Legal

Legal2019-04-10T14:42:35+00:00

LAST UPDATED APRIL 1, 2019

Privacy & Security

Information We Collect

TenantReports.com llc may obtain personal information about you from various sources.

Personal identification information

We may collect personal identification information from Users in a variety of ways, including, but not limited to, when Users visit our site, register on the site, place an order, fill out a form, and in connection with other activities, services, features or resources we make available on our Site. Users may be asked for, as appropriate, name, email address, mailing address, phone number, credit card information, social security number. Users may, however, visit our Site anonymously. We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal identification information, except that it may prevent them from engaging in certain Site related activities.

Non-personal identification information

We may collect non-personal identification information about Users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

We may collect this information when you provide it in our website forms, our social media platforms, or in connection with our social networking or mobile applications, or at one of our events. When you visit this site, our social media platforms, or our social networking or mobile applications, we may also collect certain information about your device or usage by automated means or by using technologies such as cookies, web server logs and web beacons.

Information You Provide

You may choose to provide personal information to us in a number of ways, such as when you participate in an offer or promotion, or when you make a purchase on our site. The types of personal information you may provide to us includes:

Contact information (such as name, postal address, email address, and mobile or other phone number)
Age and date of birth
Gender
Username and password
Payment information (such as your payment card number, expiration date, delivery address, and billing address)
Your product concerns

Content you provide (such as photographs, videos, reviews, articles and comments)
Information provided to us by social networks or mobile applications when you visit our social media platforms or use one of our social networking or mobile applications (such as your name, profile picture, likes, location, friend list and other information described in the social networking application sign-up page, or your geo-location details when using one of our mobile applications)

How we use collected information

TenantReports.com llc collects and uses Users personal information for the following purposes:

To process transactions
We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.

To send periodic emails
The email address Users provide for order processing, will only be used to send them information and updates pertaining to their order. It may also be used to respond to their inquiries, and/or other requests or questions. If User decides to opt-in to our mailing list, they will receive emails that may include company news, updates, related product or service information, etc. If at any time the User would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or User may contact us via our Site.

Send you promotional materials or other communications

Provide services to you
Process your payment
Create and manage your online account
Respond to your inquiries
Communicate with you about, and administer your participation in, special events, contests, sweepstakes, programs, surveys and other offers
Operate and communicate with you about our social networking or mobile applications
Operate, evaluate and improve our business (including developing new products and services; managing our communications; analyzing our products; performing data analytics; and performing accounting, auditing and other internal functions)
Comply with applicable legal requirements, relevant industry standards and our policies

We also may use the information in other ways for which we provide specific notice at the time of collection.

Information We Collect by Automated Means

When you visit this site or our online advertisements or use one of our social networking or mobile applications, we collect certain information about your usage or device by automated means or by using technologies such as cookies, web server logs and web beacons. For example, if you use one of our mobile applications, we may collect your unique device identifier (or other device identifier) and/or geolocation data in order to offer you certain features or functionalities within that mobile application. As set forth in more detail below, we may also collect information about your usage and browsing habits using various web-based technologies.

Cookies, Web Server Logs and Web Beacons

Cookies are small text files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our website. In conjunction with obtaining information through cookies, our web servers may log details such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone in which your device is located. The web server logs also may record information such as the address of the web page that linked you to our site and the IP address of the device you use to connect to the Internet.

To control which web servers collect this information, we may place tags on our web pages called “web beacons.” These are computer instructions that link web pages to particular web servers and their cookies.

For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org

Third Party Web Analytics Services

We may use third party web analytics services on this site, our social media platforms, or our social networking or mobile applications, such as those of Facebook and/or Google Analytics. The service providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the site. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the website. You may deactivate the ability of these analytics services to analyze your browsing activities on this site. To exercise your choice with respect to their collection of information on this site:

For social media platforms, please follow the instructions from the social network;

To disable the Google Analytics cookie and any other third party web analytics service provider cookies, some browsers indicate when a cookie is being sent and allow you to decline cookies on a case-by-case basis.

Targeted Advertising

We also may contract with third-party advertising networks that collect IP addresses and other information through the use of cookies, web server logs and web beacons on our websites and emails; on third-party websites and emails; and on our advertising placed on third-party websites. They use this information to provide advertisements about products and services tailored to your interests (including for companies not affiliated with us). You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts.

Behavioural Advertising
As described above, we use your personal information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
GOOGLE – https://www.google.com/settings/ads/anonymous
BING – https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

How We Use the Information Collected by Automated Means

We may use the information collected through automated means on this site for market research, data analytics and system administration purposes, such as to determine whether you’ve visited us before or are new to the site, and for compliance with our legal obligations, policies and procedures, including compliance with relevant industry standards and the enforcement of our Terms & Conditions. We also may use the information in other ways for which specific notice is provided at the time of collection.

