Introduction

SecurTest, Inc. is committed to the responsible use of information and protecting individual privacy rights. SecurTest strives to provide services to businesses, consumers, and government agencies that help make sound hiring decisions, mitigate risk, facilitate more informed business decisions, and make society safer.

SecurTest, Inc. (the “Company” or “we”) has developed this California privacy policy out of respect for the privacy of our clients, visitors to our website, job applicants, and independent contractors. This policy describes the personal information we collect, use, and disclose about individual clients, consumers, applicants, and contractors who visit or interact with this website, visit our Company headquarters, purchase, or inquire about any of our services, contract with us to provide services, apply for a position of employment, or otherwise interact or do business with us.

Whenever you visit our website, we will collect some information from you automatically simply by you visiting and navigating through this site, and some voluntarily when you submit information using various forms on the website, enroll in or subscribe to our newsletter or marketing communications, request information, or use any of the other interactive portions of our website. Through this website, we will collect information that can identify you and/or your activity.

Additionally, whenever you communicate, interact, or do business with us, whether online or at our headquarters, or whether you are contracted to perform services for us or apply for a position of employment, we will be collecting personal information from you or about you during our interaction or dealings with you.

Scope of Application

The California Consumer Privacy Act (the “CCPA,” as codified in Cal. Civ. Code §1798.100 et seq.) is a data privacy law that provides California residents with several privacy protections. It is important to note that the CCPA does not apply (or has specific exceptions) to the types of business services provided by SecurTest that are governed by the federal Fair Credit Reporting Act (the “FCRA”) as a consumer reporting agency, such as employment background screening If you are a U.S. resident, and were the subject of a background screen, and would like to exercise your rights under the FCRA; you can do so by emailing us at privacy@securtest.com.

Outside of FCRA-type services, the following SecurTest services may be subject to the CCPA, depending on your organization’s use of the services:

• Drug Testing
• Driver Services
• Fleet Compliance
• Fingerprinting
• I9 Services

This California Consumer Privacy Act privacy policy is provided by SecurTest that either (1) acts as a business within the meaning of the CCPA or (2) is controlled by SecurTest and uses the SecurTest name. This policy refers to these companies as “we” or “us.” California law requires us to disclose to California residents certain information regarding the categories of Personal Information we collect. For purposes of this section, “Personal Information” has the meaning provided by the California Consumer Privacy Act (the “CCPA”) and may exclude certain publicly available information, deidentified, aggregated, subject to GLBA, FCRA, HIPAA, or the Driver’s Privacy Protection Act of 1994, or otherwise exempt or excluded from the CCPA.

Use of Personal Information

SecurTest uses the Personal Information about you, which is subject to the CCPA, for the following purposes:

• Providing services to our clients (usually your employer).
• Enhancing and improving the services we provide our clients.
• Developing new functionality to offer to our clients.
• Establishing and maintaining communications with you and the SecurTest client you work with.
• Meeting legal, security, processing, and regulatory requirements.
• Ensuring the terms of the Service Agreement are complied with.
• Establishing, enforcing, or defending legal claims.
• Protecting against fraud, suspicious, or other illegal activities.
• Compiling statistics for analysis of the Sites and our business.

We may use Personal Information for any of the above purposes, but such use will be necessary and proportionate for such purpose.

Personal Information We Collect

SecurTest collects Personal Information in several different ways. We collect Personal Information from you directly when you interact with our services (“direct data collection”). We collect Personal Information automatically when you interact with our website or mobile applications (“navigational data collection”). Finally, we collect Personal Information from publicly available databases, such as public government records or other data compilers (“third-party data collection”).

Direct Data Collection

As part of our direct data collection, we collect the following categories of Personal Information about California consumers:

• Personal identifiers (such as first and last name, postal address, telephone number, social security number, and driver’s license).
• Sensitive Personal Information (such as physical characteristics, insurance policy number, bank account number, credit card number, debit card number, general financial information, medical information, health insurance information, precise geolocation information, race, or gender).
• Commercial or transactional data (such as records of property, products, or services purchased, obtained, or considered; vehicle information; insurance claims; insurance underwriting information); and
• Credential information (such as professional or employment-related information and educational information).

This information will be collected directly from you.

Third-Party Data Collection

As part of our third-party data collection, we collect the following categories of Personal Information about California consumers:

• Personal identifiers (such as first and last name, postal address, telephone number, social security number, and driver’s license).
• Sensitive Personal Information (such as physical characteristics, insurance policy number, bank account number, credit card number, debit card number, general financial information, medical information, health insurance information, race, or gender).
• Commercial or transactional data (such as records of property, products, or services purchased, obtained, or considered; vehicle information; insurance claims; insurance underwriting information); and
• Credential information (such as professional or employment-related information and educational information).

