Privacy Policy

1. INTRODUCTION

Alias Intelligence, Inc. (“Alias,” “we,” “us,” or “our”) is committed to protecting the privacy and security of personal information. This Privacy Policy (“Policy”) explains how we collect, use, disclose, and retain personal information when you interact with our services, including our website, background screening solutions, and contractor marketplace (collectively, the “Services”).

This Policy applies to the following categories of individuals:

• Website visitors
• Customers, vendors, and business partners
• Candidates and data subjects (background screening subjects)
• Employees and job applicants
• Marketplace Contractors

Depending on the context, Alias acts in different roles under applicable privacy laws:

• Consumer Reporting Agency. Under the Fair Credit Reporting Act (“FCRA”), we prepare and furnish consumer reports at the direction of our customers.
• Service Provider or Data Processor. We process personal information on behalf of employers, organizations, or other customers who determine the purpose and means of processing.
• Data Controller. We process personal information for our own business purposes, such as website operations, security, billing, marketing, human resources, and contractor management.

When acting as a service provider or data processor, we process personal information only in accordance with our customers’ lawful instructions and applicable contractual obligations.

2. WHAT INFORMATION WE COLLECT

We collect personal information depending on how you interact with Alias.

2.1 Website Visitors

When you visit our website, we may automatically collect:

• IP address
• Browser type and device identifiers
• Referring and exit pages
• Pages viewed and time spent
• General location information
• Cookies and similar tracking technologies

We also may collect information you provide voluntarily, such as:

• Name
• Company name and job title
• Email address, phone number, mailing address
• Inquiry or contact form submissions

2.2 Customers, Vendors, and Business Partners

If you are a customer, vendor, or business partner, we may collect:

• Business contact details
• Company verification information
• Billing and payment information
• Transaction and fraud-prevention data

2.3 Candidates and Data Subjects

If you are a candidate or data subject of a background screening engagement, we may collect information necessary to provide our screening services, including:

• Name, aliases, and prior names
• Contact details and address history
• Date of birth and government identifiers (where permitted)
• Criminal history records (where legally permitted)
• Professional licenses and certifications
• Publicly available information (such as court records and media reports)
• Global sanctions and watchlist data

Important: We collect this information only when authorized by the customer and, where required, with proper disclosure and consent under applicable law, including the FCRA.

Marketplace Contractors may access candidate and data subject personal information through our Portal in connection with their assignments.

2.4 Employees and Job Applicants

For employees and applicants, we may collect personal information needed for:

• Recruiting and onboarding
• Payroll and benefits
• HR compliance and administration
• Workplace security and performance management

2.5 Marketplace Contractors

If you are a Marketplace Contractor, we collect the following categories of personal information in connection with your onboarding and use of the Marketplace. Capitalized terms used but not defined in this Policy have the meanings given to them in the Marketplace Terms of Service.

Account and Identity Information

• Full legal name
• Contact information (email address, phone number, mailing address)
• Date of birth
• Government-issued identification (for identity verification)

Payment and Tax Information

• Bank account or payment processing details
• Tax identification number (for IRS Form 1099-NEC reporting)

Portal Activity Data

• Login and authentication data
• Assignment history
• Fee and payment history
• Super Snapper data
• Artificial intelligence tool usage data
• Virtual payment card transaction data

Performance Data

• Quality assurance review results
• Performance evaluation records

3. SOURCES OF INFORMATION

We may collect personal information from:

• The individual directly
• Our customers (employers or authorized entities)
• Public records (courts, government databases)
• Educational institutions and employers
• Credit bureaus (where legally authorized)
• Law enforcement or regulatory bodies
• References provided by the candidate
• Publicly available online sources

4. HOW WE USE INFORMATION WE COLLECT

We use personal information only for lawful and legitimate purposes, including:

• Providing background screening and consumer reporting services
• Operating and administering the Marketplace
• Verifying identity, eligibility, and licensing status
• Processing payments and issuing tax forms
• Responding to inquiries and customer requests
• Website operations, analytics, and improvement
• Fraud prevention and security monitoring
• Legal compliance, audits, and dispute resolution
• Contract performance and business administration
• Enforcing our agreements, including applicable terms of service and other contractual arrangements

5. HOW WE SHARE YOUR INFORMATION

We disclose personal information only as necessary to provide our Services or comply with law, including with:

• Customers. We share screening reports and related information with customers who have requested them.
• Service Providers and Vendors. We share personal information with third-party service providers who support our operations, including cloud infrastructure providers (such as AWS), customer relationship management platforms, and payment processors. These providers act as data processors on our behalf and are contractually required to protect personal information and use it only for the purposes we specify.
• Government Authorities. We share personal information where required by law, regulation, legal process, or governmental request.
• Affiliates and Partners. We share personal information with affiliates and partners under contract and confidentiality obligations.
• Corporate Transactions. We may disclose personal information in connection with a merger, acquisition, divestiture, consolidation, or sale of all or substantially all of our assets, or in the unlikely event of bankruptcy.

