Effective date: January 4, 2023
Your privacy is important to us, and in this Policy, we tell you what personal information we collect, why we collect it, how we use it, under what circumstances we may share it with third parties, how we protect that information, and what choices you may make about that information.
Vcheck Global is a background check provider for our clients (our “Clients”) and collects and processes personal information in the course of providing its Services.
This Policy reflects how Vcheck Global processes personal information through our Platform and our Services. It does not apply to our Clients’ uses of your data, or the use of your data by any third party (for example, when you visit a third-party website or interact with third-party services). You should review those third parties’ privacy policies before you use any of their services (“Third Party Services”). In some instances, Vcheck Global only acts as a “processor” of your information and may not be the “controller” of the information (which may be our Client or our vendor). Our use of your information is usually in the context of providing a service to our Clients, and you may be required to reach out to the Client directly to remove your information from their databases as well as Vcheck Global’s.
Internally, your personal information will only be shared with members of our company who need to know this information in order for us to provide our Services. At times, we may need to disclose your personal information to third parties outside the company who may be assisting us with providing Services to you, as set forth in this Policy, or to our Clients.
We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). The categories of Personal Information we collect may include:
We may also obtain Personal Information from you where you expressly provide us with the information. Examples of sources from which we collect information include telephone calls with you, letters, e-mails or other communications from you, information provided via online chat or support services, web forms or inputs/uploads into our Platform, documents you have provided to us, or references and referrals provided to us in connection with your employment application.
Your decision to provide us with the Personal Information above is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Platform or our Services.
Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Platform (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with our Platform. Usage Information may include:
For location information, we may use this information to provide customized Services, content, promotional offers, and other information that may be of interest to you.
If you no longer wish for us or our service providers to collect and use location information, you may disable the location features on your device. Consult your device manufacturer settings for instructions. Please note that if you disable such features, your ability to access the Platform, or certain features, Services, content, promotions, or products may be limited or disabled.
As stated above, Vcheck Global is a service provider to our Clients. We are not a direct-to-consumer provider. The Platform and Services may include functionality that allows certain kinds of interactions between us and our Client. The use of this functionality may involve the Client or a third-party providing your Personal Information to us. Our receipt of this information is always controlled by an agreement with the Client that contains specific provisions about our ability to use your Personal Information. We cannot use your Personal Information for any purpose other than fulfilling the business relationship with the Client. We may also collect information about you from other sources, including consumer credit reporting agencies, background check vendors, court and other public records, and state, federal or international agencies.
The Site and Platform may also include functionality that allows certain kinds of interactions between the Site or Platform and your account on a third-party website or application, like YouTube, BuzzSprout, or LinkedIn. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Platform to facilitate sending a communication from the Site (e.g., “Contact Us”) or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). We may combine the information we collect from third parties with information that we have collected from you or through your use of the Services.
The Client or these third parties may retain any information used or provided in any such communications or activities and their privacy practices may be subject to different Terms or Privacy Policies. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using these third-party tools on our Site. Please also see our Terms for more information.
We may use Personal Information for various purposes, including the following:
We may be required under our agreement(s) with our Clients to share Personal Information and preferences that we have collected with them. We also may share your information, including your Personal Information, with our affiliates, service providers, business associates, and other third parties that perform essential services for us; for example, a payment processor, a cloud-service or internet service provider, an email marketing vendor, a customer service provider, or entities that handle other business functions for us.
As permitted by law, we insist that these partners follow the same rules and standards with respect to your personal information as we do, and we typically have a contractual agreement in place with the other party which prohibits them from disclosing or using the information other than for the business purposes for which it was disclosed.
We do not “sell” your information to any third parties, as that term is defined under California law. If you are a California resident, you may have additional rights with respect to the transmission of your information. Please see the section entitled “Your California Privacy Rights” below for more information.)
We may aggregate, de-identify, and/or anonymize any information collected through the Platform or Services such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (which is no longer considered Personal Information) for any purpose, including without limitation, for research and marketing purposes, analytics, and may also share such data with our affiliates and third parties, including advertisers, promotional partners and others.
Certain Personal Information about you may also be disclosed in the following situations:
We do not “sell” your information to any third parties, as that term is defined under California law, but California’s separate definition of “share” may mean that we share your information with our affiliates and other third parties, such as companies with whom we have marketing or other relationships, for direct marketing purposes. If you are a California resident, you may have additional rights with respect to the transmission of your information. Please see the section entitled “Your California Privacy Rights” below for more information.)
