PRIVACY POLICY - INTERNATIONAL

I. Policy Scope

Hello Verify India Private Limited is dedicated to protecting your personal Information

and will make every reasonable effort to handle collected Information appropriately. This

Privacy Policy (“Policy”) describes how Hello Verify India Private Limited ("Hello Verify

India” or "we" or "our") treats Information collected or provided in connection with an end

user’s (“you” or “user” or “client”) use of Hello Verify India products and background

screening services (the “Services “). This privacy statement covers the data collected by

Hello Verify India. By accessing, using or by providing data directly to Hello Verify India

you accept and agree to Hello Verify India Privacy Policy. We are committed to protecting

privacy and information provided by end users to enable Hello Verify India to complete its

Services. This Privacy Policy sets forth Hello Verify India policy with respect to

Personally Identifiable Information (“PII”), Sensitive Personal Information ("SPI") and

certain other information that is collected from users of the site.

This Policy has been drafted in accordance with the provisions of the Information

Technology Act, 2000 and the Rules thereunder, including, without prejudice to the

generality of the foregoing, the Information Technology “Reasonable security practices

and procedures and sensitive personal data or information” Rules 2011. Your use of and

interaction with Hello Verify India’s online portals constitutes your unconditional

acceptance of the practices described in this privacy policy, as they may be modified from

time to time. If you do not agree with and accept all of the practices described in this

privacy policy, you may refrain from using Hello Verify India’s website/online portals

and/or providing or submitting Personally Identifiable Information (“PII”) & Sensitive

Personal Information ("SPI") by means of or while using Hello Verify India’s

website/online portals. By providing personal information to us, you consent to our

collection, use and disclosure of your personal information in accordance with this privacy

policy.

Hello Verify India Privacy Policy applies to all of the services offered by Hello Verify

India Private Limited including services offered on the websites/online portals. The Policy

applies to all the Clients, Vendors, Employees, CEO, COO and such other stakeholders

who are associated with Hello Verify India.

II. Policy Changes

We reserve the right to modify Hello Verify India’s privacy policy at any time which will be

published on our website. If we make material changes to this privacy policy, we will notify

the same by means of a notice on our home page. By continuing to use our service after

notice of changes have been published on the website, the Client is deemed to be consenting

to the changes.

III. Policy Content

This policy seeks to answer questions you may have about the Services and Hello Verify

India information practices.

i. What information we collect and why we collect it.

ii. How we share and use that information.

iii. General Exceptions.

iv. Consent and Update of Records.

v. Services regarding tracking, analytics and email communications.

vi. Security and Compliance with regulatory authorities.

vii. How we protect your information.

viii. Where is the information processed or stored?

ix. Who can use the services?

x. Grievance officer.

IV. Information we collect

Personally Identifiable Information

Personally Identifying Information (“PII”) of a person means such information that can

potentially identify you, such as your name, date of birth and address. It does not include

anonymized, aggregate or statistical information.

Personally Identifying Information that we collect and hold about an individual will vary

depending upon the background checks required by the Client and the information the

individual supplies to us. Personally Identifiable Information and Sensitive Personal

Information or Data (SPI) shall have the same meaning as defined under The Information

Technology Act, 2000 read with Rules along with the amendments made thereunder.

Hello Verify India does not collect any Sensitive Personal Data or Information, without due

notification to you and without your consent unless it is mandated by law. We recognize the

importance of PII and SPI provided to us with respect to privacy issues and confidentiality of

the PII and SPI. Therefore, we collect and deal with PII and SPI in accordance with the

privacy legislations in India and this Privacy Policy (as amended from time to time).

Personally Identifiable Information about an individual that we may collect and hold includes

name, age, date of birth, employment history, reference information, education, professional

qualifications, residency, sanctions, immigration status, claims, judgments, insolvency,

current and previous directorships, character, personal reputation, and such other checks and

enquiries as the client considers necessary to verify information provided by an individual.

From clients we may collect company address and the name, email and phone number of any

system users.

From clients and individuals, we may collect information related to conducting a background

check, payment details.

From the sources of our background checks we may collect the name and job title of the

person who supplied us with the information.

We recognize the importance of privacy issues and respect the confidentiality of the

Personally Identifying Information individuals or clients provide to us. We will collect and

deal with Personally Identifying Information in accordance with the local laws and this

Privacy Policy (all as amended from time to time).

How do we collect information?

In order to process and verify information for a client’s request, the client and Hello Verify

India may collect an individual’s Personally Identifying Information directly from the

individual. We may also collect information which the client provides directly through their

client portal access or usage of our applicant portal, wherein clients/applicant upload

applicant’s details on the portal and access is given to Hello Verify India Users. We collect

information to provide better services to all in the following ways:

a) Information given to us. i. Clients: If client want to use the services to screen applicants we may collect

the following information including, but not limited to:

Account creation information, including client name, email address

Contact information such as address and phone number;

Corporate and individual applicable license information not limited to

Driver license, doctor’s license

If client is an employer, employee identification number

ii. Applicants: If applicant directly provide us details who will be the subject of

a screening or background check, we may collect the following information

including, but not limited to:

Account creation information, including full name, e-mail address;

Contact information, including phone number and address;

Identity verification information, including identity number and date of

birth; and

Additional information or supporting documentation submitted or

upload regarding identity, background, query;

Examples include an uploaded picture, a driver’s license, or education

qualification document

We may use the Personally Identifiable Information (“PII”) & Sensitive Personal

Information ("SPI"), documents and any responses an individual or third party

reference has provided to us for verification of an individual’s personal and other

information, to collect additional Personally Identifiable Information (“PII”) &

Sensitive Personal Information ("SPI"), and to conduct public court record searches.

