Your privacy and trust are important to us. This Privacy Policy (the “Policy”) provides important information about how Authenticating.com LLC and its worldwide affiliated companies and subsidiaries (“Authenticating.com,” “we,” or “us”) handle your Personal Information. This Policy applies to any Authenticating.com website, application, product, software, or service that links to it (collectively, our “Services”). Occasionally, the Service will link to a different Privacy Policy that will outline the particular privacy practices of that Service.

We offer a wide range of Services to businesses, and individuals, including background screening and identity verification. For example, we offer:

• Technological solutions for providing trust and safety on peer-to-peer exchanges.
• Identity confirmation for individuals to prove themselves online.
• Background checks and identity verification for businesses that want to screen current or prospective users.

Depending on the Service you use, we may collect different information about you, and additional privacy terms, notices, and/or disclosures may apply to your use of those Services. This Policy does not cover data collected by or through third-party websites or services or any information collected in any way other than through the Services.

IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU ARE NOT GRANTED PERMISSION TO USE THIS WEBSITE OR THE SERVICES AND MUST EXIT IMMEDIATELY

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your Personal Information choices. It is important that you check back often for updates to this Policy. If we materially change this Policy, we will notify you in accordance with applicable laws, by placing a notice on the relevant Services and/or contact you using other methods such as email.

This Policy was last updated on March 3, 2022.

Personal Information

Authenticating.com is committed to the responsible handling and protection of your Personal Information.

“Personal Information” means any information relating to an identified or identifiable natural person – i.e., a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

We collect, use, disclose, transfer, and store Personal Information when needed to provide our Services, for our operational and business purposes, and as otherwise described in this Policy. We want to be clear about our privacy practices so that you can make informed choices about the use of your information, and we encourage you to contact us at any time with questions or concerns.

The types of Personal Information We Collect:

We collect Personal Information from you in many ways. For example, if you purchase or use our Services, request information, register for an event, or request customer support, we may ask you to provide information such as your name, address, phone number, government-issued identification number, email address, user name and password, and information about your device. Not all of the Personal Information Authenticating.com holds about you will always come directly from you. It may, for example, come from your employer, other organizations to which you belong, or a professional service provider such as your tax or accounting professional or attorney, or another company/website, if they use our Services. We also collect Personal Information from third parties such as our partners, service providers, and publicly available websites, to offer Services we think may be of interest and to help us maintain data accuracy and provide and enhance the Services.

In addition, our servers, logs, and other technologies automatically collect certain information to help us administer, protect, and improve our Services; analyze usage; and improve users’ experience. We share Personal Information with others only as described in this Policy, or when we believe that the law permits or requires it.

Services for Business Customers

We may collect Personal Information from you in order to provide Services to our business customers. For example, if you are the subject of a background check, or if a business customer requests that you verify your identity with us, we may collect some identifying information about you in order to provide those Services.

• Verifying your identity. To run an identity verification check on you for a business customer, we collect Personal Information from you so that we can confirm that you are who you say you are. This Personal Information could include your legal name, date of birth, and other identifying details such as your Social Security number, residential address, phone number, email address, social media handles, photos or a government-issued photo ID document.
• Authorizing a background check. When you authorize one of our business customers to run a background check on you, we may use your legal name, date of birth, and other identifying details such as your Social Security number, residential address, phone number, email address, social media handles, etc. (depending on the type of background check requested).
• We corroborate your legal name, date of birth, and other identifying details such as your Social Security number, residential address, phone number, email address, social media handles, and photos against authoritative databases, such as those maintained by consumer data bureaus, financial institutions, and government agencies.
• We confirm your phone number during the provision of the Services by verifying a unique code that we send you.
• We confirm your email during the provision of the Services by verifying a unique link that we send you.
• We confirm your photos during the provision of the Services by verifying a unique self-portrait taken instantaneously by you.
• We confirm your social media accounts during the provision of the Services by verifying your login information.

Collection from Third Party Sources

If you authorize us to create a background report about you, we'll collect public records and other information from third-party sources to assemble the report. We may also verify information you provide us against authoritative government databases or information providers. If you are a business customer, we may also use data providers like Salesforce, HubSpot, and LinkedIn to supplement the information you provide to us.