California Do Not Track Notice

Under California law, website and online service operators are required to disclose how they respond to web browser “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information about a consumer’s online activities over time and across third party websites, to the extent the operator engages in that collection. At this time, we do not track our customers’ personal information over time and across third-party websites and therefore this requirement does not apply to us.

California law also requires website and online service operators to disclose whether third parties may collect personal information about their users’ online activities over time and across different sites when the users use the operator’s website or service. Third parties that have content or services on our site such as a social feature, analytics service, or an advertising network partner, may obtain information about your browsing or usage habits but this information does not include personal information. We do not knowingly permit such third parties to collect any personal information from our site unless you directly provide it to us and we provide it to them with your consent.

HOW WE PROTECT YOUR INFORMATION

We maintain appropriate administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Links To Other Websites

Our website may provide links to other websites for your convenience and information. These websites may operate independently from us. Linked sites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not owned or controlled by us, we are not responsible for the sites’ content, any use of the sites, or the privacy practices of the sites.

Updates To Our Privacy Policy

We reserve the right to update this Privacy Policy at any time without prior notice to you to reflect changes in our personal information practices. We will post a notice on our website to notify you of any significant changes to our Privacy Policy and indicate at the top of the Policy when it was most recently updated.

We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site.

Sensitive and private data exchange between the Site and its Users happens over a SSL secured communication channel and is encrypted and protected with digital signatures.

INFORMATION WE SHARE

TenantReports.com llc does not sell, trade, or rent Users personal identification information to others except as described here. We may share generic aggregated demographic information not linked to any personal identification information regarding visitors and users with our business partners, trusted affiliates and advertisers for the purposes outlined above.

We may share your personal information with:

We share with third parties to help us use your personal information, as described above.  We use Google Analytics to help us understand how our customers use our site. You can read more about how Google uses your Personal Information here:  https://www.google.com/intl/en/policies/privacy/.  You can also opt-out of Google Analytics here:  https://tools.google.com/dlpage/gaoptout.

We share with our affiliates within the TenantReports.com llc. umbrella of companies.
We share with service providers who perform services on our behalf based on our instructions. We do not authorize these service providers to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. Examples of these service providers include entities that process credit card payments, fulfill orders, and provide web hosting and marketing services.
We share with other third parties with your consent (e.g., some of our Facebook applications may share information collected through those apps with your Facebook friends or other Facebook users).

In addition, we may disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity.

We also reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Policy. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.

YOUR RIGHTS AND CHOICES

We offer you certain choices in connection with the personal information we collect from you, such as how we use the information and how we communicate with you. To update your preferences, ask us to remove your information from our mailing lists or submit a request, please contact us as specified below.

Email Opt-Out

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below.

Postal Mail Opt-Out

You can ask Igloo to stop sending you marketing communications by postal mail by following the instructions that may be included in a particular promotion. You also can request that we refrain from sending you promotional postal mail by contacting us as indicated below.

Social Networking Application Opt-Out

To remove or delete our apps from your social networking account, follow the instructions from the social network.

Geo-Location Information

When you use one of our mobile applications, you may be asked for your geo-location via our mobile application. You may choose not to share your geo-location details by adjusting your mobile device’s location services settings. To decline from sharing your geo-location details, follow the instructions on your mobile device on changing the relevant settings; otherwise, please contact your service provider or device manufacturer.

Withdrawing Consent

You may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your personal information. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal information will mean that you cannot take advantage of some of our products or services.

Children’s Privacy

Our site is not intended for the use of children. We do not knowingly market to, or solicit data from, children. We encourage parents and guardians to monitor and participate in their children’s online activities. No information should be submitted to our sites by users under the age of majority in their state or province of residence, and users under the age of majority are not permitted to register on the site, purchase products or participate in surveys, promotions or contests. Where appropriate, the company many ask you to indicate your age to verify compliance with these policies.

The company does not knowingly collect information from our guests under the age of majority or provide personally identifying information from such guests to any third party for any reason. We do not allow guests known to be under 18 years of age to receive direct marketing communications from company or third parties.

Updates To Our Privacy Policy

We reserve the right to update this Privacy Policy at any time without prior notice to you to reflect changes in our personal information practices. We will post a notice on our website to notify you of any significant changes to our Privacy Policy and indicate at the top of the Policy when it was most recently updated. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:

TenantReports.com LLC
370 Reed Road, Suite 101, Broomall, PA 19008
855-244-2400
info@TenantReports.com

Client Disclosures

Client shall use each consumer report only for a one-time use for the purpose of the tenant screening and shall hold the report in strict confidence, and not disclose or resell it to any third parties; provided however that (a) Client may, but is not required to, disclose the report to the subject of the report only in connection with an adverse action based on the report, and (b) Client may disclose the report to any person if required to do so under Applicable Law. Moreover, for scores obtained from Experian Information Solutions, Client shall not disclose to consumers or any third party, any or all such scores provided under this Agreement, except as required by Applicable Law which includes the use with a legitimate business purpose in connection with a business transaction that is initiated by the consumer.