All third parties are required to protect personal information consistent with this Policy.

Alias does not sell personal information. We also do not share personal information for cross-context behavioral advertising as defined under applicable privacy laws.

6. DATA RETENTION

We retain personal information only as long as necessary to:

• Provide our Services
• Meet contractual obligations
• Comply with legal and regulatory requirements (including FCRA record retention obligations)
• Resolve disputes and enforce agreements

For subject searches, we retain PII and findings for a period of ten (10) years, or until deletion is specifically requested from our clients, whichever is sooner.

For Contractors, we retain account and identity information for the duration of the contractor’s access to the Marketplace and for a reasonable period thereafter. Assignment-related data is retained in accordance with our FCRA obligations and internal data retention policies. Fee and payment history is retained as required for tax reporting purposes.

When personal information is no longer required, we securely delete or anonymize it.

7. SECURITY

We maintain administrative, technical, and physical safeguards designed to protect personal information, including:

• Access controls and least-privilege restrictions
• Encryption in transit where appropriate
• Secure storage and monitoring
• Vendor risk management requirements
• Incident response and breach notification procedures

We process and store data using secure third-party providers, including AWS, whose servers may be located within the United States, the European Union, or other jurisdictions offering adequate protection under applicable law.

No system is completely secure, but we take reasonable, industry-aligned steps to protect data. We are not responsible for the circumvention of any privacy settings or security measures we may provide.

8. COOKIES AND TRACKING TECHNOLOGIES

Our website uses cookies and similar technologies to:

• Operate and secure the website
• Analyze traffic and usage
• Improve user experience

Essential cookies are required for website functionality. Non-essential cookies (such as analytics cookies) are activated only with your consent where required by applicable law. You may control cookies through your browser settings. Disabling cookies may affect site functionality.

9. INTERNATIONAL DATA TRANSFERS

We may process personal information in the United States and other jurisdictions. Where required by applicable law, we implement safeguards such as:

• Standard Contractual Clauses (SCCs)
• UK Addendum / International Data Transfer Agreement (IDTA)
• Vendor contractual privacy obligations

9.1 EU-U.S. Data Privacy Framework

We comply with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework (collectively, the “DPF”) as set forth by the U.S. Department of Commerce. We have certified to the U.S. Department of Commerce that we adhere to the EU-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the DPF, and the Swiss-U.S. Data Privacy Framework Principles with regard to the processing of personal data received from Switzerland in reliance on the DPF. If there is any conflict between this Policy and the applicable DPF Principles, the Principles will control.

We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If third-party agents process personal data on our behalf in a manner inconsistent with the DPF Principles, we remain liable unless we prove we are not responsible for the event giving rise to any damages.

In compliance with the DPF, we commit to refer unresolved complaints concerning our handling of personal data received in reliance on the DPF to JAMS, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF-related complaint from us, or if we have not addressed your complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Under limited circumstances and after other available dispute resolution mechanisms have been exhausted, binding arbitration is available to address certain residual complaints under the DPF not resolved by other means.

10. EXERCISING YOUR PRIVACY RIGHTS

10.1 Submitting Requests

To exercise any privacy rights described in this Policy, please contact us at info@aliasintelligence.com, or write to us at: Alias Intelligence, Inc., PO Box 741, Teaneck, NJ 07666. For Marketplace Contractor inquiries, please contact us at contractor@aliasintelligence.com.

Your request must provide sufficient information to identify you and the law that applies to you, such as your name, email address, home or work address, or other information we maintain. Do not include Social Security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, or health information in your request.

10.2 Verifying Requests

We verify requests by matching information in the request to information we maintain. We may require you to confirm your identity by authenticating through your account or other access method. If your request is unclear or we are unable to authenticate your identity, we may ask for additional information, in accordance with the law that applies to you. If we cannot verify the identity of the individual in the request, we may deny it in full or in part.

10.3 Authorized Agents

If you are an authorized agent submitting a request on behalf of another individual (where permitted by applicable law), we may require proof of the individual’s written authorization before processing the request.

10.4 Responses to Requests

We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. We will respond in accordance with any deadlines or requirements specified by the laws that apply to you. At times, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable, and unreasonable risk to the security of the information, user accounts, or the security of our systems or networks.

