We may revise our privacy policy from time to time. If we make material changes we will post an announcement on our Website. If we are going to use consumers’ personal information in a manner different from that stated at the time of collection we will notify the consumer directly or indirectly through our customer, to obtain the consumer’s consent for the new use of their personal information.

Personally Identifiable Information 

ValidiFI collects the following personally identifiable information (PII):

From visitors to our website (www.validifi.com) we may collect:

• Name, company name, telephone number, email address, and any other information provided in a web form.
• We improve our products and advertising by using Microsoft Clarity to see how you use our website. By using our site, you agree that we and Microsoft can collect and use this data.

From our employees and job applicants we may collect:

• Name, physical address, telephone number, email address, date of birth, social security number, driver’s license or other government issued document identification, marital and gender status, employment and education history, and other personal information necessary to provide health and other employee benefits as well as consider employment and onboard employees.

From our customers we may collect:

• Name, company name, mailing address, telephone number, email address, and payment information.

From consumers (and/or from customers acting with the authorization of consumers) we may collect:

• Name, physical address, telephone number, email address, date of birth, social security number, bank account number, bank routing number, credit or payment card information, employment information, driver’s license number, username and password, records of personal property.
• Name, driver’s license or other form of government-issued identification and any other information you provide for purposes of exercising your rights under the Fair Credit Reporting Act and/or California law (the latter as described in the section entitled California Residents: Your Rights of this privacy policy).

Cookies

ValidiFI uses cookies to store information about your preferences, to record user-specific information on which pages of our Sites you access or visit, and to personalize or customize our web page content based upon your browser type or other information that you send via your browser.

Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. Our Websites use first and third party cookies, however PII is not collected through the use of cookies.

While most browsers are set to accept cookies by default, you can set yours to refuse cookies or to alert you before accepting them. Your browser manufacturer has information on changing the default setting for your specific browser. However, be aware that if you do not accept cookies from our Websites, you may not be able to use some of the features of our Sites.

Non-personally Identifiable Information

Our Websites collect non-personally identifiable information. For example, as you browse www.validifi.com we may collect information about your visit, but not about you personally. Via web server logs, for example, we may monitor statistics such as: the number of people that visit our site, which page(s) are visited on our site, from which domain our visitors come (e.g., aol.com, hotmail.com), and which browsers people use to visit our site (e.g., Google Chrome, Microsoft Internet Explorer).

Our Websites may use an outsourcing program to assist us in analyzing this data to better tailor our Websites for our visitors. For example, we use Google Analytics to help us analyze how visitors are using our Websites. Google Analytics uses cookies to collect information about, for example, the number of visitors to a site, the webpage that referred visitors to a site, and the pages that visitors view within a site. You can opt-out of Google Analytics by downloading Google’s Opt-Out Browser Add-on.

Some internet browsers have “Do Not Track” features which, when turned on, send a signal (“DNT” signal) to websites that the individual visiting the website does not wish to be tracked. ValidiFI does not respond to DNT signals because we engage in online behavioral advertising on third-party sites, known as “retargeting,” through which information collected about the pages an individual visits on ValidiFI’s Websites is used to display ads for ValidiFI on third-party websites.

To learn more about DNT and online advertising, below links provide more information:

• http://www.aboutads.info/choices/
• http://www.networkadvertising.org/choices
• https://support.microsoft.com/en-us/help/17288/windows-internet-explorer-11-use-do-not-track
• http://www.youronlinechoices.com/

ValidiFI provides a suite of data and payment services to measure risk and facilitate payments for our customers and consumers through products such as Bank Aggregation, Payment Instrument Risk Score, and Bank Account Validation. Through our suite of products ValidiFI uses consumer PII to provide services to our customers, including analyzing consumer credit risk, data analytics, risk mitigation, Know Your Customer due diligence, fraud detection, and identity verification.

We also collect PII from prospective employees and employees for employment purposes related to working for ValidiFI.

We use PII collected to:

• Respond to visitor and customer comments, inquiries, or requests for demonstrations.
• Enroll visitors and customers in our newsletter subscription.
• Inform visitors and customers of ValidiFI products or services we think may be of interest.
• Consider employment and/or onboard employees, including to complete necessary paperwork for background checks, employment eligibility, payroll and tax purposes, health, and other employee benefits.
• Maintain customer accounts or verify identity.
• Offer our suite of data and payment service products to our customers which require the use of consumer PII.

