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Privacy Policy

Effective date: July 03, 2019

Introduction

Reference Services, Inc. (“RSI,” “we,” “our,” or “us”) operates the www.referenceservices.com website (the “Service”). We are committed to protecting the privacy, confidentiality, and security of personal information. This Privacy Policy describes how we collect, use, disclose, protect, retain, and dispose of information obtained through our website and related services. It also explains the choices available to individuals regarding their personal information.

As a provider of background screening and consumer reporting services, RSI complies with applicable privacy, consumer protection, and information security requirements, including the Fair Credit Reporting Act (FCRA) and other applicable federal and state laws.

By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used here have the same meanings as in our Terms and Conditions, accessible from www.referenceservices.com.

Scope

This Privacy Policy applies to:

Visitors to our website;

Individuals who contact RSI through our website, email, telephone, or other communication channels;

Customers and prospective customers interacting with RSI services; and

Personal information collected in connection with the operation and maintenance of our website.

Consumer information collected and processed in connection with background screening services may also be governed by RSI’s Consumer Information Privacy Policy and applicable law.

Definitions

Service

Service is the www.referenceservices.com website operated by Reference Services, Inc

Personal Data

Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

Information We Collect

Information You Provide

We may collect information you voluntarily provide that can be used to contact or identify you, including:

  • Name (first and last)
  • Company name
  • Email address
  • Telephone number
  • Mailing address (address, city, state/province, ZIP/postal code)
  • Job title
  • Information contained in inquiries, requests, communications, or forms submitted to RSI

Information Collected Automatically (Usage Data)

When you visit our website, we may automatically collect information on how the Service is accessed and used, including:

  • IP address
  • Browser type and version
  • Device information and unique device identifiers
  • Operating system
  • Date and time of access
  • Website pages visited and time spent on those pages
  • Referring websites
  • Session information and website activity
  • Other diagnostic data

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service and to improve and customize our Service. You can enable or disable location services at any time through your device settings.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies, such as beacons, tags, and scripts, to track activity on our Service and to hold certain information. Cookies are files with a small amount of data, which may include an anonymous unique identifier, that are sent to your browser from a website and stored on your device.

We use these technologies to:

Maintain website functionality;
Improve user experience;
Analyze website traffic;
Enhance website security; and
Understand website usage patterns.

Examples of cookies we use:

  • Session Cookies to operate our Service.
  • Preference Cookies to remember your preferences and settings.
  • Security Cookies for security purposes.

You may instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Consumer Reporting Information

RSI is a consumer reporting agency that provides background screening and related services.

Consumer information collected, maintained, or disclosed in connection with background screening services is also governed by RSI’s Consumer Information Privacy Policy, which is available on our website and upon request. This Privacy Policy should be read in conjunction with the Consumer Information Privacy Policy when evaluating RSI’s handling of consumer report information and personal data.

Information collected, maintained, or disclosed in connection with consumer reports is handled in accordance with:

  • The Fair Credit Reporting Act (FCRA);
  • Applicable state laws;
  • Contractual obligations with customers; and
  • RSI privacy and information security requirements.

RSI does not sell consumer report data or consumer information for marketing purposes.

How We Use Information

We may use personal information to:

  • Provide and maintain our Service;
  • Notify you about changes to our Service;
  • Allow you to participate in interactive features of our Service when you choose to do so;
  • Respond to inquiries and requests;
  • Provide customer support;
  • Communicate regarding products and services;
  • Provide you with news, special offers, and general information about other goods, services, and events we offer that are similar to those you have already purchased or inquired about, unless you have opted not to receive such information;
  • Gather analysis or valuable information so that we can improve our Service and website functionality;
  • Monitor usage, website performance, and security;
  • Detect, investigate, prevent, and address fraud, unauthorized activity, and technical issues;
  • Comply with legal and regulatory obligations; and
  • Protect the rights, property, and security of RSI, our customers, and others.

Marketing Communications and Opt-Out

We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that may be of interest to you. You may opt out of receiving any or all of these communications by following the unsubscribe link or the instructions provided in any email we send, or by contacting us using the information below.

Legal Basis for Processing Personal Data

Where required by applicable law, including the General Data Protection Regulation (GDPR) for individuals in the European Economic Area (EEA), RSI’s legal basis for collecting and using personal information depends on the Personal Data we collect and the specific context in which we collect it. RSI may process your Personal Data because:

  • We need to perform a contract with you;
  • You have given us permission to do so (consent);
  • The processing is in our legitimate interests and is not overridden by your rights;
  • We need to comply with the law; or
  • Another lawful basis permitted under applicable law applies.

Information Sharing & Disclosure

RSI does not sell personal information.

We may disclose information:

  • To authorized customers for permissible purposes;
  • To service providers performing services on our behalf;
  • To auditors, regulators, accreditation bodies, or legal authorities when required;
  • To comply with legal obligations, court orders, subpoenas, or lawful requests;
  • To protect and defend the rights, security, or property of RSI or others, to prevent or investigate possible wrongdoing in connection with the Service, to protect the personal safety of users of the Service or the public, or to protect against legal liability; or
  • In connection with a merger, acquisition, reorganization, or sale of assets.