10.5 Appeals

Residents of jurisdictions that provide for an appeal mechanism (including Colorado, Connecticut, and Virginia) may appeal a decision we have made regarding their requests by contacting us at info@aliasintelligence.com. We will respond to appeals in accordance with the timeframes required by applicable law.

11. U.S. STATE PRIVACY RIGHTS

If you are a resident of California, Colorado, Connecticut, Utah, Virginia, or another state with a comparable data privacy law, you may have additional rights that you (or, in certain states, an authorized agent acting on your behalf) can exercise by contacting us. These rights may include:

• Access to and/or a copy of certain personal information we hold about you
• Correction of inaccurate personal information
• Deletion of certain personal information
• Opt-out of the sale or sharing of personal information for targeted advertising
• Opt-out of profiling or automated decision-making that produces legal or similarly significant effects, if applicable
• Non-discrimination for exercising your privacy rights

These rights may be subject to exceptions, including where information must be retained to comply with legal obligations or where consumer reporting laws apply. Certain personal information processed under the FCRA is exempt from state privacy law requirements.

11.1 Additional Information for California Residents

In addition to the rights described above, California residents are afforded additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”).

Categories of Personal Information Collected

The information we collect, as described in Section 2, falls into the following CCPA-defined categories of personal information:

• Identifiers (name, email address, IP address, account login credentials, and government identifiers)
• Financial data (payment and billing records, tax identification numbers)
• Internet or other electronic network activity information (browsing history, interactions with the Services)
• Geolocation data (as inferred from IP address)
• Professional or employment-related information (PI license number, employment history for candidates)
• Inferences drawn from the above categories

Categories Disclosed for Business Purposes

In the preceding twelve (12) months, we have disclosed the following categories of personal information for business purposes:

• Identifiers — to customers (in screening reports), service providers, and government authorities
• Financial data — to payment processors
• Internet or other electronic network activity information — to analytics providers and service providers
• Professional or employment-related information — to customers (in screening reports)

No Sale or Sharing

Alias does not sell personal information. We do not share personal information for cross-context behavioral advertising as defined under the CCPA. We have not sold or shared personal information for these purposes in the preceding twelve (12) months.

Sensitive Personal Information

Some personal information we collect may be considered Sensitive Personal Information under the CCPA, such as:

• Government-issued identifiers (such as Social Security numbers and driver’s license numbers)
• Financial information (where legally authorized)
• Criminal history information

We collect and use Sensitive Personal Information only as necessary to provide our Services, comply with legal obligations, prevent fraud, and maintain security. We do not use Sensitive Personal Information for purposes of inferring characteristics about individuals or for cross-context behavioral advertising. Where required by law, you may have the right to limit the use or disclosure of Sensitive Personal Information.

Do Not Track and Global Privacy Control

Our Services are designed to honor Global Privacy Control (GPC) signals sent from California IP addresses through browser or device-level settings, provided the signal complies with the CCPA’s requirements. When we detect a valid GPC signal, we will treat it as a request to opt out of any sale or sharing of personal information associated with that browser or device.

California’s Shine the Light Law

Under California Civil Code Section 1798.83, California residents may request information about third parties who have received personal information for their direct marketing purposes. Alias does not share personal information with third parties for their direct marketing purposes.

California Department of Consumer Affairs

In accordance with California Civil Code Section 1789.3, California residents may report complaints to the California Department of Consumer Affairs’ Division of Consumer Services in writing at: Complaint Assistance Unit, 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.

12. UK AND EEA DATA PROTECTION RIGHTS

This section applies to individuals located in the United Kingdom and the European Economic Area (“EEA”).

Alias may act as a processor when we process personal data on behalf of our clients, and as a controller when we process personal data for our own business purposes.

12.1 Lawful Basis for Processing

Where we act as a controller, we process personal data under one or more of the following lawful bases:

• Consent. When you voluntarily provide your data for marketing or communication purposes.
• Contractual Necessity. When processing is required to perform a contract with you (including the Marketplace Terms of Service).
• Legal Obligation. When we must process your data to comply with legal requirements.
• Legitimate Interest. When processing is necessary for our legitimate business purposes and does not override your rights.

Where we rely on legitimate interest, we ensure that such processing is necessary, proportionate, and does not override your rights or freedoms. You may object to processing based on legitimate interest at any time.

12.2 Your Rights

Subject to applicable law and identity verification, you may have the right to:

• Request access to your personal data
• Request correction of inaccurate personal data
• Request deletion of your personal data
• Object to processing
• Request restriction of processing
• Request data portability
• Withdraw consent where processing is based on consent

To exercise these rights, see Section 10.