Occasionally, we may collect and process what may be considered Sensitive Personal Information. “Sensitive Personal Information” is a subset of Personal Information and is generally defined as any information related to racial/ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health, other medical information including biometric and genetic data, or sexual life or preferences. In some instances, Sensitive Personal Information may also include criminal allegations or convictions, precise geolocation information, financial and bank account numbers, or unique identifiers such as governmentissued social security numbers, driver’s license, and passport numbers.

For example, if you purchase something from us or subscribe to our Services, we will collect payment information, such as financial or bank card information, and other information necessary for us to process the transaction. If your service professional uses our Services, we will collect and process financial and tax information. Some of our Services will ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the Service. We may also collect information such as a government-issued identification number. Information that is considered sensitive under applicable law will be handled in accordance with such laws.

Biometric Identity Verification

Biometric identity verification is performed using facial recognition, namely, by comparing two or more captured images of faces. For example, we may compare the face on a government-issued photo ID against a "selfie" that you capture and send to us. The biometric identifiers used to perform this comparison are derived from the photographs that you submit. After performing the comparison, the biometric identifiers are destroyed within a reasonable time, although the underlying photographic images may be retained indefinitely. We may also reanalyze the photographic images to confirm the results of an initial identity verification, and the resulting re-created biometric identifiers will similarly be destroyed within 24 hours after re-analysis. Because biometric identifiers are derived from these photographic images for the initial purpose of identity verification and fraud prevention, you agree that we may use this biometric information for up to 3 years after you submit it to us.

You acknowledge and agree that:

• biometric information is being collected from you when you submit images to us;
• you have been informed in writing of the specific purpose and length of term for which biometric information is being collected, stored, and used; and
• by using the Services, you are providing a release to us in writing that you expressly authorize us to perform these activities

We may automatically fail your identity verification, or ask you to provide supplemental identity documents if we detect anomalies or suspicious activity during the provision of the Services, even if you correctly pass other portions of the verification process.

How we use Personal Information:

• Account setup and administration: We use Personal Information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.
• Personalization: We use Personal Information to deliver and suggest tailored content and to personalize your experience with our Services. Some of our Services will ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the Service. If you agree to share your precise geolocation with us, you will be able to turn it off at any time by going to the privacy settings on your mobile device or online.
• Marketing and events: We use Personal Information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
• Surveys and polls: If you choose to participate in a survey or poll, any Personal Information you provide may be used for marketing or market research purposes.
• Research and development: We use personal information for internal research and development purposes and to improve and test the features and functions of our Services.
• Chat rooms, messaging, and community and event forums: As part of our Service offerings, we may from time to time provide features including chat rooms, messaging services, and community and event forums for collaboration, peer connection, games, and information exchange purposes. Depending upon the Service, the Personal Information you choose to post, share, upload, or make available is public and visible to others who use those Services. You should never post or share any information that is confidential or about others unless you have permission to do so. We may use information you provide in community and event profiles and forums to personalize your experience and to make content and peer connection recommendations. These Services may have their own Terms of Use and, where appropriate, their own privacy statements. We moderate these Services for compliance with our Terms of Use.
• Hosted services: Some of our Services provide data and document storage as an integral part of the product or solution offering. Documents and data stored by our customers may contain Personal Information in business and personal tax forms, payroll and financial data, for example. Any information stored by or on behalf of our customers is controlled and managed by and only made accessible to those customers or others our customers may authorize from time to time. Our access to this information is limited to Authenticating.com personnel with a critical business reason, such as technical support.
• Legal obligations: We may be required to use and retain Personal Information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use Personal Information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, or those of other persons.

We process personal information for these Service- and business-related purposes:

When we share Personal Information:

Authenticating.com shares or discloses Personal Information when necessary to provide Services or conduct our business operations as described below. When we share Personal Information, we do so in accordance with data privacy and security laws. We may occasionally share non-personal, anonymized, and statistical data with third parties. Below are the parties with whom we may share your Personal Information and why.

