SELECTION MANAGEMENT SYSTEMS, INC. (SELECTiON.COM®) respects the privacy interests of all current and prospective clients, all web users and visitors and all subjects of consumer reports or investigative consumer reports. Hence, we make the following statement and pledge. We are committed to protecting any information you provide while doing business with SELECTiON.COM® or while visiting our sites as well as protecting any information gathered during the performance of our service. Please carefully read this Privacy Policy to understand how we will treat your personal information.
We Are Committed to Safeguarding Customer Information
In order to provide the consumer report and investigative consumer report products (As defined in the Fair Credit Reporting Act “FCRA”) and services requested from us, we may obtain consumer reports and other information from national credit bureaus and/or other sources of information.
We understand your concern about what we will do with such collected information and believe that you have a right to know how we utilize such information. SELECTiON.COM® takes extreme precautions in protecting the privacy of any and all information gathered. Therefore, we have adopted this Privacy Policy to govern the use and handling of all personal information.
Applicability
This Privacy Policy governs our use of the information provided to us or we otherwise obtain in providing our products and services to you.
This Policy may change from time to time and those changes will be posted on this page (https://selection.com/privacy-policy/) Please check back periodically for the most current information.
Use of Cookies
SELECTiON.COM® sometimes uses cookies to collect anonymous information from visits to our websites to help us provide better service. We may use this data to analyze trends and statistics and to help us provide better customer service, but we do so in ways that keep the information anonymous. A cookie is an element of data that a website can send to your browser, which may then be stored on your system. To learn more about setting browser cookie preferences, review the help section within your browser.
Types of Information
When you visit a SELECTiON.COM® website, we may collect general data including your domain name, the name of the web page from which you entered our site, which pages you visit on our site, and how much time you spend on each page. This general information does not include specific identifying information about you. We use this information only to monitor and improve our sites and, ultimately, our service to you. We do not store any of this data nor do we provide this information to outside parties.
During the establishment of an account with SELECTiON.COM®, certain information about your organization is requested. This information is necessary to document needs, legitimate volumes, and permissible purposes. SELECTiON.COM® must satisfy certain responsibilities to various overseeing bodies in the overall effort to prevent fraud and misuse. We do not share or provide any of this information to anyone other than legitimate governmental bodies during audits of our services or to comply with the law.
SELECTiON.COM® may collect personal information about the subject of any consumer report or investigative consumer report, both when a report is ordered, and during the investigation. When a report is requested from SELECTiON.COM®, personal information is required in order to process the request and perform identity verification. This information may include name, mailing address, Social Security Number, date of birth, phone number, and employment data as well as other information. This information is necessary to ensure that any information gathered and delivered to you is appropriate and pertinent to the subject of the request. We do maintain this personal information in our database but do not provide any of this information to outside parties.
We implement a variety of security measures to maintain the safety of your personal information when you access your personal information. We offer the use of a secure server, and all supplied sensitive information is transmitted via Transport Layer Security (TLS) technology. The information is then stored in in our Database, on servers behind multiple levels of physical security, to be accessed only by those authorized with special access rights to our systems and are required to keep the personal information confidential.
Sensitive PII documents are defined as any one or more type of information including, but not limited to:
- First and Last Name, when combined with two other pieces of PII
- Social Security number
- Username and password
- Passport number
- Credit card number
- Clearances
- Banking information
- Biometrics
- Date and place of birth when combined with other pieces of PII
Access to Sensitive PII is limited to those with a defined need to perform their specific job functions.
We never leave Sensitive PII documents unattended or unsecured.
All files that contain Sensitive PII reside within an approved Company Information System.
Documents containing Sensitive PII are not viewed by unauthorized persons (e.g., Visitors, Contractors, or employees without authorization).
Sensitive PII is not downloaded to personal or employee-owned workstations or mobile devices (such as laptops, personal digital assistants, mobile phones, tablets, or removable media).
In the case of a Social Security Number, only the last four digits are transmitted at any time outside the Company unless an exception exists.
Sensitive PII is not sent through any form of insecure electronic communication (e.g., e-mail, instant message, etc.). E-mails containing Sensitive PII are encrypted using the Company’s prescribed method.
We prohibited sending Sensitive PII by fax to a public fax machine. We contact the recipient beforehand to arrange for its receipt, and a fax cover page is used. The cover page does not contain any Sensitive PII.
By disposing of files that contain sensitive PII, the files are deleted or otherwise disposed of once they are no longer of use.
Sensitive PII documents once no longer of use are placed in designated locked shred receptacles that are emptied by the contracted shredding vendor.
Use of Information
Under no circumstances will we provide or disclose any information regarding you or the subject of a consumer report or investigative consumer report to anyone other than an established, authorized contact of the account. We do not share, disclose, or sell any information, and we only provide consumer reports or investigative consumer reports for permissible purposes in compliance with federal, state, and local laws and regulations.
Former Customers
Even if you are no longer our customer, our Privacy Policy will continue to apply to you.
Children’s Online Privacy Protection Act Compliance
We are in compliance with the requirements of COPPA (Children’s Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our website, products, and services are all directed to people who are over the age of 13.
Confidentiality and Security
We will use our best efforts to ensure that no unauthorized parties have access to any of your information. We restrict access to non-public personal information about you to those individuals and entities who need to know that information to provide products or services to you. We will use our best efforts to train and oversee our employees and agents to ensure that your information will be handled responsibly and in accordance with this Privacy Policy. We currently maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your non-public personal information.
