinion such is required or permitted by law; iii) protect the rights, property or safety of Checkr, our Consumers, our Customers, or third parties; (iv) prevent fraud or abuse of Checkr or our users; or (v) perform a task carried out in the public interest.
• To Provide Security: Checkr uses collected information to create Consumer and Customer account credentials, to verify identity prior to granting access to account information, to validate against existing information maintained by Checkr, to protect against duplicate or unauthorized account creation, to secure the Site and Services, and to address fraud, abuse or safety concerns of Checkr, our Customers or Consumers , including investigation of complaints or suspected fraud or wrongdoing.
• To Improve our Systems: Checkr uses collected information to continuously improve system functionality through quality assurance checks and audits, and to troubleshoot problems. See Machine Learning and Anonymized Information for more information about how collected information is processed.

Data Retention
Checkr will retain collected information in accordance with applicable laws and agreements between Checkr and its Customers and affiliates. See Privacy Choices for more information.

Sale of Information
The California Consumer Privacy Act (CCPA) sets forth certain obligations for businesses that “sell” personal information.  Checkr does not sell personal information subject to the CCPA. We do share information as described in this Policy. For more information refer to Privacy Choices.

Anonymized Information
We may use and share anonymized information without limitation, including sharing with third parties. This includes aggregated, de-identified information about Consumers, Customers, Site Visitors, and information collected from third parties such as public records.

Machine Learning
In some instances, Checkr applies software algorithms and machine learning techniques to information collected from Consumers, Customers, Third Parties, and Site Visitors. For example, we apply automated compliance filtering to collected data from third parties to ensure we are complying with all applicable reporting laws and responsibilities.

To improve accuracy and safeguard consumer rights and interests, our approach is to apply automated methods of processing in targeted instances and to implement thoughtful human review and supervision as needed. Consumers also reserve the right to dispute the accuracy of all reported information that applies to them.

3. When does Checkr share collected information?

Checkr shares collected information as described below:

As authorized: Certain collected information may be shared when authorized, either expressly or implicitly, through the use of the Site or Services. Such authorization includes:

• Consumer authorization to share collected personal information, as well as public and private information with Customers (e.g., background check information, supplemental information, etc.);
• Customer authorization to share certain account information necessary to administer requested Services (e.g., company name and contact information provided to Consumers) or to integrate with third party service providers (e.g., applicant tracking systems);
• Site Visitor authorization through the submission of contact information.

To Perform Services: Certain Services necessitate sharing collected information (e.g., to perform a background check). Checkr may share or transfer certain collected information to third party partners and affiliates who perform services on behalf of Checkr, including but not limited to data storage, analysis and processing. For more information on how Checkr keeps information secure, see How does Checkr protect your information? below. Personal Information Disclosure: United States or Overseas – In connection with its preparation and processing of investigative consumer reports, Checkr may transfer personal information about you to our authorized service providers and affiliates outside the United States and its territories. Such transfer will be conducted in accordance with this privacy policy and all applicable laws and regulations. By using the Services, you consent to this transfer of information outside of your country, even if your country has more rigorous data protection standards.

To Meet Legal and Compliance Requirements:  Checkr may disclose certain collected information where, in good faith, we believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe it is necessary to protect the rights or property of Checkr, our Consumers, our Customers, or third parties.

To Provide Security: Checkr may share information with and between Customers, relevant Partners or third parties to verify account credentials and to address fraud or safety concerns.

To Analyze Usage of Services: We use analytics services for purposes of analyzing usage of the Services. See What choices do you have about online tracking, analytics and email communications from Checkr? for more information. 

To Transfer Business: In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Checkr, the information we possess may be transferred as a corporate asset to the acquiring entity.

To Conduct Research and Marketing: We may disclose information to non-affiliated third parties for research and marketing purposes. See Anonymized Information above.

4. How can you access, change, or delete information about you?

For Consumers
Consumers may access and control the contents and use of their information as described below:

• Accessing your Information: Consumers may access and review their account by visiting Checkr’s Candidate Portal and using their personal information to login. 
• Disputing Incorrect Information: If at any time you believe Checkr possesses or has communicated incorrect information about you to Customers, you should contact Checkr. You can contact Checkr through our Candidate Portal or by reaching out to our Candidate Experience Team. 
• Submitting Supplemental Information:In certain instances, Consumers may be requested or given the opportunity to share additional information or context to collected information. This information is included in the Consumer’s file and will only be shared with Customers and third parties (such as employers) where directed by the Consumer.
• Exercising your rights under the California Consumer Privacy Act (CCPA):The California Consumer Privacy Act (CCPA) affords additional rights to California residents. See For California Residents for more information.

For Customers:
Customers may access and control the contents and use of their information as described below:

• Account information: Requests to update Customer account information should be directed to your account representative or emailed to [email protected].

