Privacy Policy

Last Updated: January 16, 2025

Scope of this Policy

KarmaCheck, Inc. (“KarmaCheck”) has created this privacy policy in order to describe how we collect, use, maintain, share and protect your personal information when you use our website, karmacheck.com (hereinafter “Website” or “Site”) in connection with KarmaCheck’s background screening services. This privacy policy applies solely to information collected when you visit our Website, except where stated otherwise.

This policy describes the following:

• What information we collect;

• With whom it is shared;

• Whether we sell personal information;

• Cookies, Third-Party Links, Choice, Opt-Out, and Do Not Track signals;

• Data security and confidentiality;

• And who to contact with concerns or questions about our privacy practices.

This policy also includes information specific to California residents under California law.
KarmaCheck’s Site and our services are not directed at children.
‍

Changes to this Policy

This policy may be subject to updates. Any future material changes or additions to the processing of personal information as described in this policy will be communicated to you through an appropriate channel. For example, we may place a prominent notice on our Website or email you to let you know of an updated policy.
‍

Information Collection on our Website

KarmaCheck strives to limit its collection of personal information to that necessary for the offering and administration of our services. Our Site collects the following types of information when you visit:

• Personally identifiable information;

• Non-personally identifiable information.

Personally Identifiable Information

Personally identifiable information (“PII” or “personal information”) is any information that can identify you, such as your name, address, or IP address. Personal information includes background screening results and information and materials provided for background screening purposes. It does not include anonymized, aggregate, or statistical information. Based on your relationship with us, you may be asked to provide certain PII as described below. If certain information is requested but not mandatory, KarmaCheck will identify which information is required.

• Online Questions or Requests (which may be collected through our Site or offline). When you are requesting materials or information from KarmaCheck, we may collect your name, job title, address, email address, phone number, IP address, company name, country/state of residence, and other PII, as well as any other information you provide.

• KarmaCheck Dashboard. As a consumer subject to a background check, you may choose to use the KarmaCheck Dashboard to take control of your background check. When you log in using app.karmacheck.com, my.karmacheck.com, or another KarmaCheck provided URL/portal to access the KarmaCheck Dashboard, we may collect your name, email, phone number, social security number (SSN), DOB, password, and/or other PII in order to set up your KarmaCheck account and create a digital profile for you.

• Background Screening Services. When an organization requests a background check on you, KarmaCheck may collect your PII from the organization or directly from you to process the request. This includes information such as your name, address, date of birth, phone number, social security number (SSN), and other information relevant to your background check, such as your education and employment history and professional license information. This information may be stored in your digital profile.

• Blogs and Newsletters. When you subscribe to our communications, we will collect your email address.

• Billing Information. If you purchase our services you may need to provide payment and billing information, such as your credit card details and billing address.

Non-personally Identifiable Information

When you visit our Website, we may collect and store general Internet data, such as your domain name, browser type, date and time of access, which of our web pages you visited, the referring Uniform Resource Locator (URL) and how long you spent on each page. This information may be collected to assist us in making improvements to our Website and to administer our Website. KarmaCheck may employ third party companies and individuals to facilitate these services (e.g., maintenance, analysis, audit, development). These third parties have limited access to your information and only to perform these services or tasks on our behalf.
‍

Information Use

Personally identifying information may be used to:

• Respond to your inquiries, process requests, or otherwise correspond with you;

• Conduct background checks and pre-fill background check information as requested by KarmaCheck's customers;
  

• Communicate with you about your KarmaCheck background check, including via email and/or SMS text messaging;
  

• Create a digital profile and provide other services authorized by you;
  

• Present you as a qualified individual for potential work opportunities or similar offers;
  

• Provide you with marketing information about KarmaCheck’s services and products;
  

• Process billing, invoice and payment functions when you request KarmaCheck’s services; and
  

• Analyze and improve KarmaCheck’s services.
  

Sale of Personal Information

KarmaCheck does not sell any personal information for marketing purposes. Your phone number will not be shared with third parties or affiliates for marketing/promotional purposes.
‍

Cookies

Cookies can make use of the Internet easier by saving and administering status, preferences, and other user information. In other words, a cookie allows a website to “remember” a user’s actions or preferences over time. For instance, when we use a cookie to identify you, you will not have to enter your log-in credentials during subsequent visits to our Site. Cookies used by the Site do not contain your PII.