• Within Authenticating.com: Our business is supported by a variety of Authenticating.com teams and functions in various jurisdictions, and Personal Information will be made available to them if necessary for the provision of Services, account administration, sales and marketing, customer and technical support, and business and product development, for instance. All of our employees and contractors are required to follow our data privacy and security policies when handling Personal Information.
• Our business partners: We may occasionally partner with other organizations to deliver co-branded or private-label Services, provide content, or to host content, and events. As part of these arrangements, you may be a customer of both Authenticating.com and our partners, and we and our partners may collect and share information about you. Authenticating.com will handle Personal Information in accordance with this Policy, and we encourage you to review the privacy policies of our partners to learn more about how they collect, use, and share Personal Information.
• Our third-party service providers: We partner with and are supported by service providers around the world. Personal Information will be made available to these parties only when necessary to fulfill the services they provide to us, such as software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfillment and delivery. Our third-party service providers are not permitted to share or use Personal Information we make available to them for any other purpose than to provide services to us.
• Data Analysis Partners: We may partner with unaffiliated third parties (such as data brokers, marketing companies, and IT service providers) to provide data integrity analysis. We may share certain demographic information, location data, advertising and device identifiers, IP address, and usage statistics with these partners and other third parties, some of whom may use it to offer promotions to you for other products and services.
• Third parties for legal reasons: We will share Personal Information when we believe it is required, such as:
  • To comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities, which may include such authorities outside your country of residence.
  • In the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings)
  • To protect our rights, users, systems, and Services.

You acknowledge that, due to the nature of the Services, we will need to share your Personal Information with third parties for the purpose of confirming its authenticity. Those third parties may include consumer data bureaus, government agencies, financial institutions, mobile network operators, and other vendors that provide access into these systems. If a third-party business partner (someone who requires you to provide an identity before accessing their services) has directed you to Authenticating.com to verify your information, you agree that we may share verification results with that party.

Where we store and process Personal Information.

The Services are controlled and operated from within the United States. We make no representation that the Services are appropriate or available for use outside the United States, or that access to and use of the Services in accordance with this Policy complies with the laws of your jurisdiction. Those who choose to access the Platform from outside the United States do so on their own will and are fully responsible for compliance with applicable laws.

How we secure Personal Information.

Authenticating.com takes data security seriously, and we use various technologies and procedures to protect your Personal Information. Our information security policies and procedures are closely aligned with widely accepted standards and are reviewed regularly and updated to meet our business needs, changes in technology, and regulatory requirements.

For example:

• Policies and procedures
  • We have measures in place to protect against accidental loss and unauthorized access, use, destruction, or disclosure of data
  • We have a Business Continuity and Disaster Recovery strategy that is designed to safeguard the continuity of our service to our clients and to protect our people and assets
  • We place appropriate restrictions on access to Personal Information
  • We implement security measures and controls, including monitoring and physical measures, to store and transfer data securely
  • We conduct Privacy Impact Assessments in accordance with legal requirements and our business policies
• Training for employees and contractors
  • We require privacy, information security, and other applicable training on a regular basis for our employees and contractors who have access to Personal Information and other sensitive data
  • We take steps to ensure that our employees and contractors operate in accordance with our information security policies and procedures and any applicable contractual conditions
• Vendor risk management
  • We require, through the use of contracts and security reviews, our third-party vendors and providers to protect any Personal Information with which they are entrusted in accordance with our security policies and procedures

How long we keep Personal Information.

Authenticating.com implements policies and rules relating to the retention of Personal Information. We retain Personal Information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, Authenticating.com takes into consideration local laws, contractual obligations, and the expectations and requirements of our customers. When we no longer need Personal Information, we securely delete or destroy it.

Your right to access and correct your Personal Information.

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Information.

• Access to Personal Information: If you request access to your Personal Information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
• Correction and deletion: In some jurisdictions, you have the right to correct or amend your Personal Information if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Information; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by contacting us.
• Marketing preferences: To opt out of email marketing, you can use the unsubscribe link found in the email communication you receive from us or visit the applicable email preference center. For other marketing preferences, you can use the “Contact Us” option within the relevant Service. Information related to controlling cookies can be found herein, as can information related to Interest-Based and Mobile Advertising.
• Filing a complaint: If you are not satisfied with how Authenticating.com manages your personal data, you may have the right to make a complaint to a data protection regulator in your jurisdiction.
• California Residents: California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the Personal Information (if any) that we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request to us at the addresses listed below.

Please contact us with any requests related to your Personal Information.

Cookies and similar technologies

Authenticating.com and our third-party providers set and use cookies and similar technologies to store and manage user preferences, deliver targeted advertising, enable content, and gather analytic and usage data, for example. The use of cookies and other tracking technologies is standard across websites and apps through which information is collected about your online activities across applications, websites, or other services. More information about how we use cookies and similar technologies is below.

What is a cookie?

A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of four categories, depending on their function and intended purpose: absolutely necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.

Types of cookies and why we use them.

