Privacy Notice
Last Updated: September 2023
This policy represents our commitment to your privacy and the respectful use of your data.
Contents:
- What This Policy Covers
- Information Collection
- How We Use Your Personal Information
- Information Sharing and Disclosure
- Personal Information Disclosure: United States and International
- Cookies and Tracking Technology
- Security
- Links
- Your Ability to Review or Modify Personal Information, or Unsubscribe
- Children’s Information
- Changes to this Privacy Policy
- Contact Us
What This Policy Covers
This privacy policy applies to the websites and applications owned or operated by Subrosa Investigations, LLC (“Subrosa Investigations” or “Subrosa”). It also describes your choices regarding use, access and correction of your personal information.
As a consumer reporting agency governed by the Fair Credit Reporting Act (FCRA) among other applicable state and federal laws, Subrosa Investigations is committed to protecting your privacy.
This privacy policy covers Subrosa Investigations’ web site, and Subrosa’s practices for handling personal information provided to Subrosa. This policy also covers personal information provided by Subrosa Investigations’ clients, their job applicants and their employees, as well as other individuals who have given their written authorization for Subrosa Investigations’ clients to request a background investigation for their use). Subrosa Investigations will collect, store, and use personally identifiable information only in compliance with applicable law, including the FCRA.
We offer a wide range of services to businesses, employers and individuals, including investigation and background check services. For example, we provide:
- Criminal record, motor vehicle record, credit report and other background investigation services to employers for current and prospective employee background checks.
Depending on the service you use, we may collect different information about you, and additional privacy terms, notices, and/or disclosures may apply to your use of the services. This policy does not cover data collected by or through third-party websites or services.
IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE SUBROSA INVESTIGATIONS’ SERVICES OR VISIT SUBROSA INVESTIGATIONS’ WEBSITES.
Information Collection
When you browse Subrosa Investigations’ publicly accessible web site, you do so anonymously. Subrosa Investigations collects personally identifiable information from you only if you choose to provide this information to us. In some instances, Subrosa may collect non-personal (e.g., aggregate or demographic) data through cookies. This information is used to better understand and improve the usability, performance and effectiveness of the Subrosa Investigations web site, as is further described below under "Cookies and Tracking Technology".
The types of personal information we may collect about you through our publicly accessible web site include the following (should you decide to provide such information to Subrosa Investigations): (a) contact and identifying information (e.g., name, address, e-mail address, phone and fax numbers, employer(s), job title) in connection with your expression of interest in receiving information about, or your registering for, Subrosa Investigations products or services, newsletters and conferences; (b) your resume information and employment application information in response to Subrosa Investigations job openings; and (c) any other personal information that you may voluntarily provide to us in an online form or through e-mail.
In order to provide services, we collect personal information directly from our users, from our customers as part of providing our services, from visitors to our services, and from public records.
Access to certain Subrosa Investigations web pages and online services is not available to the general public and requires a login code and password provided by Subrosa Investigations. Those web pages, and the information downloadable to and from those pages, are made available only to users approved by Subrosa, including Subrosa’s clients and employees. On these web pages, Subrosa Investigations collects only information that the user voluntarily shares with Subrosa Investigations.
If you are using Subrosa Investigations web pages and online services to open a client account with Subrosa, we request and collect the information necessary to create the client account, including contact information and financial information (such as credit card number or billing information). This information is used for internal purposes, such as account establishment, billing, fulfillment of orders and customer service.
How We Use Your Personal Information
When your personal information is collected on Subrosa Investigations’ publicly accessible web site, Subrosa will inform you at the point of collection of the purpose for the collection. Subrosa Investigations will use your personal information only in the way we specify when it is collected unless you consent to a different use. For example, Subrosa Investigations may use personal information submitted in an account application to set up and maintain your account. Subrosa Investigations also may use the personal information you provide to answer your questions and inquiries, to support Subrosa Investigations’ own recruitment activities in response to your inquiries into Subrosa’s job postings, and to provide newsletters and other information (if any) that you have requested.
If you have provided your personal information over this web site in connection with a background investigation ordered by a Subrosa Investigations' client, Subrosa may use your personal information to perform your background investigation for that client. Subrosa Investigations will not use your information to conduct a background screening investigation and create a report unless Subrosa Investigations' client has provided a certification required by the FCRA and any other applicable law. In this certification, Subrosa Investigations' client certifies to Subrosa that it has a legally permissible purpose for ordering the background investigation, and that it has, to the extent required by applicable law, obtained your informed consent to conduct the background screen.
Information Sharing and Disclosure
Subrosa Investigations does not sell or rent personal information to third parties. Subrosa will not disclose your personal information to a third party without your permission, except in connection with performing your background investigation for Subrosa Investigations' client or as otherwise described in this Privacy Policy. Subrosa Investigations may disclose personal information as necessary or appropriate in connection with any of the purposes for which we use personal information as described above in "How We Use Your Personal Information."
When Subrosa Investigations conducts a background screening investigation about you, Subrosa may disclose information that you submit only to the Subrosa Investigations’ client that ordered your background screening. Subrosa Investigations also may disclose your information to certain third parties as necessary to conduct the background investigation (such as data providers, educational institutions, prior employers, courts, law enforcement agencies and other persons or entities that may provide or verify information about you), as well as to a third-party representative or subcontractor authorized by Subrosa Investigations to assist in the background screening investigation. These third party representatives and subcontractors include service providers that help host or support the web site or otherwise provide technical assistance, court researchers and other data and service vendors. Subrosa Investigations transfers to these representatives and subcontractors only the personal information they need to deliver to Subrosa Investigations (for the benefit of Subrosa’s client) the requested product or service. Subrosa Investigations prohibits these third parties from using that information for any other purpose. Subrosa Investigations requires that these parties maintain commercially reasonable measures to protect the confidentiality of your information.
Subrosa Investigations also may in good faith disclose personal information and any other additional information available to Subrosa for any of the following purposes: (i) investigate, prevent or take action regarding actual or suspected illegal activities or fraud, situations involving potential threats to the physical safety of any person, or violations of Subrosa Investigations' terms of use; (ii) respond to or defend against subpoenas, court orders, or other legal process; (iii) establish or exercise Subrosa Investigations' legal rights; or (iv) otherwise comply with applicable law.
Subrosa Investigations may acquire other businesses, and other businesses may acquire Subrosa Investigations. If that occurs, the information Subrosa collects may be one of the assets examined or transferred as part of the transaction. Subrosa Investigations will not permit another business to examine the information Subrosa has collected without a confidentiality agreement and only to the extent permitted by law. Subrosa Investigations will not transfer the information it has collected unless the recipient agrees to provide privacy protections equal to or exceeding those established by this privacy policy.
Personal Information Disclosure: United States or International
Personal information submitted to Subrosa Investigations for a background screening investigation may at times be transferred outside of the United States in order to perform the background investigation. All personal information will be transmitted and stored in a secure manner in accordance with the terms of this privacy policy.
Cookies and Tracking Technology
Subrosa Investigations' web site may use the standard technology called a "cookie" to collect information about how you use the web site. A cookie is a small data file that is transferred to your hard drive and used for record-keeping purposes. A cookie file can contain information such as the URL you came from, your computer's IP address (i.e., the Internet address of your computer) and domain type (e.g., .com or .org, etc.), your browser type, the country, state and telephone area code where your server is located, the pages of our site that were viewed during a visit, and any search terms that you entered on our site. This information is used for internal purposes only, and we do not link your URL or IP address to any personal information unless you have logged into our web site with a Subrosa Investigations account login and password. In addition, Subrosa’s web site does not allow other parties to collect personally identifiable information about an individual consumer’s online activities over time and across different Web sites when a consumer uses the Subrosa Investigations web site.
If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies, although it is possible that some areas of our web site will not function properly if you do so. In particular, you may be required to accept cookies in order to complete certain actions on Subrosa Investigations’ web site. Subrosa Investigations’ web site does not currently recognize “do not track” signals transmitted by web browsers.
Security
Subrosa Investigations is committed to protecting the personal information that Subrosa receives about consumers. While we cannot guarantee the security of that information, we utilize a combination of online and offline security technologies, procedures and organizational measures to help safeguard consumer information against loss, misuse, and unauthorized access, disclosure, alteration and destruction.
We employ Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our web site. We have installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. Strong password protection protocols are used on our computers, and employees are kept up-to-date on our security and privacy policies. The servers used to store consumer information are maintained in a secure environment with appropriate security measures.
Links
Subrosa Investigations’ web site may provide links to third-party web sites. Please be aware that those third-party web sites are outside of our control and are not covered by this Privacy Policy. If you have questions about how another site uses your information, consult that site's privacy statement.
Your Ability to Review or Modify Personal Information, or Unsubscribe
Subrosa Investigations strives to protect the quality and integrity of your personal information. If you have provided your personal information (such as zip code, phone, e-mail or postal address) to Subrosa Investigations while browsing Subrosa’s publicly accessible web site, and wish to update such personal information (if any) that you have provided us, please e-mail us at info@subrosapi.com. Also, if you wish to unsubscribe from any of our newsletters or other communications for which you have registered, you may e-mail us at info@subrosapi.com.
If you are a Subrosa Investigations client with a registered account, you may review (and update) your account information by logging into your account or by contacting Subrosa Investigations at info@subrosapi.com.
If you are an individual of whom a Subrosa Investigations client has requested a background screening investigation, and have submitted personal information to Subrosa Investigations at the request of such client for purposes of procuring a background report, then you can review your Subrosa Investigations file in accordance with your file disclosure rights under the Fair Credit Reporting Act, California Civil Code Section 1786.22 and any other applicable state laws by contacting Subrosa Investigations at info@subrosapi.com. Click here to review a summary of your consumer rights (including file disclosure rights) under the Fair Credit Reporting Act.
California Consumer Privacy Act
California residents, as defined in the California Code of Regulations, have certain rights under the California Consumer Privacy Act (CCPA). The vast majority of personal information collected and stored by Subrosa Investigations is exempt from the CCPA under Section 1798.145(d) (Fair Credit Reporting Act exemption) or under Section 1798.145(l)(1) (which exempts personal information collected in the context of a business to business transaction). Additionally, for much of Subrosa Investigations’ non-FCRA Services, Subrosa acts as a service provider rather than a business as defined by the CCPA. Nonetheless, Subrosa Investigations may be considered a business subject to the CCPA in regards to a small percentage of the personal information that Subrosa Investigations collects.
Children’s Information
Our services are not directed to individuals under the age of 18 and we do not knowingly collect personal information from children under the age of 13. If we discover that we have collected personal information on a child under the age of 13, we will promptly remove it from our systems.
Changes to this Privacy Policy
Subrosa Investigations may revise this policy from time to time. If there is a material change to this privacy policy, we will post the revised policy at this location. Subrosa Investigations will not provide less privacy protection, without your consent, to information collected under a prior privacy policy. We encourage you to periodically review this privacy policy to be informed of how Subrosa Investigations is protecting your information.
Contact Us
Questions about a current background check:
If your background check is currently being performed by Subrosa Investigations and you have questions or need assistance, please contact:
Subrosa Investigations Phone: 602-256-2266
Subrosa Investigations Email: info@subrosapi.com
Report Requests and Disputes:
If you would like to request a copy of your background report(s) (if any) prepared prepared by Subrosa Investigations and/or your active database files (if any) maintained on you by Subrosa; or to dispute the accuracy of the information in your background report, please contact info@subrosapi.com.
Privacy Policy questions:
If you have any questions specifically regarding our privacy policy, you may contact us at:
Dan Perez
Erin Biggs
3003 N Central Avenue, Suite 1070
Phoenix, AZ 85012
(602) 256-2266
In accordance with California Civil Code § 1786.20, the representative(s) named above will be able to assist you with additional information regarding our privacy practices and policies in the event of a compromise of your information.
Effective Date: March 11, 2020
(Contact information updated September 2023)