Data Privacy Statement

Effective Date: February 8, 2022

Identifee, Inc. and its subsidiaries and affiliates (“Identifee,” “we,” “us,” “our,” or the “Company”) are committed to respecting your privacy. This Privacy Statement describes Idenifee's privacy practices in relation to the websites, products, services, and programs owned and operated by the Company. In addition, this policy states how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Statement.

We urge you to read this Privacy Statement so that you understand our commitment to you and your privacy, and how you can participate in that commitment. When you visit our websites, or provide personal information to us through other means, you consent to the use of your information as described in this Privacy Statement.

Identifee may review and update this Privacy Statement periodically to reflect changes to our privacy practices. We will provide notification of material changes to this Privacy Statement through the Company’s websites or via email prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Web sites covered

This Privacy Statement covers information practices, including how the Company collects, uses, shares,and secures the personal information you provide, of websites that link to this Privacy Statement.

Identifee’s websites may contain links to other websites. The information practices or the content of such other websites is governed by the privacy statements of such other websites. We encourage you to review the privacy policies of other websites to understand their information practices.

Please also note that co-branded websites (i.e., websites where Identifee presents content together with one or more of our business partners) may be governed by additional or different privacy statements. Please refer to the privacy statement on those websites for more information about applicable privacy practices.

Personal information we collect

This Privacy Statement applies to personal information and other information collected by Identifee or its service providers from or about:

  1. Visitors to, or users of, its websites;
  2. Prospective and current customers using our products or services;
  3. Service providers and business partners;
  4. Job applicants; and
  5. Other third parties that it interacts with.

The personal information collected includes the following:

Web registration information. When (i) expressing an interest in obtaining additional information about Identifee’s products or services, (ii) registering to use our websites or other services, or (iii) registering for an event, we may require you to provide us with personal contact information such as your name, company name, address, phone number, and email address.

Job applications. When you apply for a position with Identifee through the careers section of our website, we may collect personal information such as your name, email address, physical address, LinkedIn profile, phone number, compensation expectations and work history. You also have the option to upload your resume that may include additional personal information.

The Company also utilizes third party recruitment firms for certain recruiting activities. Such firms may send us potential candidate information such as name, email address, physical address, compensation expectations and work history.

Website navigational information. We may collect certain information about you from your web browser when you visit our websites. This information may include your Internet Protocol ("IP") address, browser type, browser language, and the date and time of your request. This information could indirectly identify you and gathering this information from you helps us ensure our websites and other services work correctly in support of our customer analytic efforts.

Email communication. We use pixel tags or web beacons in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on an Identifee website. We use these tools to determine potential interest in particular topics, as well as measure and improve the effectiveness of our communications with you.

Cookies and similar technologies. We may collect information about your use of our websites through cookies and similar technology, such as Google Analytics. A "cookie" is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to our websites. The Company uses cookies to operate and improve our websites as well as to simplify the interaction with you. When you visit our websites, our servers send a cookie to your computer or mobile device to help personalize your experience. Cookies help us better understand user behavior. Cookies only stand to recognize your web browser, but information collected from cookies is not personally identifiable. We may also use web beacons or other technologies in conjunction with cookies to gather information about your visit to our websites. Web beacons may be embedded through our website or electronic communications and can allow servers to collect information related to your visit. Web beacons are primarily used to provide content and advertisements that are more relevant to you.

Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet, or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our services.

Google Analytics. we use Google Analytics' third-party audience data to better understand the behavior of our visitors and work with companies that collect information about your online activities to provide advertising targeted to suit your interests and preferences. For example, you may see certain ads on this or other websites because we contract with Google and similar companies to target our ads based on information we or they have collected, including information that was collected through automated means (such as cookies and web beacons).

Users can access information explaining how Google uses cookies to process and collect data by visiting the Google Privacy Policy Page. Users may opt out of Google's use of cookies to personalize ads by visiting the Google Ads settings page. Users may opt out of Google Analytics by visiting the Google Analytics Opt-out Page and installing the Opt-out browser ad-on. This browser ad-on informs Google Analytics via JavaScript that no data and information about website visits may be transmitted to Google Analytics. Users may opt out of third-party vendor use of cookies by visiting the Network Advertising Initiative Opt-out Page.

Social media applications. Our websites may include social media features, such as the LinkedIn or Twitter button and other widgets that run on our website. These features may collect your IP address and which page you are visiting on our website and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with these features are governed by the privacy policy of the organization providing it.

