Last Updated: January 14, 2022
- Communicate with us electronically, such as via email; and
- Interact with us offline, including in person, at an event or via phone.
Note to IDCOM® Mexico Clients
Note to IDCOM® EU Clients
How we collect and use your Personal Information
“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household, such as your name, email address, IP address, telephone number, and broader categories of information such as your professional, educational or health information, commercial information and internet activity.
The categories of Personal Information that we collect from you depend on your interactions with us. For example, we may collect:
- Direct Identifiers, such as your name, postal address, phone number, e-mail address, IP address, online identifiers, account names, associated passwords, social media profiles and other similar identifiers. We may collect this information to verify your identity and information, to communicate with you, to create your IDCOM® Account (“Account”) and to facilitate your use of our Sites.
- Professional and Employment-Related Information, such as information about your current and former employment, professional degrees and certifications, education background, information about references you list on your application form, certain some Direct Identifiers (to contact you), and other employment-related information, including your employment goals and objectives. We may collect this information to process and manage your profile when you submit an employment or other application to us.
- Commercial Information, such as products and services purchased from us through the use of our Sites. We may collect this information to conduct business analytics and improve our services to you.
- Profile Information, such as information about your preferences and characteristics. We may collect this information to understand your preferences and tailor our services and communications to you.
- Health and Travel Information: If you visit our premises, we may collect information to protect the health and safety of our personnel, clients, guests, and the public, such as health and travel information.
In addition to the purposes for collection described above, we also may collect each category of information for performing services for you and maintaining our relationship with you, which include:
- Maintaining and servicing your Account, including managing your preferences.
- Taking steps to improve our services to you, including to run analytics, improve our artificial intelligence tools, assess the quality of our services, and for other related internal business purposes.
- Administering and improving our Sites, including to measuring the effectiveness of the Sites, diagnosing problems with our server, analyzing where Site traffic is coming from, and to identifying our Site users.
- Communicating with you to personalize your experience with the IDCOM® and improve our understanding of your needs, and to respond to inquiries you send to us.
- Sending you messages promoting our products and services. You may opt out of receiving certain promotional e-mail messages from us, as described in the “Marketing Opt-Out” section below.
- Protecting the health and safety of our personnel, clients, guests, and the public.
- Complying with our legal, regulatory and risk management obligations, including establishing, exercising and/or defending legal claims.
How we disclose your Personal Information
We may share your Personal Information in the following circumstances:
- We may share your Personal Information with companies or individuals that we contract with to receive services (our “Service Providers”). These services may include, among other things, providing products or services to you on our behalf, creating or maintaining our databases, payment processing, researching and analyzing the people who request information from us, preparing distribution communications, responding to inquiries, or processing applications. We may also disclose to these Service Providers your health and travel-related information to protect the health and safety of our personnel, clients, guests, and the public. Our policy is to inform our Service Providers not to use or disclose your Personal Information for any purpose besides for providing services to us.
- We may share your Personal Information with companies that we own or control, including health and travel-related information, to protect the health and safety of our personnel, clients, guests, and the public.
- We may share your Personal Information with companies or individuals outside IDCOM® who may use your Personal Information for their purposes (a “Third Party”). For example:
- If you choose to submit Personal Information through the “Testimonials” link, we may share your Personal Information publicly or with Third Parties.
- From time to time, we may be required to provide Personal Information to a Third Party in response to a court order, subpoena, government investigation, or as otherwise required by law or legal process.
- We may share your Personal Information with Third Parties, such as law enforcement agencies, other government agencies, or health authorities (i) when we, in good faith, believe you or others are acting unlawfully, (ii) when we believe it is necessary or appropriate to satisfy any law, regulation or other governmental request, (iii) to operate our business and Sites properly, (iv) to protect or defend our rights or the rights or well-being of our users, even without a subpoena, warrant or court order, or (v) we believe disclosure is necessary to protect the health and safety of our personnel, clients, guests, and the public.
Cookies and Other Technologies
Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, your Flash player can be set to reject or delete Flash cookies. Refusing a cookie will generally not interfere with your use of the Sites. However, refusal of a cookie may, in some cases, preclude you from using or negatively impact the display or function of the Sites or certain areas or features of the Sites.
