We value your privacy and respect your interest in knowing how information about you is collected and used. VerifyWho app, website www.verifywho.com (collectively referred to as the "Services"), are owned by Lead Cactus LLC (hereinafter referred to as "the Company"). Company is committed to respecting and protecting your privacy. To that end, we have prepared this privacy policy ("Privacy Policy") to describe our information gathering and dissemination practices, how we use it, and any choices you may have and our data protection practices for the Services. The terms “VerifyWho”, “We” “Us” and "Our" refer to the Company and its subsidiaries and affiliates. The terms "You”, “Your", "Yours" and “Users” refer to the User utilizing the Services. This Privacy Policy is also governed by our Terms of Use. By using this Services, you agree to our use of your information as described in this Privacy Policy. We are committed to provide a confidential and safe Service for You to discuss/share Your thoughts and opinions and where Your anonymity is respected therefore we strive to ensure the highest standards of compliance with data protection laws. The information provided by you when using Services, will be used in accordance with this Privacy Policy.
SERVICES
VerifyWho is a database of publicly available sources of information aggregated for your convenience. Through VerifyWho, Visitors can access certain materials posted to or made available through the Site as compiled, distributed, and displayed by VerifyWho and other third-party content providers ("Third-Party Providers") including, but not limited to, third-party websites or services that provide information about individuals (each, a "Search Subject") that can be searched for and accessed through the Site ("VerifyWho Checks").
APPLICATION OF PRIVACY POLICY
This Privacy Policy applies to any visitor to our Services; individuals who contact us or with whom we communicated via phone, email, or otherwise; and Users, including both free trial and paid account holders.
INFORMATION WE COLLECT ABOUT YOU
This section describes information that we collect about you.
We collect personal data about you directly from you, from others, and automatically when you use the Services. If the personal data we process is needed to comply with law, or to enter into or perform an agreement with you, we will inform you accordingly at the time of such data collection. If we cannot collect this data, we may be unable to on-board you as a User or provide Services to you
Information We May Collect Directly from You.
At Account Creation: An email address is required to provision a new account (paid or trial) to use our Services. Without this, we are unable to create your account. You may choose to provide other information at account creation, including contact information (full name, email, phone number, etc.),
When Purchasing Services: If you purchase a paid subscription, you may need to provide us billing and payment information, including full name, email address, company name, credit card number. If you do not provide us this information, you may be unable to subscribe and your access to our Services may be limited:
In Online Submissions: We collect information through interactive features of our Services – e.g., when you submit online forms; participate in surveys, contests, promotions; join online chat discussions; request User support; respond to “Contact Us” invitations; submit testimonials. Personal data gathered may include contact information (full name, phone number, email, etc.), information about your use of VerifyWho, information associated with a Search Subject (such as a name, age, or address) that you use to conduct a VerifyWho Check, and any other information you choose to share.
In Other Communications: You may share information in communications with us relating to the Services, including during phone calls (and call recordings), chats, or over email. Personal data gathered may include contact information, and any other information you choose to share. Please only provide us personal data that we need in order to respond to your request.
Information We Collect from Third Parties:
When Purchasing Services: A third-party intermediary is used to manage credit card processing. It is not permitted to store, retain, or use your billing information for any purpose except for credit card processing on our behalf.
Third Party Sources: Subject to applicable laws, we may gather information about you from lead-sharing tools including LinkedIn Lead Generation, as well as public information – including internet searches relating to you or your company – in order to better service your account and to provide more relevant assistance and marketing.
Information We Collect Automatically: We gather information about your use of the Services through cookies, web beacons, java script, log files, database lookup, pixels, and other technologies. We may automatically collect: your domain name, browser type, browser language preference, device type and operating system; page views and links you click within the Services; IP address, device ID, or other identifier; location information; date and time stamp, and time spent using the Services; referring URL; and your activity within the Services. We may combine this information with other information we have collected about you, including your username, name, and other personal data. See “Use of Cookies, Tracking Technologies, Analytics and Behavioural Marketing” for details.
