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Privacy Policy

Red Brick Workforce Solutions · Updated: September 12, 2026

At Red Brick Workforce Solutions ("Red Brick," "we" or "our"), accessible from https://redbrickworkforce.com/ and https://redbrick.bgsecured.com/, one of our main priorities is the privacy of our end users ("you" or "user") and visitors.

This Privacy Policy ("Policy") document contains types of information that is collected and recorded by Red Brick and how we use it in connection with Red Brick's products and services (the "Services").

If you have additional questions or require more information about our Privacy Policy, contact us at admin@redbrickworkforce.com, by phone at (855) 332-6789, or at: Attn: Privacy Questions, Red Brick Workforce Solutions.

This Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in Red Brick. This policy is not applicable to any information collected offline or via channels other than Red Brick's websites.

Please note that your use of these Sites constitutes your acceptance of and consent to this Policy. When you sign up to use the Services, you also consent to receive electronic notices and disclosures, as set forth in Section 5 below.

Red Brick reserves the right to change this Policy at any time. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Policy will mean you accept those changes.

This Policy seeks to answer questions you may have about the Services and Red Brick's information practices. Please contact us if you have other questions.

1. What information does Red Brick collect through the Services?

Information Provided Directly To Us

We may collect information you provide directly through the Services. For example, we may collect your name, email address, or other contact information when you access certain Red Brick content available through the Services such as whitepapers, videos, webinars, and other materials, or request additional information about Red Brick or the Services. Red Brick also collects information from you when you fill out any form in the Services such as when you submit questions or comments.

A. Customers

If you want to use the Services to screen applicants ("Customers"), Red Brick may collect the following information (collectively, the "Customer Information"), including, but not limited to:

  • Account creation information, including your name, email address, and a custom password;
  • Contact information such as address and phone number;
  • Corporate information;
  • Hiring practice information such as employee work location and salary necessary for the application of state and federal consumer reporting laws;
  • If you are an employer, employer identification number; and
  • Payment information, including credit card and/or bank account information and billing address.

Please note: We do not store the credit card or bank account numbers you may use to make payments in the Services. Such information is passed on to our third-party payment processor. You can review information on their privacy practices at the processor's website.

B. Applicants

If you are an applicant who will be the subject of a screening or background check ("Applicants"), Red Brick may collect the following information (collectively, the "Background Check Information"), including, but not limited to:

  • Account creation information, including your full name, e-mail address, and custom password;
  • Contact information, including phone number and address;
  • Identity verification information, including Social Security Number (or Social Insurance Number) and date of birth; and
  • Additional information or supporting documentation you submit or upload regarding identity, background, evidence of rehabilitation, or a dispute. Examples include an uploaded picture, a driver's license, or court records.

Automatically Collected Information

When you visit or use the Services, we automatically gather certain technical and usage information, which may be associated with your user account. This technical and usage information ("Technical Information") includes usage information, such as information on when, how often and for how long you use the Services; and server log data such as a computer's IP address, browser type, device type, operating system and version, or the webpage you were visiting before you came to the Services.

Technical Information also includes "Cookies," which are small text files containing a string of alphanumeric characters that are downloaded by your web browser when you visit a website. Like many online services, we may use both session cookies and persistent cookies when you access and use the Services. Cookies are used to remember your user account information and your preferences, to customize the Services for you and to assist us in measuring and analyzing utilization of the Services.

Third-party web analytics services providers we engage, such as Google Analytics, may use cookies in order to provide analytics services for the Services to us. A session cookie disappears after you close your browser. A persistent cookie remains after you close the browser and may be used by your browser on subsequent visits to the Services. Persistent cookies can be removed. Please review your web browser's documentation to learn the best way to modify your cookie settings and see Section 7 below.

2. How does Red Brick use the collected information?

Red Brick uses the information it maintains about you (including information you provide, Customer Information, Background Check Information, and Technical Information):

  • For the purposes for which you provided it;
  • To create your account and enable you to use the Services;
  • To verify your identity;
  • To provide the features and functionality of the Services;
  • For customer support and to respond to your inquiries;
  • To respond to and fulfill your requests;
  • With your consent, to contact you by text message regarding your account and certain services or information you have requested;
  • To improve the Services;
  • For internal record-keeping purposes and for legal purposes;
  • To address fraud or safety concerns, or to investigate complaints or suspected fraud or wrongdoing; and
  • To resolve disputes, to protect ourselves and other users, and to enforce any legal terms that govern your use of the Services.