We may also use web beacons (a.k.a. clear GIFs, web bugs or pixel tags) to personalize your experience on the Sites, to generate information about Site traffic and trends, and to verify your viewing and/or receipt of communications. Web beacons collect information automatically, such as the type of browser that you use and your IP address. Web beacons may be used alone or with cookies. When web beacons are used with cookies, they may link this information to other Personal Information that you have provided to us. Web beacons usually are not visible to you.
How we respond to Do Not Track Signals
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option, and DNT signals are not yet uniform. For this reason, many digital service operators, including IDCOM®, do not recognize or respond to DNT signals.
If you would like to opt out of receiving promotional or marketing e-mail from us, you may use the “unsubscribe” mechanism included in each marketing message. You may let us know by emailing us to firstname.lastname@example.org with REMOVE in the subject line, and stating the e-mail address you wish to be removed from our mailing list. If you have an Account, you may be able to manage your subscriptions through your Account. However, your option not to receive promotional, and marketing e-mail shall not preclude us from corresponding with you, by e-mail or otherwise, regarding your existing relationship with us. Your opt-out request will also not apply to correspondence that has already been initiated.
Your California Privacy Rights
California’s residents are entitled to the following privacy rights listed below.
- The right to know. You are entitled to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we sold or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was sold or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information. Generally:
- Within the preceding 12 months, IDCOM® has collected the categories of Personal Information detailed in “How We Collect and Use Your Personal Information” above.
- IDCOM® has disclosed the following categories of Personal Information for a business purpose in the preceding 12 months: Direct Identifiers; Commercial Information; Internet Activity Information; Professional and Employment-Related Information; Profile Information; and any other information disclosed in response to a court order, subpoena, government investigation, or as otherwise required by law or legal process.
- In the context of providing our Investigative Due Diligence (“IDD”) services, IDCOM® has “sold”* the following categories of Personal Information in the preceding 12 months: Direct Identifiers; Commercial Information; Professional and Employment-Related Information; Profile Information; and any other information collected in the context of providing our IDD services. Please note:
- We do not sell the Personal Information of minors under 13 without the consent from the minor’s parent or guardian. We do not sell the Personal Information of minors between 13 and 16 years old without the minor’s own consent.
* A “sale” of Personal Information under the CCPA is defined broadly to include the “selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means” the Personal Information of a California consumer to another business or third party “for monetary or other valuable consideration.”
- The right to deletion. You are entitled to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.
- The right to opt out of the sale of your Personal Information. You are entitled to opt out of the sale of your Personal Information. If you are a California resident, and you wish to opt out of our Investigative Due Diligence services, you can submit your request to opt out of the sale of your Personal Information by completing our “Contact Form“.
- The right to equal service. If you choose to exercise any of these rights, IDCOM® will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of IDCOM® ’s Sites or services.
You may exercise your right to know and your right to deletion twice a year free of charge. To exercise your right to know or your right to deletion, contact us at 1 (210) 340-6292 or complete our “Contact Form“.
We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to reasonably verify you are the individual about whom we collected Personal Information. If you have an Account with us, we will use our existing Account authentication practices to verify your identity. If you do not have an Account with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.
You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
Information for Visitors from outside the United States
We maintain one or more databases to store your Personal Information and may retain it as reasonably required to serve you, run our business, and comply with our legal obligations. We have implemented reasonable safeguards designed to protect your information from loss, misuse, alteration, or destruction. We also take reasonable steps designed to ensure that third parties who work with us agree to protect the Personal Information.
We do not knowingly collect any Personal Information from children under 13 without prior verifiable parental consent. If IDCOM® learns that a child under the age of 13 has submitted Personal Information without parental consent, we will take all reasonable measures to delete the information as soon as possible and do not use such information for any purpose, except where necessary to protect the safety of the child or others as required or allowed by law. If you believe a child under 13 has provided us with Personal Information, please contact us at email@example.com or the mailing address below.
We encourage you to periodically review this page for the latest information on our privacy practices.