SafestHires, Inc. Privacy Policy
Updated: March 31, 2021

At SafestHires Background Checks (“SafestHires” or “we” or “our”), accessible from https://www.safesthires.com/ and https://secure.safesthires.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 SafestHires Background Checks and how we use it in connection with SafestHires’ products and services (the “Services“).

If you have additional questions or require more information about our Privacy Policy, contact us at support@safesthires.com or at:

SafestHires, Inc.
Attn: Privacy Questions
4756 Red Deer Trail
Broomfield, CO 80020

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 SafestHires Background Checks. This policy is not applicable to any information collected offline or via channels other than SafestHires’ websites. Our Privacy Policy was created with the help of the Privacy Policy Generator and the Free Privacy Policy Generator.

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.

SafestHires 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 SafestHires’ information practices. Please contact us if you have other questions.

1. What information does SafestHires 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 SafestHires content available through the Services such as whitepapers, videos, webinars, and other materials, or request additional information about SafestHires or the Services. SafestHires 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”), SafestHires 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, Authorize.net. You can review information on their privacy practices at .

B. Applicants

If you are an applicant who will be the subject of a screening or background check (“Applicants”), SafestHires 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 your 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 SafestHires use the collected information?

SafestHires 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.

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

SafestHires 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 SafestHires 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.

SafestHires 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 SafestHires 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 SafestHires, 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 SafestHires, 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 find more information about Google privacy practices here. here.

Note that SafestHires 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 SafestHires’ control by contacting SafestHires as set forth at the end of this Policy. Applicants can dispute background check reports by printing this form and mailing the completed form along with required documentation to the address on the form.

Once a Customer, such as an employer, has received a background check report, SafestHires 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 SafestHires’ 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

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 the following address: 4756 Red Deer Trail, Broomfield, CO 80020. 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 email us at support@safesthires.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 SafestHires?

• 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 by clicking here. here.

• 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 SafestHires protect your information?

SafestHires 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. SafestHires 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 DEFINITIVE PROMISE OF SECURITY IN CONNECTION WITH YOUR INFORMATION OR TECHNICAL INFORMATION.

9. Where is your information processed or stored?

SafestHires uses servers located in the United States. SafestHires 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 SafestHires 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 support@safesthires.com or at:

SafestHires, Inc.
Attn: Privacy Questions
4756 Red Deer Trail
Broomfield, CO. 80020

CCPA / CPRA Service Provider Addendum

This Addendum shall form part of the agreement entered into by the parties for SafestHires (SH) to provide services to Customer (the “Agreement”) and is effective as of the later of January 1, 2023 or the Effective Date of the Agreement between Customer and SH.

1. 1. Relationship of the Parties. SH 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 SH in connection with SH’s performance of the Agreement. Pursuant to this, the parties seek to clarify their applicable responsibilities in this Addendum.
   2. Definitions.
      1. “Business”, “Collects”, “Consumer”, “Business Purpose”, “Sell”, “Service Provider”, and “Share” shall have the meanings given to them in §1798.140 of the CCPA.
      2. “Business Purpose” has the meaning given in Section 5 of this Addendum. 
      3. “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.
      4. “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.
      5. “Personal Information” means personal information as defined by §1798.140 of the CCPA submitted to SH for processing pursuant to the Agreement.

Capitalized terms used but not defined in this Addendum shall have the meanings given in the Agreement. 

1. Relationship with the Agreement.
   1. 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.
   2. 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.
   3. No one other than a party to this Addendum, its successors and permitted assignees shall have any right to enforce any of its terms.
   4. 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.
   5. This Addendum shall continue in effect, and shall survive termination or expiration of the Agreement, as long as SH retains possession, custody, or control of, or access to, any Personal Information in connection with or as a result of the Agreement.
   6. 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.
2. Scope. This Addendum only applies where, and to the extent that, SH 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.
3. Business Purpose. SH 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”). SH 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.
4. Data Protection.
   1. Service Provider Appointment. Customer is a Business and appoints SH as its Service Provider to Collect and process the Personal Information for the Business Purpose. SH 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 SH to Collect and process the Personal Information for the Business Purpose.
   2. Service Provider Certification. SH 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 SH and Customer (except where SH 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. SH certifies that it understands the restrictions set out in this Section and will comply with them. SH shall notify Customer if it determines that it cannot meet its obligations under the CPRA.
   3. Consumer Rights. SH 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 to 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.
   4. Assistance. SH 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 for the California Attorney General in connection with the Collection and processing of the Personal Information.
   5. Deletion. Upon receipt of Customer’s written request, SH shall, at Customer’s election, delete or return any Personal Information within ninety (90) days of termination, except where SH is permitted by applicable law to retain some or all of the Personal Information, which Personal Information SH shall continue to protect from any further processing, except to the extent required by applicable law.
   6. Reasonable Steps. Customer has the right to take reasonable and appropriate steps to (i) ensure that SH 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. 
5. Subcontractors. If Company wishes to engage a subcontractor to assist in processing Personal Information for purposes of performing the services under the Agreement, SH shall provide prior notice of any new subcontractor, and shall enter into written and binding contract with the subcontractor that requires the subcontractor to observe all requirements set forth in this addendum.
6. Security. SH 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. SH 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.
7. Contact. If Customer has any questions or complaints with respect to this Addendum, Customer may contact SH by mail at SafestHires, Inc. 4756 Red Deer Trail, Broomfield, CO 80020, email at admin@safesthires.com, or by phone at +1.469.629.1609, 9:00 AM – 6:00 PM MST, Monday through Friday (excluding SH holidays).
8. If Customer requires an executable version of this Addendum, please send a request email to admin@safesthires.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, SafestHires will comply with the applicable law for customers, users and applicants in Canada.

For example, SafestHires 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 SafestHires 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).

SafestHires 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 SafestHires 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. We may charge you a small fee for this service.

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@safesthires.comor at:

SafestHires, Inc.
Attn: Privacy Questions
4756 Red Deer Trail
Broomfield, CO 80020

SafestHires, 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, SafestHires 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, SafestHires uses servers located in the United States. SafestHires 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.

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.

SafestHires, Inc. 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.