For information and protections relating to California residents, please see section below titled For California Residents. 

For Site Visitors:
Site Visitors may control the collection and use of their information as described below:

• Analytics and Tracking: For information about choices regarding analytics and email communications, see What choices do you have about online tracking, analytics and email communications from Checkr? below.
• Exercising your rights under the California Consumer Privacy Act (CCPA):
  The California Consumer Privacy Act (CCPA) affords additional rights to California residents. See For California Residents for more information.

For California Residents:
Under the California Consumer Privacy Act (CCPA), California residents have the right to make certain requests, including:

• Access to or details about the personal information (other than background check information) that we retain about you twice in a 12 month period; and 
• Deletion of certain personal information. 

Checkr will help you exercise these rights free of charge, where applicable. If you make a data access or deletion request, we will take steps to verify your identity. Please note that certain information may be exempt from such requests under California law.

See Privacy Choices to exercise your rights under the California Consumer Privacy Act (CCPA). See How can you contact Checkr with more questions? for additional ways to exercise your rights.

5. Will you receive notices and disclosures electronically?

Yes. The Services are offered through Checkr’s website, mobile site, and application. To obtain Services from Checkr, you must create an online account and (1) be able to access Services on a computer or other device that is capable of accessing the Internet, (2) have an active email account, and (3) consent to our use of our website, application, or email to provide you any written information that we may be required to send you in connection with the Services, your account, and/or background checks and reports. However, you may still exercise your rights under the Fair Credit Reporting Act by contacting us through non-electronic means such as mail or a phone call. See How can you contact Checkr with more questions? below. 

Method of Providing Communications to You in Electronic Form
All Communications that we provide to you in electronic form will be provided either (1) via email, telephone or text, (2) by making it available online and accessible via the Services, or (3) by requesting you download a PDF file containing the Communication.

Your Consent to Electronic Disclosures
By creating an account and/or authorizing a background check or other Services, you acknowledge and agree that:

• You can access and read the information we post on our website or mobile app;
• To provide an email address that is active and effective for receiving emails from us;
• To receive electronically on our website, app, or via email notices and disclosures, required by law related to your account and the Services; and
• You have received the following disclosures as required by the federal Electronic Signatures in Global and National Commerce Act (“ESIGN”).

Please read this Federal ESIGN disclosure and consent carefully and keep a copy for your records. Your consent is voluntary, but we cannot provide the Services to you if you do not consent. If you are unwilling to receive these disclosures and notices electronically, you may terminate the creation of your account by closing your browser at any time before you create an account and/or authorize a background check.

Accurate Contact Information
It is your responsibility to provide us with true, accurate and complete contact information, such as email address, and other information related to your account, and to maintain and update promptly any changes in this information. If you give us an incorrect email address or fail to update or correct your email address, an electronic communication will be deemed provided to you if we use the email address in our records for the electronic communication. To update your contact information, please see section 4 titled, “How can you access, change, or delete information about you?”

Scope of Communications to Be Provided in Electronic Form
Your consent to receive electronic communications and transactions includes, but is not limited to, all legal and regulatory notices or disclosures and communications associated with your account, the Services, your request for a background check, and any product or service we agree to provide you (each, a “Communication”).

How to Withdraw Consent
You may at any time withdraw your consent to receive Communications in electronic form. To begin receiving Communications in paper form, please contact us at the following address: One Montgomery Street, Suite 2400, San Francisco, CA 94104. Please specify the information you wish to receive in paper form. Be sure to state that you are requesting a copy of the disclosures, notices, etc., and include your name and mailing address. Your request will apply only to those specific items you designate. We will not impose any fee to process the withdrawal of your consent to receive electronic Communications. Any withdrawal of your consent to receive electronic Communications will be effective only after we have a reasonable period of time to process your withdrawal.

Required Equipment
In order to use the Services and to view and retain a copy of this Policy and certain Communications, you understand that you must have a computer or device equipped with at least: a browser with 128-bit encryption, a current version of a software that can open and display PDF files (e.g., Adobe), and either a printer or other electronic storage device.

Retaining Copies of the Communications
To retain a copy of any Communication we provide electronically, you can download an electronic copy to your computer or a storage device (such as a disk or USB storage device), request a copy by email, or print copies on a printer attached to your computer. You will not be charged for a downloaded or emailed copy.

6. Does this Policy apply to third parties or third-party links?

No. Site and Services may contain links to third-party websites, but this Policy does not apply to information that you may provide to or that may be collected by such third parties. We encourage you to review such third parties’ privacy policies and terms and conditions before engaging with such third parties.

