BACKGROUND PROFILES PRIVACY NOTICE

The purpose of this privacy notice is to describe: (1) the types of information that Background Profiles provides in its products; (2) the types of sources from which Background Profiles obtains its information; (3) how the information is collected; (4) the types of entities to whom Background Profiles makes its products available; and (5) the uses that the information may be put. This notice also describes how for a fee you can obtain a copy of the non-public information in Background Profiles products that identify you.

TYPES OF INFORMATION

Background Profiles provides customers with individual contact information including name, phone number, address and other contact information. We do not maintain or distribute any non-public financial information, tax information, or employment information.

Background Profiles products that provide contact information include information obtained from public record sources such as courts, liens, bankruptcy records, and other public record information compiled from local, state, and federal governments. Public record information also includes those motor vehicle records that are available to the public without restrictions. All of this information is available to the public from various other sources including directly from its original source.

Additionally, some Background Profiles products contain directory-type or identifying information originally obtained from credit bureaus.

This information consists of:

• an individual's name or alias including previous names such as maiden name or name from a prior marriage
• an individual's address including his or her previous addresses
• telephone information

To a select group of subscribers an individual's social security number with the last four digits deleted and the month and year of his or her birth may be included.

SOURCES OF INFORMATION

Public Record Information is information about an individual that is obtained from the records of a governmental entity and is available to the public. Examples of public record sources of information contained in Background Profiles products include records maintained by state and federal agencies, state and federal courts, and the state's department of motor vehicles.

Publicly Available Information is information about an individual that is available to the general public from non-governmental sources such as telephone and business directories.

Non-Public Information is information about an individual that is not generally available to the public from public records or commercial sources. Background Profiles uses directory-type or identifying information that is originally obtained from the major credit bureaus. This identifying information does not contain any of the financial or credit information found in consumer reports.

HOW INFORMATION IS COLLECTED

Background Profiles obtains its information from various suppliers that maintain databases and obtain information from sources including the credit bureaus and local, state, and federal governments.

TYPES OF ENTITIES TO WHOM INFORMATION IS DISCLOSED AND USES TO WHICH THE INFORMATION MAY BE PUT

All Background Profiles products are available only to established professional and commercial users and to government agencies who will use the information in accordance with written agreement with Background Profiles that limits the customer's use of our data. These customers primarily consist of employers, recruiters working on behalf of an employer, law firms, state and local government agencies, debt collectors, benefit administrators, and individuals engaged in law enforcement and investigation. These customers use the non-public data primarily to locate individuals.

OBTAINING COPIES OF INFORMATION ABOUT YOU IN Background Profiles PRODUCTS

Copies of Non-Public Information

Background Profiles for a fee will provide individuals with a copy of non-public information about them that is available in our Public Record products distributed to established professional and commercial users. Individuals can request a copy by calling Background Profiles. Payment for these reports must be made by acceptable credit card in advance of the individual receiving the report.

Background Profiles uses but does not maintain databases of non-public information. Individuals wishing to correct any inaccuracies in non-public information about them made available in our Public Record Profile product should contact the credit reporting agencies directly. Contacting each agency directly will assist in ensuring that in the future correct data will be reflected not only in this Background Profiles product, but also in all products identifying the person that are released by the consumer credit reporting agency.

Each agency has its own procedure for correcting information in or obtained from its credit reports. The consumer credit reporting agencies that serve as sources of non-public information for our products can be contacted as follows:

Copies of Public Information Contained in Background Profiles Products

If an individual wishes to obtain copies of information from public or publicly available information sources or choose to correct inaccuracies to information in such sources the individual should contact such sources directly. These sources include local, state, and federal government courts and agencies.

For example:

• In the case of a Judgment Search individuals should contact the appropriate state, local or federal court.
• In the case of bankruptcy or liens the individual should contact the appropriate federal bankruptcy court.
• For automobile and license information, the individual should contact the appropriate Department of Motor Vehicles.

The process of directly contacting the original public record source will assist in ensuring that information obtained by our various suppliers will be consistent and accurate.