Information We Collect When you Use VerifyWho App. When you download and use the VerifyWho Background Check App, we also may collect your mobile device’s unique identification number. We will not collect any precise geolocation information from you or your mobile device unless you expressly consent to such collection.
Information About Search Subjects. In connection with providing the VerifyWho Checks, we collect information about Search Subjects from our third-party data providers.
PURPOSES FOR WHICH WE USE PERSONAL DATA
We use the personal data we collect under this Policy in furtherance of our legitimate business interests, which include:
Provision of Services: To provide and operate our Services, fulfil your orders and requests, process your payments, for bug and error reporting and resolution, to perform upgrades and maintenance, and for similar purposes.
User Support: To communicate with you about your use of the Services; respond to your communications, complaints, and inquiries; provide technical support; and for other User service and support purposes
Personalization: To tailor content we send or display to you in order to offer location customization and personalized help and instructions, and to otherwise personalize your experience using the Services.
Marketing and Promotions: With your permission and/or where permitted by law, we may use contact information for direct marketing and promotional purposes. For example, we may use contact information such as your email address to send you newsletters, special offers or promotions, or to otherwise contact you about VerifyWho products or information we think may interest you. As explained above, we do not use Content for direct marketing purposes. You may opt out of receiving marketing emails by following the opt-out instructions in the email or emailing [email protected]. We may still email User service and transaction-related communications, even if you have opted out of receiving marketing communications.
Advertising: To assist in advertising the Services on third party websites.
Analytics and Improvement: To better understand how users’ access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Services and to develop additional products, services, and features.
Protect Legal Rights and Prevent Misuse: To protect the Services; prevent unauthorized access and other misuse; and where we believe necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, or violations of our Terms of Use Agreement or this Policy.
General Business Operations: Where necessary to the administration of our general business, accounting, recordkeeping, and legal functions.
VerifyWho uses data about Search Subjects to provide responses to VerifyWho Checks performed through the Srvices.
We may share information about you with your consent, at your request, or as follows:
To Payment Processors: If you use a third party to facilitate your payment obligations, we will share certain account-usage and billing-related information about your account with such third party for billing and business administration purposes. Payment processors are independent data controllers of your personal data.
To Our Service Providers: We may share information about you with third party vendors, consultants, and other service providers (data processors) who are working on our behalf or providing services to us. We obtain appropriate contractual protections to limit these service providers’ use and disclosure of any information about you that we share with them.
Infrastructure Processors: We use certain third parties for some of the infrastructure used to host data that is submitted to Services, including cloud providers.
Service Processors: We use third party service providers to process your personal data to assist us in business and technical operations. VerifyWho has data processing agreements with such service providers, and their use of and access to personal data is limited to specific purposes. They provide services relating to: billing, User support, internet and connectivity, marketing (direct mail, email, lead generation), security, user experience.
As Required by Law: We release information about you if we believe we must do so to comply with the law or a subpoena, bankruptcy proceeding, or similar legal process.
To Protect Rights: We may disclose information about you, such as your name, contact information, and billing information, to enforce our agreements with you or to protect the rights and safety of VerifyWho, our Users, our users, and the general public, or as evidence in litigation in which we are involved
In a Business Transaction: If VerifyWho is involved in a merger, acquisition, or sale of all or a portion of its assets, your information may be transferred to the acquiring entity as part of the transaction, and may also be reviewed as part of the due diligence review for the transaction. For example, we may need to provide a list of all User accounts and payment histories.
Aggregate and Anonymized Information: We may share aggregate or anonymized information about users with third parties for providing our Services, marketing, advertising, research, or similar purposes. For example, if we display advertisements on behalf of a third party, we may share aggregate demographic information with that third party about the users to whom we displayed the advertisements.