Nevada Resident Rights
Under Nevada Revised Statutes, we do not sell your covered information, as defined by Section 1.6 of Chapter 603A. If you reside in Nevada, you may submit a request to [email protected] in regard to the sale of covered information.
California Information-Sharing Disclosure
SELECTiON.COM® does not share your personal information with third parties for direct marketing purposes without your permission.
California Consumer Privacy Act (CCPA)
Under the California Consumer Privacy Act (CCPA), California residents (as defined in the California Code of Regulations) have specific rights. Nevertheless, under Section 1798.145(d) (Fair Credit Reporting Act exemption) or under Section 1798.145(l)(1) (which exempts personal information collected in the context of a business to business transaction) most of personal information collected and stored by SELECTiON.COM® is exempt from the CCPA. On the other hand, SELECTiON.COM® acts as a service provider rather than a business as defined by the CCPA for much of the services that are not covered by the FCRA.
Nonetheless, related to a small percentage of the personal information that SELECTiON.COM® collects, we may be considered a business subject to the CCPA. For this small percentage of the personal information, we informed you and outline the legal rights of California residents.
Categories of Personal Information We Collect/Disclose for a Business Purpose Only:
- Personal Identifiers: When you interact with SELECTiON.COM®, such as when you create an account or when you visit our website, personal identifiers such as your name, email address, postal address, Internet Protocol (IP) address is collected from your device (IP address) or you. This information may be collected to identify you as visitor to our website or to create your account with us. This information may be disclosed to our payment processors.
- Categories of personal information under California Civil Code: When you make a purchase on one of SELECTiON.COM®’ Services, categories of personal information described in California Civil Code Section 1798.80(e) (like your name, address, telephone number, credit or debit card number, any other financial information, among others) can be collect by us directly from you to process your purchase. This information may be disclosed to our payment processors.
- Commercial information: When you make a purchase on one of SELECTiON.COM®’ Services, Commercial Information, including records of products or services purchased can be collected by us directly from you to process your purchase. This information is collected to facilitate our internal business purposes (such as financial record-keeping) and facilitate your transactions.
- Biometric Information: Under CCPA, “biometric information” may include voice recordings. For quality assurance purposes your call may be recorded if you speak over the phone with a representative of SELECTiON.COM®, and we will inform you that the call will be recorded. SELECTiON.COM® does not collect any other biometric information. This information is not sold or disclosed for any business purpose.
- Internet or other electronic network: When you interact with our website, internet or other electronic network activity information, including search history, browsing history, and information regarding your interaction with our website is collected directly from your device. This information is used for security and internal user analytics purposes.
Your Rights Under the California Consumer Privacy Act (CCPA):
ANY BACKGROUND CHECK DATA LIKE SELECTION.COM® REGULATED BY THE FAIR CREDIT REPORTING ACT (FCRA) IS EXEMPT FROM CCPA DATA RIGHTS REQUESTS.
Where SELECTiON.COM® is acting as a business as defined by the CCPA and where the data collected is not otherwise exempt, you have the right to request that we delete any personal information about you that we have collected.
Where SELECTiON.COM® is acting as a business as defined by the CCPA and where the data collected is not otherwise exempt, you have the right to request that we disclose the categories and specific pieces of personal information about you that we have collected.
Please note that the right to delete under the CCPA is subject to several exceptions including where retention of the information is necessary to do the following:
- Complete your transaction for which the personal information was collected;
- Provide a good or service to you;
- Perform a contract between SELECTiON.COM® and you;
- Detect security incidents, protect you against malicious, deceptive fraudulent, or illegal activity;
- Repair technical errors;
- Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech;
- Comply with applicable law or legal obligation; or
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
You have the right to request that we disclose the following:
(1) The categories of personal information we have collected about you.
(2) The categories of sources from which the personal information is collected.
(3) The business or commercial purpose for collecting personal information.
(4) The categories of third parties with whom we share personal information.
(5) The specific pieces of personal information we have collected about you.
(6) The categories of personal information that we have disclosed about you for a business purpose.
Please note that SELECTiON.COM® does NOT “sell” personal information as this term is defined by the CCPA.
SELECTiON.COM® will not discriminate against you because you exercised your rights under the CCPA. SELECTiON.COM® will not deny you services, charge you different prices or rates for services, provide a different level or quality of services, or suggest that you will receive a different price, level, or quality of services as a result of your decision to exercise your rights under the CCPA.
SELECTiON.COM® does not and will not “sell” personal information as this term is defined by the CCPA, including information collected from minors under 16 years of age.
To exercise your rights under the CCPA or to contact us about our privacy policy, send us an email at [email protected]. You will need to provide basic personal information, such as your name, phone number, and email address so that SELECTiON.COM® may locate your information within our systems. To verify your identity, SELECTiON.COM® requires that you submit a copy of your California driver’s license or proper governmental identification along with your request. If your identity cannot be verified, requests may be denied. This information will only be used to verify your identity and will not be shared with third parties. According to California law, you may allow an authorized agent to make a request for information on your behalf. Also, valid government-issued identification must be provided for this request purpose.
Children’s Information
Our Services are not directed to individuals under the age of 18 and we do not knowingly collect personal information from children under the age of 13. If we discover that we have collected personal information on a child under the age of 13 via the Services, we will promptly remove it from our systems.
Contacting Us
If there are any questions regarding this Privacy Policy, you may contact us using the information below.
SELECTiON.COM®
155 Tri-County Parkway
Suite 150
Cincinnati, OH 45246
e-mail: [email protected]