KarmaCheck may use cookies to route users through the Site, customize users’ experiences on the Site, to help us send you information about our services, and to improve the Site. When you access the Site, certain non-PII is automatically logged. This information may include your operating system, screen settings, Web browser software, and referring website, if any. It is used for system improvement and administration, security, statistical analysis purposes, and other internal business purposes. The Site may use service providers for analytics purposes. These providers collect information about you anonymously and report website trends without identifying individual visitors. These service providers use their own cookies to track visitor interactions. Website owners can view a variety of reports containing aggregate information about how visitors interact with their website so they can improve their website. KarmaCheck does not control third-party cookies and their use may be governed by the privacy policies of the service providers employing these cookies.

Most browsers are set to accept cookies but users can change the setting to block cookies or otherwise choose how cookies are handled. Although disabling cookies will not interfere with your ability to access the Site, users will need to accept cookies to use certain services on the Site.

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 of our Site 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.

• Google Chrome™

• Mozilla Firefox®
  

• Safari®
  

• Microsoft®
  

• Internet Explorer
  

Third-Party Links and Websites

This privacy policy applies to KarmaCheck’s Website. However, you are able to access third-party sites through our Site by, for example, clicking on hyperlinks to those third-party sites from within our Site. We are not responsible for the content or privacy practices of any third-party sites, and if you visit those websites, we encourage you to review their respective privacy policies. Third party links on our Site 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). KarmaCheck 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. KarmaCheck shall not be responsible or liable, directly or indirectly, for any damage or loss incurred or suffered by any user in connection therewith. Your access and use of linked websites, including information, material, products and services therein, is solely at your own risk.
‍

Choice, Opt-Out and How We Respond to Do Not Track Signals

As a user of our Website, you make the decision whether to proceed with activities that request PII. Note, however, that if you do not provide the requested information, you may not be able to complete certain transactions or receive information from us. If, after subscribing to receive emails or other electronic communications from KarmaCheck you no longer wish to continue receiving such from us, you will be provided with instructions in our communications on how to opt-out of such communications, including by unsubscribing. In addition, you can also contact us through the Point of Contact information provided in this policy.

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/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. This information may be used for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Microsoft Clarity utilizes the system built by the Digital Advertising Alliance to enable opt-out choices. You can opt out of Clarity telemetry by selecting Microsoft here. If you install the Protect My Choices app for your browser, you can ensure your opt-out preference is saved.

KarmaCheck does not respond to Do Not Track (DNT) signals. To learn more about the choices you have regarding online tracking, please visit these sites:

• 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/
  

Information Sharing and Disclosure

KarmaCheck may disclose information we collect through this Site:

• To KarmaCheck’s parent, subsidiaries and affiliates;

• To complete a transaction that you request through our Site;
  

• To complete a transaction requested by KarmaCheck's customers for background screening purposes;
  

• To government agencies or KarmaCheck’s suppliers or vendors in order to conduct; background investigations as requested by you or KarmaCheck's customers;
  

• When required by law, subpoena or other legal process, when pertinent to judicial or governmental investigations or proceedings;
  

• When necessary to investigate, take action or prevent suspected or actual illegal activities, fraud, or potential threats to safety or personal physical safety; and,
  

• If our company or our assets are acquired or purchased by another company, that company will assume responsibility for the personal information collected by us through our Website, and it will assume the rights and obligations regarding the information collected through our Website, as described in this Privacy Policy.
  

Data Retention

KarmaCheck retains personal information to provide you services or product information, respond to inquiries, consider your employment application, partner with you, or as required by contractual, statutory or other legal obligations. Personal information collected for background screening purposes subject to the Fair Credit Reporting Act will be retained for a minimum of five years. KarmaCheck will retain all other personal information as allowed by law. Your personal information, including personal information collected for background screening purposes, will be stored in a digital profile, which may be made available to you at KarmaCheck’s sole discretion. Information in your digital profile may be reused by KarmaCheck for future background screening and/or employment purposes, including to pre-fill background check information as requested by KarmaCheck's customers, as well as for any other purposes authorized by you.
‍

Security and Confidentiality

KarmaCheck strives to protect personal information that we collect, maintain and disclose through the use of appropriate and reasonable administrative, physical and technical safeguards.

