1. Notice at Collection
At or before collection, PROFID provides the categories of personal information collected, the purposes for collection and use, whether the information is sold or shared, and the applicable retention period or criteria. Collection is limited to what is reasonably necessary and proportionate for the disclosed purposes.
| Category | Purpose | Retention | Sold or shared for advertising |
|---|---|---|---|
| Identifiers and contact information | Identity, account creation, communications, matching, screening, file disclosure, disputes, and legal compliance. | Generally five years for hosted authorization and audit evidence; investigative consumer reports at least two years; shorter source rules may apply. | No |
| Sensitive identifiers and government information | Identity authentication, fraud prevention, Social Security number trace, driver and source requirements, and authorized searches. | Only as long as legally and operationally necessary; motor vehicle recipient-and-purpose records at least five years; source payload may have a shorter binding schedule. | No |
| Identity-verification and biometric information | Document authentication, facial comparison, liveness, impersonation prevention, manual review, security, and identity disputes. | Biometric source images, videos, facial templates/maps, and raw liveness signals generally 30 days after completion, cancellation, or abandonment, subject to the separate Biometric Policy and limited exceptions. | No |
| Screening records and public records | Authorized criminal, registry, watchlist, motor vehicle, and other activated searches; source verification; reporting; disputes; corrections. | California investigative consumer reports at least two years after delivery; other records only for the period permitted by law and source contracts. | No |
| Reports and Standard PROFID Analytics | Report delivery, human review, factual organization, consumer rights, disputes, quality control, and compliance evidence. | At least two years for a California investigative consumer report; analytics and dispute evidence only as long as permitted by law and source contracts. | No |
| Internet, device, and security information | Authentication, security, fraud detection, session integrity, support, debugging, and incident response. | For the security, operational, legal, or limitation period reasonably necessary, then deleted or de-identified. | No |
| Client, transaction, and communications information | Credentialing, permissible-purpose certification, account administration, billing, support, audits, and legal claims. | For the Client relationship and applicable legal, accounting, security, or limitation period. | No |
“Shared” in the final column refers to sharing for cross-context behavioral advertising under California privacy law. PROFID may disclose information to service providers and authorized recipients for the business purposes described below. Consumer Report Information and biometric information are not sold or used for advertising.
2. California Investigative Consumer Reporting Privacy Practices
PROFID may prepare or process an investigative consumer report concerning a California Consumer. Under California law, a report may be an investigative consumer report even when no personal interview is used. California screening is activated only when the required employer forms, copy-delivery process, report contact fields, and platform controls are active.
Personal Information Disclosure: United States or Overseas
NO — personal information is not transferred to, accessed from, or processed outside the United States or its territories.
PROFID stores and processes personal information in the United States. Personnel and contractors located outside the United States are prohibited from accessing production systems or personal information. They may access only source code, technical documentation, and test environments that do not contain real personal information.
3. Information We Process
- Names, aliases, date of birth, address history, contact information, Social Security number or partial Social Security number, and account identifiers.
- Government identification, document images, driver-license and motor vehicle information, device/session information, and fraud-prevention signals.
- Public-record and source information used for authorized criminal, registry, watchlist, driving, employment, education, license, or other activated searches.
- Reports, source status, matching and verification information, dispute records, corrected reports, delivery evidence, and compliance records.
- Standard PROFID Analytics derived from an eligible completed report. The raw report remains the authoritative record.
- Biometric identifiers and biometric information only for disclosed identity-verification and fraud-prevention purposes under a separate notice and consent.
4. Sources and Purposes
Information may come from the Consumer, requesting employer, courts, government agencies, motor vehicle agencies, registries, data providers, prior employers or schools when the relevant service is activated, and authorized identity, hosting, security, support, and technology providers.
PROFID uses the information for identity authentication, fraud prevention, authorized screening, source verification, report and analytics delivery, file disclosure, disputes, corrections, security, audit, legal compliance, and legal claims. Biometric information is not used as an employment-suitability factor or individual analytics input. PROFID does not make or recommend the employer’s final employment decision.
5. Disclosures
- The credentialed employer or Client that requested the authorized report.
- Courts, government agencies, registries, motor vehicle agencies, and lawful data sources needed to perform or verify the authorized search.