To Business Admins: We don't share User's email to the business admin to protect their privacy if the process is anonymous, we can expect a clear and honest feedback from the customers. We may share User details like IP, email, and other tracing information when User makes some serious threats/abusive comments on the business.
We will not share the information of the Search Subjects for any other purpose; to any acquiring entity in connection with any sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of VerifyWho;
We do not share precise geolocation information (such as collected from your mobile device) with third parties unless you expressly consent to such sharing (except where in response to a valid subpoena or the like).
In order to make our Services as user-friendly as possible, we - like many other companies - use “cookies”.
A cookie is a small text file that a website sends to a visitor’s browser and that sends back information each time the visitor makes a request from the website. A cookie contains a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. Cookies can be accepted, rejected, or identified by configuring your browser’s preferences. Pixel tags or clear gifs are tiny graphics with a unique identifier that are embedded invisibly on a webpage and are used to track a visitor’s movements on a website. We do not tie the information gathered by clear gifs to Personal Information. You can learn more about cookies by visiting www.allaboutcookies.org.
Cookies and pixel tags are used to help recognize a returning visitor, and to help customize the visitor’s online experience. Unless a visitor specifically informs us of his/her identity (e.g. by registering with us), we will not know who the individual visitor is. Our third-party advertising partners may employ pixel tags that help us better manage content on our Services by informing us what content is effective.
Third-Party Analytics: We also use automated devices and applications, such as Google Analytics (more info here) and Optimizely (more info here) to evaluate use of our Services. We use these tools to gather non-personal data about users to help us improve our Services and user experiences. These analytics providers may use cookies and other technologies to perform their services and may combine the information they collect about you on our Services with other information they have collected for their own purposes. This Policy does not cover such uses of data by third parties.Do Not Track: Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Currently, our systems do not recognize browser “do-not-track” requests. In the meantime, you can use the “help” portion of the toolbar on most browsers to learn how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you disable cookies, be aware that some features of our Services/Services may not function.
| Who issues this? | What is its purpose? |
|---|---|
| To allow easy handling and logging of mobile payments to an order. | |
| For analytics | |
| Recaptcha | |
| VerifyWho |
For redirection depending on your location.
_______________ cookies to track if you consent to cookies creation.
______________ session cookies.
Are pixel tags (aka, web beacons or clear GIFs)
To save your preferred currency for products.
|
| Youtube |
To track the number of views for a particular video and user preferences.
To serve up related content or adverts within an embedded YouTube video on the website.
|
YOUR CHOICES AND RIGHTS
Right of access, modification - In general, you have the right to access your Personal Information and to correct or update the Personal Information that you have provided to VerifyWho. If you wish to do so, please contact us with proof of identity, as provided in the Contact Us section (below). You can expect a response to your request within 5 business days
Right to be forgotten - If you wish to cancel your account or request that we no longer use your information to provide you services, please contact us with proof of identity, as provided in the Contact Us section (below). We will accommodate your request to the extent practicable and to the extent that it does not otherwise conflict any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
Right to opt-out of the use of your Personal Information - You may unsubscribe from receiving a newsletter by contacting us as set out in the Contact Us section (below) or clicking on the unsubscribe link provided in the newsletter.
If you wish to opt-out of direct marketing communications, you can always do so by contacting us as set out in the Contact Us section (below). In some cases, we may not be able to remove your Personal Information, in which case we will let you know this and explain why.
Right to Block Cookies - You have the right to block cookies and pixel tags. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or prompt you before accepting a cookie from the Site that you visit. If you decide not to accept our cookies, you will be able to access those parts of our Site that are available to the general public, but you will not be able to access most of our Services.