We will collect all this information from public sources or third parties legally permitted to provide such data.

Navigational Data Collection

For visitors to our website or users of our mobile applications (collectively, the “Sites”), we may also collect information using commonly used information-gathering tools, such as cookies and web beacons (collectively “Navigational Data”). Navigational Data 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). Where Navigational Data is attributable to you, directly or indirectly, we will consider it Personal Information.

Cookies

Like many companies, we may use cookies on the Site. Cookies are pieces of information shared between your web browser and a website. The 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 are only stored on your computer during your web session. They are automatically deleted when the browser is closed.
• Persistent cookies: A persistent cookie is stored as a file on your computer and 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 SecurTest Party’s servers and your computer’s hard drive. They are not used for anything other than personalization, as you set. 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 server and your computer’s hard drive. These cookies are usually Persistent cookies.

IP Addresses

When you visit our Sites, we collect your 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 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.

We use the above technologies (or ones we incorporate in the future) for the purposes set out above or as permitted by law.

Automated Preference Signals

Some browsers have attempted to implement the draft “Do Not Track” (“DNT”) standard of the World Wide Web Consortium (“W3C”). As this standard has not been finalized and is not generally accepted in the industry, the Sites are incompatible 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.

Disclosure of Personal Information

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. We may disclose Personal Information for any purposes stated in this Policy or as otherwise permitted by applicable law.

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 for purposes described earlier in this Policy.

Service Providers

We may disclose Personal Information to our Service Providers for any of the purposes stated in this Policy. Because a number of the service providers we use are in the United States, your Personal Information may be processed and stored inside the United States, and the U.S. government, courts, law enforcement, or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws. We do not disclose Personal Information to service providers outside the scope of obtaining services from them. We may disclose your personal information to background screening providers or educational institutions upon your consent as part of our background screening services.

SecurTest Clients

Due to the nature of your relationship with a SecurTest client, we consider your personal information a business record of the client affiliated with you. As such, we may disclose your Personal Information to the client affiliated with you. We will do this for any of the purposes specified in this Policy, as well as upon your request or the client’s request.

Other Legally Required Disclosures

SecurTest reserves the right to disclose, without your prior permission, any Personal Information about you or your use of the Site if we have a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of SecurTest, our employee, 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.

Should law enforcement contact us with a demand for Personal Information, we will attempt to redirect the law enforcement agency to request that data directly from you. If compelled to disclose Personal Information to law enforcement, we will promptly notify you and provide you a copy of the demand unless legally prohibited from doing so. If we are compelled by law to delete Personal Information, we will promptly comply and, if legally permitted, notify you of such deletion.

Your Rights Regarding Personal Information

California residents have certain rights with respect to the Personal Information collected by businesses. As a California resident, you may exercise the following rights regarding your Personal Information:

The Right To Know

This section applies only to California residents who are natural persons; it does not apply to any entities (whether business, non-profit, or governmental). If you are a California resident, you have the following rights:

(a) the categories and specific pieces of Personal Information we collect, use, and disclose about you; (b) the categories of sources of the Personal Information; (c) the categories of Personal Information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed; (d) the business or commercial purposes for collecting Personal Information.

• The right to correct Personal Information that may need to be corrected.
• The right to request that we delete the Personal Information we have collected from you.
• Any disclosure of your Personal Information to a SecurTest client is at your direction.
• The right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA.

Please note that these rights are not absolute and are subject to several exceptions. Should we decline any request to exercise a right noted below, we will explain the reason for our declining such request.

Rights Under the CCPA and CPRA

1. The right to request, up to 2 times in a 12-month period, that we identify to you (1) the categories of personal information we have collected about you going back to January 1, 2022, unless doing so would be impossible or involve disproportionate effort, or unless you request a specific time period, (2) the categories of sources from which the personal information was collected, (3) the business or commercial purpose for collecting, selling, or sharing this information, (4) the categories of third parties with whom we share or have shared your personal information;
2. Right to Access. The right to request, up to 2 times in a 12-month period, that we disclose to you, free of charge, the specific pieces of personal information we have collected about you going back to January 1, 2022, unless doing so would be impossible or involve disproportionate effort, or unless you request a specific time period.
3. Right to Delete. The right to request, up to 2 times in a 12-month period, that we delete personal information that we collected from you, subject to certain exceptions.

Exercising Your Rights

To exercise any of the above rights, please contact us using the following information and submit the required verifying information, as further described below:

By email at privacy@securtest.com

By phone at 1-800-845-6004

By mail to:

600 Grand Panama Blvd., Suite 202,
Panama City Beach, FL 32407

Verification Process and Required Information

Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. To exercise your rights for a copy of the specific pieces of Personal Information we process under the CCPA, we will require you to provide, at a minimum, first name, last name, social security number, and address. For requests submitted by mail, you will need to send copies of two forms of identification that include your first name, last name, and current address.