Employee information. When you join our Company as an employee, we collect personal information such as your name, national identification, physical address, email address, phone number, ethnicity, gender, background check information, dependent information, benefit information and bank information for payroll purposes.

Third party sources. Identifee may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our services to you, and prevent or detect fraud. We work closely with third parties (for example, business partners, service providers, sub-contractors, analytics providers, and search information providers) and may receive information about you from them.

Public forums, blogs, and the customer reference program

Identifee websites may feature bulletin boards, blogs, or forums. Any personal information that you choose to submit via such a forum may be read, collected, or used by others who visit these forums, and may be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums.

How we use and disclose personal information

Identifee may use your personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your personal information to support our business functions, such as sales, marketing, services, recruitment, and legal functions. For example, we may use this information to:

  • Fulfill requests;
  • Send product and services updates;
  • Respond to customer service requests;
  • Send marketing communications;
  • Improve our websites and marketing efforts;
  • Conduct research and analysis;
  • Comply with legal and/or regulatory requirements;
  • Respond to questions and concerns; and
  • Process employment applications and background checks.

Apart from using your personal information to support our own business functions, we may disclose your personal information under the following conditions:

Disclosure of personal information to third parties. Identifee will not rent or sell your personal information to others but may disclose personal information with third-party vendors and service providers that work with us. We will only share personal information to these vendors and service providers to help us provide a product or service to you. Examples of third parties we work with are background check agencies, benefits providers, financial institutions, and other service providers that provide corporate functions to us such as human resources and customer relationship management. These third parties only have access to personal information necessary for them to perform their services.

Disclosure of personal information for business purposes. In the event of corporate divestures, mergers, acquisitions, bankruptcies, dissolutions, reorganizations, liquidations, or general business transactions or proceedings, Identifee may buy, sell, divest, or transfer your personal information.

Disclosure of personal information for legal and safety reasons. The Company may be required to disclose personal information to regulatory authorities, law enforcement agencies or government agencies. We may disclose information to:

  • comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law;
  • respond to lawful requests by public authorities, including to meet national security or law enforcement requirements;
  • in the event of an emergency that threatens an individual's life, health, or security; or
  • to the extent permitted by applicable law, in special cases in which we believe it is reasonably necessary to investigate, identify, or take preventive measures or bring legal action against someone who may commit or cause harm, fraud, abuse, or illegal conduct, such as a threat of harm to you or anyone else, interference with our rights or property, or interference with U.S. homeland or national security or public safety anywhere in the world.

Disclosure of personal Information via links to third party services and applications. Using our websites or services may link you to third party websites, services, and applications. Identifee is not responsible for any personal information collected by such third parties which use is governed through the third party's website's privacy policies. Any interactions you have with these websites, services, or applications are beyond the control of Identifee. When you post information to or through such services, those websites' privacy policies apply. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.

International data transfers; Privacy Shield participation

Identifee is a global organization, with legal entities, business processes, and technical systems that operate across borders. The Company may transfer your personal information to other Company entities in the United States and elsewhere. The United States and other countries may not have the same data protection laws as the country from which you initially provided the information. By accessing our websites, registering for an account or service, or otherwise providing Identifee with your personal information, you consent to this transfer of your personal information. When transferring your personal information internationally, we will protect your personal information as provided in this Privacy Statement.

Identifee participates in and has certified to the U.S. Department of Commerce that it complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, the “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 and Switzerland to the United States. Identifee is committed to subjecting to the Principles of the Privacy Shield Framework all personal information received from EU member countries and Switzerland in reliance on the Privacy Shield Framework. If there is any conflict between the policies in this Privacy Statement and the Privacy Shield Framework Principles, the Privacy Shield Framework Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

Privacy Shield inquiries, complaints, recourse, and enforcement

In compliance with the Privacy Shield Framework, Identifee commits to resolve inquiries and complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield practices should first contact us using the information in the “How to contact us” section, below. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

With regard to unresolved Privacy Shield complaints concerning both human resources and non-human resources data transferred from the EU or Switzerland, Identifee has committed to cooperate with the EU data protection authorities for citizens and residents of the EU and the Swiss Federal Data Protection and Information Commissioner for citizens and residents of Switzerland.