Example of sources include, but are not limited to, government agencies, law

enforcement bodies, publicly available records, public registries, court or tribunal

records, insolvency registers, educational institutions, current and/or precious

employers, and regulatory and licensing bodies.

b) Information used by Hello Verify India. We collect information for conduct and delivery of services contracted by our client or

applicants. Hello Verify India may collect this information via online request through email,

this information includes:

i. Log information:

Hello Verify India Private Limited may use (only with permission) this

information to provide its client with background check information &

additional information regarding products and services.

verify applicant identity;

conduct background checks bases upon information provide by client;

conduct quality assurance checks;

investigate disputes; or

provide certain communications, including adverse action notices.

contact client regarding their use of the Services;

send client communications regarding updates or modifications to the

services.

Hello Verify India obtains client’s consent to use, transfer or store the information only for its

legitimate business purpose. Such information shall be stored, processed and retained in the

Hello Verify India database to be used only for the legitimate business purposes.

V. Information we share

We do not share Personal Identifiable Information with companies, organizations and

individuals outside of Hello Verify India unless one of the following circumstances applies:

With client and applicant consent

We will share applicant Information with companies, organizations or individuals

outside of Hello Verify India for employment services when we have client consent to

do so.

For external processing

For conduct of background reports that may arise during the course of the verification

service. Hello Verify India may use researchers & third party service Providers,

whom Hello Verify India may provide access to client information to select third

parties who perform services on our behalf. These third parties provide a variety of

services to us, including without limitation conducting components of background

checks, billing, fulfillment, data storage, analysis and processing, identity verification,

fraud, accounting, auditing, and legal services.

For legal reasons

We will share Personally Identifiable Information (“PII”) & Sensitive Personal

Information ("SPI") /data with companies, organizations or individuals outside of

Hello Verify India if we have a good-faith belief that access, use, preservation or

disclosure of the information is reasonably necessary to:

Meet any applicable law, regulation, legal process or enforceable

governmental request.

Enforce applicable Terms of Service, including investigation of potential

violations.

Detect, prevent, or otherwise address fraud, security or technical issues.

Protect against harm to the rights, property or safety of Hello Verify India,

our users or the public as required or permitted by law.

If Hello Verify India is involved in a merger, demerger, acquisition or asset sale or

reconstruction we will continue to ensure the confidentiality of any Personally Identifiable

Information (“PII”) & Sensitive Personal Information ("SPI")/ data and give affected users

Notices.

Data Retention: Hello Verify India retains Personally Identifiable Information (“PII”) &

Sensitive Personal Information ("SPI") as needed to provide services or product information,

respond to inquiries, or as required by contractual obligation such as Client – Hello Verify

India contracts, statutory or other legal obligations. All Client Information is stored/ retained

digitally.

Data Retention is defined as the maintenance of data in a production or live environment

which can be accessed by an authorized user in the ordinary course of business. For the

avoidance of doubt, data used in staging, development, and testing or draft versions of data

shall not be retained beyond their active use period, nor copied into production or live

environments.

The retention period of Hello Verify India data shall be an active use period of five years

unless an exception has been obtained from client in a documented/stated expression -

permitting a longer or shorter active use period by the division responsible for creating, using,

processing, disclosing storing and destroying the data or as directed by client contracts.

Hello Verify India data may be classified into paper data such as contracts or hard drives on

servers namely the Oniverify production servers and the Oniverify backup servers. After

active use has expired and according to appropriate exceptions, data shall be archived until

the data is destroyed. For the purposes of enforcing retention in accordance with this policy,

each function is responsible for the data it creates, uses, stores, processes and destroys.

VI. General Exceptions

If we are required to intercept, disclose, monitor and/or store client Personally Identifiable

Information (“PII”) & Sensitive Personal Information ("SPI"):

by law;

to conduct our business;

to secure our systems; or

to enforce our own rights, we will do so in the manner as prescribed by law.

Such interception, disclosure, monitoring and storage may take place. In that case, we will

not be liable for any third party damages howsoever arising from such interception,

disclosure, monitoring and storage. In order to ensure that all our users comply with the User

Agreement or Terms of Use of the Hello Verify India platform or application, we may

monitor Personally Identifiable Information (“PII”) & Sensitive Personal Information ("SPI")

to the extent that this may be required to determine compliance and/or to identify instances of

non-compliance. To ensure that the security and integrity of our Services is safeguarded, we

may monitor Personally Identifiable Information (“PII”) & Sensitive Personal Information

("SPI"). This monitoring may include (without limitation) the filtering of incoming and

outgoing electronic data messages to identify, limit and/or prevent the transmission of spam,

viruses and/or unlawful, defamatory, obscene or otherwise undesirable material or content.

We may under certain circumstances procure an element of the Services from a third party

service provider. To the extent that it may be necessary, and solely for the purposes of

providing the Service to client, Client are deemed to be in agreement of disclosure to such

third party of their Personally Identifiable Information (“PII”) & Sensitive Personal

Information ("SPI") that may be necessary for the procurement of services from the third

party.

VII. Withdraw Consent

Client/candidate may at any time withdraw their consent of PII and SPI stored with Hello

Verify India. Any withdrawal of will be effective only after a reasonable duration of 15 days

from the date of communication of such withdrawal of consent.

VIII. Update Records

Clients should promptly update their contact information pursuant to a change or inaccuracy

of such information, with their customers/employer or may contact us on their behalf.

Applicants may review, access, and change certain account information such as email

address, phone number and mailing address via the applicant portal on the services. Requests

to change certain other information, such as identity numbers, may require verification before

the change is accepted. Applicants can request deletion of certain information in Hello Verify

India’s control by directly contacting Hello Verify India, as set forth at the end of this Policy.

Applicants can dispute background check reports through the applicant portal/ or by directly

contacting their employer/customer (requestor), which is accessible through the Services.

Once a Customer, such as an employer, has received a background check report, Hello Verify

India Private Limited does not control the customer’s retention of such information.