In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity or where the information is subject to an exemption, as discussed above.

Authorized Agent

You may designate an authorized agent to make a CCPA request on your behalf through the designated methods set forth in these disclosures, where we can verify the authorized agent’s authority to act on your behalf.

For requests to know or delete Personal Information: (i) receiving a power of attorney valid under the laws of California from you or your authorized agent; or (ii) receiving sufficient evidence to show that you have: (a) provided the authorized agent signed permission to act on your behalf; (b) verified your own identity directly with us pursuant to the instructions set forth in these Disclosures; and (c) directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf. This may be done by mailing two forms of identification showing your first name, last name and current address and a signed authorization allowing an agent to request information on your behalf.

Safeguards

We have 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 SecurTest expressly disclaim any such obligation.

Changes

If there is any material change to your rights under this Policy, SecurTest will provide you with notice of such change 30 calendar days before the changes go into effect. As part of this notice, SecurTest may post a notice of the change on the Site in a clear and conspicuous manner for the 30-day calendar-day notice period. SecurTest may also communicate the change via email or postal mail if this is the way that SecurTest normally corresponds with you. Please note that your continued use of the Site once this 30 calendar day period is over indicating your agreement to the changes that were the subject of the notice.

4. Right to Correct. The right to request that we correct inaccurate personal information (to the extent such an inaccuracy exists) that we maintain about you.

5. The right to designate an authorized agent to submit one of the above requests on your behalf. See below for how you can designate an authorized agent; and

6. The right to not be discriminated or retaliated against for exercising any of the above rights, including an applicant’s and independent contractor’s right not to be retaliated against for exercising the above rights.

You can submit any of the above types of consumer requests through any of the 3 options below:

1. Submit an online request to privacy@securtest.com

2. Call our privacy toll-free line at 1-800-445-8001.

How We Will Verify That it is You Are Submitting the Request

If you are a California resident, when you submit a Right to Know, Right to Access, Right to Delete, or Right to Correct request through one of the methods provided above, we will ask you to provide some information to verify your identity and respond to your request. Specifically, we will ask you to verify information that can be used to link your identity to particular records in our possession, which depends on the nature of your relationship and interaction with us. For example, we may need you to provide your name, email, phone number, IP address, browser ID, amount of your last purchase with the business, and/or date of your last transaction with the business.

Responding to Your Right to Know, Right to Access, Right to Delete, and Right to Correct Requests

Upon receiving a verifiable request from a California resident, we will confirm receipt by ten business days after receiving it. We endeavor to respond to a verifiable request within forty-five (45) calendar days of receipt. If we require more time (up to an additional 45 calendar days, or 90 calendar days total from the date we receive your request), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Our response will also explain why we cannot comply with a request, if applicable.

We only charge a fee to process or respond to your verifiable request if it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide a cost estimate before completing your request.

For a request to correct inaccurate personal information, we will accept, review, and consider any documentation you provide, and we may require that you provide documentation to rebut our own documentation that the personal information is accurate. You should make a good-faith effort to provide us with all necessary information at the time that you make the request to correct. We may deny a request to correct if we have a good faith, reasonable, and documented belief that a request to correct is fraudulent or abusive. If we deny your request to correct, we shall inform you of our decision not to comply and provide an explanation as to why we believe the request is fraudulent.

If You Have an Authorized Agent:

If you are a California resident, you can authorize someone else as an authorized agent who can submit a request on your behalf. To do so, you must either (a) execute a valid, verifiable, and notarized power of attorney  or (b) provide other written, signed authorization that we can then verify. When we receive a request submitted on your behalf by an authorized agent who does not have a power of attorney, that person will be asked to provide written proof that they have your permission to act on your behalf, and we will also contact you and ask you for information to verify your own identity directly with us and not through your authorized agent. We may deny a request from an authorized agent if the agent does not provide your signed permission demonstrating that they have been authorized by you to act on your behalf.

Consent to Terms and Conditions

By using this website, you consent to all terms and conditions expressed in this Privacy Policy.

Changes to Our Privacy Policy

As our services evolve and we perceive the need or desirability of using information collected in other ways, we may from time to time amend this Privacy Policy. We encourage you to check our website frequently to see the current Privacy Policy in effect and any changes that may have been made to them. If we make material changes to this Privacy Policy, we will post the revised Privacy Policy and the revised effective date on this website. Please check back here periodically or contact us at the address listed at the end of this Privacy Policy.

Consumers With Disabilities

This policy is in a form that is accessible to consumers with disabilities.

Questions About the Policy

This website is owned and operated by SecurTest, Inc. If you have any questions about this Privacy Policy, please contact us at privacy@securtest.com or call 1-800-445-8001.

**This policy was last updated February 28, 2024.