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ScreenlyyID, INC. PRIVACY POLICY

Effective Date: 1ST JUNE, 2020

 

This Privacy Policy (“Policy”) describes how ScreenlyyID, Inc. (“ScreenlyyID” or “we” or “our”) manages information collected or provided in connection with an end user’s (“you” or “user”) visit to or use of the website located at www.screenlyyid.com and ScreenlyyID products and services (the “Services“). Please note that your use of the Site constitutes your acceptance of and consent to this Policy. When you sign up to use the Services, you also consent to receive electronic notices and disclosures, as set forth in Section 5 below. ScreenlyyID reserves the right to change this Policy at any time.

Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will mean you accept those changes. Please read the following policy for complete information on this important subject.

  1. What information do we collect?

Information Provided Directly To Us

We may collect information you provide directly through the Services. For example, we may collect your name, email address, or other contact information when you access certain ScreenlyyID content available through the Services such as whitepapers, videos, webinars, and other materials, or request additional information about ScreenlyyID or the Services. ScreenlyyID also collects information from you when you fill out any form in the Services such as when you submit questions or comments.

  1. By Customers

If you want to use the Services to verify and screen customers (“Customers”), ScreenlyyID may collect the following information (collectively, the “Customer Information”), including, but not limited to:

  • Account creation information, including your name, email address, and a custom password;
  • Contact information such as email, address and phone number;
  • Corporate and license information;
  • If you are an employer, employer identification number; and
    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. Such information is passed on to our third-party payment processor, Stripe. You can review information on Stripe’s privacy practices at https://www.stripe.com.
  1. Applicants

If you are an applicant who will be the subject of an Identity verification & screening check (“Applicants”), ScreenlyyID may collect the following information (collectively, the “Background Check Information”), including, but not limited to:

  • We collect data which may include personal information (verification data) for the purpose of providing identity, document and data verification services. Verification data may include your name, date and place of birth, address, contact details (such as telephone number and email address), identification details (such as your tax file number, passport details or driver’s licence details) and biometric information (such as facial images and fingerprints).
  • We also collect personal information if you create an account or enter an agreement with us to use our services, such as your or your representatives’ name, address, title and contact details.
  • We also collect personal information that is provided to us in the course of normal business operations, such as if we engage you as supplier, if you apply for employment with us or make an enquiry about our services. The kinds of information we collect will depend on what is provided to us, but typically would include your name, address and contact details.
  • We generally do not collect sensitive information, such as information about your racial or ethnic origin, political opinions or associations, religious beliefs or affiliations, sexual orientation or practices, criminal record or health or genetic information.

Automatically Collected Information

When you visit 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”) includes usage information, such as information on when, how often and for how long you use the Services; and server log data such as a computer’s 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. Like many online services, we may use both session cookies and persistent cookies when you access and use the Services. Cookies are used to remember your user account information and your preferences, to customize the Services for you and to assist us in measuring and analyzing utilization of the Services.

Third-party web analytics services providers we engage, such as Google Analytics, may use cookies in order to provide analytics services for the Services to us. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed. Please review your web browser’s documentation to learn the best way to modify your cookie settings and see Section 7 below.

  1. How does ScreenlyyID use the collected information?

ScreenlyyID uses the information it maintains about you (including information you provide, Customer Information, and Technical Information):

  • For the purposes for which you provided it;
  • To create your account and enable you to use the Services;
  • To verify your identity;
  • To provide the features and functionality of the Services;
  • For customer support and to respond to your inquiries;
  • To respond to and fulfil your requests;
  • With your consent, to contact you by text message regarding your account and certain services or information you have requested;
  • To improve the Services;
  • For internal record-keeping purposes and for legal purposes;
  • To address fraud or safety concerns, or to investigate complaints or suspected fraud or wrongdoing; and
  • To resolve disputes, to protect ourselves and other users, and to enforce any legal terms that govern your use of the Services.

ScreenlyyID uses the contact information that you provide to access ScreenlyyID content available in the Services (such as whitepapers) or to obtain more information about ScreenlyyID or its Services to provide such content and information. ScreenlyyID may also use this information to provide you with additional information regarding products and services from ScreenlyyID or our business partners that may be of interest to you. ScreenlyyID does not use  identity, document and data verification services Information for this purpose. If you do not wish to receive such communications, please see Section 7 below.