Red Brick uses the contact information that you provide to access Red Brick's content available in the Services (such as whitepapers) or to obtain more information about Red Brick or its Services to provide such content and information. Red Brick may also use this information to provide you with additional information regarding products and services from Red Brick or our business partners that may be of interest to you. Red Brick does not use Background Check Information for this purpose. If you do not wish to receive such communications, please see Section 7 below.

Red Brick uses Background Check Information as reasonably necessary to:

  • verify applicant identity;
  • conduct background checks;
  • conduct quality assurance checks;
  • investigate disputes; or
  • provide certain communications, including adverse action notices.

We may use Customer Information to:

  • contact you regarding your use of the Services;
  • process billing and payment;
  • send you product announcements and special promotions from Red Brick or our business partners, or to administer participation in special events, surveys, contests and sweepstakes; or
  • send you communications regarding updates or modifications to the Services.

We may use Customer Information and Technical Information to:

  • personalize the content that you and others see based on personal characteristics or preferences;
  • troubleshoot problems;
  • provide you with required notices, in connection with disputes between you and another user; or
  • alert you to changes in our policies or agreements that may affect your use of the Services.

Red Brick may also use Technical Information to analyze your use of the Services to help us improve the Services and develop and improve other products and services.

3. When does Red Brick share information about you?

We may share the information we collect from and maintain about you as follows:

  • Employers or Other Customers Requesting Background Reports. We provide background reports, which may include Background Check Information, about Applicants to the requesting employer or Customer. We may also provide an employer or Customer other communications related to background reports such as notification of a dispute.
  • Furnishers and Researchers. We provide Background Check Information to entities that research and furnish data contained in background reports.
  • Service Providers. We may provide access to your 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.
  • Affiliates. We may share information with our affiliates for use as described in this Policy.
  • Legal Requirements. We will use and disclose information where we, in good faith, believe that the law or legal process (such as a court order, search warrant or subpoena) requires us to do so or in other circumstances where we believe is necessary to protect the rights or property of Red Brick, our users, or third parties.
  • De-identified information. We may share de-identified information with third parties, including without limitation: (1) sharing aggregated, de-identified information about our user base and its interests and usage patterns and (2) providing de-identified information to third-party partners for our business arrangements, including without limitation to jointly offer a product or service to you or create interoperability between our products and services and theirs.
  • Consent. We may disclose your information to nonaffiliated third parties based on your consent to do so.
  • Business Transfer. In the event of a merger, sale of capital stock or assets, reorganization, consolidation or similar transaction involving Red Brick, or in contemplation of such a transaction (e.g., due diligence), the information we possess may be transferred as a corporate asset to the acquiring entity.
  • Analytics. We use Google Analytics for purposes of analyzing usage of the Services. You can review Google's privacy practices for partner sites.

Note that Red Brick will not provide your personally identifiable information to third parties for their own marketing purposes without your consent.

4. How can you access, change or delete information about you?

Applicants should promptly update their contact information if it changes or is inaccurate. 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 Social Security Information, may require verification before the change is accepted. Applicants can request deletion of certain information in Red Brick's control by contacting Red Brick as set forth at the end of this Policy. Applicants can dispute background check reports by contacting us at admin@redbrickworkforce.com.

Once a Customer, such as an employer, has received a background check report, Red Brick does not control the Customer's retention of such information.

Our policy is to retain personally identifiable information only as long as reasonably necessary to provide the Services or as otherwise required for legal compliance purposes. For example, we may retain information, including 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.

5. Will you receive notices and disclosures electronically?

Yes. The Services are offered through Red Brick's website and mobile site. To obtain Services from us, you must create an online account and (1) be able to access Services on a computer or other device that is capable of accessing the Internet, (2) have an active email account, and (3) consent to our use of our websites to provide you any written information that we may be required to send you in connection with the Services, your account, and/or background checks and reports.