ValidiFI uses PII when interacting with consumers to offer a service they have requested through a customer of ours, such as an application for a service or to purchase a product.  If you complete an application with a business and the business uses ValidiFI’s data and payments solutions they may share your PII to assist them with determining eligibility for the issuance of credit in the form of a financial service product or business service. ValidiFI may in turn share your PII with our vendors to process our customer’s request.  ValidiFI’s business relationship is with business providers and the capture of PII is through our customer and on the basis of a consumer’s consent.

In the event PII, such as telephone numbers are collected, and ValidiFI provides a data service to its customers for verification and risk analysis of the telephone number, ValidiFI, and its customers will provide notice to you and will require your authorization to your wireless provider (e.g., AT&T, Sprint, T-Mobile, US Cellular, Verizon, or any other branded wireless operator) to disclose your mobile telephone number, name, address, email, network status, customer type, customer file, billing type, mobile device identifiers (IMSI and IMEI) and other subscriber status and device details, if available, to our third-party service provider, solely and in order to verify your identity and prevent fraud for the duration of the business relationship.

We may also use and disclose PII when onboarding a job candidate and we conduct a background check for employment purposes.  Any PII provided to us by the prospective employee will be provided to our third-party background screening company for purposes of conducting a background check.

If our company or our assets are acquired by another company, that company will assume the responsibility and the rights and obligations regarding the PII maintained by ValidiFI.

Finally, we may disclose information when required by law or in the good faith belief that such action is necessary in order to comply with the law or a legal process.

ValidiFI does not sell PII to third parties for marketing purposes.  The PII collected by us—whether online or offline—is used only for purposes of providing visitors to our Websites, customers and consumers, and employees with services requested or authorized.

We take steps to protect against the loss, misuse, or unauthorized alteration of PII we collect. ValidiFI has implemented administrative, technical, and physical safeguards necessary to reasonably and appropriately protect the confidentiality, security, and integrity of PII in our possession. The PII we collect is protected using industry standard, secure socket layer (SSL) encryption. We limit access to PII to those employees who need access in order to carry out their job responsibilities. When we dispose of PII, we use appropriate procedures to dispose of it, such as shredding physical documents and erasure of electronic media so that information cannot be practicably read or reconstructed.

Third party links on our Sites are provided for your convenience and to provide further information or serve as a resource. They do not signify that we endorse the website(s). ValidiFI exercises no control whatsoever over such other websites and web-based resources and is not responsible or liable for the availability thereof or the content, advertising, products or other materials thereon.

The ValidiFI privacy policy does not apply to third-party websites.  Therefore, when visiting external websites which you may have accessed through our Sites, we recommend that you review the online privacy policy of that website to determine how the operator of that website handles personal information collected through their website.

ValidiFI may offer via the Website third party services, such as social media login, social media sharing and social media commenting. Any information which is collected by ValidiFI when you access a third party service is processed under this privacy policy. Information collected by third party service providers themselves will be governed by their own privacy policy.

For information about our privacy policy and practices please contact:

ValidiFI

6120 Windward Pkwy

Suite 100

Alpharetta, GA 30005

855-562-6678

Privacy@ValidiFI.com

PREPARATION AND PROCESSING OF INVESTIGATIVE CONSUMER REPORTS  

This notice is provided to California residents pursuant to state law.

Pursuant to California law, ValidiFI is an investigative consumer reporting agency that furnishes end-users with investigative consumer reports. Under California law, an “investigative consumer report” is a report containing information on a consumer’s character, general reputation, personal characteristics, or mode of living. ValidiFI compiles investigative consumer reports about individuals and provides them to businesses for background screening and similar purposes.

Personal Information Disclosure: United States or Overseas.  In connection with its preparation and processing of investigative consumer reports, ValidiFI does not transfer personal information about consumers outside the United States and its territories.

CALIFORNIA RESIDENTS: YOUR RIGHTS

California residents (“You” and “Your”) have specific rights regarding their personal information (“personal information” or PI) under the California Consumer Privacy Act (CCPA). This section describes these rights and explains how consumers may exercise their rights with ValidiFI. Please note, however, that the CCPA, and therefore this section of the policy, does not apply to certain activities governed by the Fair Credit Reporting Act.