Safe Harbor Provisions of Privacy Policy

Background Profiles hereby confirms our strong policy to protect and maintain the privacy of personal data that we collect and assemble on behalf of employers concerning consumers. We certify that we comply with the "Safe Harbor" principles of the United States Department of Commerce, in relation to personal data collected in the European Union (EU). We endorse and follow the seven principles and practices outlined by the European Commission's Directive on Data Protection. These principles can be found at the U.S. Department of Commerce website at http://export.gov/safeharbor/. Background Profiles fulfills our obligations under the seven principals in the following manner:

1. Notice
Prior to having Background Profiles conduct employment screening on a consumer, it is always disclosed to the consumer (as prescribed by the Fair Credit Reporting Act, hereinafter "FCRA") that the information they provided will be used to conduct employment screening for the employer desiring to use it for employment related decisions (to determine eligibility to hire, retain, promote, or reassign). Background Profiles' contact information is included on the authorization form in the event the consumer has any inquiries or complaints. Background Profiles collects information on individuals for the purpose of providing the information to employers for employment related decisions. Employers may also use this information to conduct employee investigations where an employer has a suspicion of work related misconduct or wrongdoing. The Human Resources and Security professionals within the employer organization will also use this information. Prior to receiving information from Background Profiles and in accordance with the FCRA, each employer must provide a certification to Background Profiles that it will only use Background Profiles' services for employment purposes or other permissible purpose under the FCRA and that it will comply with all applicable state and federal regulations and obligations.

2. Choice (opt-out of sensitive information)
Background Profiles gives consumers a choice for the collection of information by virtue of the fact that the information is only collected with the consumer's explicit consent (as required by the FCRA). Furthermore, the information collected is only utilized for the purposes described above in the section on "Notice." In the event a consumer wishes to opt-out of any information collected by Background Profiles, a consumer can withdraw his/her consent by notifying Background Profiles through the contact link on this web site or through contact information provided on the consent form. This does not, however, mean that information will automatically be erased or deleted because various laws require Background Profiles to maintain the data on file for a certain period of time. However, in the event of an opt-out, the data will not be forwarded or utilized by Background Profiles for any purpose.

3. Onward Transfer
The information obtained by Background Profiles is forwarded only to an entity that has been specifically authorized by the consumer to receive the data and only for the purpose described in the section under "Notice." Background Profiles takes reasonable steps to ensure that any party that receives information will maintain and protect the privacy and confidentiality of the information. (See the certification portion described in the section under "Notice.") Any third party that receives information from Background Profiles has obtained written authorization from the consumer and has disclosed to the consumer the purpose of collecting this data. In addition, each client certifies they will comply with the confidentiality clause in our Service Agreement and is given a copy of the FTC's Notice to Users, which outlines their obligations with respect to the use of this information.

4. Access
Background Profiles provides access to consumers on all data collected about the consumer in order to allow the consumer the reasonable opportunity to ascertain what personal data Background Profiles possesses about the consumer, and to correct, amend, or delete information that is inaccurate or incomplete. Disclosure is provided under the terms of the FCRA. Under all circumstances, a consumer is entitled to a copy of his/her report, including a consumer who is a citizen of the EU. However, Background Profiles reserves the right to engage in reasonable efforts to confirm the identity of anyone requesting this data.

5. Security
Our company takes all reasonable procedures to protect personal and identifiable information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. We utilize a 128-bit encryption on a secured server for all Internet communications. Furthermore, only employees who need the information to perform a specific job are granted access to personally identifiable information. All employees are kept up-to-date on our security and privacy policies. Finally, the servers that are used to store personally identifiable information are kept in a secure environment, with appropriate security measures.

6. Data Integrity
Background Profiles only collects data that is strictly necessary for the purposes listed under the section on "Notice." The data includes information that is necessary to identify the consumer for purposes of collecting employment related information. In accordance with the FCRA, Background Profiles makes every reasonable effort to assure maximum possible accuracy of the information collected.

7. Enforcement
Background Profiles adheres to the EU Safe Harbor Policy by means of in-house verification by the management of this company. In addition, we provide an independent recourse mechanism by which each individual's complaints and disputes are investigated and resolved. All complaints and disputes that cannot be resolved by the consumer and Background Profiles can be forwarded to the European Data Protection Authorities to handle the dispute resolution process.

For more information on Privacy click on the link below:
Federal Trade Commission Home Page
Effective 7/10/2004