For instance, our products and/or services online are transmitted through a secure sockets layer (SSL) transmission, which is a protocol for establishing a secure connection for transmission of your personal information. Further, we have security protocols and measures in place to ensure confidentiality of PII and to protect the PII we maintain about you from unauthorized access or alteration as well as unlawful disclosure. These measures include internal and external firewalls, physical security and technological security measures, as well as encryption of certain information and password protection for account information.

Our security program is designed to: (1) ensure the security and confidentiality of personal information; (2) protect against any anticipated threats or hazards to the security or integrity of the information; and (3) protect against unauthorized access, use, alteration, or unlawful disclosure of the information that could result in substantial harm or inconvenience to any individual.

In the course of business, KarmaCheck may collect or ask that you disclose your Social Security Number. To the extent practicable, KarmaCheck protects the confidentiality of all information we collect, including Social Security Numbers. Accordingly, we prohibit the unlawful disclosure of personal information, including Social Security Numbers, and limit access to same. We dispose of such information by taking reasonable measures to protect against unauthorized access to or use of the information.
‍

Point of Contact

If you have any questions or comments about KarmaCheck’s privacy policy or our privacy practices please contact us at: KarmaCheck, Inc. Privacy Officer privacy@karmacheck.com
‍

PRIVACY NOTICE: CALIFORNIA RESIDENTS

California Residents: Your Rights

California residents have specific rights regarding their personal information (“personal information” or PI) under the California Consumer Privacy Act (CCPA). This section describes your CCPA rights and explains how to exercise them. Please note that data regulated by the federal Fair Credit Reporting Act, including data collected for background screening, is exempt from the following rights created by the CCPA. Other lawful exemptions and applicab
‍

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

You have the right to request that KarmaCheck disclose certain information to you about our collection, use, disclosure and sale of your personal information over the past twelve (12) months. Once we receive and confirm your request, 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;
  

• 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 KarmaCheck delete any of your personal information that we have collected from you and maintain, subject to certain exceptions. Once we receive and confirm your request (including 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; or
  

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  

Data collected for background screening purposes as regulated by the federal Fair Credit Reporting Act is exempt from deletion requests.
‍

Exercising Your Rights to Know and Deletion

To exercise your rights please submit a request to the following email: privacy@karmacheck.com or call the following toll-free phone number: 877-732-2129.

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. You may also make a request on behalf of your minor child. An authorized agent is someone acting on your behalf and KarmaCheck 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.
  

In order to verify your request we will require that you provide us with at least two (2) identifiers based on information we have about you to verify your identity. Those identifiers may include your Social Security Number and Date of Birth.

Existing Account Holders: 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 your account.

We will only use personal information provided in a request to verify the requestor’s identity or authority to make the request.
‍

Right to Non-Discrimination for the Exercise of Your Privacy Rights Under the CCPA

KarmaCheck 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; and/or
  

• 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 KarmaCheck has collected and disclosed from its consumers within the last twelve (12) months.
‍

Categories of PI Collected

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

• Identifiers such as name, physical address, email address, Social Security Number, date of birth, driver’s license number;

• Gender;
  

• Information contained in a consumer report or investigative consumer report, such as criminal history information, professional or employment-related information and education information, reference information, credit history (if permissible), motor vehicle records, drug testing results, and social media information;
  

• Internet or other electronic network activity information, including information regarding your interaction with our Site.
  

This information is collected from you, the consumer, as well as from other sources, such as law enforcement agencies, public record repositories, educational institutions, credit bureaus, employers, and third party databases.

