Privacy Policy:
Marketing Policy

Welcome to Securecheck360’s privacy notice. Securecheck360 respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. This privacy policy relates only to how we handle personal data for marketing purposes. If you are a candidate or employee of a Securecheck360 Client or of Securecheck360 itself, please follow this link to read the privacy policy applicable to you.

Important Information and who we are

This privacy notice aims to give you information on how Securecheck360 collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Securecheck360 is made up of different legal entities, details of which can be found here. This privacy notice is issued on behalf of the Securecheck360 so when we mention “Securecheck360”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Securecheck360 responsible for processing your data.

In Europe we have appointed a data protection officer (“DPO”) and in the United States of America we have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please make contact using the details set out below.

Contact Details

Securecheck360, LLC

 Postal Address:

6494 Weathers Place Suite 200,

San Diego, CA 92121

 If you are located in Europe, you have the right to make a complaint at any time to the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority, so please contact us in the first instance.

Changes to the privacy policy

Securecheck360 may revise this policy from time to time. If there is a material change to this Privacy Policy, we will post the revised policy at this location. Securecheck360 will not provide less privacy protection, without your consent, to information collected under a prior privacy policy. We encourage you to periodically review this Privacy Policy to be informed of how Securecheck360 is protecting your information.

What data will Securecheck360 collect?

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

What happens if I do not provide my personal data?

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How does Securecheck360 collect my data?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• apply for our products or services;
• create an account on our website;
• subscribe to our service or publications;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources that may be located within the EU, as set out below:

• Technical Data from the following parties:
  • analytics providers, such as Google, based outside the EU;
  • website personalisation providers such as DemandBase, based outside the EU
  • advertising networks, such as Double-click, based outside the EU; and
  • Identity and contact data from the following parties:

• search information providers
• publicly available sources
• data brokers or aggregators
• social media lead generation companies
• lead generation companies such as DemandDrive

• • Contact, Financial and Transaction Data from the following parties:

• Payment and delivery services
• Once collected how does Securecheck360 use personal data?

Securecheck360 collects personal data for various purposes. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

In the next section of this privacy policy you will find further information in respect to the circumstances in which we use personal data and the lawful basis we rely upon.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting [email protected].

Information processed and lawful basis relied on

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Securecheck360 group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or to update your personal information that you have provided us by emailing [email protected] at any time.

When you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of the Services you contract us to perform.

What happens if there is a change in the purpose of processing?

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact [email protected].

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Does Securecheck360 disclose personal data to third parties?

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• Specific third parties such as DemandDrive lead generation, and carefully selected marketing agencies.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Does Securecheck360 provide links to third party websites?

Securecheck360’s web site may provide links to third-party web sites. Please be aware that those third-party web sites are outside of our control and are not covered by this Privacy Policy. If you have questions about how another site uses your information, consult that site’s privacy statement.

Does Securecheck360 use cookies?

Securecheck360’s web site may use the standard technology called a “cookie” to collect information about how you use the web site.

A cookie is a small data file that is transferred to your hard drive and used for record-keeping purposes. A cookie file can contain information such as the URL you came from, your computer’s IP address (i.e., the Internet address of your computer) and domain type (e.g., .com or .org, etc.), your browser type, the country, state and telephone area code where your server is located, the pages of our site that were viewed during a visit, and any search terms that you entered on our site. This information is used for internal purposes only, and we do not link your URL or IP address to any personal information unless you have logged into our website with a Securecheck360 account login and password. In addition, Securecheck360’s website does not allow other parties to collect personally identifiable information about an individual consumer’s online activities over time and across different Websites when a consumer uses the Securecheck360 website.

If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies, although it is possible that some areas of our web site will not function properly if you do so. In particular, you may be required to accept cookies in order to complete certain actions on Securecheck360’s website. Securecheck360’s website does not currently recognize “do not track” signals transmitted by web browsers.

To find out more please click here to view the cookie policy.

What security measures does Securecheck360 use?

Securecheck360 is committed to protecting the personal information that Securecheck360 receives. While we cannot guarantee the security of that information, we utilize a combination of online and offline security technologies, procedures and organizational measures to help safeguard consumer information against loss, misuse, and unauthorized access, disclosure, alteration and destruction.

We employ Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our website. We have installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. Strong password protection protocols are used on our computers, and employees are kept up-to-date on our security and privacy policies. The servers used to store consumer information are maintained in a secure environment with appropriate security measures.

Does Securecheck360 transfer personal data within its group companies and/h4>the European Economic Area (the “EEA”)?

Securecheck360 is a global business providing global services. As such Securecheck360 will share your personal data within Securecheck360. This will involve transferring your data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers or for transfers within the Securecheck360, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

How long is personal data retained for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

What are my rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please follow this link for a summary of your rights.

If you wish to exercise any of the rights set out above, please contact the Securecheck360 Data Protection Officer as set out in the Contact details section.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.