Client certifies that it has received, read and understands the “Notice to Users of Consumer Reports” required by the FCRA.

VantageScore Credit Score Notice

ConnectAPI utilizes the VantageScore® credit score. The VantageScore credit score may or may not be used by Report Subject’s lenders, and is not an endorsement or guarantee of Report Subject’s credit worthiness as seen by lenders.

Please be aware that there are many scoring models used in the marketplace. Each scoring model may have its own set of factors and scale. The information and credit scoring may be different than that used by a lender. The VantageScore credit score may not be identical in every respect to any other credit score produced by another company or used by Report Subject’s lender.

Report Subject’s VantageScore credit score is calculated using Report Subject’s actual data from Report Subject’s credit file at the time of TenantReports.com’s request. Keep in mind, however, that other factors, such as length of employment and annual salary, are often taken into consideration by lenders, and other users of credit files, when making decisions about Report Subject. How each decision maker weighs its chosen factors may vary, but the exact formula used to calculate Report Subject’s score is proprietary.

Also note that each consumer reporting agency has its own set of data, resulting in a separate VantageScore credit score for each of Report Subject’s credit files.

You agree to request VantageScore credit scores only for your use alone for the purposes certified to TenantReports.com and for no other purpose or use. All VantageScore credit scores provided hereunder will be held in strict confidence and may never be sold, licensed, copied, reused, disclosed, reproduced, revealed or made accessible, in whole or in part, to any person except as required by law or as otherwise set forth in your agreement with TenantReports.com

VantageScore® is owned by VantageScore Solutions, LLC

Notice to Users of Consumer Reports

The Fair Credit Reporting Act (FCRA), 15 USC §1681-1681Y, requires that this notice be provided to inform users of consumer reports of their legal obligations. State law may impose additional requirements. The text of the FCRA is set forth in full at the Federal Trade Commission’s Website at http://www.ftc.gov/credit. At the end of this document is a list of United States Code citations for the FCRA. Other information about user duties is also available at the Commission’s Web site. Users must consult the relevant provisions of the FCRA for details about their obligations under the FCRA.

The first section of this summary sets forth the responsibilities imposed by the FCRA on all users of consumer reports. The subsequent sections discuss the duties of users of reports that contain specific types of information, or that are used for certain purposes, and the legal consequences of violations. If you are a furnisher of information to a consumer reporting agency (CRA), you have additional obligations and will receive a separate notice from the

CRA describing your duties as a furnisher.

I. OBLIGATIONS OF ALL USERS OF CONSUMER REPORTS

A. Users Must Have a Permissible Purpose

Congress has limited the use of consumer reports to protect consumers’ privacy. All users must have a permissible purpose under the FCRA to obtain a consumer report. Section 604 contains a list of the permissible purposes under the law. These are as follows:As ordered by a court or a federal grand jury subpoena, see Section 604 (a)(I)

  • As instructed by the consumer in writing, see Section 604 (a)(2)
  • For the extension of credit as a result of an application from a consumer, or the review or collection of a consumer’s account, see Section 604(a)(3)(A)
  • For employment purposes, including hiring and promotion decisions, where the consumer has given written permission, see Sections 604(a)(3)(B) and 604(b)
  • For the underwriting of insurance as a result of an application from a consumer, see Section 604(a)(3)(C)
  • When there is a legitimate business need, in connection with a business transaction that is initiated by the consumer, see Section 604(a)(3)(F)(i)
  • To review a consumer’s account to determine whether the consumer continues to meet the terms of the account, see Section 604(a)(3)(F)(ii)
  • To determine a consumer’s eligibility for a license or other benefit granted by a governmental entity required by law to consider an applicant’s financial responsibility or status, see Section 604(a)(3)(D)
  • For use by a potential investor or servicer, or current insurer, in a valuation or assessment of the credit or prepayment risks associated with an existing credit obligation, see Section 604(a)(3)(E)
  • For use by state and local officials in connection with the determination of child support payments, or modifications and enforcement thereof, see Sections 604(a)(4) and 604(a)(5)

In addition, creditors and insurers may obtain certain consumer report information for the purpose of making “prescreened” unsolicited offers of credit or insurance. Section 604(c). The particular obligations of users of “prescreened” information are described in Section VII below.

 B.    Users Must Provide Certifications

Section 604(a) prohibits any person from obtaining a consumer report from a consumer reporting agency (CRA) unless the person has certified   to the CRA the permissible purpose(s) for which the report is being obtained and certifies that the report will not be used for any other purpose.

C. Users Must Notify Consumers When Adverse Actions Are Taken

The term “adverse action” is defined very broadly by Section 603. “Adverse actions” include all business, credit, and employment actions affecting consumers that can be considered to have a negative impact as defined by Section 603(k) of the FCRA — such as denying or canceling credit or insurance, or denying employment or promotion. No adverse action occurs in a credit transaction where the creditor makes a counteroffer that is accepted by the consumer.

