PRIVACY POLICY

easyBackgrounds, Inc.

easyBackgrounds, Inc. (easyBackgrounds) has established policies and procedures dedicated to maintaining the privacy of information which relates to, and can be used to identify, contact, or track a discreet, natural person (“Personal Information”) while providing its clients with the necessary information for making informed decisions involving background screening. In most cases, our clients represent current and or potential employers engaged in pre- or post-hire background screening on individuals who have provided consent to have their Personal Information released and used for background screening purposes. Individuals can also use easyBackgrounds to access their own background information by submitting Personal Information directly. easyBackgrounds does not differentiate between company clients and individual clients and this privacy policy applies to both individuals and companies that provide Personal Information to easyBackgrounds for this purpose.

1. Scope This policy incorporates the practices of easyBackgrounds as they pertain to data submitted by clients via www.easybackgrounds.com (the “easyBackgrounds Website”, or “Website”), and to other information secured from third parties and other sources in connection with delivering background screening information or results to our clients. With respect to providing background screening information, easyBackground will only be processing such data at the direct instruction of an entity who is subject to the Fair Credit Reporting Act as a user of consumer reports.

easyBackgrounds complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States. easyBackgrounds has certified to the Department of Commerce that it adheres to the principles of Notice, Choice, Accountability for Onward Transfers, Security, Integrity & Purpose Limitation, Access, and Recourse (“Privacy Shield Principles”). If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view easyBackgrounds’s certification, please visit https://www.privacyshield.gov/.

easyBackgrounds is subject to the investigatory and enforcement powers of the Federal Trade Commission.

2. Data Security easyBackgrounds will employ reasonable safeguards to protect Personal Information in its possession from loss, misuse, unauthorized access, disclosure, alteration or destruction. For Personal Information subject to electronic storage or transmission, easyBackgrounds maintains an internal private, secure network that is protected from computer malicious software and monitored for unauthorized access. Personal Information is transferred utilizing secure socket layer (SSL) technology and is User ID and Password protected. Our servers reside in a secure environment protected from unauthorized access, natural disaster, fire, or other compromising conditions.

3. Notice

Purpose for Collection, Use, and Disclosure of Personal Information

Generally, Personal Information about an employee will only be released to the entity or entities to whom the individual consented to receive such information. This information will not be released to any other individual and will not be used for any other purpose by easyBackgrounds except as permitted by this Privacy Policy or as required by law.

Information Collected

Information Provided Directly by You

easyBackgrounds’ clients provide Personal Information regarding their employees or prospective employees via our Website when placing an order for background screening services. Information provided may include but is not limited to residential history, personal history including name, date of birth, Social Security number, motor vehicle operator’s (driver’s) license number, professional license information, employment history, education and other credentials. easyBackgrounds will use information provided by the client and subject of the order, along with any other information provided by third-parties, only for the execution of producing a background screening report for the client placing the order, and for no other purpose.

Information Collected Automatically

easyBackgrounds sometimes collects and stores non-personal data submitted by individuals that are neither clients nor employees or prospective employees of clients, and are inquiring about services provided by easyBackgrounds (e.g. contact inquiry section). This data is collected for market analysis purposes.

Website Navigational Information

As you navigate the site, we may also collect information through the use of commonly used information-gathering tools, such as cookies and web beacons (collectively “Website Navigational Information”). Website Navigational Information 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).

Cookies

Like many companies, we may use cookies on this site. Cookies are pieces of information shared between your web browser and a website. Use of cookies enables a faster and easier experience for the user.

We use cookies for the following purposes:

Where strictly necessary

These cookies are essential in order to enable you to move around the site and use its features, such as accessing secure areas of the site. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.

Performance

These cookies collect information about how visitors use a site, for instance which pages visitors go to most often, and if they get error messages from web pages. They also allow us to record and count the number of visitors to the site, all of which enables us to see how visitors use the site in order to improve the way that our site works. These cookies do not collect information that identifies a person, as all information these cookies collect is anonymous and is used to improve how our site works.

Functionality

These cookies allow our site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. For instance, a site may be able to remember your log in details, so that you do not have to repeatedly sign in to your account when using a particular device to access our site. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize. They may also be used to provide services you have requested such as viewing or commenting on content on the site. The information these cookies collect is usually anonymized.

Please consult your web browser’s ‘Help’ documentation or visit aboutcookies.org for more information about how to turn cookies on and off for your browser.

Disclosures to Third Parties & Accountability for Onward Transfers

We do not disclose any Personal Information about you collected by this site to any third parties, except as stated in this Privacy Policy, or as otherwise permitted by law, or authorized by you.