Your Consent to Electronic Disclosures

By creating an account and/or authorizing a background check, you acknowledge and agree:

  • you can access and read information we post on our website;
  • to provide an email address that is active and effective for receiving emails from us;
  • to receive electronically on our website or via email the notices and disclosures, required by law, related to your account and the Services; and
  • that your consent to receive Communications electronically remains in effect until you withdraw it in writing as described below.

Scope of Communications to Be Provided in Electronic Form

Your consent to receive electronic communications and transactions includes, but is not limited to, all legal and regulatory notices or disclosures and communications associated with your account, the Services, your request for a background check, and any product or service we agree to provide you (each, a "Communication").

Method of Providing Communications to You in Electronic Form

All Communications that we provide to you in electronic form will be provided either (1) via email, telephone or text, (2) by making it available online and accessible via your account portal, or (3) by requesting you download a PDF file containing the Communication.

How to Withdraw Consent

You may at any time withdraw your consent to receive Communications in electronic form. To begin receiving Communications in paper form, please contact us at admin@redbrickworkforce.com or (855) 332-6789. Please specify the information you wish to receive in paper form. Be sure to state that you are requesting a copy of the disclosures, notices, etc., and include your name and mailing address. Your request will apply only to those specific items you designate. We will not impose any fee to process the withdrawal of your consent to receive electronic Communications. Any withdrawal of your consent to receive electronic Communications will be effective only after we have a reasonable period of time to process your withdrawal.

How to Update Your Records

It is your responsibility to provide us with true, accurate and complete email address, contact, and other information related to your account, and to maintain and update promptly any changes in this information. You can update information (such as your email address) through your account portal or by emailing us at admin@redbrickworkforce.com. If you give us an incorrect email address or fail to update or correct your email address, an electronic Communication will be deemed provided to you if we use the email address in our records for the electronic Communication.

Required Equipment

In order to use the Services and to view and retain a copy of this Policy and certain Communications, you understand that you must have a computer or device equipped with at least: a browser with 128-bit encryption, a current version of a software that can open and display PDF files (e.g., Adobe), and either a printer or other electronic storage device.

Retaining Copies of the Communications

To retain a copy of any Communication we provide electronically, you can download an electronic copy to your computer or a storage device (such as a disk or USB storage device), request a copy by email, or print copies on a printer attached to your computer. You will not be charged for a downloaded or emailed copy.

6. Does this Policy apply to third parties?

No. The Services may contain links to third-party websites, but this Policy does not apply to information that you may provide to or that may be collected by such third parties. We encourage you to review such third parties' privacy policies and terms and conditions before engaging with such third parties.

7. What are your choices regarding online tracking, analytics and certain email communications from Red Brick?

Online Tracking and Cookies

Like many websites, the Services do not currently respond to "do not track" browser headers. But you can take steps to limit tracking by erasing cookies from your computer's hard drive and by setting your browser to block all cookies or warn you before a cookie is stored. If you disable cookies, you may be prevented from taking full advantage of the Services because they may not function properly without cookies.

Analytics

To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on.

Promotional Emails

As discussed in this Policy, subject to any restrictions under applicable laws, we may send periodic promotional or informational emails to you. You may opt-out of such communications by replying with the words "Opt Out" or "Remove." Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any services you have requested or received from us.

8. How does Red Brick protect your information?

Red Brick maintains safeguards to help protect the security of information we maintain about you. We may use encryption, passwords, and physical security measures to help protect your information against unauthorized access and disclosure. However, no security measures are 100% effective and we cannot guarantee your information will not be collected, disclosed and/or used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. Red Brick is not responsible for the unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your account via unauthorized password activity. WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ENSURING, GUARANTEEING, OR OTHERWISE OFFERING ANY DEFINITE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION OR TECHNICAL INFORMATION.

9. Where is your information processed or stored?

Red Brick uses servers located in the United States. Red Brick may also use partners or affiliates located in other countries besides the US to store and process your information. By using the Services, you consent to the transfer of information outside of your country, even if your country has more rigorous data protection standards.