Our policy is to retain Personally Identifiable Information (“PII”) & Sensitive Personal

Information ("SPI") only as long as reasonably necessary to provide the Services or as

otherwise required for legal compliance purposes. For instance, we may retain information,

including information from closed accounts, in order to comply with the law, prevent fraud,

collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations

of any user, enforce our Terms of Use, and/or for any other purposes otherwise permitted by

law that we deem necessary in our sole discretion.

Hello Verify India will be unable to proceed with the provision of services to Clients in the

absence of necessary permissions or consent from the individual subject to the background check.

IX. Choices regarding online tracking, analytics and email

communications

Hello Verify India may send periodic promotional or informational emails to its Clients.

Clients may opt out of such communications by connecting with their concerned account

manager or sending an email to Hello Verify India (please see last section for contact email

id). Please note that it may take up to 15 business days for us to process opt-out requests. If

client opts out of receiving emails about recommendations or other information we think may

interest them, we may still send emails about clients account or any services that have been

requested or received from us.

X. Security and Confidentiality

Hello Verify India strives to protect Personally Identifiable Information (“PII”) & Sensitive

Personal Information ("SPI") that we collect, maintain and disclose through the use of

reasonable administrative, physical and technical safeguards. Our products and/or services

online are transmitted through a Secure Socket Layer (SSL) transmission, which is a protocol

for establishing a secure connection for transmission of Personally Identifiable Information

(“PII”) & Sensitive Personal Information ("SPI").

Hello Verify India has also employed security protocols and measures to ensure

confidentiality and protection of Personally Identifiable Information (“PII”) & Sensitive

Personal Information ("SPI"), in order to avert unauthorized access or alteration as well as

unlawful disclosure of the collected information. These measures include internal and

external firewalls, physical security and technological security measures, as well as

encryption of certain information and password protection for account information. Ergo, our

security program is designed to: (1) ensure the security and confidentiality of personal

identifiable information that may include Pan Number, Aadhar Card Number etc.;(2) protect

against any anticipated threats or hazards to the security or integrity of the information; and

(3) protect against unauthorized access, use, alteration, or unlawful disclosure of the

information that could result in substantial harm or inconvenience to any individual.

XI. Compliance and cooperation with regulatory authorities

Hello Verify India ensures regularly review our compliance with our Policy. We also adhere

to several self-regulatory frameworks, including and not limited to adherence to Information

Technology, Privacy and Data Protection legislations applicable in India.

XII. Protection of Information

Hello Verify India provides for adequate safeguards to protect/secure Information we

maintain about Client. Hello Verify India strives to use information security best practices as

defined within ISO 27001 and client provided security requirements, such as, encryption,

passwords, secure network, IT hardening and physical security measures to protect

Information against unauthorized access and disclosure.

XIII. Information processing or stored

For the purposes of processing or storing information, Hello Verify India employs servers

installed in its facility located in Noida, India. Our servers reside in a secure environment

protected from unauthorized access, natural disaster, fire or other compromising conditions.

Hello Verify India uses servers located in facility in Noida, India. Additionally, Hello Verify

India may engage with its partners or affiliates located in India in order to store and process

information for the purposes of backup or retention, as the case may be. By using our

services, Clients consent to transmit data to sources for verification that may be within India

or outside India. Hello Verify India ensures safe data transmission and handling.

XIV. International – Onward Transfer of Personal Identifiable

Information

We may disclose Personally Identifiable Information (“PII”) & Sensitive Personal

Information ("SPI") for the purposes of conducting our services to overseas recipients. The

circumstances of disclosure may be as follows: -

We may need to disclose an individual’s Personally Identifiable Information overseas in

order to carry out background checks. For example, if an individual lived, studied or worked

overseas, we may need to disclose that individuals Personally Identifiable Information (“PII”)

& Sensitive Personal Information ("SPI") to obtain data from sources, employers, third party

reference or education institutes. Disclosures of this kind may be to any country in the world,

depending upon the nature and scope of work to be carried, and where the candidate’s data

resides.

We may also disclose an individual’s Personally Identifiable Information (“PII”) & Sensitive

Personal Information ("SPI") to related bodies for purposes including operations, processing

of background report or make it accessible to law enforcement and national security

authorities in India, upon receipt of authorization letter, notice, warrants or legal mandate.

XV. Information from Children

Hello Verify India background verification is not directed to children under the age of 13 and

we do not knowingly collect personally identifiable information from children under the age

of 13. If we learn that we have collected personally identifiable information of a child under

the age 13, we will take reasonable steps to delete such information from our files as soon as

is practicable.

Please contact us at privacy@Helloverify.com if you believe we have any information from

or about a child under the age of 13.

XVI. Grievance Officer

As required under The Information Technology Act of India, the name and contact details of

the grievance officer are as provided below:

Vinod Chandra Mamgai

Email: privacy@Helloverify.com

Phone Number: +91 011 30441084

The Grievance Officer/Privacy protection officer is designated exclusively for addressing

discrepancies and grievances of data providers with respect to processing of information in a

time bound manner. Please do NOT use the contact information for login issues for any portal

of Hello Verify India.

XVII. U.S. PRIVACY POLICY

Hello Verify India Privacy Vision

Hello Verify India is committed to the responsible use of information and protecting

individual privacy rights. Hello Verify India strives to provide services to businesses,

consumers, non-profit organizations and government agencies that help reduce fraud,

mitigate risk, facilitate more informed decisions, and make society safer, in ways that protect

consumer privacy. We aspire to protect consumer privacy through the design of our

products, by credentialing, monitoring, and auditing our customers as appropriate, and

through other information security safeguards. We also strive to promote transparency

through consumer education initiatives, privacy principles and policies, and appropriate

opportunities for consumer choice, access, and correction with respect to personal

information about the consumer.