DATA RETENTION
Except as noted below, we will retain your account profile data as necessary for our legitimate business purposes or to comply with our legal obligations (such as record keeping, accounting, fraud prevention and other business administrative purposes); generally, where we no longer have a legitimate business purpose to retain it, we will anonymize or delete such personal data within 180 days after the closing of your account. However, we will maintain your personal information longer where required for tax or accounting purposes, to ensure we would be able to defend or raise a claim, or where we have a specific need to retain, though we will generally not keep personal data for longer than five years following the last date of communication with you. Legitimate business purposes that we may rely on to keep your personal data when you are not a User include direct marketing (where you have not opted out) for up to two years. Where your information is no longer required, we will ensure it is disposed of in a secure manner.
HOW WE PROTECT YOUR INFORMATION
We have implemented technical, physical, and administrative safeguards to protect your information. However, no company, including VerifyWho, can guarantee the absolute security of Internet communications.
In order to protect your information from loss, misuse or unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. These steps include the following:
A copy of our internal Data Security Policy is available on request.
If you have any questions about how we secure your information, please contact us at [email protected].
DATA BREACHES
Our Data Security Policy includes a clear process for handling a personal data breach, should one occur. Where appropriate, VerifyWho will promptly notify you of any unauthorized access to your personal information.
LINKED SITES/THIRD-PARTY WIDGETS
Our Services include links to other websites with privacy practices that may differ from ours. Any information you submit to a website not belonging to VerifyWho is governed by that site’s privacy statements, not this one. We encourage you to carefully read the privacy statement of any website you visit.
BLOG
Our Site offers publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. In order to post comments within the blog area of our Site you must be a member of our service provider’s site. Our service provider will then allow us to view the comments before they are posted. To request removal of your personal information from our blog, contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Our Services include Social Media Widgets, such as the Share this button or interactive mini-programs that run on our site. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Services. Your interactions with these Features are governed by the privacy policy of the company providing it.
CHILDREN’S PERSONAL DATA
The Services are not directed toward children and we do not encourage children to participate in providing us with any personally identifiable information. We do not knowingly collect any personal data from children under the age of 18. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide personal data through the Services. If you have reason to believe that a child under the age of 18, without a parent or guardian’s consent has provided personal data to us through the Services, please contact us at [email protected], and we will use commercially reasonable efforts to delete that information.
CHANGES TO THIS POLICY
We may update this Policy to reflect changes to our privacy practices. If you are a VerifyWho User and we make any material changes that affect the way we treat information that we have previously collected from you, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice through the Services prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices.
HOW TO CONTACT US/DISPUTE RESOLUTION
If you have any questions or concerns regarding the way in which your personal data is being processed or you want to exercise your rights above, please reach out to VerifyWho using the contact information below:
VerifyWho
101 Colorado St.
#1809
Austin,TX 78701
Email: [email protected]
All communications with us or our authorized agents may be monitored or recorded.
NOTICE FOR CALIFORNIA RESIDENTS
In addition to the above, the following, intended solely for California residents, concerns our handling of certain personally identifiable and/or personal information as required by the California Online Privacy Protection Act and the California Consumer Privacy Act (collectively, "CCPA"). If you are a California resident, you may have additional rights where some of your "Public" and "Personal" information is concerned. If applicable, you may have the right to request that we disclose to you categories and specific pieces of Public information we may have obtained from public data sources and Personal information we may have collected directly from you, if any, and delete such, where required. Please note that we never sell Personal information obtained from you under any circumstances.
Categories of personal information we obtain, collect and/or disclose for business purposes:
Various methods for submitting requests are referenced above, as well as the specific types of Public information we obtain from publicly available data sources and/or Personal information we collect directly from our users. Per CCPA, in response to verified requests for disclosure, we will provide those "categories" of information we obtain or collect. The categories we have obtained or directly collected are: identifiers (such as name, address, email address); general geolocation information (e.g., your city and state); and/or other information that identifies or can be reasonably associated with you. We may disclose these categories of information about you or your use of the Site for business purposes (as defined by applicable law) or as required by applicable law.