13. INFORMATION FOR USERS IN BRAZIL

Users residing in Brazil are afforded additional rights under the Lei Geral de Proteção de Dados (“LGPD”). If you are a Brazilian resident, this section applies to you.

In addition to the rights described in Section 10, Brazilian residents may exercise the following rights:

• Right of access to your personal data
• Right to rectify your personal data if it is incorrect
• Right to anonymize, block, or erase unnecessary or excessive personal data
• Right to the portability of your personal data
• Right to object to the processing of your personal data
• Right to withdraw consent
• Right to review decisions based on the processing of personal data carried out exclusively by automated means

To exercise these rights, see Section 10.

14. INFORMATION FOR USERS IN CANADA

Users residing in Canada are afforded additional rights under the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial privacy legislation. If you are a Canadian resident, this section applies to you.

In addition to the rights described in Section 10, Canadian residents may exercise the following rights:

• Right of access to your personal data
• Right to rectify your personal data if it is incorrect
• Right to withdraw consent
• Right to file a complaint regarding the processing of your personal data with the Office of the Privacy Commissioner of Canada

To exercise these rights, see Section 10.

15. INFORMATION FOR USERS IN THE REPUBLIC OF KOREA

Users residing in the Republic of Korea are afforded additional rights under the Personal Information Protection Act (“PIPA”). If you are a Korean resident, this section applies to you.

In addition to the rights described in Section 10, Korean residents may exercise the following rights:

• Right of access to your personal data
• Right to rectify your personal data if it is incorrect
• Right to erase your personal data
• Right to limit the processing of your personal data
• Right to the portability of your personal data
• Right to object to the processing of your personal data
• Right to withdraw consent

To exercise these rights, see Section 10.

16. INFORMATION FOR USERS IN AUSTRALIA

We comply with the Privacy Act 1988 (Cth), including the Australian Privacy Principles. If you are an Australian resident and have a privacy-related complaint, you may contact us at info@aliasintelligence.com. If you believe that we have failed to resolve your complaint satisfactorily, you have the option of contacting the Office of the Australian Information Commissioner (OAIC). Contact details for the OAIC may be found at www.oaic.gov.au.

17. SWISS ADDENDUM

For residents of Switzerland, data processing complies with the Swiss Federal Act on Data Protection (FADP). Where applicable, data transfers outside Switzerland are governed by Standard Contractual Clauses (SCCs) and equivalent safeguards.

18. CHILDREN

Our Services are not directed to children, and we do not knowingly collect personal information from children under the age of 13, or older where required by applicable law. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete it. Parents or legal guardians may contact us to request deletion of such information.

19. ACCURACY

We understand the importance of accurate data and have legal obligations under the FCRA and other laws to ensure the accuracy of our screening results. When we collect personal information directly from you, we deem such information accurate. When we collect personal information from other sources, each source is responsible for the accuracy of the information it provides. If we discover that personal information is inaccurate, we will correct the inaccuracies. To request correction of your personal information, please contact us using the information in Section 10.

20. DATA BREACH NOTIFICATION

In the event of a data breach involving personal information, Alias will take reasonable steps to investigate, contain, and remediate the incident. Where required by applicable law, we will provide notice to affected individuals and relevant authorities within the legally required timeframes.

21. ARTIFICIAL INTELLIGENCE SYSTEMS AND DATA USAGE

Where Alias deploys AI systems, any personal data used for AI model development is aggregated to prevent identification.

22. FCRA DISPUTE AND REINVESTIGATION

If you believe that information contained in a background screening report prepared by Alias is inaccurate or incomplete, you have the right to dispute the information.

22.1 How to Submit a Dispute

You may submit a dispute by contacting us at:

To help us process your dispute efficiently, please include:

• Your full name
• Contact information
• A clear description of the information being disputed
• Any supporting documentation, if available

22.2 Reinvestigation

Upon receipt of a valid dispute, Alias will conduct a reinvestigation in accordance with the FCRA. We will review the disputed information, contact relevant data sources as necessary, and notify you of the outcome within the timeframe required by law.

23. HOW TO CONTACT US

For general privacy inquiries, to exercise your data protection rights, or if you have any concerns about our data practices, please contact us at:

If you remain dissatisfied, you may make a complaint to your relevant supervisory authority or data protection regulator.

24. EU AND UK REPRESENTATIVES

Under Article 27 of the UK GDPR, we have appointed a UK Representative:

Under Article 27 of the GDPR, we have appointed an EU Representative:

25. CHANGES TO THIS PRIVACY POLICY

We may update this Policy periodically. Changes will be posted with an updated “Last Updated” date.