Data Privacy Principles

The Hello Verify India Data Privacy Principles speak to the personally identifiable

information including sensitive personally identifiable information, collected, maintained,

used or disseminated in connection with services offered by Hello Verify India, or by its

affiliates (all hereinafter "Hello Verify India").

Hello Verify India applies these Principles to our domestic products and services where

appropriate. In addition, other uses or disclosures may occur as required by applicable law,

such as the Fair Credit Reporting Act and its state analogues ("FCRA"), the Driver's Privacy

Protection Act and its state analogues ("DPPA"), and the Gramm-Leach-Bliley Act ("GLB").

If the law requires or upon request of law enforcement, or, if necessary, to prevent fraud or to

protect our computer systems, these principles may not apply. Hello Verify India also, from

time to time, may revise our Data Privacy Principles by posting changes on its Web site.

1. SECURITY Data security is a company imperative. Hello Verify India strives to protect personally

identifiable information that we maintain or disseminate, including through the use of

appropriate administrative, physical, and technical safeguards, so it is not obtained by

unauthorized individuals or used impermissibly.

2. DISTRIBUTION OF PERSONALLY IDENTIFIABLE INFORMATION

Hello Verify India seeks to limit the distribution of personally identifiable information

consistent with the nature and sensitivity of the information. In its services, Hello Verify

India also strives to make available personally identifiable information from sources other

than public records or publicly available information only to its authorized users or

customers. Similarly, where applicable, Hello Verify India strives to restrict access to

information in accordance with privacy laws such as the FCRA, the GLB, and the DPPA and

comparable state statutes. In the case of public record information available to the general

public (such as bankruptcy, liens, judgments, criminal records and Uniform Commercial

Code filings) and publicly available information (such as telephone directory information or

personal information available through widely available media), we may make this

information available to the general public unless applicable law operates to limit our

distribution of such information to authorized users.

If, upon investigation, Hello Verify India finds that personally identifiable information has

been used or accessed inappropriately or unlawfully, Hello Verify India strives to take

reasonable steps to stop the misuse or access, educate the user concerning the appropriate use

of the information, and prevent similar future misuses. Such steps may include measures up

to and including discontinuation of the user's access to Hello Verify India information

products and services, pursuit of other legal remedies, and the referral of misuse to the

appropriate authorities.

3. ACCURACY

Hello Verify India strives to accurately report information in its products. Hello Verify India

also strives to accurately report information that it receives from its data sources. Hello

Verify India recognizes, however, that reporting errors may occur and offers consumers

opportunities, where applicable, to dispute and correct information that we report as

discussed further in Principle 9 on Access and Correction.

4. PROTECTION OF SOCIAL SECURITY NUMBERS

Hello Verify India strives to provide additional safeguards for sensitive personally

identifiable information, such as Social Security numbers and driver's license numbers. Hello

Verify India strives to limit the availability and access to full Social Security Numbers

("SSNs"), Driver's License Numbers and State Identification Numbers. Hello Verify India

strives to protect the confidentiality of SSNs by limiting access to SSNs to certain legitimate

and authorized users, such as: state, local and federal government entities; financial

institutions; insurers; employers; creditors; debt collectors and other user types to which

Hello Verify India may decide to provide such access. A limited number of public records

may contain SSNs that are already available to the public and, if such public records are

accessed through Hello Verify India services, our services may provide access to such SSNs.

Hello Verify India prohibits the unlawful disclosure of SSNs. Hello Verify India also takes

steps to limit the availability of Driver's License Numbers ("DLNs") and state identification

card numbers.

5. EDUCATION

Hello Verify strives to inform its employees, users and the general public about appropriate

use of Hello Verify India products and services. Hello Verify strives to inform its users and

employees about:

- Privacy and security issues associated with Hello Verify India information products and

services; and

- The responsible use of personally identifiable information.

Hello Verify India strives to inform the public about:

- The responsible use of personally identifiable information; and

- Measures Hello Verify India has undertaken to enhance consumer privacy; and choices

available to consumers regarding information access and the ability to opt-out of certain

products and services which utilize personally identifiable information.

6. REPUTABLE SOURCES

Hello Verify India strives to acquire personally identifiable information from established,

reputable sources in the government and private sectors. In support of this Principle, Hello

Verify India takes reasonable steps to assess the reputation and reliability of its private sector

data sources before incorporating personally identifiable information from the source into its

products and services. Hello Verify India also strives to obtain assurances from its data

suppliers that they have the legal right to license or sell the data to Hello Verify India.

7. NOTICE

Hello Verify India strives to make its Data Privacy Principles publicly known. Hello Verify

India publicly posts these Data Privacy Principles.

Security;

Distribution of Personally Identifiable Information;

Accuracy;

Protection of Social Security Numbers and Driver's License Numbers;

Education;

Reputable Sources;

Notice;

Choice;

Access and Correction;

Accountability;

Online Privacy;

Identity Theft; and

Compliance

8. CHOICE

Hello Verify India strives to allow consumers to opt-out of the dissemination of personally

identifiable information from certain Hello Verify India owned databases used solely for

marketing services.

9. ACCESS & CORRECTION

Hello Verify India strives to provide consumers with a central point of contact regarding their

questions about Hello Verify India and its commitment to the responsible use of personally

identifiable information. Hello Verify India strives to inform individuals about the nature of

the public records, non-public information, and publicly available information that Hello

Verify India makes available in its information products and services. Hello Verify India also

strives, whenever practicable, to provide consumers, upon request, with meaningful

opportunities to review personally identifiable information we maintain about them. Hello

Verify India also strives, as appropriate and practicable, to provide opportunities for

consumers to dispute and correct information by assisting them in identifying the potential

information sources at which corrections should be made. Hello Verify India strives to direct

individuals to the government and private entities that collect and maintain public records and

publicly available information to correct any claimed inaccuracies found in that data, and to

direct individuals to consumer reporting agencies where such agency is the source of the

information about the individual and where the individual seeks to correct claimed

inaccuracies found in that data.