7. What choices do you have about email and text communications from Checkr?

Promotional Emails: Subject to any restrictions under applicable laws, we may send periodic promotional or informational emails to you. You may opt-out of such communications by clicking the unsubscribe link in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

Opting Out of Checkr Text Messages: The number of text messages you receive may depend upon factors, including how you use our Services and whether you take steps to generate additional text messages from us (such as by sending a HELP request). If you no longer want to receive Checkr text messages, you may reply STOP to our messages at any time. After doing so, we will send you confirmation of your opt-out via text message. If you have revoked consent and want to re-enroll in our text message program, you can re-enroll by emailing us at [email protected]

8. How does Checkr protect your information?

Checkr maintains industry standard physical, technological, and administrative safeguards to help protect the security and privacy of the information we maintain about you. We may use encryption, multi-factor authentication, and other proactive security measures to help protect your information against unauthorized access and disclosure. However, no security measures are 100% effective and we cannot guarantee your information will not be collected, disclosed and/or used by others. You should take steps to protect against unauthorized access to your information, passwords, accounts, phones, computers, and other devices. Checkr is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords or other authentication information, or for any activity on your account via unauthorized activity. WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION OR TECHNICAL INFORMATION

9. International Considerations 

Checkr uses infrastructure primarily located and operated in the United States. Checkr may also use partners or affiliates located in countries outside the US to store, process, and transmit your information.

Additional Information for Canadian Users
This Policy applies to Customers, Candidates and Site Visitors in Canada. However, to the extent that this Policy is inconsistent with any applicable Canadian laws, Checkr will comply with the applicable law for Customers, Candidates and Site Visitors in Canada. For example, Checkr will only send commercial electronic messages to persons located in Canada with explicit, opt-in consent, unless otherwise permitted pursuant to Canadian legislation that is applicable to such activities.

Consumers who are located in Canada should also understand that the nature of the Services will involve Checkr obtaining potentially sensitive personal information about them, including consumer reports, criminal record, driving record, as well as education and employment records, from third parties such as consumer reporting agencies, police services and government agencies (e.g., provincial transportation ministries).

Checkr will also share Consumers’ personal information with a third party service provider in Canada, for the purpose of completing or facilitating the background checks described in this Policy.

In addition, as indicated under Section 9 above, personal information that is collected in the course of providing the Services will be transferred outside Canada. Therefore, such information may be accessible to law enforcement and national security authorities in the jurisdiction(s) where it is stored or processed.

Canadian Customers, Consumers, and Site Visitors will be notified of any material changes to this Policy, where such a change would result in use or disclosure of their personal information by Checkr in a manner not contemplated by this Policy or reasonably expected by the individual.

Privacy Shield

We comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union (EU), the United Kingdom, and Switzerland to the United States. Checkr has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov

Pursuant to the Privacy Shield Frameworks, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to [email protected] If requested to remove data, we will respond within a reasonable timeframe. 

We do not share your data with third parties other than our agents or use it for a purpose other than which it was originally collected or subsequently authorized. Should this position change in the future, we will provide you with the option to opt-out of such sharing or use.

We are responsible for the processing of personal data we receive and subsequent transfers to a third party acting as an agent on our behalf, under the Privacy Shield Frameworks. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. 

In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at: [email protected]

Checkr has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://bbbprograms.org/privacy-shield-complaints/ for more information and to file a complaint. This service is provided free of charge to you.   

If your Privacy Shield 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 Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

10. Who can use the Services?

You must be 18 years of age or older to use the Services. If you are a parent or guardian and believe that your child under the age of 13 has provided personally identifiable information to us through the Services, please contact us at the contact information listed below. If we discover that an individual under 13 has provided us with personal information, we will take steps to delete the account and any such personally identifiable information to the extent required by applicable law.

11. Changes to the Privacy Policy

Checkr reserves the right to change this Policy at any time. Please check this page periodically for changes. Your continued use of our Site and Services following the posting of changes to this Policy will mean you agree with, and consent to be bound by, the new revised Privacy Policy.

12. How can you contact Checkr with more questions?

If you have any questions, concerns or complaints about our Policy or Checkr’s handling of your personal information, or if you would like to access or update personal information that is not available via the Candidate portal, please contact us at: 

Checkr, Inc.
Attn: Privacy Questions
One Montgomery Street, Suite 2400
San Francisco, CA 94104
[email protected]
(844) 824-3257

To exercise any of these rights, you may review the information provided above, contact us as described in the “How can I contact you with more questions?,” or contact us at [email protected] In addition to those rights, you have the right to contact your relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

PRIVACY CHOICES

You can view your background check, download a PDF of your report, or request a copy of your consumer file.
Access My Data

You have the right to delete your data. After deleting your data, you will no longer have access to our Candidate Portal.

• If you are a US-based candidate:  Delete My Data
• If you are not a US-based candidate:  Delete My Data

We do not sell your personal information.
Learn More