• Absolutely necessary cookies: These cookies are essential to enable you to move around a website and use its features. Without these cookies, services you have asked for, like adding items to an online shopping cart, cannot be provided.
• Performance cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies don’t collect information that personally identifies you and only collect aggregated and anonymous information. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.
• Functionality cookies: These cookies allow the website to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide services you have asked for, such as watching a video or commenting on a blog. The information these cookies collect may be anonymized, and they cannot track your browsing activity on other websites.
• Targeting and advertising cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.

Managing cookies.

You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.

Other tracking technologies.

• Local shared objects/Flash cookies: Flash cookies, also known as local shared objects, are designed to support browser content supported by Adobe® Flash. They are usually used to enable ads and video content on websites. Like other cookies, they will store information on your device, some of which will be specific to the Flash-enabled content. Flash cookies can only be deleted within Adobe Flash rather than via your browser.
• Web beacons: Our web pages may contain electronic images known as web beacons (also called single-pixel gifs and transparent graphic images) that we use to help deliver cookies on our sites, count users who have visited those sites, deliver services, and analyze the effectiveness of our promotional campaigns, for example. We may also include web beacons in our marketing email messages or newsletters to determine whether an email is opened or if links are clicked.
• Web server & application logs: Our servers automatically collect certain information to help us administer and protect the Services, analyze usage, and improve users’ experience. The information collected includes:
  • IP address and browser type
  • Device information including Unique Device Identifier (UDID), MAC address, Identifier For Advertisers (IFA), and similar identifiers we or others may assign
  • Device operating system and other technical facts
  • The city, state, and country from which you access our website
  • Pages visited and content viewed, stored, and purchased
  • Information or text entered
  • URLs visited before and after you use our Services

Interest-based advertising (IBA)

Interest-based advertising (IBA) allows us to deliver targeted advertising to users of our Services. IBA works by showing you advertisements that are based on the type of content you access or read. For example, as you browse our Services, one of the cookies placed on your device may be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests.

Opting out of IBA.

If you want to opt out of receiving interest-based advertising, it does not mean that you will no longer receive advertising when you are using our Services. It just means that we will not use information collected about you for IBA and that any advertising you see will not be customized or relevant to you. You can exercise your online advertising choices at http://optout.aboutads.info or by clicking the AdChoices icon in an ad and following the instructions. You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative's (NAI) Opt Out Tool (http://www.networkadvertising.org/choices). If you delete cookies, use a different device, or change web browsers, you may need to opt out again.

Advertising on mobile devices.

Mobile devices have an identifier that gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. Another tool you can use to control advertising on your mobile device is the AppChoices App: http://youradchoices.com/appchoices. You may also choose to turn off location tracking on your mobile device. If you turn off ad tracking or location tracking, we will no longer use information collected from your device’s advertising identifier for the purposes of advertising. You may still see the same number of ads but they may be less relevant because they will not be based on your interests.

Do not track

Some browsers transmit Do Not Track (DNT) signals to websites. Due to the lack of a common interpretation of DNT signals throughout the industry, Authenticating.com does not currently alter, change, or respond to DNT requests or signals from these browsers. We will continue to monitor industry activity in this area and reassess our DNT practices as necessary.

Connecting via social networks

Some of the Services may include social networking features, such as the Facebook® “Like” button and widgets, “Share” buttons, and interactive miniprograms. Additionally, you may choose to use your own social networking logins from, for example, Facebook or LinkedIn®, to log into some of our Services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your Personal Information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on the Services.

Links and connections to third-party services

Our Services may contain links to and may be used by you in conjunction with third-party apps, services, tools, and websites that are not affiliated with, controlled, or managed by us. Examples include Facebook, LinkedIn, Twitter® and other third-party apps like voice software and readers. The privacy practices of these third parties will be governed by the parties’ own Privacy Policies. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to these third-party services.

Children’s privacy

Authenticating.com provides information solutions for professionals, and our Services are generally not aimed at children. If, however, we collect and use information about children, such as to develop an educational resource, we will comply with industry guidelines and applicable laws.

How to contact us

We understand that you may have questions or concerns about this Policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:

Authenticating.com Data Protection Officer

Address

730 Arizona Avenue, 230
Santa Monica, CA 90401
Attention: Data Protection Officer

Marketing preferences and services support

To update your account information or email marketing preferences, or for technical support or other help with your Services, please visit the applicable email preference center or use the Contact Us option for the relevant Service.