ScreenlyyID uses Identity verification and Identity, document and data verification services screening Information as reasonably necessary to:

  • verify customer identity;
  • conduct background screening checks;
  • conduct quality assurance checks;
  • investigate disputes; or
  • provide certain communications.

We may use Customer Information to:

  • contact you regarding your use of the Services;
  • process billing and payment;
  • send you product announcements and special promotions from ScreenlyyID or our business partners, or to administer participation in special events, surveys, contests and sweepstakes; or
  • send you communications regarding updates or modifications to the Services.

We may use Customer Information and Technical Information to:

  • personalize the content that you and others see based on personal characteristics or preferences;
  • troubleshoot problems;
  • provide you with required notices, in connection with disputes between you and another user; or
  • alert you to changes in our policies or agreements that may affect your use of the Services.

ScreenlyyID may also use Technical Information to analyze your use of the Services to help us improve the Services and develop and improve other products and services.

  1. When does ScreenlyyID share information about you?

We may share the information we collect from and maintain about you as follows:

  • Employers or Other Customers Requesting Background screening results. We only provide Identity, document and data verification and background screening pass/fail results. We do not provide background screening reports about Applicants to the requesting Customer.
  • Service Providers. We may provide access to your information to select third parties who perform services on our behalf. These third parties provide a variety of services to us, including without limitation conducting components of Identity, document and data verification checks, background screening checks, billing, fulfillment, data storage, analysis and processing, fraud, accounting, auditing, and legal services.
  • Affiliates. We may share information with our affiliates for use as described in this Policy.
  • Legal Requirements. If we are compelled or authorized to do so by law.
  • De-identified information. We may share de-identified information with third parties, including without limitation: (1) sharing aggregated, de-identified information about our user base and its interests and usage patterns and (2) providing de-identified information to third-party partners for our business arrangements, including without limitation to jointly offer a product or service to you or create interoperability between our products and services and theirs.
  • Consent. We may disclose your information to non-affiliated third parties based on your consent to do so.
  • Business Transfer. In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving ScreenlyyID, or in contemplation of such a transaction (e.g., due diligence), the information we possess may be transferred as a corporate asset to the acquiring entity.
  • Analytics. We use Google Analytics for purposes of analyzing usage of the Services. You can find more information about Google privacy practices here. here.

Note: ScreenlyyID will not provide your information or personally identifiable information to third parties for their own marketing purposes without your consent.

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

Applicants should promptly update their contact information if it changes or is inaccurate. Applicants may review, access, and change certain account information such as email address, phone number and mailing address via the applicant portal on the Services. Requests to change certain other information, such as Social Security Information, may require verification before the change is accepted. Applicants can request deletion of certain information in ScreenlyyID’s control by contacting ScreenlyyID as set forth at the end of this Policy.

Once a Customer has received a identity, document and data verification and background screening check report, ScreenlyyID does not control the Customer’s retention of such information.

Our policy is to retain personally identifiable information only as long as reasonably necessary to provide the Services or as otherwise required for legal compliance purposes.

  1. Will you receive notices and disclosures electronically?

The Services are offered through the ScreenlyyID website’s www.screenlyyid.com, mobile site, and app. To obtain Services from us, 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, app, 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 identity, document and data verification services, background checks and reports.

Your Consent to Electronic Disclosures

By creating an account and/or authorizing an identity verification, document verification, data verification or background screening check, you acknowledge and agree:

  • you can access and read 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 the 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 an identity, document and data verification or background screening check.

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  identity, document and data verification services check, and any product or service we agree to provide you (each, a “Communication”).

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 your account portal, or (3) by requesting you download a PDF file containing the Communication.

How to Update Your Records

It is your responsibility to provide us with true, accurate and complete email address, contact, and other information related to your account, and to maintain and update promptly any changes in this information. You can update information (such as your email address) through your account portal. 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.

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.

  1. Does this Policy apply to third parties?

No. The 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.

  1. What are your choices regarding online tracking, analytics and certain email communications from ScreenlyyID?
  • Online Tracking and Cookies. Like many websites, the Services do not currently respond to “do not track” browser headers. But you can take steps to limit tracking by erasing cookies from your computer’s hard drive and by setting your browser to block all cookies or warn you before a cookie is stored. If you disable cookies, you may be prevented from taking full advantage of the Services because they may not function properly without cookies.
  • Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. here.
  • Promotional Emails. As discussed in this Policy, 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 unsubscribe 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 ScreenlyyID 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 HELPrequest). If you no longer want to receive ScreenlyyID text messages, you may text STOP 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] .
  1. How does ScreenlyyID protect your information?

