This Privacy Policy (this “Policy”) covers the information practices of www.backgroundsonline.com (the “Site”). I.Q. Data Systems dba Backgrounds Online (“BGO”) believes in protecting your privacy and the confidentiality of your Personal Information (as defined below). We acknowledge that you may have privacy and security concerns with respect to the information we collect, use, and disclose to third parties. As a result, we have developed this Policy.

As used in this Policy, the term: (a) “Affiliate” means, as to any person or entity, any other person or entity that, directly or indirectly, is in Control of, is Controlled by or is under common Control with such person or entity; (b) “Control” means the possession, directly or indirectly, of the power to direct or cause the direction of the management, policies or activities of the person or entity in question, whether through ownership of voting securities, by contract or otherwise; (c) “BGO Parties” means BGO and all of its Affiliates; and (d) “Personal Information” means any combination of information, in the possession of or likely to come into the possession of a BGO Party that reasonably relates to; or can be used to identify, contact or locate; a discrete individual.

For purposes of clarification, any information which cannot be reasonably related to a discrete individual (such as aggregated statistical information) is not Personal Information.

NOTE: THIS POLICY DOES NOT APPLY TO PERSONAL INFORMATION PROCESSED AS PART OF A BACKGROUND CHECK.

Regarding the provision of background screening services, BGO participates in the EU-US Data Privacy Framework and its related extensions. For more information for individuals located in the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”) related to our processing of Personal Information as part of our background screening services, please review our Backgrounds Online Service Privacy Policy here.

Purposes for collection, use, and disclosure

The BGO Parties collect, use and disclose your Personal Information in its normal course of business for the following purposes:

• Facilitating transactions with you on the Site;
• Establishing and maintaining communications with you;
• Where you have requested products or information from any of the BGO Parties, assisting you in the completion of your request and the assessment of your eligibility for any such request;
• Responding to your inquiries about the BGO Parties’ products or services;
• Enabling the BGO Parties to notify you of certain products or services offered by other BGO Parties;
• Regular operation of the BGO business;
• Meeting legal, security, processing and regulatory requirements;
• Protecting against fraud, suspicious or other illegal activities; and
• Compiling statistics for analysis of the Sites and our business.

Categories of Personal Information Processed

The information gathered and/or generated by the BGO Parties about you falls into two categories: (1) information voluntarily supplied by visitors to the Site; and (2) navigational information gathered as visitors use the Site.

When using the Sites or doing business with a BGO Party, you may choose to provide a BGO Party with information to help one or more BGO Parties serve your needs. The Personal Information that we collect will depend on how you choose to use the Sites; and what Personal Information you share with a BGO Party outside of the Sites.

The Categories of Personal Information we collect via the Site is as follows:

Voluntarily Provided Information

We collect and use Personal Information you may provide directly to us in the following ways:

Registration. If you register for an account with our Services, we may collect your name, account credentials, contact information, demographic information and billing information, including email and physical address, username, password and payment card information.

We use this information to administer your account, provide you with the relevant Services and information, communicate with you regarding your account and your use of the Services, and for customer support purposes. Please note that we work with third-party payment processors for the collection and use of payment card information and do not receive such data directly.

Communications. If you communicate with us through any paper or electronic form, we may collect your name, email address, mailing address, cell phone number, or any other Personal Information you choose to provide to us.

Website Navigational Information

As you navigate the Site, we may also collect Personal Information through the use of commonly-used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information includes standard information from your web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Site (such as the web pages viewed and the links clicked), embedded scripts, and entity tags (ETags).

• Cookies

  Like many companies, we may use cookies on the Site. Cookies are pieces of information shared between your web browser and a website. Use of cookies enables a faster and easier experience for the user. A cookie cannot read data off your computer's hard drive. There are different kinds of cookies with different functions:

  Session cookies: These are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer.

  Persistent cookies: A persistent cookie is one stored as a file on your computer, and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.

  First-party cookies: The function of this type of cookie is to retain your preferences for a particular website for the entity that owns that website. They are stored and sent between a BGO Party’s servers and your computer’s hard drive. They are not used for anything other than for personalization as set by you. These cookies may be either Session or Persistent cookies.

  Third-party cookies: The function of this type of cookie is to retain your interaction with a particular website for an entity that does not own that website. They are stored and sent between the third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies.

  The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help websites analyze how users use the site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the applicable Site, compiling reports on website activity, and providing other services relating to website activity and internet usage for a BGO Party. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the Site.

  The major browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”) in their latest releases. As this standard has not been finalized and is not generally accepted across businesses, the Sites are not compatible with DNT. Additionally, since we do not deploy third party cookies for purposes of cross contextual behavioral advertising, the Site does not respond to Global Privacy Control signals, or similar browser settings.