We may use various methods and technologies to store or collect information about you (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. A few of the Tracking Technologies used on the Site or Apps, include, but are not limited to, the following (as well as future-developed tracking technology or methods that are not listed here):
We may use Tracking Technologies for a variety of purposes, including:
Do Not Track (“DNT”) is a web browser setting that requests that a web application disable its tracking of an individual user. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party websites or online services (e.g., browser do not track signals), but there is no universally agreed-upon standard for what a company should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.
You have choices when it comes to how we use your information, and we want to ensure you have the information to make the choices that are right for you.
If you no longer want to receive marketing-related emails or newsletters, you may opt out by following the instructions in any such email you receive from us, or contacting us at [email protected].
Please note that Vcheck Global’s Clients, as the controllers of the data, remain wholly responsible for obtaining any necessary consent for an applicable consent and giving effect to users’ choices with respect to that consent. If you wish to revoke your consent for us to conduct a background check, you must contact the Client to whom you provided your prior consent in order to revoke it.
The Platform and our Services are not intended for use by children under the age of 16. We do not request, or knowingly collect, any Personal Information from children under the age of 16. If you are the parent or guardian of a child under 16 who you believe has provided her or his information to us, please contact us at [email protected] to request the deletion of that information.
We use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your information has been compromised), please immediately notify us in accordance with the “Contact Us” section, below.
We prefer to keep your Personal Information accurate and up to date. If you would like to change your contact information, please contact us at [email protected]. We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable (but we may retain prior information as business records).
Under applicable law, we are considered a “processor” of Personal Information we handle for our Clients. For our employees and job applicants, we are considered the “data controller.” If you are a resident of or located within the UK or EEA, you have certain data protection rights. These rights include:
In most instances, Vcheck Global is a processor of Personal Information; however, in some instances Vcheck Global may be a controller of Personal Information. Vcheck Global’s legal basis for collecting and using the Personal Information described in this section depends on the Personal Information we collect and the specific context in which we collect it.
Vcheck Global may collect or process your Personal Information because:
More specifically, we rely on the following legal bases for processing your Personal Information:
Vcheck Global will also retain Personal information, including Usage Data, for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.
Under certain circumstances, Vcheck Global may be required to disclose your Personal Information if required to do so by law or by contract, or in response to valid requests by public authorities (e.g., a court or government agency).
Vcheck Global may disclose your Personal Information in the good faith belief that such action is necessary to:
If applicable, you may exercise any of your rights under the GDPR by submitting a verifiable data subject request to us by using the details in the Contact Us section below. You may make a request related to your Personal Information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of the UK or the EEA by including your country of citizenship or residence in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in the UK or EEA in order to obtain the information. We will respond to your request within 30 days or let you know if we need additional time.
Please note that we will ask you to verify your identity before responding to such requests, and we may deny your request if we are unable to verify your identity or authority to make the request.
Should you wish to raise a concern about our use of your data (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority; however, we hope that we can assist with any queries or concerns you may have about our use of your Personal Information first by contacting us at [email protected].
For more information about the GDPR, please contact your local data protection authority in the EEA.
If you are a resident or citizen of the United Kingdom, the following provisions also apply:
“UK GDPR” means the Retained Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.
If we share your personal data within the Company or with third parties located outside the United Kingdom, we take steps to ensure that appropriate safeguards are in place to guarantee the continued protection of your personal data, such as by entering into the international data transfer addendum to the European Commission’s Standard Contractual Clauses, adopted by the UK Government under section 119A of the Data Protection Act 2018.
You have the same data subject rights as those for the EU listed above, except that references to the “GDPR” should be read as references to the “UK GDPR” and complaints should be filed with the UK supervisory authority, the Information Commissioner’s Office.
If you are located in the national territory of Brazil, you have certain additional data protection rights under the Lei Geral de Proteção de Dados (“LGPD”). These rights include:
Vcheck Global’s legal bases for collecting or processing your Personal Information are as follows:
Vcheck Global will also retain Personal Information and usage data for internal analysis purposes. Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit). Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site or we are legally obligated to retain this data for longer periods.