Any third-party service providers that receive personal information are required to maintain appropriate confidentiality and security safeguards.

Information Security

RSI maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction, or misuse.

Security controls may include:

  • Role-based access controls;
  • Need-to-know access restrictions;
  • Multi-factor authentication where appropriate;
  • Encryption of sensitive information and backups;
  • Network monitoring and logging;
  • Security awareness training;
  • Vendor security reviews; and
  • Physical and environmental safeguards.

The security of your data is important to us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While we employ commercially reasonable measures to protect your Personal Data, we cannot guarantee its absolute security.

Data Retention

RSI retains information only as long as necessary to:

  • Fulfill business purposes;
  • Meet contractual obligations;
  • Comply with legal, regulatory, and accreditation requirements;
  • Resolve disputes; and
  • Enforce agreements and policies.

Retention periods may vary based on the type of information and applicable legal requirements. RSI also retains Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time than other information, except when it is used to strengthen security or improve the functionality of our Service, or when we are legally obligated to retain it for longer periods.

Secure Disposal

When personal information is no longer required, RSI disposes of information using secure destruction methods designed to render the information unreadable and unrecoverable, consistent with applicable legal and regulatory requirements.

Incident Response and Notification

RSI maintains information security incident response procedures designed to detect, investigate, contain, and remediate security incidents.

If a security incident involving personal information occurs, RSI will provide notifications as required by applicable law and regulatory requirements.

Your Privacy Rights

Depending on applicable law, individuals may have rights to:

  • Access, update, or delete personal information;
  • Correct inaccurate or incomplete information (rectification);
  • Object to processing;
  • Restrict processing;
  • Request data portability, meaning a copy of your information in a structured, machine-readable, and commonly used format;
  • Withdraw consent at any time where processing is based on consent; and
  • Submit complaints to appropriate regulatory authorities.

Where possible, you can access, update, or request deletion of your Personal Data directly within your account settings. If you are unable to do so yourself, please contact us and we will assist you. If you wish to be informed about what Personal Data we hold about you and want it removed from our systems, please contact us.

Please note that we may ask you to verify your identity before responding to such requests.

Additional Information for Residents of the European Economic Area (EEA)

If you are a resident of the EEA, you have the data protection rights described above under the GDPR. RSI aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA.

Third-Party Services and Service Providers

We may employ third-party companies and individuals to facilitate our Service, provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These providers are authorized to access personal information only as necessary to perform these tasks on RSI’s behalf, are required to maintain appropriate safeguards, and are obligated not to disclose or use it for any other purpose.

Analytics

RSI may use website analytics services and similar technologies to help understand website performance, visitor activity, security events, and opportunities for service improvement.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt out of having your activity on the Service made available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information about visit activity with Google Analytics. For more information on Google’s privacy practices, please visit https://policies.google.com/privacy?hl=en.

Microsoft Clarity and Microsoft Advertising

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay, to improve and market our products and services. Website usage data is captured using first- and third-party cookies and other tracking technologies to determine the popularity of products and services and online activity. We also use this information for site optimization, fraud and security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement: https://privacy.microsoft.com/en-US/privacystatement.

Users may also manage analytics and cookie preferences through available browser settings and applicable third-party opt-out mechanisms.

Transfer of Information

Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction, where data protection laws may differ from those of your jurisdiction. Information may be stored or processed within the United States or other jurisdictions in which RSI or its service providers operate.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

RSI will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.

Children’s Privacy

RSI’s website is not directed toward children and is not intended for use by individuals under the age of 18 (“Children”). We do not knowingly collect personally identifiable information directly from anyone under the age of 18 through our public website, including for marketing purposes.

If you are a parent or guardian and you are aware that your Child has provided us with Personal Data through our website, please contact us. If we become aware that we have collected Personal Data from children through our website without verification of parental consent, we take steps to remove that information from our servers.

However, in connection with authorized background screening and consumer reporting services, RSI may receive, process, or maintain personal information relating to minors when such information is provided by a parent, legal guardian, educational institution, employer, client, or other authorized party and when permitted by applicable law. Such information is handled in accordance with applicable legal requirements, contractual obligations, and RSI’s privacy and information security controls.

Parents or legal guardians with questions regarding information relating to a minor may contact RSI using the information provided in this Privacy Policy.

Links to Other Websites

Our website may contain links to external websites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. RSI has no control over, and assumes no responsibility for, the content, privacy policies, security, or practices of any third-party sites or services.

Changes to This Policy

RSI may update this Privacy Policy periodically to reflect changes in legal requirements, business practices, technologies, or services.

Updated versions will be posted on this page with a revised effective date. We will let you know via email and/or a prominent notice on our Service prior to the change becoming effective, and will update the effective date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, please contact us: