Last updated: December 29, 2022
We care about privacy and know that you do, too.
Checkr Pay ("Checkr Pay", "we", "us" and/or "our") is a full-service payments platform for 1099 contractors (“Workers”, “you,” or “your”) and their employers (“Customers”).
This Policy does not apply to any third-party applications or software that integrate with the Services through the Checkr Pay platform (“Third Party Services”), which are governed by their respective privacy policies.
If you reside in certain states (such as California), you have certain rights, which we describe in more detail below.
Checkr Pay as a service provider
When you sign up for an account with Checkr Pay, Checkr Pay may collect and use your Personal Data on behalf of Thread Bank (collectively, Checkr Pay’s “Bank Partners”) to facilitate the provision of banking services pursuant to the Bank Partners’ privacy policies as applicable. Checkr Pay acts as a “service provider” that processes your Personal Data in accordance with the restrictions set forth in the agreements with our Bank Partners. Federal law requires our Bank Partners to provide notice to certain consumers to explain what Personal Data they collect, how they share it, and how consumers may limit our Bank Partners’ sharing of the information. The privacy practices of our Bank Partners are subject to their privacy policies, which we strongly suggest you review. Checkr Pay is not responsible for our Bank Partners’ privacy practices or policies.
In addition, when you sign up to work with one of our Customers, Checkr Pay acts as a “service provider” that processes your Personal Data in accordance with the restrictions set forth in the agreements with our Customers. The privacy practices of our Customers are subject to their privacy policies, which we strongly suggest you review. Checkr Pay is not responsible for our Bank Partners’ privacy practices or policies.
Information we collect and how we collect it
When you access our Site or use the Services, we collect and store certain information about you, including Personal Data. Personal Data is information that, alone or in combination with other information in our possession, could be used to personally identify you. We collect the following categories of Personal Data and other information as described below.
Information you provide directly
We may collect or receive the following categories of Personal Data when you create an account, verify your identity, use any of the Services, or otherwise communicate with us:
- Identifiers, such as name, email address, mailing address, and phone number.
- Login credentials, including credentials foryour Checkr Wallet account.
- Financial information, such as bank account information and information relating to tax forms, such as Form W-9 and Form 1099-NEC.
- Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as Social Security number, driver’s license, passport number, and state identification card number.
- Protected classification characteristics under California or federal law, such as age, national origin, or citizenship.
- Professional or work-related information, such as names of Customers for whom a Worker has performed work.
- Audio or visual information, such as photos of your government-issued identification card.
- Other information you voluntarily provide, such as information you provide through support or feedback channels or when you otherwise communicate with us.
Information we collect from third parties
We may collect and receive information about you, including Personal Data, from third parties, such as Customers, Customers’ service providers, and our own service providers, including for identity verification, fraud protection, providing the Services, and other purposes.
If you elect to use integrated Third Party Services, we may also have access to your Personal Data through such Third Party Services.
Information collected automatically
We may also automatically collect, generate, and/or receive Personal Data from the Site or Services as follows:
- Online identifiers, such as device identifier, operating system, browser type, and IP address.
- Internet or other electronic network activity information, such as metadata, log data, web beacons, cookies, and similar technologies. We use both session cookies (which are deleted once you close your browser) and persistent cookies (which remain on your computer or device until you delete them or they expire).
How we use your information
We use the information we collect from you for the following purposes:
To provide, market, and improve the Services
We use the information we collect to provide, update, and maintain the Services. For example, we may use your Personal Data in the following ways:
- Registration information. We use your registration information to verify your identity, create your Checkr Wallet account, and provide you with access to the Services we provide through our Site.
- Provide authentication. We use your credentials to authenticate you when logging into Checkr Pay. In addition, we integrate with Apple and Android device-based biometric technologies to enable you to authenticate using your face or fingerprint ("Device-Based Authentication"). Checkr Pay cannot access and does not store or otherwise process biometrics data. When you log into Checkr Pay for the first time, you will be asked whether you would like to opt into Device-Based Authentication. You may toggle this setting on and off at any time in your account settings.
- Provide financial services. We use your financial information to facilitate fund transfers between your external bank accounts and Checkr Wallet, generate tax forms, help you estimate your tax liability, provide cash advances, and manage your Wallet.
- Investigate disputes. We may use your information to investigate and settle any dispute or claim which relates to our Services.
- Provide support. We may use Personal Data to provide Workers or Customers with support in using our Services.
- Marketing our Services. We may use your information to market new products or services to you, both on and off the Checkr Pay platform.