10. Who can use the Services?

You must be 18 years of age or older to use the Services. If you are a parent or guardian and believe that your child under the age of 13 has provided personally identifiable information to us through the Services, please contact us at the contact information listed below. If we discover that an individual under 13 has provided us with personal information, we will take steps to delete the account and any such personally identifiable information to the extent required by applicable law.

11. How can I contact you with more questions?

If you have any questions, concerns or complaints about this Policy or Red Brick's handling of your personal information, or if you would like to access or update personal information that is not available via the applicant portal, please contact us at admin@redbrickworkforce.com or (855) 332-6789, Attn: Privacy Questions, Red Brick Workforce Solutions.

CCPA / CPRA Service Provider Addendum

This Addendum shall form part of the agreement entered into by the parties for Red Brick to provide services to Customer (the "Agreement") and is effective as of the later of September 12, 2026 or the Effective Date of the Agreement between Customer and Red Brick.

Relationship of the Parties

Red Brick is a Service Provider to Customer in connection with the provision of services as specified in the Agreement. Customer is a Business that is subject to the California Consumer Privacy Act and the California Privacy Rights Act. Customer intends to send Personal Information relating to California Consumers to Red Brick in connection with Red Brick's performance of the Agreement. Pursuant to this, the parties seek to clarify their applicable responsibilities in this Addendum.

Definitions

"Business", "Collects", "Consumer", "Business Purpose", "Sell", "Service Provider", and "Share" shall have the meanings given to them in §1798.140 of the CCPA. "Business Purpose" has the meaning given in the Business Purpose section of this Addendum. "California Consumer Privacy Act" or "CCPA" means Title 1.81.5 California Consumer Privacy Act of 2018 (California Civil Code §§1798.100—1798.199), as amended or superseded from time to time. "California Privacy Rights Act" or "CPRA" means the California Privacy Rights Act of 2020 (2020 Cal. Legis. Serv. Proposition 24, codified at Cal. Civ. Code §§1798.100 et seq.), and its implementing regulations, as amended or superseded from time to time. "Personal Information" means personal information as defined by §1798.140 of the CCPA submitted to Red Brick for processing pursuant to the Agreement. Capitalized terms used but not defined in this Addendum shall have the meanings given in the Agreement.

Relationship with the Agreement

This Addendum supersedes any conflicting or inconsistent provisions in the Agreement related to data protection and, in the event of conflict, this Addendum will govern and control. The terms of the Agreement, as amended by this Addendum, remain in full force and effect. Any claims brought under or in connection with this Addendum shall be subject to the terms and conditions, including but not limited to, the exclusions and limitations set forth in the Agreement. No one other than a party to this Addendum, its successors and permitted assignees shall have any right to enforce any of its terms. This Addendum shall be governed by and construed in accordance with the governing law and jurisdiction as specified in the Agreement, unless otherwise required by CCPA and/or CPRA. This Addendum shall continue in effect, and shall survive termination or expiration of the Agreement, as long as Red Brick retains possession, custody, or control of, or access to, any Personal Information in connection with or as a result of the Agreement. The parties agree that this Addendum shall be interpreted in favor of their intent to comply with the CCPA and CPRA and therefore any conflict or ambiguity shall be resolved in favor of a meaning that complies and is consistent with the CCPA and CPRA, as applicable.

Scope

This Addendum only applies where, and to the extent that, Red Brick processes Personal Information that is subject to the CCPA and/or the CPRA on behalf of Customer as a Service Provider in the course of providing the services pursuant to the Agreement. In this Addendum, references to sections of the CCPA are to those sections as amended by the CPRA.

Business Purpose

Red Brick shall only Collect and process Personal Information as a Service Provider upon lawful documented instructions from Customer, including those in the Agreement, this Addendum, and Customer's configuration of the Services or as otherwise necessary to provide the Services specified in the Agreement (the "Business Purpose"). Red Brick will not process the Personal Information for any purpose other than for the Business Purpose, except where and to the extent permitted by the CCPA and/or CPRA.