  1. Adverse Actions Based on Information Obtained From a CRA

If a user takes any type of adverse action as defined by the FCRA that is based at least in part on information contained in a consumer report, Section 615(a) requires the user to notify the consumer. The notification may be done in writing, orally, or by electronic means. It must include the following

  • The name, address, and telephone number of the CRA (including a toll-free telephone number, if it is a nationwide CRA) that provided the report.
  • A statement that the CRA did not make the adverse decision and is not able to explain why the decision was made.
  • A statement setting forth the consumer’s right to obtain a free disclosure of the consumer’s file from the CRA if the consumer makes a request within 60 days.
  1. Adverse Actions Based on Information Obtained From Third Parties Who Are Not Consumer Reporting Agencies

If a person denies (or increases the charge for) credit for personal, family, or household purposes based either wholly or partly upon information from a person other than a CRA, and the information is the type of consumer information covered by the FCRA, Section

615(b)(l) requires that the user clearly and accurately disclose to the consumer his or her right to be told the nature of the information that was relied upon if the consumer makes a written request within 60 days of notification. The user must provide the disclosure within a reasonable period of time following the consumer’s written request.

  1. Adverse Actions Based on Information Obtained From Affiliates

If a person takes an adverse action involving insurance, employment, or a credit transaction  initiated by the consumer, based on information of the type covered by the FCRA, and this information was obtained from an entity affiliated with the user of the information by common ownership or control, Section 6l5(b)(2) requires the user to notify the consumer of the adverse action. The notice must inform the consumer that he or she may obtain a disclosure of the nature of the information relied upon by making a written request within 60 days of receiving the adverse action notice. If the consumer makes such a request, the user must disclose the nature of the information not later than 30 days after receiving the request. If the consumer report information is shared among affiliates and then used for an adverse action, the user must make an adverse action disclosure as set forth in I.C.1 above.

D.     Users Have Obligations When Fraud and Active Duty Military Alerts are in Files

When a consumer has placed a fraud alert, including one relating to identity theft, or an active duty military alert with a nationwide consumer reporting agency as defined in Section 603(p) and resellers, Section 605A(b) imposes limitations on users of reports obtained from the consumer reporting agency in certain circumstances, including the establishment of a new credit plan and the issuance of additional credit cards. For initial fraud alerts and active duty alerts, the user must have reasonable policies and procedures in place to form a belief that the user knows the identity of the applicant or contact the consumer at a telephone number specified by the consumer; in the case of extended fraud alerts, the user must contact the consumer in accordance with the contact information provided in the consumer’s alert.

E. Users Have Obligations When Notified of an Address Discrepancy

Section 605(h) requires nationwide CRAs, as defined in Section 603(p), to notify users that request reports when the address for a consumer provided by the user in requesting the report is substantially different from the addresses in the consumer’s file. When this occurs, users must comply with regulations specifying the procedures to be followed, which will be issued by the Federal Trade Commission and the banking and credit union regulators. The Federal Trade Commission’s regulations are available at http://www.ftc.gov/credit.

F. Users Have Obligations When Disposing of Records

Section 628 requires that all users of consumer report information have in place procedures to properly dispose of records containing this information. The Federal Trade Commission, the Securities and Exchange Commission, and the banking and credit union regulators have issued regulations covering disposal. The Federal Trade Commission’s regulations may be found at http://www.ftc.gov/credit.

II. CREDITORS MUST MAKE ADDITIONAL DISCLOSURES

If a person uses a consumer report in connection with an application for, or a grant, extension, or provision of, credit to a consumer on material terms that are materially less favorable than the most favorable terms available to a substantial proportion of consumers from or through that person, based in whole or in part on a consumer report, the person must provide a risk-based pricing notice to the consumer in accordance with regulations to be jointly prescribed by the Federal Trade Commission and the Federal Reserve Board.

Section 609(g) requires a disclosure by all persons that make or arrange loans secured by residential real property (one to four units) and that use credit scores. These persons must provide credit scores and other information about credit scores to applicants, including the disclosure set forth in Section 609(g)(1)(D) (“Notice to the Home Loan Applicant”).

III. OBLIGATIONS OF USERS WHEN CONSUMER REPORTS ARE OBTAINED FOR EMPLOYMENT PURPOSES

  A.  Employment Other Than in the Trucking Industry

If information from a CRA is used for employment purposes, the user has specific duties, which are set forth in Section 604(b) of the FCRA. The user must:

  • Make a clear and conspicuous written disclosure to the consumer before the report is obtained, in a document that consists solely of the disclosure, that a consumer report may be obtained.
  • Obtain from the consumer prior written authorization. Authorization to access reports during the term of employment may be obtained at the time of employment.
  • Certify to the CRA that the above steps have been followed, that the information being obtained will not be used in violation of any federal or state equal opportunity law or regulation, and that, if any adverse action is to be taken based on the consumer report, a copy of the report and a summary of the consumer’s rights will be provided to the consumer.
  • Before taking an adverse action, the user must provide a copy of the report to the consumer as well as the summary of consumer’s rights. (The user should receive this summary from the CRA.) A Section 615(a) adverse action notice should be sent after the adverse action is taken.