- Improving your experience. As we seek to improve your experience with the Services, we may analyze data we collect about your use of the Services to inform how we can make improvements.
- Anonymized and aggregate data. We also may use your Personal Data to generate anonymized or aggregate data, which are not subject to the restrictions outlined in this Policy.
To protect Checkr Pay, our Customers, Workers, and third parties, and to comply with applicable law
We may use your information to protect the rights, property, and safety of Checkr Pay, our employees, Customers, Workers, and third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues. In addition, we may use your information as permitted by law or as reasonably necessary to comply with applicable law and to enforce this Policy, our Terms of Service, and other related agreements.
For example, when you open an account, we will use your name, address, date of birth, and social security number to verify your identity in compliance with federal laws designed to help the government fight the funding of terrorism and money laundering activities.
To operate our business
We may use your information to operate our business, such as when we process payments or manage and enforce contracts.
To communicate with you
We may use your information to communicate with you about our Services and your account, such as to send you email or text messages, or to permit Customers to send you such messages.
With your consent
We may use your information for any other purpose for which you expressly authorize.
When and with whom we share your information
Checkr Pay does not sell your Personal Data. We will only share your information under the circumstances listed below, unless otherwise stated when we collect your information:
To work with Customers and Bank Partners
Checkr Pay may share Personal Data with Customers and Bank Partners so that we can provide, improve, and protect the Services. For example, we may share your Form 1099-NEC with a Customer so that they can file it with the IRS when required by law.
To work with service providers
Checkr Pay may share Personal Data with third-party service providers contracted to provide services on our behalf. These third-party service providers may use data we provide to them only as instructed by Checkr Pay. For example, we may share your information with our service provider, Plaid, so they can obtain information from your financial institution to enable us to provide our Services. We also work with Abound to provide tax or financial-related services. By using the Services, you agree and understand that our service providers, such as Plaid or Abound, may transfer, store, and process your data. Any such data use shall be in accordance with the restrictions in this policy.
To work with joint marketing partners
Checkr Pay may share Personal Data with joint marketing partners so that we can engage in joint marketing activities. These joint marketing providers may use data we provide to them only as instructed by Checkr Pay.
To integrate with third party services
To provide an integrated payments platform, you may enable integrated Third Party Services, such as Google Wallet or Apple Wallet. When enabled, Checkr Pay may share Personal Data with Third Party Services. Third Party Services are not owned or controlled by Checkr Pay and third parties that have been granted access to Personal Data may have their own policies for its collection, use, and sharing. Any permissions you have granted to that Third Party Service will govern their use of your data. Please check the policies of these Third Party Services or contact the provider for any questions.
To facilitate a change in Checkr Pay’s business
Checkr Pay may be involved with a transaction such as a merger, acquisition, joint venture, financing, or sale of company assets. In connection with such a transaction, Checkr Pay may disclose Personal Data to a third party.
To investigate and help prevent abuse
We may share your Personal Data to protect the rights, property, and safety of Checkr Pay, our employees, Customers, Workers, and third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
To comply with applicable law, regulation, or legal process
We may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of Checkr Pay, prevent fraud, act in urgent circumstances to protect the personal safety of users of the Services or the public, or protect against legal liability. We may share your Personal Data with professional advisors, such as accountants, auditors, or legal counsel, who help us meet such obligations.
With corporate affiliates
We may share Personal Data with third parties when we have consent to do so.
Your privacy rights and choices
We respect your choices over your Personal Data. When visiting our Site or using our Services, you have the following choices with respect to your Personal Data.
By providing us with a telephone number for a cellular phone or other wireless device and opting into transactional messages, you agree to receive autodialed and pre-recorded, non-marketing, service-related text messages from or on behalf of Checkr Pay at the phone number provided. Message frequency varies.
By providing us with a telephone number for a cellular phone or other wireless device and opting into promotional messages, you consent to receive autodialed and pre-recorded text messages from or on behalf of Checkr Pay at the number provided for marketing or promotional purposes. Message frequency varies. You understand that consent to marketing-related messages is not a condition of using the Services. You can opt out of promotional text messages from us by replying “STOP.” If you decide to opt out, we may still send you transactional messages, such as important messages about your account.
You can opt out of our promotional emails by using the unsubscribe link located at the bottom of our promotional emails.
Cookies and similar technologies
Do not track
Some browsers may transmit “Do Not Track” signals. There is no universal standard that establishes what websites should do with respect to these “Do Not Track” signals, so we do not currently respond to them. If and when a standard is established, we may revise our policy on “Do Not Track” signals.
California and other state privacy laws
If you reside in California or certain other states (including Virginia), you have certain privacy rights under state law.
The California Consumer Privacy Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”) generally do not apply to Personal Data collected, processed, or disclosed pursuant to the federal Gramm-Leach-Bliley Act (“GLBA”) and its implementing regulations. Most of the Personal Data Checkr Pay collects about California and Virginia residents is collected for the purposes of providing Workers and Customers with financial products from our Bank Partners pursuant to the GLBA and is not subject to the CCPA or the VCDPA.
Furthermore, in many cases, we act as a “service provider” under the CCPA and VCDPA with regard to Personal Data we receive and process through our Services, and conduct our data processing in accordance with the restrictions set forth in the data processing agreements with our Customers and Bank Partners.
If your Personal Data has been submitted to us by or on behalf of a Checkr Pay Customer and you wish to exercise your rights under the CCPA or VCDPA, please inquire with the applicable Customer directly. If you contact Checkr Pay directly for these purposes, we may be required to inform the relevant Checkr Pay Customer (if we can identify them from the contact details you provided).
If you are a California or Virginia resident and believe we have collected your Personal Data outside of a “service provider” relationship, you may contact us at email@example.com to make requests regarding the following rights:
- Right to know: California and Virginia residents have the right to know what categories of Personal Data Checkr Pay has collected about them and whether Checkr Pay has disclosed or sold that Personal Data for a business purpose in the past 12 months.
- For a description of the categories of Personal Data that Checkr Pay has collected in the past 12 month, see the section above entitled, Information we collect and how we collect it.
- For a description of the categories of Personal Data that Checkr Pay has disclosed for a business purpose in the past 12 month, see the section above entitled, Information we collect and how we collect it. Checkr Pay does not sell your Personal Data or share it for the purposes of cross-contextual behavioral advertising.
- For a description of the categories of third parties with whom Checkr Pay has disclosed Personal Data for a business purpose in the past 12 month, see the section above entitled, When and with whom we share your information.
- Access: California and Virginia residents have the right to request that Checkr Pay disclose what Personal Data it collected, used, and disclosed in the past 12 months.
- Deletion: California and Virginia residents have the right to request the deletion of certain Personal Data.
- Right to Non-Discrimination: Checkr Pay enforces a strict non-discrimination policy when you exercise your rights.
- Right to limit the processing of sensitive personal information. California residents have the right to limit processing of sensitive personal information. Checkr Pay may process sensitive personal information under California law, such as social security number, driver’s license, state identification card, passport number, as well as account log-in, financial account information, and credential information. Checkr Pay only uses such sensitive personal information for the following purposes:
- To the extent it is necessary to perform the services reasonably expected by the average Worker who requested them;
- To help ensure security and integrity to the extent the use of the Worker’s personal information is reasonably necessary and proportionate for these purposes; and
- Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, or providing similar services on behalf of the business.
Checkr Pay will help you exercise these rights free of charge, where applicable. If you make a request under the CCPA or VCDPA, we may need to take additional steps to verify your identity. If you designate an authorized agent to make a request on your behalf, we may require you to provide the authorized agent written permission to do so and to verify your own identity directly with us. Please note that certain Personal Data may be exempt from such CCPA or VCDPA requests based on exemptions under federal laws, such as the GLBA.
How we protect your Personal Data
We employ a number of technical, organizational and physical safeguards designed to protect the Personal Data we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your Personal Data.
Our policy toward children
You must be 18 years old in order to use the Services on our Site. Checkr Pay does not knowingly collect or solicit any Personal Data from children under the age of 18. If you believe that a child under the age of 18 may have provided Personal Data to Checkr Pay, please contact us. In the event that we learn that we have collected Personal Data from a child under the age of 18, we will delete that information as quickly as possible.
The Services are not intended for use by anyone located outside of the United States. By using our Services, you consent to the collection, transfer, storage, and processing of Personal Data to and in the United States.
Checkr Pay uses infrastructure primarily located and operated in the United States. Checkr Pay may also work with service providers or affiliates located in countries outside of the United States store, process, and transmit your information.
If you have any questions about this Policy or wish to exercise your rights, please contact us at firstname.lastname@example.org or by using the contact information below. Checkr Pay will respond to your request within a reasonable timeframe or as required by law.
Attn: Privacy Questions
One Montgomery Street, Suite 2400
San Francisco, CA 94104