  For information on all of these categories of cookies, and for more information generally on cookies please refer to www.aboutcookies.org.

  We use generally cookies as follows:

  Functionality

  These cookies allow our Sites to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, the Site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our Sites. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing a video or commenting on an article. The information these cookies collect is usually anonymized. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.

  Performance

  These cookies collect information about how visitors use the Site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the Site, all of which enables us to see how visitors use the Site in order to improve the way that the Site works. The information these cookies collect is normally anonymous and is used to improve how our Site works. However, some of these cookies may include Personal Information.

  Please consult your web browser's ‘Help’ documentation or visit www.aboutcookies.org. for more information about how to turn cookies on and off for your browser.

• Web Beacons

  The Site may also use web beacons and pixels (including web beacons and pixels supplied or provided by third parties) alone or in conjunction with cookies to compile information about users’ usage of the Site and interaction with e-mails from a BGO Party. Web beacons are clear electronic images that can recognize certain types of information on your computer when you view a particular Site tied to the web beacon, and a description of the Site tied to the web beacon. We use web beacons to operate and improve the Sites and e-mail communications, as well as for the other purposes described in this Policy. We may use information from web beacons in combination with other data we have about our clients to provide you with information about one or more BGO Parties and our products.

• IP Addresses

  When you visit our Sites, we collect your Internet Protocol (“IP”) addresses to track and aggregate visitor behavior. For example, we use IP addresses to monitor the regions from which users navigate the Sites.

• Embedded Scripts

  An embedded script is programming code that is designed to collect information about your interactions with the Site, such as the links you click on. The code is temporarily downloaded from our web server (or a third party service provider), is active only while you are connected to the Site, and is deactivated or deleted thereafter.

• ETag, or entity tag

  An Etag or entity tag is a feature of the cache in browsers. It is an opaque identifier assigned by a web server to a specific version of a resource found at a URL. If the resource content at that URL ever changes, a new and different ETag is assigned. Used in this manner ETags are a form of device identifier. ETag tracking may generate unique tracking values even where you block HTTP, Flash and/or HTML5 cookies.

Use and Disclosure of Personal Information

We use and disclose Personal Information as described in this Policy. Generally, we use Personal Information for the following purposes, including:

• Fulfill transactions completed on the Site;
• To provide the information and products you have requested from us;
• To notify you, or allow our Affiliated companies to notify you, of certain products or services offered by our affiliated companies;
• Prevention of fraudulent activity and improved security functionality.
• To assess the performance of the Site.
• To offer you enhanced functionality when accessing the Site, including identifying you when you sign in to our Site or keeping track of your specified preferences.
• To better understand your interest in order to deliver content relevant to your interests on our Site and third party sites based on how you interact with our deals or content.

We do not disclose any Personal Information about you to third parties except as stated in this Privacy Policy, as otherwise permitted by law, or as authorized by you.

Third parties to whom we generally disclose information are required by law or a contract with us, to keep your Personal Information confidential and secure, to use and disclose such Personal Information for purposes that a reasonable person would consider appropriate in the circumstances, and generally for purposes specified in this Policy.

Affiliate Sharing

In the normal course of performing services for our clients, Personal Information may be shared among BGO Parties for research and statistical purposes, corporate record keeping and administration, system administration, joint marketing, providing you products or services, and crime prevention or detection.

Service Providers

Because a number of the service providers we use are located in the United States, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws.

In addition, generally, we will only provide your Personal Information to our lawyers, accountants, tax consultants and employees for the purpose of conducting our business and providing you with products or services. Our service providers adhere to the same protections regarding the collection, use, and retention of data as we do.

Business Transactions

As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if a BGO Party itself or substantially all of a BGO Party’s assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third party purchaser in these circumstances.

Other Legally Required Disclosures

The BGO Parties reserve the right to disclose, without your prior permission, any Personal Information about you or your use of the Site if the BGO Party has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of a BGO Party, a BGO Party’s employees, other users of the Site, or the public; (b) enforce the terms and conditions that apply to use of the Site; (c) as required by a legally valid request from a competent governmental authority; or (d) respond to claims that any content violates the rights of third-parties. We may also disclose Personal Information as we deem necessary to satisfy any applicable law, regulation, legal process, or governmental request.

Third Party Links

In some instances, BGO may provide links to non-BGO controlled services. However, BGO does not control such third-party services, and cannot be responsible for the content or the privacy practices employed by other services or websites.