Right to Know About Personal Information Collected, Disclosed, or Sold

California residents have the right to request that ValidiFI disclose certain information to You about our collection, use, disclosure, and sale of Your personal information over the past twelve (12) months. Upon receipt and verification of Your identity we will disclose to You:

• The categories of personal information we collected about You;
• The categories of sources for the personal information we collected about You;
• Our business or commercial purpose for collecting that personal information;
• The categories of third parties with whom we share that personal information; and
• The specific pieces of personal information we have collected about You (also called a data portability request).

Right to Request Deletion of Personal Information

You have the right to request that ValidiFI delete any of Your personal information that we have collected from You and maintain, subject to certain exceptions. Upon receipt and verification of Your identity we will delete Your personal information from our records unless retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the personal information, take actions reasonably anticipated within the context of our business relationship with You, or otherwise perform our contract with You.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on Your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which You provided it.

Exercising Your Rights to Know and Deletion

To exercise your rights please submit a request to:

ValidiFI

6120 Windward Pkwy

Suite 100

Alpharetta, GA 30005

855-562-6678

Privacy@ValidiFI.com

For email correspondence please write in the subject line in ALL CAPS the following:

CALIFORNIA RESIDENT EXERCISE OF CCPA RIGHTS

You may also complete the following web form: https://validifi.com/consumer-access/

Only You, or someone legally authorized to act on Your behalf (i.e., your authorized agent), may make a request related to Your personal information. An authorized agent is someone acting on Your behalf and ValidiFI may ask that You provide Your authorized agent with written permission to act on Your behalf and also to verify their own identity.

Your request must:

• Provide sufficient information for us to reasonably verify You are the person about whom we collected personal information or an authorized agent.
• Describe Your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

Making a request does not require You to create an account with us, however, if You have an existing account with us, all requests must be made through that account.

We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request. ValidiFI will require a requesting consumer to provide two to three pieces of personal information which we will match with personal information we maintain in our records in order to verify the identity of the individual making the request.

Non-Discrimination

ValidiFI will not discriminate against You for exercising any of Your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you services.
• Charge You different prices or rates for services, including through granting discounts or other benefits, or imposing penalties.
• Provide You a different level or quality of services.
• Suggest that You may receive a different price or rate for services or a different level or quality of services.

Categories of Personal Information Collected and Disclosed in the Last Twelve (12) Months

You have the right to know, without making a request, the categories of personal information ValidiFI has collected and disclosed from its consumers within the last twelve (12) months.

Categories of PI Collected

In the preceding twelve (12) months, ValidiFI has collected the following categories of personal information about consumers:

• Identifiers, such as name, physical address, telephone number, email address, date of birth, social security number, bank account number, bank routing number, credit or payment card information, employment information, driver’s license number, username and passwords either to provide services requested by our customers or for internal employment-related purposes.
• Personal information such as that listed in the California Customer Records statute, including name, driver’s license or other form of government-issued identification and any other information provided by consumers in the process of exercising their right under the Fair Credit Reporting Act and/or California law.
• Protected classification characteristics such as age.
• Commercial information such as records of personal property to provide services requested by our customers.
• Internet or other similar network activity such as browsing and search history to improve the usability of our Website.
• Geolocation data to provide services requested by our customers.
• Professional or employment-related information such as employment history and information captured from our employees for on-boarding purposes as well as to administer benefits, payroll, and for tax purposes related to employment.

The PI collected is also explained above in our Information We Collect section of our privacy policy.

Categories of PI Disclosed

In the preceding twelve (12) months, ValidiFI has disclosed the following categories of personal information to our customers as well as third party service providers for a business purpose:

• Identifiers, such as name, physical address, telephone number, email address, date of birth, social security number, bank account number, bank routing number, credit or payment card information, employment information, driver’s license number, username and passwords either to provide services requested by our customers or for internal employment-related purposes.
• Commercial information such as records of personal property to provide services requested by our customers.
• Protected classification characteristics such as age.
• Geolocation data to provide services requested by our customers.
• Professional or employment-related information such as employment history and information captured from our employees for on-boarding purposes as well as to administer benefits, payroll, and for tax purposes related to employment.

The PI disclosed is also explained above in our When, Why and Who We Disclose Information To section of our privacy policy.