An adverse action notice also is required in employment situations if credit information (other than transactions and experience data) obtained from an affiliate is used to deny employment. Section 615(b)(2) outlines the procedures for investigative consumer reports and employee misconduct investigations are set forth below.

Special rules apply for truck drivers where the only interaction between the consumer and the potential employer is by mail, telephone, or computer. In this case, the consumer may provide consent orally or electronically, and an adverse action may be made orally, in writing, or electronically. The consumer may obtain a copy of any report relied upon by the trucking company by contacting the company.

IV. OBLIGATIONS WHEN INVESTIGATIVE CONSUMER REPORTS ARE USED

Investigative consumer reports are a special type of consumer report in which information about a consumer’s character, general reputation, personal characteristics, and mode of living is obtained through personal interviews by an entity or person that is a consumer reporting agency. Consumers who are the subject of such reports are given special rights under the FCRA. If a user intends to obtain an investigative consumer report, Section 606 requires the following:

  • The user must disclose to the consumer that an investigative consumer report may be obtained. This must be done in a written disclosure that is mailed, or otherwise delivered, to the consumer at some time before or not later than three days after the date on which the report was first requested. The disclosure must include a statement informing the consumer of his or her right to request additional disclosures of the nature and scope of
  • the investigation as described below, and the summary of consumer rights required by Section 609 of the FCRA. (The summary of consumer rights will be provided by the CRA that conducts the investigation.)
  • The user must certify to the CRA that the disclosures set forth above have been made and that the user will make the disclosure described below.
  • Upon the written request of a consumer made within a reasonable period of time after the disclosures required above, the user must make a complete disclosure of the nature and scope of the investigation. This must be made in a written statement that is mailed, or otherwise delivered, to the consumer no later than five days after the date on which the request was received from the consumer or the report was first requested, whichever is later in time.

V.  SPECIAL PROCEDURES FOR EMPLOYEE INVESTIGATIONS

Section 613(x) provides special procedures for investigations of suspected misconduct by an         employee or for compliance with federal, state or local laws and regulations or the rules of a self-regulatory organization, and compliance with written policies of the employer. These investigations are not treated as consumer reports so long as the employer or its company complies with the procedures set forth in Section 603(x), and a summary describing the nature and scope of the inquiry is made to the employee if an adverse action is taken based on the investigation.

VI. OBLIGATIONS OF USERS OF MEDICAL INFORMATION

Section 604(g) limits the use of medical information obtained from consumer reporting agencies (other than payment information that appears in a coded form that does not identify the medical provider). If the information is to be used for an insurance transaction, the consumer must give consent to the user of the report or the information must be coded. If the report is to be used for employment purposes — or in connection with a credit transaction (except as provided in regulations issued by the banking and credit union regulators) — the consumer must provide specific written consent and the medical information must be relevant. Any user who receives medical information shall not disclose the information to any other person (except where necessary to carry out the purpose for which the information was disclosed, or as permitted by statute, regulation, or order).

VII. OBLIGATIONS OF USERS OF “PRESCREENED” LISTS

The FCRA permits creditors and insurers to obtain limited consumer report information for use in connection with unsolicited offers of credit or insurance under certain circumstances. See Sections 603(I)604(c), 604(e), and 615(d). This practice is known as “prescreening” and typically involves obtaining from a CRA a list of consumers who meet certain pre-established criteria. If any person intends to use prescreened lists, that person must (I) before the offer is made, establish the criteria that will be relied upon to make the offer and to grant credit or insurance, and (2) maintain such criteria on file for a three-year period beginning on the date on which the offer is made to each consumer. In addition, any user must provide with each written solicitation a clear and conspicuous statement that:

  • Information contained in a consumer’s CRA file was used in connection with the transaction.
  • The consumer received the offer because he or she satisfied the criteria for credit worthiness or insurability used to screen for the offer.
  • Credit or insurance may not be extended if, after the consumer responds, it is determined that the consumer does not meet the criteria used for screening or any applicable criteria on credit worthiness or insurability, or the consumer does not furnish required collateral.
  • The consumer may prohibit the use of information in his or her file in connection with future prescreened offers of credit or insurance by contacting the notification system established by the CRA that provided the report. The statement must include the address and toll-free telephone number of the appropriate notification system.

In addition, once the Federal Trade Commission by rule has established the format, type size, and manner of the disclosure required by Section 615(d), users must be in compliance with the rule. The FTC’s regulations will be at http://www.ftc.gov/credit.