State Privacy Rights

Residents of some states in the US have certain rights, under the specific state law, as it relates to how their Personal Information is handled. These are the “right to know”, the “right to correct”, the “right to delete”, and the “right to opt-out”.

Right to Know. You may request us to provide you the specific pieces of Personal Information that we have about you, categories of Personal Information we have collected about you, categories of sources from which the Personal Information is collected, categories of Personal Information that we sold or disclosed for a business purpose about you, categories of third parties to whom the Personal Information was sold or disclosed for a business purpose, and the BGO business or commercial purpose for collecting or selling Personal Information. Please note that much of the information for which you can make a request is already contained in this Policy. Should you wish to exercise this right, please contact us via one of the methods noted below under “Exercising State Privacy Rights.” If you do not have an account with us, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.

Right to Correct. You have the right to request we correct any personal information which is incorrect. Note that the right of correction is limited to information that is objectively incorrect, or where there is no legal obligation to retain “incorrect” data.

Right to Delete. Some state law gives its residents a limited right to request deletion of their Personal Information. However, this right is limited by a number of exceptions. Fundamentally, if we have a permissible need to retain Personal Information, we are not under an obligation to delete such information, even when requested. Generally, we retain Personal Information so we may complete the transaction for which the Personal Information was collected, provide information or a service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us and you; detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity; debug to identify and repair errors that impair existing intended functionality of our online properties; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; comply with a legal obligation; or otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which your provided the information. As such, we generally do not accept requests to delete Personal Information. However, we will respond to requests to remove Personal Information from some of our systems as a part of a request to close or otherwise disable an account. If you would like to request deletion of Personal Information, please contact us via one of the methods noted below under “Exercising State Privacy Rights.” If you do not have an account with us, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request.

Right to Opt-Out. We do not sell your Personal Information to unaffiliated third parties in the normal sense of the word. Nor do we share Personal Information for the purpose of cross-contextual behavioral advertising.

Designating an Authorized Agent. Some state law permits residents of that state to designate an agent to manage their rights under state law. If you would like to designate an agent to manage your privacy preferences, you may do so using the mechanisms noted below under “Exercising State Privacy Rights.” Note that if you do not have an account with us, we may ask for some Personal Information in order to verify your identity and your rights to the data subject to your request. We will also need sufficient Personal Information about your authorized agent to be able to identify them. As part of this process, you must have permission from your authorized agent to disclose their Personal Information to us for the purpose of acting as your agent.

Non-discrimination. Some state law prohibits discrimination against you because you exercised any your rights under state law, including, but not limited to, by: denying you access to goods or services; charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties; providing a different level or quality of goods or services; or suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising State Privacy Rights. If you are a resident in a state which provides separate privacy rights, and would like to exercise any of your rights, you may do so by contacting us at support@backgroundsonline.com. Please be aware that we will need to have sufficient information to be able to verify your identity and the rights you have in the data subject to your request.

Please note that your privacy rights are not absolute. There are reasons where we may be legally permitted to decline your request. Should we determine that we cannot complete your request, we will notify you with an explanation as to why we are unable to complete your request.

Should you believe that our decision related to declining your request is in error, or in violation of this Policy, you may appeal any decision by sending us an email at support@backgroundsonline.com

Please explain the reason you believe your request should have been followed and any correspondence you may have had with us or our agent prior to your appeal. We will escalate your concerns to the appropriate members of our team to address any issues you may raise in your appeal.

Safeguards

We have in place reasonable safeguards appropriate to the sensitivity of the information we maintain. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information. They include physical, technical and managerial measures to keep Personal Information protected from unauthorized access. Note that due to the nature of the Internet and related technology, we cannot absolutely guarantee the security of Personal Information disclosed over the Internet, and the BGO Parties expressly disclaim any such obligation.

External Links

Sites may include links to other websites whose privacy policies we do not control. Once you leave our Site, use of any Personal Information you provide is governed by the privacy policy of the operator of the website you are visiting. That policy may differ from this Policy.

Accuracy

Our knowing about changes to some of your Personal Information (e.g. email address) may be key to effectively communicating with you at your request. If any of your details change you can update us by e-mailing us at support@backgroundsonline.com. Please keep us informed of changes to your Personal Information.

Questions

If you have any questions or concerns about how your Personal Information is handled by the BGO Parties, please let us know by sending an email at support@backgroundsonline.com

Privacy Policy Changes

If there is any material change to your rights under this Policy, BGO will provide you with notice of such change prior to the changes going into effect. As part of this notice, BGO may post a notice of the change on the Site in a clear and conspicuous manner. BGO may also communicate the change via email or postal mail if this is the way that BGO normally corresponds with you.