While executing orders for our clients, easyBackgrounds may transfer Personal Information between its Website, its client and its client’s employee or prospective employee. It should be noted that some clients that receive our reports may be located outside the United States. We reserve the right to employ other organizations or individuals as our subcontractors, to perform functions on behalf of easyBackgrounds.

easyBackgrounds may share an individual’s information with contractors, government agencies and/or partners of easyBackgrounds in connection with services that these individuals or entities perform for, or with, easyBackgrounds. As noted earlier, where legally possible, third parties to whom we disclose information are required by law and contractual undertakings to keep your Personal Information confidential and secure, and to use and disclose it for purposes that a reasonable person would consider appropriate in the circumstances, in compliance with all applicable legislation, which purposes are as follows:

• To provide the products and services you have requested from us;

• To notify you or allow our affiliated companies to notify you of certain products or services offered by our affiliated companies;

• For legal, regulatory, and employment services;

• To process transactions through data processing service providers; and

• If the information is a credit card number, to process credit card payments through third party payment processing, clearing and settlement systems in association with various banks.

If these third parties wish to use your Personal Information for any other purpose, they will have a legal obligation to notify you of this and, where required, to obtain your consent.

easyBackgrounds may be liable for the transfer of personal data to third parties. Where easyBackgrounds has knowledge that a consultant, independent contractor or partner is using or disclosing Personal Information in a manner inconsistent with this Privacy Policy, easyBackgrounds will take reasonable steps to prevent or stop such improper use and/or disclosure.

Affiliate Sharing

In the normal course of performing services for our clients, Personal Information may be shared within easyBackgrounds and its affiliates for research and statistical purposes, system administration, and crime prevention or detection. When you supply us with information containing third party Personal Information (names, addresses, or other information relating to living individuals), we will hold and use that Personal Information to perform general screening and other services for you on the understanding that the individuals to whom the Personal Information relates have been informed of the reason(s) for obtaining the Personal Information, the fact that it may be disclosed to third parties such as easyBackgrounds, and have consented to such disclosure and use.

Service Providers

Because a number of the service providers we use are located in the United States, including certain easyBackgrounds affiliates, your Personal Information will be processed and stored inside the United States, and the U.S. government, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your Personal Information under US laws.

easyBackgrounds’ service suppliers adhere to the same protections regarding the collection, use, and retention of data as we do.

Business Transactions

As we continue to develop our business, we might sell or buy assets. In such transactions, user information, including Personal Information, generally is one of the transferred business assets. Also, if either easyBackgrounds itself or substantially all of easyBackgrounds assets were acquired, your Personal Information may be one of the transferred assets. Therefore, we may disclose and/or transfer your Personal Information to a third-party purchaser in these circumstances

Other Legally Required Disclosures

easyBackgrounds preserves the right to disclose without your prior permission any Personal Information about you or your use of this site if easyBackgrounds has a good faith belief that such action is necessary to: (a) protect and defend the rights, property or safety of easyBackgrounds, employees, other users of this site, or the public; (b) enforce the terms and conditions that apply to use of this site; (c) as required by a legally valid request from a competent governmental authority including to meet national security and/or law enforcement requirements; 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

California’s “Shine the Light” Law

California Civil Code Section 1798.83 requires any operator of a website to permit its California-resident customers to request and obtain from the operator a list of what Personal Information the operator disclosed to third parties for direct marketing purposes, for the preceding calendar year; and the addresses and names of such third parties

4. Data Integrity & Purpose Limitation

easyBackgrounds will make reasonable efforts to ensure the accuracy of information delivered. easyBackgrounds relies on other entities, including but not limited to courts, educational institutions, individuals, and other sources for its information, and, therefore, cannot guarantee the accuracy or timeliness of information reported.

easyBackgrounds will not process Personal Information in a way that is incompatible with the purposes for which it has been collected or subsequently authorized by the individual.

easyBackgrounds maintains written or electronic copies of information received in conjunction with services rendered in accordance with our Record Retention Policy. At the end of the retention period, it is destroyed either electronically or mechanically in accordance with industry standard data destruction methods. Reports generated using data collected in or originating from a European Union Member State and/or Switzerland shall not be kept longer than necessary for the purpose of meeting our obligations to our client and the law.

5. Choice

Employees or prospective employees of easyBackgrounds’s clients will be advised by their employer or prospective employer that a background check will be conducted. Consent forms that easyBackgrounds obtains from a consumer’s employer or from the consumer directly affirmatively declare that the consumer agrees to provide personally identifying information, and consents to easyBackgrounds’s use of that information in accordance with this Privacy Policy. In addition, we may rely on the following actions by you as indication of your consent:

• Your voluntary provision of Personal Information to us directly;

• Your express consent or acknowledgement contained within a written, oral, or electronic application process; and

• Your verbal consent solicited by easyBackgrounds (or our agent) for a specified purpose.