10. ACCOUNTABILITY

Hello Verify India 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. Hello Verify India also supports industry oversight and active

engagement with the privacy community. Hello Verify India believes that strong privacy and

information security protections are vital for an effective and trusted data industry.

11. ONLINE PRIVACY

Hello Verify India strives to protect the privacy of personally identifiable information

obtained over the Internet and strives to apply our Data Privacy Principles and evolving

standards to the online environment.

12. IDENTITY THEFT

Hello Verify India strives to prevent the acquisition of information from its products and

services for improper purposes, such as identity theft. Hello Verify India believes that it is

important that individuals who may have had their sensitive personally identifiable

information acquired by an unauthorized individual be notified as follows: Where a state law

requires notice, Hello Verify India complies with the law. In those states where notification

laws do not exist, Hello Verify India follows its Information Security Breach Response and

Notification Policy, which provides that affected individuals will be notified when sensitive

personally identifiable information owned or licensed by Hello Verify India is acquired by an

unauthorized individual and whenever Hello Verify India has a reasonable basis to believe

the breach has resulted in, or there is a significant risk that it will result in, identity theft to the

consumer to whom the information relates.

13. COMPLIANCE Hello Verify India will obtain assessments from a qualified, objective, independent third-

party, who uses procedures and standards generally accepted in the profession to assess Hello

Verify India' administrative, technical, and physical safeguards, as appropriate.

How We Use and Collect Information in Our Various Businesses:

A number of Hello Verify India businesses are consumer reporting agencies (CRAs)

operating in accordance with the requirements of the Fair Credit Reporting Act (FCRA).

FCRA establishes the following principles for all CRAs:

Privacy: Information about you may only be furnished to third parties that have a permissible

purpose. In general, these deal with credit, employment, insurance, rental or banking

transactions initiated by you, or where the object is to make a firm offer to you. CRAs must

qualify their customers to make certain that they have a permissible purpose to receive the

information.

Access: Consumers may receive a copy of information the CRA maintains about them. Such

reports can be obtained free of charge once per year or for a reasonable fee for additional

disclosures. Please visit the applicable subsidiary Web sites to obtain more information.

Accuracy: CRAs must follow reasonable procedures to assure accuracy of the information

they maintain and furnish. When you obtain a copy of your information, you have a right to

dispute and have the information reinvestigated and corrected in the CRAs database.

Fairness: Information is obtained from various sources including public records sources.

However, certain information over a specified time period may not be reported.

Accountability: The Federal Trade Commission is charged with overseeing the operations of

CRAs and enforcing FCRA requirements.

Privacy Notice: Preparation and Processing of Investigative Consumer Reports

This notice is provided to California residents. Under California law, an "investigative

consumer report" is a consumer report containing information on a consumer's character,

general reputation, personal characteristics, or mode of living. Hello Verify India compiles

investigative consumer reports about individuals and provides them to business for

background screening, tenant screening, and similar purposes.

Personal Information Disclosure: United States or Overseas – In connection with its

preparation and processing of investigative consumer reports, Hello Verify India may transfer

personal information about you to our authorized service providers and affiliates outside the

United States and its territories. Such transfer will be conducted in accordance with all

applicable laws and regulations.

To obtain additional information about the privacy practices and policies of Hello Verify

India in connection with its preparation and processing of investigative consumer reports,

please contact:

Hello Verify India Private Limited

Email: privacy@Helloverify.com

XIX. EUROPEAN UNION PRIVACY SHIELD PRIVACY POLICY

Hello Verify India Private Limited have committed to handling EU Personal Data received in

accordance with the EU-US Privacy Shield Principles set forth in the EU-US Privacy Shield

Framework administered by the Department of Commerce regarding the collection, use and

retention of EU Personal Data. “EU Personal Data” is data pertaining to an identified or

identifiable individual that is received by Hello Verify India from the European Union

(including Iceland, Norway and Liechtenstein).

In compliance with the EU-US Privacy Shield Principles, Hello Verify India commits to

resolve complaints about our collection or use of your personal information. Individuals in

the European Union with inquiries or complaints regarding this policy should first contact

Hello Verify India at privacy@HelloVerify.com or at one of the contacts provided below..

1. Notice

Hello Verify India receives certain EU Personal Data at the request of clients and other third

parties for investigative, credential verification, and employment related purposes, as well as

credit and fraud risk mitigation related purposes.

Where permissible, Hello Verify India gathers and maintains consumer and other data which

it provides to its clients (employers or their agents, such as recruiters or staffing firms) for use

in making employment-related decisions, such as who to hire, retain, promote, or re-assign.

Hello Verify India also gathers and maintains consumer and other data which it provides to

entities including lenders, credit reference agencies and fraud prevention agencies. Provided

below is an illustrative list of common ways in which employers use the data provided by this

service:

Performance of applicant and employee background checks

Verification of the credentials of job applicants and current employees

Investigation into a suspicion of work-related misconduct or wrongdoing

Investigation into matters of employee compliance with employer policies, or

Investigation into matters of employee compliance with Federal, State, or local laws

and regulations.

Provided below is an illustrative list of common ways in which lenders, credit

reference agencies and fraud prevention agencies use the data provided by this service

(where available):

Authentication of consumer applicants for loans or other credit services

Prevention or detection of fraud by consumer applicants for loans or other credit

services

Determination of credit worthiness or capacity of consumer applicants for loans or

other credit services

Location of absconded borrowers

Hello Verify India uses a limited number of third party service providers to assist us in

providing our services to customers. These third party providers perform reference and

credential verifications and complete portions of services requested by our customers, such as

by obtaining records from data sources. These third parties may access or process personal

data in the course of providing their services. Hello Verify India maintains contracts with

these third parties restricting their access, use and disclosure of personal data in compliance

with our Privacy Shield obligations.