VIII. OBLIGATIONS OF RESELLERS

A. Disclosure and Certification Requirements

Section 607(e) requires any person who obtains a consumer report for resale to take the following steps:

  • Disclose the identity of the end-user to the source CRA.
  • Establish and follow reasonable procedures to ensure that reports are resold only for permissible purposes, including procedures to obtain:
    1. the identity of all end-users;
    2. certifications from all users of each purpose for which reports will be used; and
    3. certification that reports will not be used for any purpose other than the purpose(s) specified to the reseller. Resellers must make reasonable efforts to verify this information before selling the report.

B. Fraud Alerts and Resellers

Section 605A(f) requires resellers who receive fraud alerts or active duty alerts from another consumer reporting agency to include these in their reports.

IX. LIABILITY FOR VIOLATIONS OF THE FCRA

Failure to comply with the FCPA can result in state government or federal government enforcement actions, as well as private lawsuits. See Sections 616, 617, and 621. In addition, any person who knowingly and willfully obtains a consumer report under false pretenses may face criminal prosecution. See Section 619.

The FTC’s Web site, http://www.ftc.gov/credit, has more information about the FCRA, including publications for businesses and the full text of the FCRA. Citations for FCRA sections in the U.S. Code, 15 U.S.C. ~ 1681 et seq.:

Section 602 15 U.S.C. 1681 Section 615 15 U.S.C. 1681m
Section 60315 U.S.C. 1681a Section 616 15 U.S.C. 1681n
Section 604 15 U.S.C. 1681b Section 617 15 U.S.C. 1681o
Section 605 15 U.S.C. 1681c Section 618 15 U.S.C. 1681p
Section 605A 15 U.S.C. 1681cA Section 619 15 U.S.C. 1681g
Section 605B 15 U.S.C. 1681cB Section 620 15 U.S.C. 1681r
Section 606 15 U.S.C. 1681d Section 621 15 U.S.C. 1681s
Section 607 15 U.S.C. 1681e Section 622 15 U.S.C. 1681s-1
Section 608 15 U.S.C. 1681f Section 623 15 U.S.C. 1681s-2
Section 609 15 U.S.C. 1681g Section 624 15 U.S.C. 1681t
Section 610 15 U.S.C. 1681h Section 625 15 U.S.C. 1681u
Section 611 15 U.S.C. 1681i Section 626 15 U.S.C. 1681v
Section 612 15 U.S.C. 1681j Section 627 15 U.S.C. 1681w
Section 613 15 U.S.C. 1681k Section 628 15 U.S.C. 1681x
Section 61415 U.S.C. 16811 Section 629 15 U.S.C. 1681y

Disclosures to Report Subjects

  1. The Fair Credit Reporting Act allows you to obtain a disclosure from every credit reporting agency of the nature and substance of all information in your file at the time of the request. Full disclosure of information in your file at Experian must be obtained directly from Experian by calling 888-397-3742 or logging on to www.experian.com/consumer. The credit report you are requesting from TenantReports.com is not intended to constitute the disclosure of Experian information required by the Fair Credit Reporting Act or similar state laws.
  2. You are entitled to receive a disclosure directly from the consumer reporting agency free of charge under the following circumstances:
    1. You have been denied credit, insurance or employment within the past sixty (60) days as a result of your credit report
    2. You certify in writing that you are unemployed and intend to apply for employment in the 60-day period beginning on the date on which you made the certification
    3. You are a recipient of public welfare assistance
    4. You have reason to believe that your file at the agency contains inaccurate information due to fraud
    5. Annually at www.annualcreditreport.com
      *Otherwise, the consumer reporting agency may impose a reasonable charge for the disclosure.
  3. The Fair Credit Reporting Act permits you to dispute inaccurate or incomplete information in your credit file. You understand that accurate information cannot be changed.
  4. You do not have to purchase your credit report or other information from TenantReports.com to dispute inaccurate or incomplete information in your Experian file or to receive a copy of your Experian consumer credit report.
  5. Experian’s National Consumer Assistance Center provides a proprietary consumer disclosure that is different from the consumer credit report provided by TenatReports.com. The disclosure report must be obtained directly from Experian. Consumers residing in the States of Colorado, Massachusetts, Maryland, New Jersey, and Vermont may receive a free copy of their consumer credit report once per year and residents of the State of Georgia may receive two copies per year.
  6. Fraud Alerts are available to any eligible consumers – free of charge – from a national consumer reporting agency.
  7. You have the right to purchase a consumer credit score directly from Experian.

 A Summary of Your Rights Under the Fair Credit Reporting Act

The federal Fair Credit Reporting Act (FCRA) promotes the accuracy, fairness, and privacy of information in the files of consumer reporting agencies. There are many types of consumer reporting agencies, including credit bureaus and specialty agencies (such as agencies that sell information about check writing histories, medical records, and rental history records). Here is a summary of your major rights under the FCRA. For more information, including information about additional rights, go to www.consumerfinance.gov/learnmore or write to: Consumer Financial Protection Bureau, 1700 G Street N.W., Washington, DC 20552.

