Accurate Background, Inc

We self-certify compliance with:

European Union and Swiss Safe Harbor Policy
Accurate Background, Inc. ("the company," "we," "us," or "our") respects individual Privacy and values the confidence of our customers, employees, consumers, business partners, and others. Our organization adheres to the Safe Harbor Agreements concerning the transfer of personal data from the European Union (EU) and Switzerland to the United States of America. Accurate Background complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. Accurate Background has certified that it adheres to the Safe Harbor Privacy Principles (the Principles) of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Accurate Backgrounds certification, please visit http://www.export.gov/safeharbor/.

This statement outlines our general policy and practices for implementing the Principles, including the types of information the company gathers, how we use it, and the choices affected individuals have regarding our use of, and their ability to correct, that information.

This statement applies to all personal information we handle, including on-line (except as noted below), off-line, and manually processed data. For purposes of this statement, "personal information" means information that:

• is transferred from the European Union or Switzerland to the United States;
• is recorded in any form;
• is about, or pertains to, a specific individual or can be linked to that individual.

Principles Protecting Individuals' Privacy

Notice and Choice
To the extent permitted by the U.S.-EU and U.S.-Swiss Safe Harbor Agreements, we reserve the right to process personal information in the course of our internal business operation without the knowledge of individuals involved.

Where the company receives personal information from its subsidiaries, affiliates, or other entities in the EU or Switzerland, the company will use and disclose such information in accordance with the purposes for which it was originally collected, or in accordance with the notices provided by such entities.

The company will provide notice and provide individuals with an opportunity to "opt out" if such personal information is to be disclosed to a third party or used for a purpose incompatible with the purpose for which it was originally collected. For sensitive personal information, affirmative or explicit, the company will provide notice and individual choice will be given to "opt-in" if such sensitive personal information is to be disclosed to a third party or used for a purpose other than the purpose for which it was originally collected.

We collect personal information from individuals only as permitted by the Principles or with the consent of the individual affected. Consent for personal information to be collected, used, and/or disclosed in certain ways may be required in order for an individual to obtain or use our services.

Disclosures and Transfers
We do not disclose an individual's personal information to third parties, except when one or more of the following conditions is true:

• We have the individual's express informed permission to make the disclosure;
• The disclosure is required by law or mandatory professional standards;
• The disclosure is reasonably related to the sale or other disposition of all or part of our business;
• The information in question is publicly available;
• The disclosure is reasonably necessary for the establishment of legal claims; or
• The disclosure is to another Accurate Background entity or to persons or entities providing services on our or the individual's behalf (each a "transferee"), consistent with the purpose for which the information was obtained, if the transferee, with respect to the information in question:
  • is subject to law providing an adequate level of privacy protection;
  • has agreed in writing to provide an adequate level of privacy protection; or
  • subscribes to the Principles.

Permitted transfers of information to third parties, within Accurate Background, or between subsidiaries of Accurate Background, include the transfer of data from one jurisdiction to another, such as transfers to and from the United States of America. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws provide less or different protection than the jurisdiction in which the information originated.

Data Security, Integrity and Access
We employ various physical, electronic, and managerial measures designed to provide personal information with reasonable protection from accidental loss or destruction, improper use, alteration, or disclosure. However, we cannot guarantee the security of information on or transmitted via the Internet.

We process personal information only in ways compatible with the purpose for which it was collected or authorized by the individual. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.

If an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may contact us using the contact information below. The individual will need to provide sufficient identifying information. We may request additional identifying information as a security precaution. In addition, we may limit or deny access to personal information where providing such access would be unreasonably burdensome or expensive in the circumstances, or as otherwise permitted by the U.S.-EU or U.S.-Swiss Safe Harbor Agreement. In some circumstances, we may charge a reasonable fee, where warranted, for access to personal information.

Information Subject to Other Policies
We are committed to following the Principles for all personal information within the scope of the U.S.-EU and U.S.-Swiss Safe Harbor Agreements. However, certain information is subject to policies of the firm that may differ in some respects from the general policies set forth in this statement.

• Links from our external website and our intranet have their own privacy policies that apply to those websites. These policies may be accessed through the websites in question.
• Information obtained from or relating to clients or former clients is further subject to the terms of any confidentiality or privacy notice to the client, any engagement letter or service agreements executed with the client, and applicable laws and professional consulting standards.

Changes to this Privacy Policy
Accurate Background, Inc. reserves the right to change this Privacy Policy from time to time and will post any revisions on this website. When we do so we will also revise the "last updated" date at the end of this Privacy Policy.

Amendments
This policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. If we amend this policy, a revised policy will be posted on our website.

How to Contact Us
Should you have any questions or suggestions about our privacy practices, or wish to update or correct any personal information that you have chosen to provide to us, please feel free to contact us at:

Accurate Background, Inc.
7515 Irvine Center Drive
Irvine, CA 92618
800.784.3911
customer_service@accuratebackground.com

Effective Date: March 1, 2007

Last Updated: April 12, 2013