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SmartStart's Privacy Statement


Privacy Policy

As a consumer reporting agency governed by the federal Fair Credit Reporting Act (“FCRA”) among other applicable state and federal laws, SmartStart Employment Screening, Inc. (“SmartStart”) is committed to protecting your privacy.

This Privacy Policy covers SmartStart's web site, and SmartStart's practices for handling personal information provided to SmartStart over the Internet by the general public using SmartStart's publicly available web site. This Policy also covers personal information provided by SmartStart's clients, and their job applicants and employees (as well as other individuals who have given their written authorization for SmartStart's clients to conduct a background investigation on them), using SmartStart's online background screening solution that is accessible only through an access-restricted portion of SmartStart's web site. SmartStart will collect, store, and use personally identifiable information only in compliance with applicable laws, including the FCRA.

Collection of Information

When you browse SmartStart's publicly accessible web site, you do so anonymously. SmartStart collects personally identifiable information from you only if you choose to provide this information to us. In some instances, SmartStart may collect non-personal (e.g., aggregate or demographic) data through cookies. This information is used to better understand and improve the usability, performance and effectiveness of the web site, as is further described below under "Cookies and Tracking Technology".

The types of personal information we may collect about you through our publicly accessible web site include the following (should you decide to provide such information to SmartStart): (a) contact and identifying information (e.g., name, address, e-mail address, phone and fax numbers, employer(s), job title) in connection with your expression of interest in receiving information about, or your registering for, SmartStart products or services, newsletters and conferences; (b) your resume information and employment application information in response to SmartStart job openings; and (c) any other personal information that you may voluntarily provide to us in an online form or through an e-mail.

Access to certain SmartStart web pages and online services is not available to the general public and requires a login code and password provided by SmartStart. Those web pages, and the information downloadable to and from those pages, are made available only to clients of SmartStart. On these web pages, SmartStart collects only information that the user voluntarily shares with SmartStart.

If you are using this web site to open an employment screening account with SmartStart, we collect the information requested on our account application form, including contact information and financial information (such as credit card number or billing information). This information is used for internal purposes, such as account establishment, billing, fulfillment of orders and customer service.

How We Use Your Personal Information

When your personal information is collected on SmartStart's publicly accessible web site, SmartStart will inform you at the point of collection of the purpose for the collection. SmartStart will use your personal information only in the way we specify when it is collected, unless you consent to a different use.

For example, SmartStart may use personal information submitted in an account application to set up and maintain your account. SmartStart also may use the personal information you provide to answer your questions and inquiries, to support SmartStart's own recruitment activities in response to your inquiries into SmartStart's job postings and to provide newsletters and other information (if any) that you have requested.

If you have provided your personal information over this web site in connection with a background screen ordered by SmartStart's client - SmartStart may use your personal information to perform your background screen for that client. SmartStart will not use your information to conduct a background screening investigation and create a report unless SmartStart's client has provided a certification required by the FCRA and any other applicable law.  In this certification, SmartStart's client certifies to SmartStart that it has a legally permissible purpose for ordering the background screen, and that it has, to the extent required by applicable law, obtained your informed consent to conduct the background screen.

Information Sharing and Disclosure

SmartStart does not sell or rent personal information to third parties. SmartStart will not disclose your personal information to a third party without your permission, except in connection with performing your background screen for SmartStart's client or as otherwise described in this Privacy Policy.

SmartStart may disclose personal information as necessary or appropriate in connection with any of the purposes for which we use personal information as described above in "How We Use Your Personal Information".

When SmartStart conducts a background screening investigation about you, SmartStart may disclose information that you submit through this web site to the SmartStart client that ordered a background screening investigation on you. SmartStart also may disclose your information to certain third parties as necessary to conduct the background investigation (such as educational institutions, prior employers, courts, law enforcement agencies and other persons or entities that may provide or verify information about you), as well as to a third-party representative or subcontractor authorized by SmartStart to assist in the background screening investigation. These third party representatives and subcontractors include service providers that help host or support the web site or otherwise provide technical assistance, court researchers and other data and service vendors. SmartStart transfers to these representatives and subcontractors only the personal information they need to deliver to SmartStart (for the benefit of SmartStart's client) the requested product or service. SmartStart prohibits these third parties from using that information for any other purpose. SmartStart requires that these parties maintain commercially reasonable measures to protect the confidentiality of your information.

SmartStart also may in good faith disclose personal information and any other additional information available to SmartStart for any of the following purposes: (i) investigate, prevent or take action regarding actual or suspected illegal activities or fraud, situations involving potential threats to the physical safety of any person, or violations of SmartStart's terms of use; (ii) respond to or defend against subpoenas, court orders, or other legal process; (iii) establish or exercise SmartStart's legal rights; or (iv) otherwise comply with applicable law.