If applicable, you may exercise any of your rights under the LGPD by submitting a verifiable data subject request to us by using the details in the Contact Us section below. You may make a request related to your personal information or on behalf of someone for which you have authorization. You must include your full name, email address, and attest to the fact that you are a citizen or resident of Brazil in your request. We may require you to confirm your identity and/or legal standing for the request as well as your residency in order to obtain the information. We will respond to your request within 15 days or let you know if we need additional time.
California residents have the following rights:
California consumers have the right to request, under certain circumstances, that a business that collects personal information about the consumer disclose to the consumer the information listed below for the preceding 12 months:
Vcheck Global collects certain types of personal information about you during your relationship with us, as explained above. In particular, due to the nature of our business, our Site and our Services have collected and sold or shared the following categories of Personal Information from consumers within the last twelve (12) months:
|Category of Personal Information Collected
|Sold or Shared(Yes/No)
|Sources of Collected Personal Information
|Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers
|Personal information categories listed in the California Customer Records statute (Cal. Civ. Code 1798.80(e))
|Characteristics of protected classifications under California or federal law (for instance, gender classification/male or female), religious affiliations, etc.
|Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
|Third Parties, if part of public records
|Internet or other electronic network activity information including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
|Audio, electronic, visual, thermal, olfactory, or similar information
|Professional or employment-related information
|Education information (as defined in 20 U.S.C. section 1232g, 43 C.F.R. Part 99)
|Inferences drawn from any of the of the information above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
|Sensitive Personal Information
Please note that if we collected information about you for a single one-time transaction and do not keep that information in the ordinary course of business, that information will not be retained for purposes of a request under this section. In addition, if we have de-identified or anonymized data about you, we are not required to re-identify or otherwise link your identity to that data if it is not otherwise maintained that way in our records.
You have the right to request that we correct any inaccurate information that we maintain about you.
You can also request that we delete your personal information. As permitted by the CCPA/CPRA, if you request deletion of Personal Information that we have collected about you, we, our services providers, and our contractors may be unable to comply with such a request if certain exceptions apply, such as if your Personal Information is necessary to:
As a California resident, you also have the right, at any time, to tell us not to sell personal information – this is called the “right to opt-out” of the sale of personal information. At this time, we do not sell our consumers’ personal information to third parties. We will, however, honor your request to opt out of any marketing emails or correspondence.
We may collect your sensitive personal information (e.g., social security number, driver’s license, state identification card, passport, or racial or ethnic origin) if it is necessary to perform our Services, as reasonably expected by you when using a due diligence and background check organization. We do not collect or process your Sensitive Personal Information for the purpose of inferring consumer characteristics about you.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us a list of what personal information (if any) we disclosed to third parties for their own direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. As stated above, we are usually required to provide your Personal Information to our Clients, as they are the ultimate controllers of the information. We do not currently disclose personal information protected under this section to other third parties for their own direct marketing purposes.
You or your authorized agent may make a request to access, correct, delete or opt-out of the sale of your information by contacting us as follows:
If you use an authorized agent to submit your CCPA request, we may require proof of the written authorization you have given to the agent. We also may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request twice in a 12-month period. For emails, please include “California Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a California resident. We will acknowledge your request within 10 days and respond to your request within 45 days or let you know if we need additional time. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
If you are a Nevada resident, you have the right to request certain information from us regarding the collection and sale of your personal information (as defined in Nevada Revised Statutes 603A.320) during your visit to our websites or when you otherwise interact with us online. At this time, we do not sell consumer’s personal information to third parties.
If you are a resident of Virginia, you have the right under the Virginia Consumer Data Protection Act, upon a verified request, to:
To exercise these rights, you may make a request to confirm, access, correct, delete, obtain a copy, or opt-out of the processing of your personal data for targeting advertising, sale, or profiling by contacting us using the information in the Contact Us section below:
We may require you to confirm your identity and your residency in order to obtain the information, and you are only entitled to make this request up to twice annually. For emails, please include “Virginia Privacy Rights” as the subject line. You must include your full name, email address, and attest to the fact that you are a Virginia resident. We will process your request within 45 days or let you know if we need additional time or cannot process your request. If you make this request by telephone, we may also ask you to provide the request in writing so that we may verify your identity. If we are unable to honor your request for any reason, we will notify you of the reason within the request time period.
If we decline to take action on your request, residents of Virginia can appeal our decision by submitting an email to [email protected] entitled “Virginia Privacy Rights Appeal” and we will review your request and respond with a written explanation of the reasons for our decision. If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint.