SJV Privacy Policies

SJV & Associates (SJV) is founded on the principles of protecting its client's information, and consumer's right to privacy. We understand the lawful responsibility and requirements in handling, processing, and protecting the privacy and confidentiality of Personal Identifiable Information (PII), and have created these Privacy Policies to demonstrate our commitment.

Please read the following to learn more about our privacy policies. By visiting the SJV website or utilizing SJV services, you are accepting the practices outlined in these Privacy Policies.

SJV may amend these Privacy Policies from time to time. Use of information we collect is subject to the Privacy Policies in effect at the time such information is used. Please check the SJV website for the most current information so you are always aware of what information we collect, how we use it, and under what circumstances if any, it is disclosed.

Website Privacy Policy

The Website Privacy Policy covers SJV's treatment of personally identifiable information (PII) that SJV gathers when you are on the SJV website. This policy does not apply to the practices of third parties that SJV does not own or control, or to individuals that SJV does not employ or manage.

Information Collected by SJV

We collect personal information that is relevant to the purpose of our website. When you visit our website we collect information that allows us to measure the use of our website. We collect the following types of information from our SJV users:

  1. Information You Provide to Us: We receive and store any information you enter on our website or provide to us in any other way such as telephone, facsimile, and/or written. We may collect personally identifiable information from you such as; applicant’s name, address, date of birth, social security number, national ID number, email address, telephone number, and driver’s license number if you choose to provide this information to us. Other type of data that you will provide with your consent may include username, password, responses to survey, inquiries about order status, and any other inquiry about our services. You can choose not to provide us with certain information, but you may not be able to fully utilize our services.
  2. Automatic Information: We receive and store certain types of non-personally identifiable information whenever you interact with this website. SJV and its authorized agents automatically receive and record certain "traffic data" on their server logs from your browser including your IP address, SJV cookie information, and the page you requested. SJV uses this traffic data to help diagnose problems with its servers, analyze trends and administer the website. SJV may collect and, on any page, display the total counts that page has been viewed, the domain type, and which browser people use to visit the website. SJV may use an outsourcing program to assist us in analyzing this data to improve our website experience.

Information Use and E-mail Communications

SJV is firmly committed to respecting your privacy. The information collected through this website may be used for processing your transactions, maintenance and administration of your account, and responding to your inquiries. We will never provide your email address a third party without your express permission, nor will share, sell, lease, or trade Personally Identifiable Information (PII) with third parties for marketing or promotional purposes, as detailed in the "Sharing Your Information" section below.

SJV may send out e-mail communications with SJV-related news, products, offers, surveys or promotions. You may also receive notification e-mails from SJV, which inform you of actions that have been performed on the site. If you do not want to receive certain e-mails from us, you have the choice to opt out from such notifications.

However, please note that in all cases you will continue to receive all system e-mails (e.g. those regarding forgotten user passwords, or search status comments) and legal notices (e.g. updates to our policies) from us.

Cookies

Sharing Your Information

We share your personal information in the following ways:

Keeping Information Secure

Children

This website is not intended for children under the age of 13 and SJV does not knowingly collect any information from children under the age of 13. In the event that we learn that SJV has collected information from a child, we will dispose of that information as quickly as possible.

Conditions of Use

By using the SJV website you acknowledge that your visit and any possible dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, arbitration of disputes, and application of Georgia state law.


Domestic and International Data Privacy Policy

SJV's Domestic and International Data Privacy Policy applies to our domestic and international products and services. This privacy policy explains (a) how we collect, use, and transfer personal data for operation, (b) how we maintain privacy in the performance of our services, and (c) the rights of consumers and clients on whose behalf we may maintain personal information.

SJV is a data Furnisher as defined within the FCRA, of domestic and international information for processing Background Screening for employment or other purposes permitted under the FCRA or other applicable law. We allow you to authorize third party access to your credit report, public record information, and related personal data ("Consumer Report Information"). We collect your personal information from third party sources only if you decide to authorize third party access to your Consumer Report Information, purchase one of our products or services, subscribe to our emails or newsletter, participate in one of our contests or surveys or transact other business with us. We are committed to protecting individual privacy rights, and to maintaining the confidentiality, security, and integrity of personally identifiable information that is collected, used, maintained and distributed in connection with our services, including any personal data submitted to us via writing, and/or electronically via our website or through our integration applications.

1. Accountability

SJV supports accountability of information industry standards and practices, responsible and effective federal regulation of the data industry, and legislation governing the practices of all data providers. We are subject to the investigatory and enforcement powers of the FTC statutory body, www.ftc.gov. We comply with applicable United States, international, and local data protection laws and regulations worldwide governing the privacy and protection of personal data that is collected, processes, transferred/exported, organized, altered, used, disclosed, combined, destroyed, and held, including adherence and commitment to the E.U. - U.S. Privacy Shield Principles (www.privacyshield.gov), 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 collected in European Union member countries and Switzerland.

2. Notice

Our clients certify to us that they have obtained the consumer's consent and that they have provided the consumer with notice regarding the background screening requirements and permissible purpose in accordance with all applicable laws and regulations. When collecting personal data from consumer's (including EU personal data), our clients certify that consumers are properly informed about the purposes for which personal data about them is collected and used, how to contact the client with any inquiries or complaints, the types of third parties to which information is disclosed, and the choices and means the client offers consumers for limiting use and disclosure. Notice is provided in clear and conspicuous language either when consumers are first asked to provide personal data or as soon thereafter as is feasible, but in any event, before SJV uses such information for the purpose for which it was originally collected or processed by the transferring organization or discloses it for the first time to a third party (other than agents acting under our instructions).

3. The Data Collected

SJV is a public records wholesaler operating on behalf of consumer reporting agencies. The information that is collected about the consumer may include, but may not be limited to, history of arrests and/or convictions, judgements, credit history, employment history, educational history, places of residence, and driving records from data sources such as law enforcement agencies, courts, educational institutions, employers, professional agencies, financial institutions, etc. Personal information may also be collected and provided to our clients for the purposes of making decisions primarily regarding employment, credential verification, and tenancy. The personal information being provided and utilized may include the name, Social Security or relevant national ID number, date of birth, address history, as well as other personal identifiers.

4. Choice

SJV's clients certify that through the process of obtaining the consumer's consent, consumers have the right to choose whether their personal information is to be disclosed to a third party or to be used for a purpose that is materially different from the purpose for which it was originally collected or a purpose subsequently authorized by the consumer.

Providing a signed consent authorizes SJV, and their designated agents, to utilize the provided personal information and transmit that information to our clients. An explicit choice is made available regarding sensitive information. Personal information will be made available to public authorities, including to meet national security or law enforcement requirements, upon receipt of a lawful request submitted to SJV or subsidiaries thereof.

For sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information specifying the sex life of the individual), consumers must provide affirmative express consent (opt in) if such information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by the individuals through the exercise of opt-in choice.

5. Accountability for Onward Transfer

In order to provide our services, SJV utilizes third party agents, both domestically and internationally, to perform tasks on behalf of and under the instruction of SJV. Personal data, including EU personal data, obtained on a consumer may be disclosed from SJV's clients to third parties (such as agents, representatives, vendors, and/or subcontractors) for the purpose of performing functions related to the limited and specified purpose for which the data was collected. SJV's agents, vendors, and/or subcontractors will be contractually obligated 1) to use, protect, and maintain the same level of confidentiality and protection of personal information consistent with this Privacy Policy and Privacy Shield Principles where Directive 95/46/EC applies, and 2) to notify SJV if they make a determination that they can no longer meet this obligation. We recognize that under privacy shield, we have potential liability for unlawful onward transfers.

6. Security

SJV takes reasonable and appropriate measures to safeguard personal information that we have collected, processed, transferred/exported, organized, altered, used, disclosed, combined, destroyed, or held to protect it from loss, disclosure, alteration, destruction, and misuse and unauthorized access, taking into account the risks involved in the processing and the nature of the personal data. Existing protections include the screening of employees handling the data, physical and electronic protective measures, as well as work procedures actively designed to safeguard the information. All such capacities are directly relevant to the purposes stated above.

7. Data Integrity and Purpose Limitation

SJV commits to accurately report information in its products and services. SJV takes reasonable steps (such as internal audit procedures) to ensure that the data and personal information we collect is accurate, complete, current, and reliable for its intended use. SJV cannot be responsible for errors that exist within public court records or within records of government agencies, etc. SJV collects data for the purpose of background screening for employment and other permissible purposes under the FCRA. We may retain information in a form identifying or making identifiable the consumer only for as long as it serves a purpose that the data was collected for.

8. Access

In cases where the information is subject to the FCRA, we comply with the FCRA's requirements regarding access and correction rights of consumers. Consumers who wish to dispute the accuracy of their personal information that we maintain can do so by calling SJV at 1.800.203.0582 or by e-mailing privacy@sjvassoc.com.

9. Privacy Shield Compliance

SJV complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce and European Commission regarding the collection, use, dissemination, and retention of personal information from European Union member countries. SJV and subsidiaries are subject to the investigatory and enforcement power of the Federal Trade Commission (FTC), Department of Commerce, Department of Transportation, or any other U.S. authorized statutory body. SJV has certified that it adheres to the Privacy Shield Principles of notice, choice, and accountability for onward transfer, security, data integrity and purpose limitation, access, recourse, enforcement and liability. To learn more about the Privacy Shield Program, and to view SJV & Associate's certification, please visit www.privacyshield.gov.

9.1 Access

A consumer may request, in writing, access to all EU Personal Data collected and maintained about him or her. We will always make good faith efforts to provide access to the data and provide the consumer a reasonable opportunity to correct, amend, or delete information that is inaccurate or incomplete, except where the burden or expense of providing access would be disproportionate to the risks to the individual's privacy, or where the rights of persons other than the individual would be violated. If we determine that access should be restricted in any particular instance, we will provide the consumer requesting access with an explanation of why we have made that determination and a contact point for any further inquiries.

SJV understands that under the Privacy Shield Principles, the right of access is fundamental to privacy protection as it allows consumers to verify the accuracy of information held about them. A consumer has the right to 1) obtain confirmation from SJV, whether or not we are processing personal data relating to them, 2) have communicated to them such data so that they could verify its accuracy and the lawfulness of the processing, 3) have the data corrected, amended or deleted where it is inaccurate or processed in violation of the Principles.

To request information relating to his or her EU personal data, a consumer may contact SJV by e-mail at the following email address, privacy@sjvassoc.com. For security reasons, we will engage in reasonable efforts to confirm the identity of the individual requesting EU Personal Data to ensure the information is provided to the correct subject of the data.

9.2 Recourse, Enforcement and Liability

A review of this privacy policy is performed annually to verify that it remains accurate and maintains conformity with the principles laid out in the E.U.-U.S. Privacy Shield program. Should an EU consumer experience concern that their rights may have been violated, they should contact us directly for resolution. SJV will work diligently to respond to all complaints within 45 days. In the event that an EU consumer does not receive timely acknowledgment of a complaint, or if the complaint resolution is not satisfactory, SJV offers to consumers an independent recourse mechanism, JAMS EU - US Privacy Shield, www.jamsadr.com/eu-us-privacy-shield, by which each consumer's complaints and disputes are investigated and expeditiously resolved at no cost to the individual. JAMS is a leader in cross-border mediation and arbitration resolving international disputes worldwide.

SJV verifies adherence to the Privacy Shield Principles via 1) in-house verification and internal policies and follow-up procedures and 2) independent party

In compliance with the Privacy Shield Principles, SJV will cooperate with US authorities (such as FTC), EU Member State authorities, DPAs and any other independent third party with regard the investigation and resolution of complaints.

European Union citizens with inquiries or complaints should first contact SJV at 1.800.203.0582 or access www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim to file a complaint with JAMS EU - US Privacy Shield web site. Please also refer to https://thedma.org/resources/compliance-resources/privacy-shield-safe-harbor-guide/privacy-shield-faqs/ for additional information.

SJV accepts the possibility, under certain conditions, for the individual to invoke binding arbitration.

9.3 Performing Due Diligence and Conducting Audits under E.U.-U.S. Privacy Shield

In case of a required audit by law or a "due diligence" review, SJV understands the requirements and obligations of the E.U. - U.S. Privacy Shield as it regards the collection and processing of personal data, such as information on senior executives and other key personnel.

9.4 The Role of the Data Protection Authorities

SJV understands the responsibilities incurred when receiving personal data from the EU and commits to employ effective mechanisms for assuring compliance with the Privacy Shield Principles. In the event of a dispute investigation, we also commit to cooperate with European Union data protection authorities ("DPAs") and comply with any advice given by the DPAs where the DPAs take the view that the organization needs to take specific action to comply with the Privacy Shield Principles.

SJV understands the requirement to disclose personal information, including transparency reports, in response to lawful requests by public authorities which have jurisdiction over the organization's compliance with the Framework.

10. U.S. - Swiss Safe Harbor Framework Compliance

SJV complies with 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 Switzerland. SJV has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view SJV certification, please visit http://www.export.gov/safeharbor/.

10.1 Notice & Choice

SJV is a public records wholesaler operating on behalf of consumer reporting agencies. Personal data is collected and provided to our clients for the purposes of making decisions primarily regarding employment, credential verification, and tenancy. Personal information being provided and utilized may include the name, Social Security or relevant national ID number, date of birth, address history, as well as other personal identifiers. Should consumers not wish to have their personal information made available to SJV and SJV's clients, information can be directly withheld by the consumer. Providing a signed consent authorizes SJV, and their designated agents, to utilize the provided personal information and transmit that information to our clients. An explicit choice is made available regarding sensitive information.

10.2 Onward Transfer

SJV does employ third party agents, both domestically and internationally. Transfer of personal information to a third party agent is contingent upon their adherence to privacy restrictions at least as restrictive as this Privacy Policy. The possibility of transfer is disclosed to the consumer at the time consumer consent is requested.

10.3 Data Security & Integrity

SJV has taken appropriate steps to ensure the security of private information from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Existing protections include the screening of employees handling the data, physical and electronic protective measures, as well as work procedures actively designed to safeguard the information. We gather and utilize personal information in capacities that are directly relevant to the purposes stated above. Internal audit procedures are in place to ensure that personal information gathered and provided is accurate, complete, and current.

10.4 Access

SJV can be contacted to receive a report allowing the consumer to review, correct, amend, or delete inaccurate information. A fee may be charged to offset the cost of compiling and delivering. The report will be provided to the consumer only after the identity of the consumer has been satisfactorily confirmed. Upon identity confirmation, the report will be sent to the consumer by mail.

10.5 Enforcement

Periodically, review and updating of this privacy policy is performed to verify that it remains accurate and is in conformity with the principles laid out in the U.S. - Swiss Safe Harbor program. Should a Switzerland consumer experience concern that their rights may have been violated, they should contact SJV directly. In the event that SJV is unable to satisfy the concerns of the consumer, SJV will cooperate with European Data Protection Authorities regarding the resolution of a complaint or dispute.

11. Amendments

SJV may amend this Privacy Policy from time to time, to reflect new products and services, or as necessary to reflect a new business practice. If we make changes to the Privacy Policy, in accordance with Privacy Shield, we will notify you by posting an announcement on the SJV website.


Contact Information

If you have questions regarding our Domestic and International Data Privacy Policy contact:

SJV & Associates
Eddie Swengross
Vice President
800.203.0582
Privacy@SJVassoc.com

Effective Date of These Privacy Policies

Original Effective Date: January 1, 2009

Last Update Date: May 9, 2017