The scope of this notice also covers consumer report data that Hello Verify India has

obtained on behalf of employers and other businesses by manually or electronically

contacting the appropriate sources of the data (court records, education and employment

references, licensing bureaus, etc.). Hello Verify India also performs services related to

corporate litigation and investigative services as requested by our clients.

2. Choice Hello Verify India or its clients will offer individuals the opportunity to choose (opt-out)

whether their EU Personal Data will be disclosed to a third party (not including our agents) or

will be used for a purpose other than the purpose for which it was originally collected or

subsequently authorized by the individual. With respect to sensitive information, however, an

individual must "opt-in" to the disclosure of the information to a non-agent third party or to

the use of this information for a purpose other than its original purpose or that purpose

authorized subsequently by the individual. Hello Verify India or its clients will provide

individuals with a readily-available mechanism to exercise their choices should

circumstances arise that require opt-out or opt-in. In addition, Hello Verify India will treat as

sensitive any EU Personal Data received from a third party where the third party identifies

and treats it as sensitive.

3. Onward Transfer (Transfers to Third Parties) With respect to the transfer of EU Personal Data to third parties (other than our agents), the

principles of "Notice" and "Choice" apply. Accordingly, EU Personal Data is only provided

to these types of third parties for purposes described in the "Notice" section or otherwise

disclosed to consumers, and will not be disseminated to such a third party where a consumer

has "opted-out" or, in the case of sensitive information, failed to "opt-in."

Non-agent third parties to whom we transfer EU Personal Data will be obligated to provide

the same level of protection as the Privacy Shield Principles.

Hello Verify India may disclose EU Personal Data to clients and third parties acting as

agents. We will transfer such data only for limited and specified purposes and ascertain that

agents are obligated to provide at least the same level of privacy protection as is required by

the Privacy Shield Principles.

4. Security

Hello Verify India takes reasonable and appropriate measures to protect EU Personal Data

from loss, misuse and unauthorized access, disclosure, alteration and destruction.

5. Data Integrity and Purpose Limitation Hello Verify India collects EU Personal Data that is relevant for the purpose(s). We process

EU Personal Data in ways that are compatible with the purpose(s) for which it has been

collected (as identified in the Notice section above, or as subsequently authorized by the

individual). To the extent necessary for those purposes, Hello Verify India takes reasonable

steps to ensure that EU Personal Data collected is accurate, complete, current, and reliable for

its intended use. Hello Verify India retains EU Personal Data only for as long as it serves a

purpose of processing.

6. Access A consumer may request, in writing, access to EU Personal Data collected and maintained

about him or her, which Hello Verify India will make a good faith effort to provide. Hello

Verify India affords 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.

Hello Verify India reserves the right to engage in reasonable efforts to confirm the identity of

the individual requesting EU Personal Data to ensure the information is provided only to the

subject of the data.

To request information relating to his or her EU Personal Data, a consumer may contact

Hello Verify India in writing or by e-mail at the following email

address: privacy@Helloverify.com; or by writing to the contacts listed below. In addition, the

consumer will be asked to provide sufficient evidence of his or her identity so we may ensure

that information is being released to the correct individual. If we are unable to provide the

consumer with access to his or her EU Personal Data or to correct the data, we will notify the

consumer.

7. Amendments

From time to time, this policy may be amended to reflect new products and services, or as

necessary to reflect a new business practice. Consistent with the Privacy Shield

requirements, we will post any revised policy on this website.

CONTACT INFORMATION

To request information relating to your EU Personal Data, please contact: Vinod Chandra

Mamgai privacy@Helloverify.com.

XX. Switzerland Privacy Policy

“Swiss Personal Data” is data pertaining to an identified or identifiable individual that is

received by Hello Verify India from Switzerland.

In compliance with the Swiss-U.S. Privacy Shield Principles, Hello Verify India commits to

resolve complaints about our collection or use of your personal information. Individuals in

Switzerland with inquiries or complaints regarding this policy should first contact Hello

Verify India at privacy@Helloverify.com or at one of the contacts provided below.

Hello Verify India may be required to disclose personal information in response to a lawful

request by public authorities, including to meet national security or law enforcement

requirements.

1. Notice

Hello Verify India receives certain Swiss Personal Data at the request of customers and other

third parties for investigative, credential verification, and employment related purposes, as

well as credit and fraud risk mitigation related purposes.

Where permissible, Hello Verify India gathers and maintains consumer and other data which

it provides to its clients (employers or their agents, such as recruiters or staffing firms) for use

in making employment-related decisions, such as who to hire, retain, promote, or re-assign.

Hello Verify India also gathers and maintains consumer and other data which it provides to

entities including lenders, credit reference agencies and fraud prevention agencies. Provided

below is an illustrative list of common ways in which employers use the data provided by this

service:

Performance of applicant and employee background checks

Verification of the credentials of job applicants and current employees

Investigation into a suspicion of work-related misconduct or wrongdoing

Investigation into matters of employee compliance with employer policies, or

Investigation into matters of employee compliance with Federal, State, or local laws

and regulations

Provided below is an illustrative list of common ways in which lenders, credit

reference agencies and fraud prevention agencies use the data provided by this service

(where available):

Authentication of consumer applicants for loans or other credit services

Prevention or detection of fraud by consumer applicants for loans or other credit

services

Determination of credit worthiness or capacity of consumer applicants for loans or

other credit services

Location of absconded borrowers.

Hello Verify India uses a limited number of third party service providers to assist us in

providing our services to customers. These third party providers perform reference and

credential verifications and complete portions of services requested by our customers, such as

by obtaining records from data sources. These third parties may access or process personal

data in the course of providing their services. Hello Verify India maintains contracts with

these third parties restricting their access, use and disclosure of personal data in compliance

with our Privacy Shield obligations.