Under certain conditions, more fully described on the Privacy Shield website, https://www.privacyshield.gov/article?id=ANNEX-I-introduction, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

With respect to personal information that Identifee receives pursuant to the Privacy Shield Framework, Identifee will remain liable for processing of that personal information by our agents, unless Identifee establishes that it is not responsible for the event giving rise to the damage.

The Federal Trade Commission has jurisdiction over our compliance with the Privacy Shield Framework.

Customer data

Identifee's customers may electronically submit data or information to us for hosting and processing purposes ("Customer Data"). In accordance with our policy, the Company will access Customer Data only for providing our products and services or for preventing or addressing service or technical problems (at a customer's request in connection with customer support matters), or as may be required by law. Identifee will not otherwise review, share, distribute, or reference any Customer Data except as authorized by the applicable customer.

Identifee may transfer personal information to third party companies that help us provide our products and services. Transfers to subsequent third parties are covered by the provisions in this Privacy Statement regarding notice and choice and the service agreements with our customers. The Company maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance with our Privacy Shield obligations, including the onward transfer provisions, and Identifee remains liable if they fail to meet those obligations and we are responsible for the event giving rise to damage.

Identifee acknowledges that you have the right to access your personal information. If personal information pertaining to you as an individual has been submitted to us by one of our customers and you wish to exercise any rights you may have to access, correct, amend, delete, or limit uses or disclosures of such data, please inquire with our customer directly. Because Identifee personnel have limited ability to access data our customers submit to our products and services, if you wish to make your request directly to Identifee, please provide the name of the Identifee customer who submitted your data to our products and services. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

How Identifee protects your data

Security of your information is of the utmost importance to us. Identifee uses reasonable security practices, including technical and physical safeguards, to protect the security of your personal information from misuse and unauthorized access and disclosure. Nevertheless, such security measures cannot prevent all loss, misuse, alteration, or unauthorized access or disclosure of personal information, and we are not able to guarantee absolute security.

Collection of information from children

The Company recognizes the importance of protecting the privacy and safety of children. Our websites and services are directed towards the general audience and are not directed towards children. We do not knowingly collect information about children under the age of 13 or minors otherwise defined in local law or regulation without verifiable parental consent. If we learn that someone under 13 has provided personal information through one of our websites, we will use reasonable efforts to remove that information from our databases

Access and choice

Identifee may retain your information for a period of time consistent with the original purpose of collection, legitimate business interests, to conduct audits, comply with our legal obligations, resolve disputes, and enforce our agreements.

We acknowledge that you have the right to access your personal information. Upon request, we will provide individuals with reasonable access to their personal information, and in doing so allow individuals the opportunity to, under certain circumstances, correct, amend, update, or delete that information or limit uses and disclosures of that information. A request may be denied under certain circumstances, such as where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question, or where the rights of persons other than the individual would be violated. For requests to access, correct, modify, delete, or limit uses or disclosures of your personal information, please contact us using the information in the “How to contact us” section below. Requests will be addressed within a reasonable timeframe. If you are an employee of Identifee, you may also wish to contact your Human Resources group for assistance in correcting or updating your information. As noted above in Section 5, if we are hosting or processing your personal information on behalf of a customer, requests to access, correct, modify, update, delete, or limit uses, or disclosures of your personal information should be made through the customer.

Additional Information for California Consumers (users)

In addition to other rights described under this Privacy Policy in relation to the Services, California consumers (users from the State of California) have the below rights under the California Consumer Privacy Act (CCPA):

  • Right to know about the personal information Identifee collected, shared, or sold: You may request that we disclose the categories of personal information (personal information is the term for PII under the CCPA) we collected, shared, sold, or disclosed in the past 12 months.
  • Right to request the deletion of personal information: You may request the deletion of personal information at any time. This can be done via your account within the Applications. This right does not include any information we are required by applicable law to retain (for example, transaction data).
  • Right to opt-out of the sale of personal information: we are not in the business of selling, renting, or disclosing personal information to third parties for their direct marketing goals. We will only disclose personal information to third party marketers upon your request.
  • Right to Non-Discrimination: Identifee shall not discriminate against you when you decide to exercise any of the rights above.

Conflicts with this Privacy Statement

This Privacy Statement may not apply to the extent it conflicts with other controlling terms and conditions (such as, for example, an agreement for our products and services between Identifee and you or your organization) or applicable law or regulation.

How to contact us

Any questions, inquiries, complaints, and requests related to this Privacy Statement can be directed to us by email at support@identifee.com.