Data Protection

  • Service Provider Appointment. Customer is a Business and appoints Red Brick as its Service Provider to Collect and process the Personal Information for the Business Purpose. Red Brick is responsible for its compliance with its obligations under this Addendum and for compliance with its obligations as a Service Provider under the CCPA and CPRA. Customer is responsible for compliance with its own obligations as a Business under CCPA and CPRA and shall ensure that it has provided notice and has obtained (or shall obtain) all consents and rights necessary under the CCPA and the CPRA for Red Brick to Collect and process the Personal Information for the Business Purpose.
  • Service Provider Certification. Red Brick shall not: (a) Sell the Personal Information; (b) retain, use, or disclose the Personal Information for any purpose other than for the Business Purpose; (c) retain, use, or disclose the Personal Information outside of the direct business relationship between Red Brick and Customer (except where Red Brick has engaged a subcontractor to assist in the provision of services); (d) Share or process the Personal Information for targeted and/or cross context behavioral advertising; (e) combine Personal Information with any other data if and to the extent this would be inconsistent with the limitations on Service Providers under the CCPA and/or CPRA. Red Brick certifies that it understands the restrictions set out in this Section and will comply with them. Red Brick shall notify Customer if it determines that it cannot meet its obligations under the CPRA.
  • Consumer Rights. Red Brick will, upon Customer's instructions (and at Customer's expense): (a) use reasonable efforts to assist Customer in deleting Personal Information in accordance with a Consumer's request (and shall instruct any subcontractors it has engaged to do the same) except where and to the extent permitted to retain the Personal Information pursuant to an exemption under the CCPA and/or CPRA; and (b) use reasonable efforts to assist Customer in responding to verified Consumer requests received by Customer to provide information as it relates to the Collection of Personal Information for the Business Purpose.
  • Assistance. Red Brick will, upon Customer's instruction and upon proof of such a communication, provide reasonable assistance to Customer to enable Customer to respond to any correspondence, inquiry, or complaint received from a Consumer or the California Attorney General in connection with the Collection and processing of the Personal Information.
  • Deletion. Upon receipt of Customer's written request, Red Brick shall, at Customer's election, delete or return any Personal Information within ninety (90) days of termination, except where Red Brick is permitted by applicable law to retain some or all of the Personal Information, which Personal Information Red Brick shall continue to protect from any further processing, except to the extent required by applicable law.
  • Reasonable Steps. Customer has the right to take reasonable and appropriate steps to (i) ensure that Red Brick uses the Personal Information received from Customer under the Agreement consistent with applicable law; and (ii) stop and remediate any unauthorized use of Personal Information.
  • Subcontractors. If Red Brick wishes to engage a subcontractor to assist in processing Personal Information for purposes of performing the services under the Agreement, Red Brick shall provide prior notice of any new subcontractor, and shall enter into a written and binding contract with the subcontractor that requires the subcontractor to observe all requirements set forth in this Addendum.
  • Security. Red Brick shall implement and maintain reasonable security procedures and practices appropriate to the nature of the Personal Information it will process to protect the Personal Information from and against unauthorized or illegal access, destruction, use, modification, or disclosure. Red Brick shall notify Customer without undue delay (and in time to fulfil any applicable reporting obligations) after becoming aware of an accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access of or to the Personal Information, and provide timely information relating to such, as it becomes known or is reasonably requested by Customer.
  • Contact. If Customer has any questions or complaints with respect to this Addendum, Customer may contact Red Brick by email at admin@redbrickworkforce.com, or by phone at (855) 332-6789, 8:00 AM – 5:00 PM CST, Monday through Friday (excluding Red Brick holidays). If Customer requires an executable version of this Addendum, please send a request email to admin@redbrickworkforce.com.

Additional Information for Canadian Users

This Policy applies to customers, users and applicants in both Canada and the United States. However, to the extent that this Policy is inconsistent with any applicable Canadian laws, Red Brick will comply with the applicable law for customers, users and applicants in Canada.

For example, Red Brick will only send commercial electronic messages to persons located in Canada with explicit, opt-in consent, unless otherwise permitted pursuant to Canadian legislation that is applicable to such activities.