The scope of this notice also covers consumer report data that Hello Verify India has

obtained on behalf of employers and other businesses by manually or electronically

contacting the appropriate sources of the data (court records, education and employment

references, licensing bureaus, etc.). Hello Verify India also performs services related to

corporate litigation and investigative services as requested by our clients.

More information regarding the nature and scope of consumer data inquiries is available by

contacting Hello Verify India in writing or by e-mail at the addresses listed on the Contact Us

page or by writing to the contacts listed below.

2. Choice

Hello Verify India or its clients will offer individuals the opportunity to choose (opt-out)

whether their Swiss Personal Data will be disclosed to a third party (not including our agents)

or will be used for a purpose other than the purpose for which it was originally collected or

subsequently authorized by the individual. With respect to sensitive information, however, an

individual must "opt-in" to the disclosure of the information to a non-agent third party or to

the use of this information for a purpose other than its original purpose or that purpose

authorized subsequently by the individual. Hello Verify India or its customers will provide

individuals with a readily-available mechanism to exercise their choices should

circumstances arise that require opt-out or opt-in. In addition, Hello Verify India will treat as

sensitive any Swiss Personal Data received from a third party where the third party identifies

and treats it as sensitive.

3. Onward Transfer (Transfers to Third Parties)

With respect to the transfer of Swiss Personal Data to third parties (other than our agents), the

principles of "Notice" and "Choice" apply. Accordingly, Swiss Personal Data is only

provided to these types of third parties for purposes described in the "Notice" section or

otherwise disclosed to consumers, and will not be disseminated to such a third party where a

consumer has "opted-out" or, in the case of sensitive information, failed to "opt-in."

Non-agent third parties to whom we transfer Swiss Personal Data will be obligated to provide

the same level of protection as the Privacy Shield Principles.

Hello Verify India may disclose Swiss Personal Data to clients and third parties acting as

agents. We will transfer such data only for limited and specified purposes and ascertain that

agents are obligated to provide at least the same level of privacy protection as is required by

the Privacy Shield Principles.

4. Security Hello Verify India takes reasonable and appropriate measures to protect Swiss Personal Data

from loss, misuse and unauthorized access, disclosure, alteration and destruction.

5. Data Integrity and Purpose Limitation Hello Verify India collects Swiss Personal Data that is relevant for the purpose(s) for which it

is to be used.We process Swiss Personal Data in ways that are compatible with the purpose(s)

for which it has been collected (as identified in the Notice section above, or as subsequently

authorized by the individual). To the extent necessary for those purposes, Hello Verify India

takes reasonable steps to ensure that Swiss Personal Data collected is accurate, complete,

current, and reliable for its intended use. Hello Verify India retains Swiss Personal Data only

for as long as it serves a purpose of processing.

6. Access

A consumer may request, in writing, access to Swiss Personal Data collected and maintained

about him or her, which Hello Verify India will make a good faith effort to provide. Hello

Verify India affords 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.

Hello Verify India reserves the right to engage in reasonable efforts to confirm the identity of

the individual requesting Swiss Personal Data to ensure the information is provided only to

the subject of the data.

To request information relating to his or her Swiss Personal Data, a consumer may contact

Hello Verify India in writing or by e-mail at the following email

address: privacy@Helloverify.com; or by writing to the contacts listed below. In addition, the

consumer will be asked to provide sufficient evidence of his or her identity so we may ensure

that information is being released to the correct individual. If we are unable to provide the

consumer with access to his or her Swiss Personal Data or to correct the data, we will notify

the consumer.

7. Amendments

From time to time, this policy may be amended to reflect new products and services, or as

necessary to reflect a new business practice. Consistent with the Privacy Shield

requirements, we will post any revised policy on this website.

CONTACT INFORMATION

To request information relating to your Switzerland Personal Data and Privacy Policy, please

contact:

Hello Verify India Private Limited

Vinod Chandra Mamgai

Email: privacy@Helloverify.com

XXI. PRIVACY POLICY FOR AUSTRALIA AND NEW ZEALAND

Hello Verify India Private Limited provides a background screening service for its clients

("Client"), to assist them in considering individuals for employment, change in the level of

responsibility, other circumstances where an individual's background is relevant (including

but not limited to insurance and claims review), or to determine if further verification or

investigation is necessary. This is achieved by preparing an employment, investigative, or

due diligence report for the Client.

This policy may change from time to time. Please check the policy each time you use our

Web site for the most current information.

In this Privacy Policy for Australia and New Zealand, the following definitions apply:

Privacy Legislation means:

- for Australia, the Privacy Act 1988 including the Australian Privacy Principles; and,

- for New Zealand, the Privacy Act 1993 including the Information Privacy Principles.

Personal Information has the same meaning as in the Privacy Legislation; i.e.:

- for Australia, "information or an opinion about an identified individual, or an individual

who is reasonably identifiable: (a) whether the information or opinion is true or not; and (b)

whether the information or opinion is recorded in a material form or not; and

- for New Zealand, "information about an identifiable individual; and includes information

relating to a death that is maintained by the Registrar-General".

THE INFORMATION WE COLLECT AND HOLD

As part of our services, we receive information about individuals for the purposes of

conducting our checks.

Personal Information that we collect and hold about an individual will vary depending upon

the background checks required by the Client and the information the individual supplies to

us. Personal Information about an individual that we may collect and hold includes name,

age, date of birth, employment history, reference information, education, professional

qualifications, residency, sanctions, immigration status, claims, judgments, insolvency,

current and previous directorships, character, personal reputation, and such other checks and

enquiries as the Client considers necessary to verify information provided by an individual.

From Clients we may collect company address and the name, email and phone number of any

system users.