You must be told if information in your file has been used against you. Anyone who uses a credit report or another type of consumer report to deny your application for credit, insurance, or employment – or to take another adverse action against you – must tell you, and must give you the name, address, and phone number of the agency that provided the information.

  • You have the right to know what is in your file. You may request and obtain all the information about you in the files of a consumer reporting agency (your “file disclosure”). You will be required to provide proper identification, which may include your Social Security number. In many cases, the disclosure will be free. You are entitled to a free file disclosure if:
    • a person has taken adverse action against you because of information in your credit report;
    • you are the victim of identity theft and place a fraud alert in your file;
    • your file contains inaccurate information as a result of fraud;
    • you are on public assistance;
    • you are unemployed but expect to apply for employment within 60 days.

In addition, all consumers are entitled to one free disclosure every 12 months upon request from each nationwide credit bureau and from nationwide specialty consumer reporting agencies. See www.consumerfinance.gov/learnmore for additional information.

  • You have the right to ask for a credit score. Credit scores are numerical summaries of your credit-worthiness based on information from credit bureaus. You may request a credit score from consumer reporting agencies that create scores or distribute scores used in residential real property loans, but you will have to pay for it. In some mortgage transactions, you will receive credit score information for free from the mortgage lender.
  • You have the right to dispute incomplete or inaccurate information. If you identify information in your file that is incomplete or inaccurate, and report it to the consumer reporting agency, the agency must investigate unless your dispute is frivolous. See www.consumerfinance.gov/learnmore for an explanation of dispute procedures.
  • Consumer reporting agencies must correct or delete inaccurate, incomplete, or unverifiable information. Inaccurate, incomplete or unverifiable information must be removed or corrected, usually within 30 days. However, a consumer reporting agency may continue to report information it has verified as accurate.
  • Consumer reporting agencies may not report outdated negative information. In most cases, a consumer reporting agency may not report negative information that is more than seven years old, or bankruptcies that are more than 10 years old.
  • Access to your file is limited. A consumer reporting agency may provide information about you only to people with a valid need — usually to consider an application with a creditor, insurer, employer, landlord, or other business. The FCRA specifies those with a valid need for access.
  • You must give your consent for reports to be provided to employers. A consumer reporting agency may not give out information about you to your employer, or a potential employer, without your written consent given to the employer. Written consent generally is not required in the trucking industry. For more information, go to www.consumerfinance.gov/learnmore
  • You may limit “prescreened” offers of credit and insurance you get based on information in your credit report. Unsolicited “prescreened” offers for credit and insurance must include a toll-free phone number you can call if you choose to remove your name and address from the lists these offers are based on. You may opt-out with the nationwide credit bureaus at 1-888-567-8688.
  • You may seek damages from violators. If a consumer reporting agency, or, in some cases, a user of consumer reports or a furnisher of information to a consumer reporting agency violates the FCRA, you may be able to sue in state or federal court.
  • Identity theft victims and active duty military personnel have additional rights. For more information, visit www.consumerfinance.gov/learnmore

States may enforce the FCRA, and many states have their own consumer reporting laws. In some cases, you may have more rights under state law. For more information, contact your state or local consumer protection agency or your state Attorney General. For information about your federal rights, contact:

TYPE OF BUSINESS: CONTACT:
1.a. Banks, savings associations, and credit unions with total assets of over $10 billion and their affiliates.

b. Such affiliates that are not banks, savings associations, or credit unions also should list, in addition to the CFPB:

a. Consumer Financial Protection Bureau
1700 G Street N.W.
Washington, DC 20552b. Federal Trade Commission: Consumer Response Center — FCRA
Washington, DC 20580
(877) 382-4357
2. To the extent not included in item 1 above:

a. National banks, federal savings associations, and federal branches and federal agencies of foreign banks

b. State member banks, branches and agencies of foreign banks (other than federal branches, federal agencies, and insured state branches of foreign banks), commercial lending companies owned or controlled by foreign banks, and organizations operating under section 25 or 25A of the Federal Reserve Act

c. Nonmember Insured Banks, Insured State Branches of Foreign Banks, and insured state savings associations

d. Federal Credit Unions

a. Office of the Controller of the Currency
Customer Assistance Group
1301 McKinney Street, Suite 3450
Houston, TX 77010-9050b. Federal Reserve Consumer Help Center
P.O. Box 1200
Minneapolis, MN 55480c. FDIC Consumer Response Center
1100 Walnut Street, Box #11
Kansas City, MO 64106d. National Credit Union Administration
Office of Consumer Protection (OCP)
Division of Consumer Compliance and Outreach (DCCO)
1775 Duke Street
Alexandria, VA 22314
3. Air carriers Asst. General Counsel for Aviation Enforcement & Proceedings
Department of Transportation
1200 New Jersey Avenue, S.E.
Washington, DC 20590
4. Creditors Subject to Surface Transportation Board Office of Proceedings, Surface Transportation Board
Department of Transportation
395 E Street, S.W.
Washington, DC 20423
5. Creditors Subject to Packers and Stockyards Act, 1921 Nearest Packers and Stockyards Administration area supervisor
6. Small Business Investment Companies Associate Deputy Administrator for Capital Access
United States Small Business Administration
409 Third Street, S.W., 8th Floor
Washington, DC 20416
7. Brokers and Dealers Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
8. Federal Land Banks, Federal Land Bank Associations, Federal Intermediate Credit Banks, and Production Credit Associations Farm Credit Administration
1501 Farm Credit Drive
McLean, VA 22102-5090
9. Retailers, Finance Companies, and All Other Creditors Not Listed Above FTC Regional Office for region in which the creditor operates or Federal Trade Commission: Consumer Response Center — FCRA
Washington, DC 20580
(877) 382-4357