ScreenlyyID maintains safeguards to help protect the security of information we maintain about you. We may use encryption, passwords, and physical 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 password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. ScreenlyyID is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password 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.

  1. Where is your information processed or stored?

ScreenlyyID uses servers located in the United States.ScreenlyyID may also use its holding or subsidiary companies, partners or affiliates located in other countries besides the US to store and process your information. By using the Services, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards.

  1. 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.

  1. How can I contact you with more questions?

If you have any questions, concerns or complaints about this Policy or ScreenlyyID’s handling of your personal information, or if you would like to access or update personal information that is not available via the applicant portal, please contact us at [email protected].

Additional Information for Canadian Users

This Policy applies to customers, users and applicants in both Canada and the United States. However, to the extent that this Policy is inconsistent with any applicable Canadian laws, ScreenlyyID will comply with the applicable law for customers, users and applicants in Canada.

Applicants who are located in Canada should also understand that the nature of the Services will involve ScreenlyyID 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).

ScreenlyyID will also share Applicants’ personal information with a third party service provider in Canada, for the purpose of completing or facilitating the identity, document and data verification services and background screening checks as 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, users and applicants will be notified of any material changes to this Policy, where such change would result in use or disclosure of their personal information by ScreenlyyID in a manner not contemplated by this Policy or reasonably expected by the individual.

 

Additional information for residents of the European Union

European Union data protection laws make a distinction between organizations that process personal data for their own purposes (known as “data controllers”) and organizations that process personal data on behalf of other organizations (known as “data processors”)

Under applicable law, ScreenlyyID is considered the “data processor” of the personal data we handle under this Privacy Policy. We retain the personal data for as long as necessary to provide the Services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements.

Our legal grounds for using personal data are as follows:

  • Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you. For example, to comply with our Terms, which you by using our Service.
  • With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent.
  • Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, analyzing and improving our business, providing security for our Services, preventing fraud, and managing legal issues.
  • Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.

Your Legal Rights Under Local Law:

The following disclosure is made pursuant to the European General Data Protection Regulation (GDPR): You have the right to withdraw your consent at any time; and to submit a complaint to the relevant supervisory data protection authority.

Your access to and right to correct the information we hold

You have the right to allow you to ask us for a copy of your personal information; to ask us to correct, delete or restrict (stop any active) processing of your personal data and to obtain the personal data you provide to us for a contract or with your consent and to ask us to share (port) this data to another data controller; to object to the processing of your personal information by us in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement or where we are using the data for direct marketing).

These rights may be limited, for example, if fulfilling your request would reveal personal data about another person or breach the privacy rights of others, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. We may request you provide us with information necessary to confirm your identity before responding to your request.

To exercise any of these rights, you may review the information provided in Sections 4, 5, and 7, or contact us as described in the “How can I contact you with more questions?” section above. In addition to those rights.

As described above, ScreenlyyID uses servers located in the United States. ScreenlyyID may also use its holding or subsidiary companies, partners or affiliates located in other countries besides the US to store and process your information. By providing us with your information, you acknowledge any such transfer, storage or use. If we provide any information about you to any such non-EU third party information processors, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy and applicable law.

 

12. California Residents

The following disclosure is made pursuant to California Online Privacy Protection Act: When you use our Service, other parties, such as Google may collect personally identifiable information about your activities over time and across different websites or online services. If you are a Californian resident, please review our CCPA privacy notice.

  1. Making a complaint

You have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

If you wish to make a complaint about the way we have handled your personal information, you can contact us [email protected] . Please include your name, email address linked to your account and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.

If you are from the EU and have unresolved concerns, you have the right to make a complaint to the data protection supervisory authority where you live, work or where you believe a breach may have occurred.

  1. Changes to this Privacy Policy

We may change this Policy. We will provide you notice of such changes through the Service’s interface. Your continued use of the Service constitutes your consent to the amended Policy. If you do not consent to the amended Policy, we may terminate the Terms and your account on the Service and block your access to, and use of, the Service, upon the elapse of 30 days after you decline to accept the revised Policy.

In case of legal requirement or necessity, we may also introduce immediate changes to this Policy. The latest version of the Terms and its effective date will always be accessible on the Service. 

  1. Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us at:

[email protected]