Applicants who are located in Canada should also understand that the nature of the Services will involve Red Brick obtaining potentially sensitive personal information about them, including consumer reports, criminal record, driving record, as well as education and employment records, from third parties such as consumer reporting agencies, police services and government agencies (e.g., provincial transportation ministries).

Red Brick will also share Applicants' personal information with a third party service provider in Canada, for the purpose of completing or facilitating the background checks described in this Policy.

In addition, as indicated under Question #9 above, personal information that is collected in the course of providing the Services will be transferred outside Canada. Therefore, such information may be accessible to law enforcement and national security authorities in the jurisdiction(s) where it is stored or processed.

Canadian customers, users and applicants will be notified of any material changes to this Policy, where such change would result in use or disclosure of their personal information by Red Brick in a manner not contemplated by this Policy or reasonably expected by the individual.

GDPR Data Subject Rights

We would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

  • The right to access – You have the right to request copies of your personal data. This service is provided free of charge, except where requests are manifestly unfounded, excessive, or repetitive, in which case we may charge a reasonable fee or refuse the request as permitted by law.
  • The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
  • The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
  • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
  • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
  • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at admin@redbrickworkforce.com, Attn: Privacy Questions, Red Brick Workforce Solutions.

Red Brick, as a Consumer Reporting Agency regulated by the Fair Credit Reporting Act in the United States, is already subject to significant regulation related to the collection, management, and retention of individuals' personal data. As a result, we are well prepared to meet the requirements of a law like the GDPR, including fulfilling data subject rights requests. Specifically, in terms of the right to access, Red Brick provides all candidates with copies of their background check report. We also already have in place a dispute process that allows candidates to request that their data be rectified. Further, candidates can revoke their consent for a background check, thereby allowing for a process to restrict or object to processing. Finally, reports are available to candidates in electronic format for easy portability.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

To exercise any of these rights, you may review the information provided in Sections 4, 5, and 7, or contact us as described in the "How can I contact you with more questions?" section above. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

As described above, Red Brick uses servers located in the United States. Red Brick may also use partners or affiliates located in other countries besides the US to store and process your information. By providing us with your information, you acknowledge any such transfer, storage or use. If we provide any information about you to any such non-EU third party information processors, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy and applicable law.

United Kingdom Data Protection Notice (UK GDPR & DPA 2018)

This section applies to personal data of individuals located in the United Kingdom and is provided in accordance with the United Kingdom General Data Protection Regulation ("UK GDPR"), the Data Protection Act 2018 ("DPA 2018"), and the Privacy and Electronic Communications Regulations ("PECR"), as enforced by the Information Commissioner's Office ("ICO").

  • Controller and Processor Roles. Where Red Brick provides background screening services to a UK employer or organisation, that organisation is the "controller" of the personal data submitted about applicants and Red Brick acts as the "processor" on its documented instructions. Where Red Brick collects personal data directly from website visitors, account holders, or for its own compliance, fraud-prevention, or business purposes, Red Brick is the "controller" of that data.
  • Lawful Bases for Processing. Red Brick processes UK personal data under one or more of the following lawful bases set out in Article 6 of the UK GDPR: Consent (Art. 6(1)(a)) — for marketing communications, optional cookies, and where the candidate has provided written authorisation for a background check; Contract (Art. 6(1)(b)) — to deliver the Services requested by the Customer or applicant; Legal obligation (Art. 6(1)(c)) — to comply with applicable UK statutory or regulatory requirements, including the Rehabilitation of Offenders Act 1974 and safeguarding legislation; Legitimate interests (Art. 6(1)(f)) — to operate, secure, and improve the Services, prevent fraud, and verify identity, balanced against the rights and freedoms of the data subject.
  • Special Category and Criminal Offence Data. Where we process special category data (Art. 9) or data relating to criminal convictions and offences (Art. 10 and DPA 2018 Schedule 1), we rely on a specified Schedule 1 condition — typically the prevention and detection of unlawful acts, the protection of the public, or for purposes of employment, in each case under an appropriate policy document maintained by Red Brick.
  • UK Data Subject Rights. Individuals in the UK have the same enumerated rights described in the GDPR Data Subject Rights section above (access, rectification, erasure, restriction, objection, portability), plus rights related to automated decision-making under Article 22. Red Brick does not use solely automated decision-making, including profiling, that produces legal or similarly significant effects on individuals.
  • International Transfers. Personal data collected in the UK is transferred to and stored in the United States. Where required, we rely on the UK Addendum to the EU Standard Contractual Clauses, the UK International Data Transfer Agreement (IDTA), the UK Extension to the EU–US Data Privacy Framework, or another transfer mechanism approved by the UK Secretary of State or ICO.
  • Retention. UK personal data is retained only for as long as necessary for the purpose for which it was collected, to comply with the FCRA-equivalent record-keeping requirements applicable to consumer reporting, or to defend legal claims, after which it is deleted or anonymised in accordance with our documented retention schedule.
  • How to Exercise Your Rights or Complain. UK residents may contact us at admin@redbrickworkforce.com to exercise any right. We will respond within one month, extendable by two further months for complex requests. If you remain dissatisfied, you have the right to lodge a complaint with the UK Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113.