SmartStart may acquire other businesses, and other businesses may acquire SmartStart. If that occurs, the information SmartStart collects may be one of the assets examined or transferred as part of the transaction. SmartStart will not permit another business to examine the information SmartStart has collected without a confidentiality agreement and only to the extent permitted by law. SmartStart will not transfer the information it has collected unless the recipient agrees to provide privacy protections equal to or exceeding those established by this Privacy Policy.

Cookies and Tracking Technology

SmartStart's web site may use the standard technology called a "cookie" to collect information about how you use the web site.

A cookie is a small data file that is transferred to your hard drive and used for record-keeping purposes. A cookie file can contain information such as the URL you came from, your computer's IP address (i.e., the Internet address of your computer) and domain type (e.g., .com or .org, etc.), your browser type, the country, state and telephone area code where your server is located, the pages of our site that were viewed during a visit, and any search terms that you entered on our site. This information is used for internal purposes only, and we do not link your URL or IP address to any personal information unless you have logged into our web site with a SmartStart account login and password.

If you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies, although it is possible that some areas of our web site will not function properly if you do so. In particular, you may be required to accept cookies in order to complete certain actions on SmartStart's web site.


SmartStart is committed to protecting the personal information that SmartStart receives about consumers. While we cannot guarantee the security of that information, we take reasonable and appropriate measures to do so.  We utilize a combination of online and offline security technologies, procedures and organizational measures to help safeguard consumer information against loss, misuse, and unauthorized access, disclosure, alteration and destruction.

We employ Secure Socket Layer (SSL) data encryption when data is transmitted over the Internet to our web site. We have installed layered firewalls and other security technologies to help prevent unauthorized access to our systems. Strong password protection protocols are used on our computers, and employees are kept up-to-date on our security and privacy policies. The servers used to store consumer information are maintained in a secure environment with appropriate security measures.


SmartStart's web site may provide links to third-party web sites. Please be aware that those third-party web sites are outside of our control and are not covered by this Privacy Policy. If you have questions about how another site uses your information, consult that site's privacy statement.

Your Ability to Review or Modify Personal Information, or Unsubscribe.

SmartStart strives to protect the quality and integrity of your personal information. If you have provided your personal information (such as zip code, phone, e-mail or postal address) to SmartStart while browsing SmartStart's publicly accessible web site, and wish to update such personal information (if any) that you have provided us, please e-mail us at Also, if you wish to unsubscribe from any of our newsletters or other communications for which you have registered, you may e-mail us at If you are a SmartStart client with a registered account, you may review (and update) your account information by logging into your account. If you are an individual on whom a SmartStart client has requested a background screening investigation, and have submitted personal information to SmartStart at the request of such client for purposes of procuring a background report, then you can review your SmartStart file in accordance with your file disclosure rights under the Fair Credit Reporting Act, California Civil Code Section 1786.22 and any other applicable state laws by contacting SmartStart's Customer Service Department at You can review a summary of your consumer rights (including file disclosure rights) under the Fair Credit Reporting Act by accessing:

Children Under Age 13

SmartStart does not offer services to children under the age of 13, and this web site is not directed to children under the age of 13. SmartStart does not knowingly collect information about children under the age of 13.

Personal Information Disclosure: United States or Overseas

Personal information submitted to SmartStart for a background screening investigation may at times be transferred outside of the United States in order to perform the background investigation. All personal information will be transmitted and stored in a secure manner in accordance with all applicable laws and the terms of this Privacy Policy.

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. SmartStart compiles investigative consumer reports about individuals and provides them to business for background screening, tenant screening, and similar purposes.  

To obtain additional information about the privacy practices and policies of SmartStart in connection with its preparation and processing of investigative consumer reports, please contact: 

SmartStart Employment Screening, Inc.
Yohama "Joey" Guarino
Chief Compliance Officer/General Counsel/EVP of Human Resources
SmartStart Employment Screening Inc.
Phone: (813) 377-4343

For additional information about privacy or consumer reporting, visit the following web sites: 

Federal Trade Commission: 
Consumer Financial Protection Bureau:
Consumer Data Industry Association: 
California Office of Privacy Protection:

Changes to this Privacy Policy

SmartStart may revise this policy from time to time. If there is a material change to this Privacy Policy, we will post the revised policy at this location. SmartStart will not provide less privacy protection, without your consent, to information collected under a prior privacy policy. We encourage you to periodically review this Privacy Policy to be informed of how SmartStart is protecting your information.

If you have any questions regarding our privacy policy, you may contact us at:

SmartStart Employment Screening Inc.
Attn: Compliance Dept
29399 US 19 N - Ste 350  
Clearwater, FL 33761

In accordance with California Civil Code § 1786.20, the representative named above will be able to assist you with additional information regarding our privacy practices and policies in the event of a compromise of your information.

Revised: October 30, 2017



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