How categories of Personal information could be used:
We and our service providers may use the categories of Personal information we collect from and about you consistent with the various aforesaid business purposes and/or as required by law. Please see the relevant sections above for more information.
Sale of Public information:
CCPA sets forth certain obligations for businesses that “sell” personal information. We do not sell Personal information obtained from our site's visitors or subscribers, such as a name or email address provided when subscribing to our Site (unless such information happens to also be publicly available "Public" information that was NOT obtained from such visitors or subscribers but was instead obtained from publicly available data sources independent of anything visitors or subscribers may have provided us). As permitted by law and CCPA regulatory guidance, we may need to share certain limited information about your activity, for example through cookies (see above), with third parties in certain instances--you can control these cookies through browser settings--but this limited sharing would not constitute a sale of Personal information.
Non-discrimination for exercising your rights:
In addition to including information as to how you can exercise your rights under CCPA, please note that we will never discriminate against you for exercising your CCPA or any other rights. We will not deny you any access or service, charge you a different price, whether via a discount or other benefit, or impose fees or penalties, provide a different level of service, or the like (though CCPA permits such practices in some scenarios). CCPA permits companies to offer certain incentives that might result in different prices, rates or quality levels, but any CCPA-permitted financial incentive should reasonably relate to your information's value and contain written terms that describe the program's material aspects and participation in any such financial incentive program requires your prior opt-in consent, which you may revoke at any time. We do not engage in any such practices.
Authorized Agents:
You may authorize another person to submit a request on your behalf. Please note that before completing any requests, and in addition to our identification verification process, we are required to verify that your agent has been properly authorized to request information on your behalf and this may take additional time to fulfill your request.
Upon receipt of a verifiable request, CCPA provides some California residents with such additional rights as follows:
Right to Know.
You may have the right to know and see the categories of data we have obtained, collected or shared about you over the past 12 months (or if we have not done so), including:
To begin your Right-to-Know request, please email us at [email protected] or contact us via the phone number or postal address listed above. We will respond within 10 days with instructions for continuing your Right-to-know request, including any additional information needed concerning yourself so that we may search for applicable Personal information collected or Public information obtained that pertains to You. The information you provide must sufficiently match the information in our database to permit us to verify your request. An authorized agent may also make a request on your behalf.
We will endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
Right to Delete.
You may have the right to request that we delete the information we have obtained regarding, or collected directly from, you (and ask our service providers to do the same). However, we cannot delete Personal information that we are under a legal obligation to maintain and there are a number of other exceptions that include, but are not limited to, when the information is necessary for us or a third party to do any of the following:
Right to ask us not to sell (also known as the right to opt-out).
As explained above, we do not sell Personal information obtained from our site's visitors or subscribers, such as a name or email address provided when subscribing to our Site (unless such information happens to also be publicly available "Public" information that was NOT obtained from such visitors or subscribers but was instead obtained from publicly available data sources independent of anything visitors or subscribers may have provided us). As for the Public information obtained from publicly available data sources, for many years now, we have accommodated requests to opt-out/not to sell/share such information, which can be done in various locations on the Site. For your convenience, you may also email us at [email protected] or contact us via the phone number or postal address listed above to request that we not sell and opt-out your Public information. While we will not sell such Public information that has been opted-out, we reserve the right to disclose Public information to third parties, without notice to you, if required to do so by law, or if we have a good faith belief that disclosure is necessary to (i) act in an emergency to protect someone’s safety; (ii) comply with legal process served on us; or (iii) protect and defend our rights or property. We also reserve the right to transfer Public information to any successor-in-interest to our business.
In summary:
At no cost, you may request information each year regarding any disclosure of your Public or Personal information to third parties for their own direct marketing purposes during the preceding calendar year. You have the right not to be discriminated against for exercising any of the rights listed above. To request access to or deletion of your information, or to exercise any other data rights under California law, please contact us using one of the methods set forth above.
Last updated: May 10, 2021