Latin America Data Protection Notice (including Brazil's LGPD)

This section applies to personal data of individuals (in Brazilian terminology, "data subjects" or titulares) located in Latin American jurisdictions whose data-protection laws apply to our processing, including but not limited to: Brazil — Lei Geral de Proteção de Dados Pessoais (Law No. 13,709/2018, the "LGPD"), enforced by the Autoridade Nacional de Proteção de Dados ("ANPD"); Argentina — Personal Data Protection Act No. 25,326 and its implementing regulations; Mexico — Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP); and Chile, Colombia, Peru, Uruguay, and Ecuador — each country's national personal-data-protection statute as applicable to the processing.

  • Brazil — LGPD Specifics. Under the LGPD, Red Brick acts as a controlador (controller) for data it collects directly (e.g., website visitors, account holders, corporate contacts) and as an operador (processor) when it conducts a background check on behalf of an employer (controlador) that has instructed it to do so. Red Brick has appointed a Data Protection Officer (Encarregado) who can be reached at admin@redbrickworkforce.com.
  • Legal Bases (LGPD Art. 7 & Art. 11). Red Brick processes personal data only when one of the following legal bases applies: (i) consent of the data subject; (ii) compliance with a legal or regulatory obligation; (iii) performance of a contract to which the data subject is a party, or for preliminary procedures related to a contract; (iv) regular exercise of rights in judicial, administrative or arbitration procedures; (v) protection of life or physical safety; (vi) protection of credit; or (vii) the legitimate interests of the controller or third party, except where the rights and fundamental freedoms of the data subject prevail.
  • Sensitive Personal Data. Where processing involves sensitive personal data (dados pessoais sensíveis), including data revealing racial or ethnic origin, religious beliefs, political opinions, trade-union membership, health, sex life, genetic or biometric data, Red Brick will rely on a specific lawful basis listed in LGPD Article 11, including the specific and highlighted consent of the data subject where required.
  • Rights of the Data Subject (LGPD Art. 18). Individuals in Brazil have the right to: (i) confirmation of the existence of processing; (ii) access to the data; (iii) correction of incomplete, inaccurate or out-of-date data; (iv) anonymisation, blocking or deletion of unnecessary or excessive data, or data processed in non-compliance with the LGPD; (v) portability of the data to another service or product provider; (vi) deletion of personal data processed with consent; (vii) information about public and private entities with which the controller has shared data; (viii) information about the possibility of denying consent and the consequences of such denial; and (ix) revocation of consent.
  • International Transfers. Personal data collected in Brazil and other Latin American countries is transferred to the United States. Red Brick relies on transfer mechanisms recognised by the LGPD (Art. 33), including standard contractual clauses, specific consent of the data subject, or other bases recognised by the ANPD. Equivalent mechanisms recognised by other Latin American regulators are used as required.
  • How to Exercise Your Rights or Complain. To exercise any right above, or to contact our Data Protection Officer / Encarregado, email admin@redbrickworkforce.com. Brazilian data subjects also have the right to file a complaint with the ANPD at gov.br/anpd. Residents of other Latin American jurisdictions may contact their respective national data protection authority.