- Restricted identity, hosting, security, communications, support, and technology providers acting for PROFID.
- The Consumer, including through report delivery, file disclosure, dispute, or correction procedures.
- Professional advisers, insurers, auditors, transaction counterparties, or government authorities when legally permitted or required.
PROFID does not sell investigative consumer report information or biometric information and does not authorize generalized model training using identifiable Consumer Report Information without a separate lawful basis and required notice and consent.
6. Retention and Disposal
- California investigative consumer reports are retained for at least two years after the report is provided.
- Consumer documents, order certifications, electronic-signature and delivery evidence, and hosted audit evidence are generally retained for at least five years unless a shorter binding schedule applies to a specific record.
- Source payload may be destroyed earlier when a binding source rule requires a shorter period. PROFID may retain lawful metadata and compliance evidence that does not reproduce the deleted source payload.
- Biometric source images or videos, facial templates or maps, and raw liveness signals generally are permanently destroyed within 30 days after completion, cancellation, or abandonment, subject to the separate Biometric Policy, a shorter legal period, and documented limited exceptions.
- A lawful legal hold or non-waivable obligation may extend retention only for the affected category and required period.
7. California Consumer Rights
Depending on the information and the law that governs it, a California Consumer may have the following rights:
- Request access to the PROFID file, a copy of a report, the sources of information where required, and recipient information.
- Dispute inaccurate or incomplete consumer report information without charge and receive the reinvestigation and correction process required by law.
- Request correction or deletion of personal information where the right applies and no legal or source retention duty requires continued retention.
- Request information about categories collected, purposes, recipients, retention, and overseas processing.
- Opt out of sale or sharing for cross-context behavioral advertising. PROFID does not sell personal information or share Consumer Report Information for that purpose.
- Limit use of sensitive personal information when California law provides that right. PROFID uses sensitive personal information only for identity, security, screening, compliance, and other disclosed service purposes.
- Exercise applicable rights without unlawful discrimination.
Some Consumer Report Information is governed by the FCRA and California consumer-reporting law and may be exempt from some California Consumer Privacy Act requirements to the extent it is collected, maintained, used, communicated, or disclosed as authorized by those laws. Rights under the FCRA and California investigative consumer reporting law remain available.
How to inspect your file.After providing proper identification, a California Consumer may inspect the file in person during normal business hours and on reasonable notice; request copies by certified mail to a specified addressee through a written request with proper identification; or request a telephone summary after submitting a written request with proper identification. A Consumer inspecting the file in person may be accompanied by one other person who provides reasonable identification, and PROFID may require written permission to discuss the file in that person’s presence. PROFID will provide trained personnel to explain the information and a written explanation of coded information. Any fee permitted by law will be disclosed before a copy is provided, and disclosures required to be provided without charge will remain free.
8. California Report Copy Election
The employer must present the separate California authorization and copy-election form before procurement. When the Consumer elects to receive a copy and the PROFID delivery workflow is activated, the complete report must be sent within three business days after the report is provided to the employer. The report copy must include the required agency contact information.
9. Requests and Verification
Submit a privacy, file disclosure, correction, deletion, or dispute request through the methods below. PROFID may request reasonable proof of identity and may verify an authorized agent. A privacy request does not replace the separate consumer-report dispute process when report accuracy is challenged.
10. Privacy and Security-Compromise Contact
| Contact | Details |
|---|---|
| Privacy and Consumer Relations Representative | EPASS Inc. d/b/a PROFID Attn: Privacy and Consumer Relations Representative 1902 Wright Place, Office 265 Carlsbad, California 92008 |
| support@theprofid.com | |
| Telephone | +1 313 327 3970 |
| Online requests | https://theprofid.com/dispute |
| General Privacy Policy | https://theprofid.com/privacy |
| Biometric Policy | https://theprofid.com/biometric-policy |
11. Changes to this Notice
PROFID may update this Notice to reflect changes in law, services, vendors, data locations, or data practices. The updated Notice will be posted with a new effective date. Material changes will receive additional notice when required by law.
Legal references: California Civil Code §§ 1786.16 and 1786.20; California Consumer Privacy Act, including Civil Code § 1798.100; Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq.