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1. Policy Statement

We value your privacy. At Checkster, we take protecting your privacy seriously. In order for us to provide our services (“services”) to you we need to collect and use some of your personal information. We want you to understand what personal information we collect and how it is used.

When you use our services, or by accessing the Checkster website, you acknowledge that you (i) have read and accepted this Policy without exception; (ii) consent to our privacy practices, including our collection, use and disclosure of your personal information as set out in this Policy; and (iii) agree to be bound by the Policy.  If you do not consent to this Policy, please do not use our services or provide any personal information.  In this Policy “we” and “us” means Checkster, Inc., offering or providing services to you.

What’s covered by this Policy

Any service which links or refers to this Policy and any collection, storage, transfer, sharing, disclosure and handling of your personal information when you use our services which we define below.

This Policy does not cover and we are not responsible for third-party sites or applications that may be linked from our sites; linking to them does not imply an endorsement. You should always review the privacy policy of any third-party site or application.

Any information collected, held or otherwise Processed by Checkster, Inc., 926 Diablo Ave #305, Novato, CA 94947, info@checkster.com or + 1 866 800-0709 relating to any individual (“Users” or “Data Subjects”) is subject to this policy. This policy sets out (i) the rights of individuals with respect to their personal information and (ii) the responsibilities of Checkster to access and use such personal information. 

The requirements of this policy are in addition to, not in substitution of, any other requirements under the applicable data protection laws and regulations. In case of conflict between the applicable data protection laws and regulations and the provisions of this privacy policy, the applicable data protection laws and regulations shall prevail.

Checkster may amend this policy at any point in time. Please check this policy periodically on http://www.checkster.com/privacy to inform yourself of any changes.

2. Definitions
Data Controller means the organization which determines the purposes and means of the Processing of Personal Data for which, and the manner in which, any Personal Data is Processed. Checkster will be acting as Data Controller when:

(a) Processing Personal Data for Purpose 3.1(c) and, in certain circumstances, for Purpose 3.1(b); and

(b) in any event when the Data Subject is using Checkster's services for its own purposes.

Data Subjects for the purpose of this policy include all identified or identifiable natural persons about whom Checkster holds Personal Data. 

Data Processor means the organization which Processes Personal Data on behalf of the Data Controller. When Processing Personal Data for Purpose 3.1(a) and, in certain circumstances, for Purpose 3.1(b), Checkster will be acting as Data Processor on behalf of Checkster's customer unless the Data Subject is using Checkster's services for its own purposes.

Personal Data or Personal Information is any data relating to a living individual which allows the individual to be identified, whether from that data alone, or in combination with other information which is in the possession, or likely to come into the possession of Checkster and also includes anything that identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household. For the purposes of this Privacy Policy, Personal Data and Personal Information may be used interchangeably and may be together defined as “Personal Data”.  A description of the Personal Data is set out in Schedule 1.  Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information excluded from the California Consumer Privacy Act of 2018 (CCPA) scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete on our website.
Indirectly from you. For example, from observing your actions on our website.

Processing means any operation or set of operations which is performed upon Personal Data or sets of Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data.

Sensitive Data means, among others, Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and the Processing of data concerning health or sex life. 

3. Collection and Use of Personal Data
Checkster may Process Personal Data for the following purposes, upon instruction of the Data Controller (the “Purposes”):

(a) In order to provide its services, including those to:

  • Fulfill a service or a service request to you;
  • Complete your purchase;
  • Establish and verify your identity;
  • Activate and maintain and your account;
  • Handle and resolve billing disputes;
  • Monitor and maintain the performance and functionality of the service consistent with your choices;
  • Provide technical support;
  • Protect and improve our services;
  • Offer updates, notices and other information about product or services available from Checkster or its affiliates as permitted by law. (Note: at any time you may choose to withdraw your consent to Checkster’s use or disclosure of your personal information for marketing and promotional purposes by contacting Checkster as outlined in this Policy);
  • Respond to your questions, inquiries, comments and instructions;
  • Preventing, detecting or investigating crime and other unlawful activities, including fraud and money-laundering or terrorist financing, and analyzing and managing commercial risks;
  • Comply with applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  • In connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
  • Update our records and keep your contact details up to date;
  • Track and analyze de-identified data and provide such data to third parties that provide services to Checkster;
  • Statistical purposes to help improve the service;
  • Protect against fraud and potential fraud;
  • Notify you of any known breach of your personal information;
  • Maintain the security and integrity of Checkster’s systems and services;
  • Market services related to the services you have subscribed to;
  • Transmit to any of our affiliated entities and relevant governmental and/or regulatory authorities, for the aforementioned purposes; and
  • Any other related purposes that would reasonably be expected for which you provided the information
(b) Operate, administer and optimize its website and to diagnose problems with its website;

(c) Direct marketing purposes so that Checkster may provide the Data Subject with information about products and services that may be of interest to the Data Subject. The Processing of Personal Data for direct marketing purposes will only be done, after explicit consent of the Data Subject. 


Personal Data relating to any user of Checkster's services (Checkster User) will be collected from the Checkster User himself, from Checkster's customer (if the Checkster User is not himself a Checkster customer for his own purposes) or from any individual who has been designated by the Checkster User as a possible rater. 

Personal Data relating to raters will be collected from the raters themselves or from a Checkster User.

Checkster shall only Process Personal Data to the extent that is relevant for the Purposes set forth herein. When you use the Checkster service, you consent to us collecting your personal information.  Please note that if we do not have your personal information, we may not be in a position to provide our services to you, (or to a company who we provide services to who you are contracted to), either to the same standard or at all.

Given that no Sensitive Data are required to achieve any of the Purposes Checkster will not Process Sensitive Data and Checkster invites anyone using its services (whether as a Checkster user, as a rater or otherwise) to refrain from sharing with Checkster any Sensitive Data about themselves or other individuals.

3.5 Checkster may offer functionality from third parties by redirecting you to the third party's website. While visiting the third party site, your privacy choices and the data you share with the third party will be subject to the third party's privacy policy, and not subject to Checkster's privacy policy. Checkster will provide a clear disclaimer when directing you to third party websites where Checkster's privacy policy does not apply, and you will have the option to continue on Checkster without using the third party.

3.6 Categories of Information We Collect and Your Rights When You Use the Checkster Platform

The following lists the categories of, and sources from which, specific pieces of personal information are collected.  The following also sets forth the categories of, and specific pieces of personal information we may sell or disclose, and the categories of third parties to whom we may sell or disclose such information, and the business purposes for which the categories of personal information may be used. 

We support data mapping and inventories of the personal information we collect about Users (and their households and/or devices) and internal processes and resources in place to be able to respond within 45 days to requests for access to or deletion of personal information submitted by our Users.  We do not collect any personal information from individuals under the age of 16, unless we receive an affirmative “opt in” consent from the User’s parent or guardian.  You have the right to access portable copies of your personal information, copy and request deletion of specific pieces of personal information we collect.

In the last twelve months, Checkster may have collected, used, and shared, for business purposes, personal information about you as described in this privacy statement. Each category of data may be used by Checkster or shared with third parties also as described in this Privacy Statement. Residents of California have the right to request access to and deletion of the information Checkster holds about them. Such requests may be submitted by email to: info@Checkster.com or by mail to Checkster at 926A, Diablo Ave #305, Novato, CA 94947.  Checkster will not sell your personal information without your consent.

Checkster will not discriminate against you for exercising your rights under CCPA. Specifically, we will not:

  • Deny access to our service;
  • Charge a different rate for the use of our services; or
  • Provide a different quality of service.

We allow all of our Users to “opt out” of any such disclosures or sales.  If you wish to opt out of disclosures or sales, please click here and fill your name and the details you used when using Checkster.

You can also contact us by email through our website (www.checkster.com or by our toll-free telephone number (866-800 0709).  We will not discriminate against Users who exercise their privacy rights and we will provide equal service and pricing even if you exercise your privacy rights.

The personal data Checkster collects or processes is justified and permitted by law, and we require your informed, explicit consent before your personal data can be collected or used.  In such case, you will need to “opt in” and separately consent to each use of your personal data.  The personal data we collect or process is limited to a specific, legitimate purpose as set forth herein.  The personal data we collect or process will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.  To this end, and to the extent required by law, we will minimize personal data, including, where appropriate, anonymizing or pseudonymizing the personal data before processing.  The personal data we collect or process will also be accurate and up to date.  If you have any changes or modifications to your personal data you provided to us, please let us know immediately, so we may quickly fix the inaccuracies or erase the data, and pass these change requests along to our affiliates, partners, or vendors that handle the same data.  We have adopted and implement data-handling procedures that limit unnecessary access to and use of personal data, as well as technical security measures (like encryption) to reduce the chance of theft or breach.  We have also adopted storage limitations to remove, delete or anonymize data that is no longer necessary in order to protect the rights of our Users.  We use commercially reasonable technical, administrative, and physical controls best practices to protect your personal information including data encryption where appropriate; however, since the internet is not a 100% secure environment, we cannot ensure the security of personal information during its transmission between you and us. Accordingly, you acknowledge that when you transmit such personal information, you do so at your own risk. Nevertheless, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. We will notify you of any confirmed security breach of your personal information to the extent required by and in accordance with local laws applying in the country in which you receive the services.


4. Timely Processing
Checkster shall retain Personal Data in a manner consistent with the applicable data protection laws and regulations. In any event, Personal Data shall not be kept longer than is necessary for the Purposes, unless the data are required to be kept longer by law. If Checkster is acting as a Data Processor, the duration of this term will be determined by the Data Controller.

5. Rights of the Data Subject
Each Data Subject has the right to access the Personal Data that the Data Controller holds about him or her and to request rectification or erasure of the Personal Data or restriction of Processing of Personal Data concerning the Data Subject or to object to the Processing of such Personal Data as well as the right to data portability. If Checkster is not the Data Controller:

(a) Checkster will pass the request on to the Data Controller; or

(b) the Data Subject may also contact the Data Controller directly. The contact details of the Data Controller will be mentioned in the initial e-mail that the Data Subject receives, inviting him or her to use the services of Checkster.

The Data Subject has a right to lodge a complaint to the competent supervisory authority if he or she deems that Checkster is Processing his or her Personal Data in violation of any applicable data protection laws and regulations. However, Checkster strongly encourages Data Subjects to contact Checkster for any complaints or queries (see section 10 for our contact details) prior to lodging any complaints to the competent supervisory authority. 

The Data Subject shall have the right to object, on grounds relating to his or her particular situation, at any time to the Processing of Personal Data concerning him or her. The Data Controller shall no longer Process the Personal Data unless the Data Controller can demonstrate compelling legitimate grounds for the Processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defense of legal claims. When Checkster is not the Data Controller:

(a) any objection to the Processing of Personal Data received by Checkster will be passed on to the Data Controller; or

(b) the Data Subject may also contact the Data Controller directly to object to the Processing of his or her Personal Data. The contact details of the Data Controller will be mentioned in the initial e-mail that the Data Subject receives inviting him or her to use the services of Checkster.

If we Process Personal Data for direct marketing purposes, the Data Subject shall have the right to object at any time to the Processing of Personal Data concerning him or her for such marketing purposes.


6.  Data Security

Checkster shall ensure that appropriate technical and organizational security measures are taken against unlawful or unauthorized Processing of Personal Data, and against the misuse, destruction, disclosure, acquisition, accidental loss of, or damage to Personal Data.


7. Disclosure of Personal Data

If it is appropriate to achieve any of the Purposes Checkster may share the Personal Data with the following categories of recipients:

(a) Checkster may disclose Personal Data with the User or Data Subject. 

(b) Checkster may share Personal Data with a subsidiary or parent company.

(c) Checkster may also share the Personal Data with external providers of IT related services.

Checkster may also disclose your personal information to:

  • Comply with the law and/or legal process in which a formal request has been made (e.g. request from an administrative oversight agency, civil suit, subpoena, court order or judicial or administrative proceeding);
  • Defend our rights and/or property or the rights and property of others;
  • Enforce this Policy;
  • Respond to claims that the content(s) of a communication violates the rights of another;
  • Detect, prevent or otherwise address fraud, security, or technical issues.

8. Transfer of Personal Data to a third country


Since Checkster is located outside the European Economic Area, Checkster and Checkster's customer have ensured that any transfer of Personal Data will be conducted in compliance with the applicable data protection laws and regulations. Checkster and Checkster's European customer have concluded a contract (or signed a Model Clause) for the transfer of Personal Data to non-EU/EEA countries, containing the standard contractual clauses approved by the European Commission. A copy of this contract is available upon request.

Checkster shall not transfer Personal Data to countries outside the European Economic Area that do not provide an adequate level of protection unless such transfer is necessary for the Purposes, in which case Checkster shall ensure that the transfer will be conducted in compliance with the applicable data protection laws and regulations.

Global Clients will either store their data in Europe or sign a Model Clause with Checkster.

8.3 General Data Protection Regulation European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), Checkster Inc. has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by:

For the purpose of compliance with EU data protection laws our data protection officer is CMS Debacker:

CMS Debacker cvba/scrl
Tel      +32 2 743 69 00
Fax     +32 2 743 69 01
Mobile +32 497 535 225
Chaussée de la Hulpe 178
1170 Brussels

For any questions or concerns about Checkster’s Privacy Policy or about Checkster’s data handling practices, you may contact CMS Debacker.


9. Cookies

Our website makes use of small text files called "cookies". These cookies are small files that are saved on the hard drive of your computer when you visit our website. By making use of cookies, Checkster is able to provide you a better overall website experience.

The following cookies are used on this website:

— User-input cookies: these are session cookies that are used to keep track of the user's input. They are required in order for the website to work properly. They are temporary files, which are erased when you close your browser. 

— Authentication cookies: these are session cookies that are used to identify the user once he or she has logged in. These cookies are needed to allow users to authenticate themselves on successive visits to the website and gain access to authorized content. They are temporary files, which are erased when you close your browser. 

— Google Analytics: Google Analytics is used to track visitors’ usage of the website (how much time spent on the website, the areas visited, etc.). This helps us understand how visitors interact with our website, which allows us to improve the overall functionality. Google Analytics is not necessary for the proper functioning of the website.

Checkster does not use any third-party cookies or flash cookies.

You may refuse our use of cookies at any point in time. It is sufficient for you to configure your browser settings to limit or exclude the use of cookies, or to delete the cookies that have already been placed on your computer. However, in such case, you might not be able to use certain functionalities on our website.
Cookie settings may vary from one browser to another. The below hyperlinks provide further guidance on how to disable the use of cookies on your browser, and/or on how to delete cookies:

— Chrome: https://support.google.com/chrome/answer/95647?hl=en;
— Internet Explorer: http://windows.microsoft.com/en-US/windows-vista/Block-or-allow-cookies and http://windows.microsoft.com/en-us/internet-explorer/delete-manage-cookies#ie=ie-11-win-7;
— Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=Enabling+and+disabling+cookies and https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored;
— Safari: http://support.apple.com/kb/index?page=search&fac=all&q=cookies%20safari).

Click here to read more about our Cookie Policy: http://www.checkster.com/cookie-policy


10. Contact

For any privacy issues, questions or complaints concerning the application of this Policy or to exercise your rights of access or rectification within the context of this Policy, individuals may contact the Checkster support team at support@checkster.com.


If, for whatever reason, you believe you have been subject to a personal data breach through Checkster, you may submit details to info@checkster.com.


We may collect the following Personal Data:

  • IP Address;
    - Full name;
    - Postal Address;
    - Phone Number;
    - E-mail Address;
    - Financial information (i.e. Credit card numbers or passwords);
    - For raters: title, current employer, past employer and relation with candidates and any other Personal Data that might be provided in a rater review;
    - For employment verification: past salary of candidate, reason for leaving and any other Personal Data that might be provided in a rater review;
    - Demographic information (i.e. information that you submit, or that we collect, that is neither personal information nor financial information, this may include, zip code, postal code, username, purchase history information, browsing history information, searching history information, registration history information.
  • We may also collect the following categories of Personal Information, among other items of Personal Information:
  • 1) Identifiers (including real name, signatures, User aliases, postal address, unique personal identifiers, telephone numbers, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, cookies, beacons, pixel tags, mobile ad identifiers, customer numbers, unique pseudonyms, physical characteristics or descriptions; state identification card numbers; insurance policy numbers; education; employment and employment history; bank account, credit card, and debit card numbers; any other financial information; and health insurance information
  • or other similar identifiers).
  • 2) Internet Activity (including browsing history, search history, information regarding a consumer’s interaction with an Internet Web site, application, or advertisement).
    3) Select Information in Customer Records
    4) Legally Protected Characteristics
    5) Commercial Purchasing Information
    6) Biometric Information
    7) Internet or Network Activity
    8) Geolocation
    9) Information Typically Detected by the Senses
    10) Employment Information
    11) Education Information
    12) Inferences from Above Used to Profile

Privacy Policy last updated JANUARY, 2020