United States State Privacy Rights Notice

This section provides additional disclosures required by United States state privacy laws, including the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA/CPRA"), and the comparable comprehensive privacy laws of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon (OCPA), Montana (MCDPA), and other U.S. states with substantially similar consumer privacy frameworks. It supplements, and does not replace, the information provided elsewhere in this Policy.

  • FCRA Interplay. Personal information collected, maintained, or disclosed in the course of preparing a "consumer report" as defined by the federal Fair Credit Reporting Act (15 U.S.C. § 1681 et seq.) is generally exempt from the CCPA/CPRA and most state consumer-privacy laws to the extent of that use. The disclosures in this section therefore apply principally to personal information Red Brick collects from website visitors, account holders, prospective customers, marketing contacts, and other non-consumer-report processing.
  • Categories of Personal Information Collected. In the preceding 12 months, Red Brick has collected the following categories of personal information enumerated by Cal. Civ. Code § 1798.140: identifiers; customer records information; commercial information; internet or other electronic network activity information; geolocation data (approximate); professional or employment-related information; and inferences drawn from any of the foregoing. When acting as a consumer reporting agency, Red Brick also collects characteristics of protected classifications, education information, and (where authorised) sensitive personal information such as government identifiers, all subject to the FCRA.
  • Sources, Purposes, and Disclosures. Sources, business purposes, and categories of recipients are described in Sections 1, 2, and 3 of this Policy. Red Brick does not "sell" personal information for monetary consideration, and does not "share" personal information for cross-context behavioural advertising as those terms are defined under the CCPA/CPRA. Red Brick does not knowingly sell or share the personal information of consumers under 16 years of age.

Your State Privacy Rights. Subject to verification and applicable exemptions (including the FCRA), eligible U.S. residents have the right to:

  • Know / Access the categories and specific pieces of personal information we have collected about you, the sources, the purposes for collection, and the categories of recipients.
  • Delete personal information we have collected from you, subject to legal exceptions.
  • Correct inaccurate personal information.
  • Portability — receive a copy of your personal information in a portable, readily usable format.
  • Opt out of the sale or sharing of personal information and of targeted advertising (Red Brick does not engage in these activities).
  • Limit use of sensitive personal information to disclosed purposes.
  • Non-discrimination — you will not receive discriminatory treatment for exercising any of these rights.
  • Appeal — in states that require it (e.g., VA, CO, CT), you may appeal a denial of a privacy request by replying to our response.

How to Submit a Request. Verifiable consumer requests may be submitted by emailing admin@redbrickworkforce.com with the subject line "U.S. Privacy Request" and identifying your state of residence and the right you wish to exercise. We may need to verify your identity (and, for requests submitted through an authorised agent, the agent's authority) before fulfilling the request. We will respond within the timeframes required by applicable law (generally 45 days, extendable once when reasonably necessary).

"Shine the Light" (California Civ. Code § 1798.83). California residents may request information regarding our disclosure of personal information to third parties for those parties' direct marketing purposes. Red Brick does not share personal information with third parties for their own direct marketing purposes.

Global Privacy Control (GPC). Where required by applicable state law (including California, Colorado, and Connecticut), Red Brick recognises and honours opt-out preference signals such as the Global Privacy Control (globalprivacycontrol.org) transmitted by a browser or device as a valid request to opt out of the sale or sharing of personal information and of targeted advertising for that browser or device. Because Red Brick does not sell or share personal information or engage in targeted advertising, this signal does not change how we process your data, but it is acknowledged.

Retention. We retain personal information for the period necessary to fulfil the purposes described in this Policy, to comply with our legal, accounting, regulatory, and FCRA record-keeping obligations, to resolve disputes, and to enforce our agreements. Retention periods vary by category of data and applicable legal requirement; consumer report files are generally retained for the period required by the FCRA and applicable state law.

Nevada, Washington, and Other State Notices. Nevada residents may direct opt-out requests for the sale of covered information (we do not sell such information) to admin@redbrickworkforce.com. Washington residents subject to the My Health My Data Act may exercise rights relating to consumer health data at the same address. Residents of any other U.S. state with applicable privacy rights may use the same contact channel.

Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Red Brick does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.