KarmaCheck collects this personal information for the reasons described in the Information Use section of our privacy policy. It is shared with the categories of third parties as described in the Information Sharing and Disclosure section of our privacy policy.
‍

Categories of PI Disclosed

In the preceding twelve (12) months, KarmaCheck has disclosed the following categories of personal information for a business purpose, primarily to provide background screening reports to employers for employment screening purposes as permitted under federal and state law:
‍

• Identifiers such as name, physical address, email address, phone number, Social Security Number, date of birth, driver’s license number;
  

• Gender;
  

• Information contained in a consumer report or investigative consumer report, such as criminal history information, professional or employment-related information and education information, reference information, credit history (if permissible), motor vehicle records, drug testing results, and social media information; and
  

• Internet or other electronic network activity information, including information regarding your interaction with our Site
  

We do not sell or share your personal information for marketing purposes, but we may share information about your interactions with your Site for marketing purposes through our partnership with Microsoft Clarity.

Microsoft Clarity utilizes the system built by the Digital Advertising Alliance to enable opt-out choices. You can opt out of Clarity telemetry by selecting Microsoft here. If you install the Protect My Choices app for your browser, you can ensure your opt-out preference is saved.
‍

KarmaCheck Biometric Data Policy

This policy explains the procedures for the collection, retention, and disclosure of biometric data used by KarmaCheck. As part of its suite of background screening offerings, KarmaCheck offers digital identity verification services to its clients using Au10tix’s proprietary facial comparison technology. Au10tix’s technology uses facial geometry scans to compare facial images to verify the authenticity of a person’s identity identification card and the identity of the person.

‍

Biometric Data Defined

“Biometric Data” includes “biometric identifiers” and “biometric information” as defined in the Illinois Biometric Information Privacy Act (“BIPA”), 740 ILCS § 14/1, et seq, “biometric identifier” as defined under Texas. Bus. & Com. Code §503.001, “biometric identifier” as used in Washington. Rev. Code Ann. §19.375.020, “biometric information” as used in the California Consumer Privacy Act, 2018, “biometric information” as used in the New York Stop Hacks and Improve Electronic Data Security Act, “biometric data” as used in the Arkansas Code §4-110-103, and further includes also any similar definitions under state or local law related to any biological characteristics of a person, or information based upon such a characteristic.

“Biometric Identifier” means, as defined under BIPA, a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry. Biometric identifiers do not include writing samples, written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo descriptions, or physical descriptions such as height, weight, hair color, or eye color. Biometric identifiers do not include information captured from a patient in a health care setting or information collected, used, or stored for health care treatment, payment, or operations under the federal Health Insurance Portability and Accountability Act of 1996. Biometric Identifier has additional similar meanings under the laws stated above under the definition of Biometric Data.

“Biometric Information” means, as defined under BIPA, any information, regardless of how it is captured, converted, stored, or shared based on an individual’s biometric identifier used to identify an individual. Biometric information does not include information derived from items or procedures excluded under the definition of biometric identifiers. “Biometric Information” has additional similar meanings under the laws stated above under the definition of Biometric Data.
‍

Purpose for Collection of Biometric Data

As part of its suite of background screening services, KarmaCheck offers digital identity verification to its clients via a direct integration with Au10tix’s proprietary facial comparison technology. Au10tix’s technology uses facial geometry scans to compare an individual’s identity document (such as a passport or driver’s license) with a live photograph of the individual’s face (“Live Selfie”). This technology is used to verify the authenticity of a person’s identity identification card and the identity of the person. Facial geometry scans may be considered Biometric Data under state laws such as the Illinois Biometric Information Protection Act.

If digital identity verification is requested as part of a background check through KarmaCheck, no Biometric Data will be collected until the subject of the background check completes a Written Release for Collection of Biometric Data.

‍

Retention of Biometric Data

KarmaCheck does not receive or store Au10tix’s facial geometry scans or any other biometric data, but KarmaCheck does store images of the identity documents and Live Selfies used to conduct digital identity verification. Au10tix may store facial geometry scans as permitted by law and in accordance with its Biometric Data Policy.
‍

Disclosure of Biometric Data

Facial geometry scans used for digital identity verification are collected and processed by Au10tix via KarmaCheck’s integration. KarmaCheck does not receive, store, or disclose Au10tix’s facial geometry scans or any other biometric data. KarmaCheck stores images of identity documents and Live Selfies used for digital identity verification and makes these available to the individual employer who requested the background check via the KarmaCheck platform. These images may also be disclosed if such disclosure is required by state or federal law or municipal ordinance or if the disclosure is required pursuant to a valid warrant or subpoena issued by a court of competent jurisdiction.