Privacy Policy

Effective Date: January 1, 2026

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This Privacy Policy describes how Coal Creek Software, Inc., doing business as Verifent (“Verifent,” “we,” “us,” or “our”) collects, uses, discloses, and protects information in connection with (i) the Verifent.com website and its related subdomains (collectively, the “Websites”), and (ii) the products and services offered by Verifent, including services subject to the Fair Credit Reporting Act (“FCRA”).

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1. SCOPE AND APPLICABILITY

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This Privacy Policy applies to information collected through the Websites and through Verifent’s online products and services. Certain Verifent services may also be governed by separate contractual agreements, privacy notices, or FCRA disclosures, which shall control in the event of any conflict.

The Websites are intended for a general audience and are not directed to children under the age of thirteen (13). Verifent does not knowingly collect personal information from any individual known to be under the age of 13.

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2. INFORMATION WE COLLECT

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2.1 Information Collected Directly From You

Verifent may collect personal and non-personal information when you voluntarily provide it, including through the following activities:

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(a) Registration and Account Creation.
When you register to receive alerts, newsletters, product information, access services, or participate in online events (such as webcasts or promotions), we may collect information such as your name, employer name, job title, email address, phone number, and account credentials.

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(b) Use of Web-Based Services or Products.
When you purchase or use Verifent’s web-based services, we may collect identifying and contact information, employer information, and payment or billing information, as applicable. Personally identifiable information may be used to establish and secure a unique user account and to support authentication and password recovery.

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(c) Communications With Verifent.
We collect information when you contact us electronically, including via email, web forms, applications, or service inquiries.

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2.2 Information Collected Automatically

When you access or use the Websites, Verifent’s systems may automatically collect certain information, including:

• Internet Protocol (IP) address

• Browser type and language

• Date and time of access

• Referring and exit pages

• Pages viewed, navigation paths, and actions taken

• Cookies or similar technologies that uniquely identify your browser or session

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Such information may be associated with personally identifiable information for purposes including security monitoring, fraud prevention, auditing, and compliance.

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Cookies.
Verifent uses session cookies to support site functionality and collect aggregated usage data. Session cookies are deleted when you close your browser.

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2.3 Information Collected From Third Parties

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Verifent may receive information from third parties, including:

• Employers or data furnishers

• Verifiers with a permissible purpose

• Vendors or service providers operating portions of the Websites or services on Verifent’s behalf

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When information obtained from third parties is combined with personal information collected directly, it will be treated in accordance with this Privacy Policy. Verifent discloses personally identifiable information obtained from third parties only as necessary to provide services or as permitted by law, including disclosures to verifiers with a permissible purpose and appropriate authorization.

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3. USE OF INFORMATION

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Verifent uses the information it collects to:

• Operate, maintain, and administer the Websites and services

• Provide, support, and improve products and services

• Respond to inquiries and fulfill requests

• Enhance user experience and site functionality

• Conduct security monitoring, auditing, and fraud prevention

• Comply with legal, regulatory, and contractual obligations

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IP addresses and related data may be linked to personally identifiable information as part of security and compliance audit trails.

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4. DISCLOSURE OF INFORMATION

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4.1 General Disclosure Principles

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Verifent takes reasonable measures to ensure that affiliates and non-affiliated third parties to whom personal information is disclosed are aware of and comply with confidentiality and data protection obligations consistent with this Privacy Policy.

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Verifent does not disclose personally identifiable information except as described below or as permitted or required by law.

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4.2 Permitted Disclosures

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Verifent may disclose personal information:

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(a) To Provide Services.
To deliver products or services requested or authorized by you or your employer.

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(b) To Service Providers and Contractors.
To vendors, contractors, and affiliates who assist in operating Verifent’s business or services, subject to contractual confidentiality and security obligations and limited to information reasonably necessary to perform their functions.

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(c) For Legal and Compliance Purposes.
To comply with applicable laws, regulations, subpoenas, court orders, or other lawful governmental requests; or where Verifent reasonably believes disclosure is necessary to protect individuals, national security, Verifent’s systems, or to prevent fraud, abuse, or unlawful activity.

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(d) In Corporate Transactions.
In connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, provided that reasonable steps are taken to ensure continued protection of personal information consistent with this Privacy Policy.

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4.3 Links to Third-Party Websites

The Websites may contain links to third-party websites. Verifent does not control and is not responsible for the privacy practices of such websites. Users are encouraged to review the privacy policies of any third-party sites they visit.

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5. YOUR CHOICES AND CONTROLS

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5.1 Information Choices

You may choose not to provide certain information or to restrict cookies through your browser settings; however, doing so may limit functionality or access to certain services.

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5.2 Cookies

Most browsers allow you to manage or disable cookies through settings. Cookie preferences must be managed separately for each device and browser.

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5.3 Marketing Communications

You may opt out of promotional or marketing emails by following the unsubscribe instructions included in such communications.

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5.4 Do Not Track Signals

Some browsers transmit “Do Not Track” signals. There is currently no industry standard governing responses to such signals, and Verifent does not currently respond to them.

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5.5 California Privacy Rights

California residents may request information regarding disclosures of personal information for direct marketing purposes under California Civil Code §1798.83 by contacting Verifent as described below.

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6. INFORMATION SECURITY

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Verifent maintains administrative, technical, and physical safeguards designed to protect personal information, including:

• Limiting access to employees with a legitimate business need

• Enforcing disciplinary measures for misuse of information

• Utilizing Transport Layer Security (TLS) encryption for data in transit

• Implementing reasonable technical and procedural controls

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Users also play a role in safeguarding information by maintaining secure passwords, logging out of sessions, and using up-to-date antivirus and security software.

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7. CHANGES TO THIS PRIVACY POLICY

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Verifent may update this Privacy Policy periodically, including in connection with material changes to services or legal requirements. Any revisions will be posted on the Websites with an updated effective date. Continued use of the Websites or services after such posting constitutes acceptance of the revised Privacy Policy.

 

8. CONTACT INFORMATION

Questions or concerns regarding this Privacy Policy or Verifent’s privacy practices may be directed as specified on the “Contact Us” page or to:

Email: security@verifent.com