Except as permitted by this Privacy Policy or as required by law, easyBackgrounds will not supply Personal Information to anyone other than the consumer, an authorized representative of the consumer, or the client that orders the background screening of the consumer.

Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. easyBackgrounds will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for easyBackgrounds to collect, use or disclose your Personal Information could mean that we cannot provide the requested services or information for you. If you wish to withdraw your consent, please refer to the contact information section below (Section 11).

Individuals that do not want personal data made available to easyBackgrounds’s client (current or prospective employers), should not submit personal data to easyBackgrounds via its client.

6. Access

As the subject of a consumer report or investigative consumer report, a consumer has the right to access any reports easyBackgrounds produces regarding him or her, as well as the personal data that was provided to easyBackgrounds in conjunction with the preparation of such reports. Consumers, including EU and Swiss individuals, may contact easyBackgrounds via the contact information below to obtain a report including this information, if such a report has been created and has not been deleted pursuant to easyBackgrounds’s data retention policy. In accordance with this policy and its efforts to maintain the privacy of personal data, easyBackgrounds requires proof of a consumer’s identity prior to delivering any Personal Information. Information will be mailed via U.S. Postal Service within 7 days of a consumer’s request, in the same format it was delivered to a consumer’s current, future, or former employer. There will be no expense to a consumer for easyBackgrounds to provide a copy of their report(s) to them.

Requests should be mailed to easyBackgrounds, Inc., PO Box 952, Newfields, NH 03856-0952 and include a photocopy of a government issued ID (driver`s license, passport, etc.).

If a consumer believes any information in easyBackground`s possession is incorrect, he or she should contact easyBackgrounds directly as described in the section that follows to discuss this belief with an easyBackgrounds support representative.

7. Independent Recourse Mechanism

For Non Human Resources Data:

In compliance with the EU-U.S. and Swiss-US Privacy Shield Principles, easyBackgrounds commits to resolve complaints about its collection or use of your Personal Information. Individuals in the European Union and/or Switzerland with inquiries or complaints regarding our Private Shield policy should first contact easyBackgrounds at:

Support at easyBackgrounds

P.O. Box 952 Newfields, New Hampshire 03856 USA

Telephone +1 (800) 538-6525

Email support@easybackgrounds.com

easyBackgrounds has further committed to refer unresolved Privacy Shield complaints to BBB EU PRIVACY SHEILD, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit http://www.bbb.org/EU-privacy-shield/ for more information or to file a complaint. The services of BBB EU Privacy Shield are provided at no cost to you.

Finally, and as a last resort, EU and Swiss individuals with unresolved non human resources complaints may, under limited circumstances, invoke binding arbitration before a Privacy Shield Panel.

For Human Resources Data:

In compliance with the EU-U.S. and Swiss-US Privacy Shield Principles, easyBackgrounds commits to resolve complaints about its collection or use of your Personal Information in the context of the HR relationship. Individuals in the European Union and/or Switzerland with inquiries or complaints regarding our Private Shield policy should first contact easyBackgrounds at:

Support at easyBackgrounds

P.O. Box 952 Newfields, New Hampshire 03856 USA

Telephone +1 (800) 538-6525

Email support@easybackgrounds.com

easyBackgrounds commits to cooperate with the panel established by the EU data protection authorities (DPAs) and/or the Swiss Federal Data Protection and Information Commissioner and to comply with the advice given by the panel and/or Commissioner, as applicable, with regard to human resources data transferred from the EU and/or Switzerland in the context of the employment relationship.

8. Verification

easyBackgrounds will conduct compliance audits of its privacy practices to verify adherence to this Statement. All reported breaches or potential breaches will be investigated by the Compliance Officer, who will take such action as deemed appropriate in the investigation.

9. Changes or Amendments

This Privacy Policy may be modified or amended at any time. If it is determined in the future that information will be used in a new and material way, easyBackgrounds will provide appropriate public notice of any changes.

10. Contact Information

Please review this Privacy Policy prior to contacting easyBackgrounds with requests or questions. Any questions or comments regarding this Privacy Policy should be submitted to the Chief Compliance Officer at the following address:

Comments at easyBackgrounds Attention: Chief Compliance Officer

P.O. Box 952 Newfields, New Hampshire 03856 USA

Telephone +1 (800) 538-6525

Email support@easybackgrounds.com