From the sources of our background checks we may collect the name and job title of the

person who supplied us with the information.

We may also collect other Personal Information which is "sensitive information". Sensitive

information is given a greater level of protection under the Privacy Legislation. The Privacy

Legislation imposes greater obligations on us regarding any collection, use or disclosure we

make of an individual's sensitive information.

Sensitive information about an individual that we may collect and hold includes criminal

records, and membership of a professional or trade association.

We recognize the importance of privacy issues and respect the confidentiality of the Personal

Information and sensitive information individuals provide to us. We will collect and deal with

Personal Information and sensitive information in accordance with the Privacy Legislation,

and our Privacy Statement and this Privacy Policy (all as amended from time to time).

MAIN PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE

PERSONAL INFORMATION

When engaged by a Client, Hello Verify India verifies an individual's information,

documentation and any responses by carrying out verification checks for the purposes of

preparing an employment, investigative, or due diligence report. This is done at the Client's

request to enable them to assess an individual's suitability for employment, promotion,

provision of services, or other purposes in accordance with their legal obligations and internal

risk management policy (including but not limited to insurance and claims review).

In certain circumstances, Hello Verify India may be engaged by a Client to prepare an

employment or investigative report because they are required by law to determine a

candidate's suitability for a position of employment.

HOW WE COLLECT PERSONAL INFORMATION

In order to process and verify information for a Client's request, the Client and Hello Verify

India may collect an individual's Personal Information directly from the individual. We may

also collect information about an individual from a third party a candidate refers us to. In

these circumstances, we will assume that the individual has referred Hello Verify India to

them and informed them of the purposes involved in the collection, use and disclosure of the

relevant personal or other information.

We may use the Personal Information, documentation and any responses an individual or

third party reference has provided to us to apply to various other entities ("Sources") for

verification of an individual's personal and other information, to collect additional Personal

Information, and to conduct public record searches. Examples of Sources include, but are not

limited to, government agencies, law enforcement bodies, publicly available records, public

registries, court or tribunal records, insolvency registers, educational institutions, current

and/or previous employers, and regulatory and licensing bodies.

HOW WE HOLD PERSONAL INFORMATION

The Personal Information provided to us by an individual, third party references, and any

other Personal Information provided by the Sources, will be processed by us.

Hello Verify India will then use the Personal Information to prepare a report outlining the

findings of its investigations and provide the report to the Client via a secure means. The

Client may then use that information to consider an individual's suitability for employment,

change in the level of responsibility, or other circumstances where an individual's background

is relevant, or to determine if further verification or investigation is necessary. If a Fit and

Proper report was requested, the Client may use this to determine whether an individual

meets the requirements as a Fit and Proper Person. If the report was requested for insurance

purposes, it may be used by the client to determine eligibility for insurance or for claims

payments.

We store the Personal Information we receive in hard copy files and/or in electronic format in

a database.

We take steps to protect against the loss, misuse, or unauthorized alteration of Personal

Information collected and subject to this policy. We recognize the importance of security for

all Personal Information collected by Hello Verify India. Once we receive Personal

Information, we take steps to protect its security on our systems. In the event we request or

transmit sensitive information, we use industry standard, secure socket layer (SSL)

encryption.

We limit access to personally-identifiable information to those employees who need this

access in order to carry out their job responsibilities.

When we dispose of personally identifiable information, we use procedures to dispose of

Personal Information by means such as shredding documents and erasure of electronic media

that information cannot be practicably read or reconstructed.

We may need to retain Personal Information collected from an individual, third party

references, or Sources to comply with our contractual, statutory or other legal obligations

even after the employment or other application process is completed or terminated.

IDENTIFIERS

An "identifier" is a unique identification number assigned to a candidate by the Australian

Government or an Australian Government Agency. Examples of identifiers include a Tax

File Number (TFN) or a Medicare number. Hello Verify India does not use identifiers to

identify a candidate's personal information in our systems.

OVERSEAS TRANSFERS OF PERSONAL INFORMATION

We may disclose Personal Information to overseas recipients. The circumstances of

disclosure may be as follows:

We may need to disclose an individual's Personal Information overseas in order to carry out

our checks. For example, if an individual lived, studied or worked overseas, we may need to

disclose that individual's Personal Information overseas to liaise with Sources, employers,

third party references, or educational institutions. Disclosures of this kind may be to any

country in the world, depending upon the circumstances of the individual.

We may also disclose an individual's Personal Information to our related bodies corporate

located overseas, most likely in Australia, India, Canada, New Zealand, the U.S. or the U.K.

Personal Information may be disclosed to related bodies corporate located overseas for

purposes including data storage, administrative purposes (creating internal and external

reports, invoicing and trends in data), and operational and/or processing purposes in

connection with the preparation of an employment or investigative report to the Client.

ACCESS AND CORRECTION OF INFORMATION

An individual has a right to request access to their Personal Information which is held by us.

An individual may apply for that information by contacting the Privacy Officer at the contact

details set out below. We will acknowledge receipt of a request for access. Where reasonable

and practicable, we will provide access to Personal Information in the form requested by an

individual. A moderate fee may be charged for this information. Proof of identity may be

required.

We will handle requests for access to Personal Information in accordance with the Privacy

Legislation. However, in some circumstances permitted under the Privacy Legislation we

may not be required to give an individual access to the information we hold about them.

It is also important to us that the information we hold about an individual is accurate,

complete and up to date. An individual has a right to request the correction of the Personal

Information that Hello Verify India holds about them. The Individual may do so by lodging a

correction request with the Privacy Officer at the contact details listed below. Hello Verify

India will handle correction requests in accordance with the Privacy Legislation.

CONTACT INFORMATION

To request information relating to your Australia and Newzealand Privacy Policy, please

contact:

Hello Verify India Private Limited

Vinod Chandra Mamgai

Email: privacy@Helloverify.com