NOTICE REGARDING BACKGROUND INVESTIGATION
PURSUANT TO CALIFORNIA LAW

TRC Test Co NO Fields (the “Company”) intends to obtain information about you from an investigative consumer reporting agency and/or a consumer credit reporting agency for tenant screening purposes. Thus, you can expect to be the subject of “investigative consumer reports” and “consumer credit reports” obtained for tenant screening purposes. Such reports may include information about your character, general reputation, personal characteristics and mode of living. With respect to any investigative consumer report from an investigative consumer reporting agency (“ICRA”), the Company may investigate the information contained in your lease application and other background information about you, including but not limited to obtaining a criminal record report, verifying references, work history, your educational achievements, licensure, and certifications, your driving record, and other information about you, and interviewing people who are knowledgeable about you. The results of this report may be used as a factor in making tenant screening decisions. The source of any investigative consumer report (as that term is defined under California law) will be Tenant Reports, 370 Reed Road, Suite 101, Broomall, PA 19008, Phone: (855) 244-2400, Fax: (855) 244-2401. The source of any credit report will be Tenant Reports, 370 Reed Road, Suite 101, Broomall, PA 19008, Phone: (855) 244-2400, Fax: (855) 244-2401.

The Company agrees to provide you with a copy of an investigative consumer report when required to do so under California law.

Under California Civil Code section 1786.22, you are entitled to find out from an ICRA what is in the ICRA’s file on you with proper identification, as follows:

  •  In person, by visual inspection of your file during normal business hours and on reasonable notice. You also may request a copy of the information in person. The ICRA may not charge you more than the actual copying costs for providing you with a copy of your file.
  • A summary of all information contained in the ICRA’s file on you that is required to be provided by the California Civil Code will be provided to you via telephone, if you have made a written request, with proper identification, for telephone disclosure, and the toll charge, if any, for the telephone call is prepaid by or charged directly to you.
  • By requesting a copy be sent to a specified addressee by certified mail. ICRAs complying with requests for certified mailings shall not be liable for disclosures to third parties caused by mishandling of mail after such mailings leave the ICRAs.

“Proper Identification” includes documents such as a valid driver’s license, social security account number, military identification card, and credit cards. Only if you cannot identify yourself with such information may the ICRA require additional information concerning your employment and personal or family history in order to verify your identity.

The ICRA will provide trained personnel to explain any information furnished to you and will provide a written explanation of any coded information contained in files maintained on you. This written explanation will be provided whenever a file is provided to you for visual inspection.

You may be accompanied by one other person of your choosing, who must furnish reasonable identification. An ICRA may require you to furnish a written statement granting permission to the ICRA to discuss your file in such person’s presence.

DISCLOSURE REGARDING BACKGROUND INVESTIGATION

[IMPORTANT — PLEASE READ CAREFULLY BEFORE SIGNING ACKNOWLEDGMENT]

TRC Test Co NO Fields (“the Company”) may obtain information about you from a consumer reporting agency for tenant screening purposes. Thus, you may be the subject of a consumer report and/or an investigative consumer report which may include information about your character, general reputation, personal characteristics, and/or mode of living, and which can involve personal interviews with sources such as your neighbors, friends, or associates. These reports may contain information regarding your criminal history, social security trace, employment and education references, credit history, professional licenses and credentials. You have the right, upon written request made within a reasonable time after receipt of this notice, to request disclosure of the nature and scope of any investigative consumer report. Please be advised that the nature and scope of the most common form of investigative consumer report obtained with regard to applicants for residency is an investigation into your education and/or employment history conducted by (“Agency”). Tenant Reports, 370 Reed Road, Suite 101, Broomall, PA 19008, Phone: (855) 244-2400, Fax: (855) 244-2401, or another outside organization. This Disclosure and Authorization allows the Company to obtain from any outside organization all manner of consumer reports and investigative consumer reports now and, if approved for residency, throughout the course of your tenancy to the extent permitted by law. As a result, you should carefully consider whether to exercise your right to request disclosure of the nature and scope of any investigative consumer report.

Maine, Massachusetts, and New Jersey applicants or residents only: You have the right to inspect and promptly receive a copy of any investigative consumer report requested by Company by contacting the consumer reporting agency identified above directly.

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