Orange Tree Privacy Policy

In order to process background screening reports on behalf of our Clients, Orange Tree collects information about subjects and Clients as needed to complete those services.  Information collected will vary based on, and will be limited by the types of background screening reports requested by our Client.  The types of personally identifiable information (PII) typically collected include Client authorized contact name, email address, phone number and title, and background screening subject name, address and address history, other names used by the subject, phone numbers and email addresses, education, employment, and reference information, driving and professional license information, credit information, sanction list information, identifying information like social security number or other identification number, date of birth, driver license number or fingerprint information.  Sensitive Consumer information collected is used only for the purpose of creating the consumer report(s) that are ordered, including sharing the information with our authorized vendors and information sources when needed in order to provide the contracted services, and only upon request from our Client.

In addition we may collect responses that visitors or Clients provide to survey questions, the number of visits to our site, IP address information, time spent on the site, pages viewed, and inquiries you make through our website. 

Our websites also collect non-personally identifiable information about individuals accessing our sites including the number of people that visit the sites, which pages are visited, and from which domain.

Requests for background screening reports are initiated by Orange Tree Clients that have agreed to request background screening reports only in those cases where there is a permissible purpose to do so, where the Client has made disclosure to the subject that they intend to procure a background screening report, and where they have received the subject’s authorization to do so, as allowed by law, or where the subject of the background screening report being created is the Client. Subject information is collected from Orange Tree Clients, from subjects directly and from authorized vendors and sources. Background screening reports are prepared using information provided from many sources, including but not limited to Orange Tree Clients, subjects, court and law enforcement agencies, local, state and federal agencies and record repositories, schools and universities (public or private), employers, references, private databases, public record researchers, credit bureaus and other Consumer Reporting Agencies.

The background screening reports that are created for Orange Tree Clients are shared only with the Client that requested the background screening reports and their authorized contact(s), an End User as defined under the FCRA, or with the subject about whom the report was prepared (upon the request of the subject).

In connection with preparing background screening reports for our Clients, we may in some instances employ other companies and individuals as our vendors or subcontractors to complete parts of the background screening process on our behalf. Subcontractors are contractually obligated to use and maintain the confidentiality of personal information in a manner consistent with this policy. These companies and individuals may not share any such information with any third party, other than their authorized subcontractors, Orange Tree's subcontractors or Orange Tree. Except as described in this policy or required by law, we will not use or otherwise disclose any of the Sensitive Consumer information that you provide or that we collect from third parties or other sources.  Note however, that Orange Tree may be required to disclose information that we collect in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.  We may use non-sensitive information (like your name and email address) to market services to you.

Notice to individuals in Canada: Orange Tree is located in the United States.  Any information that we collect about you (or that is transmitted to use by our clients, vendors or sources), will be transferred, stored and accessed from the United States.  Your information may be transferred outside of the United States if such transfer is required in order to complete the background screening services requested by our client.

We comply with the requirements of COPPA (Children’s Online Privacy Protection Act), and we do not collect any information from anyone under 13 years of age ("Children"). Our website, products and services are all directed to people who are at least 13 years old or older.

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

If you do not wish to have your personal data made available to our Client (for example, you yourself, or your current or prospective employer), do not authorize our Client to procure a background screening report about you. By consenting to the procurement of a background screening reports and submitting information to us or to us on behalf of our Client, you are agreeing to allow Orange Tree to disclose information about you to our Client and to our sharing that information with authorized vendors, subcontractors or information sources, for the purpose of completing the requested background screening report.

If you are a European Union resident or reside in other countries where Orange Tree is doing business, you may choose not to submit personal information to Orange Tree through the site or through forms provided by our Client for that purpose. You have been provided a consent form either by us or our Client. By filling out and submitting the consent form you expressly agree to provide personally identifying information and you consent to our use of that information in accordance with this policy. 

To withdraw your consent, or to restrict or object to processing contact Heidi Seaton, Vice President of Compliance at hseaton@otes.com or by phone toll free 800-886-4777, extension 7121.

Orange Tree agents are stationed in the United States and abroad, however subject information is maintained in United States.  Your information may be transferred outside of the United States if such transfer is required in order to complete the background screening services requested by our client.

Sensitive subject information is protected by reasonable and appropriate administrative, physical and technical measures and is stored in a secure manner within a secure facility. Use of background screening reports is restricted to users approved by Orange Tree Clients and Orange Tree agents with a legitimate business need to conduct background checks requested by Orange Tree Clients.  Authorized Client users to our sites access subject background screening reports in a secure manner using strong encryption and strong password protection.  Data is stored in a secure manner in accordance with security best practices and have been audited by third parties.

Orange Tree maintains written internal Information Security Policies to which all Orange Tree employees and agents must adhere. In addition, all Orange Tree agents who have access to Sensitive Consumer information have signed non-disclosure agreements.  Our Information Security Policies conform to requirements related to industry standards for the protection of personal information including but not limited to residents of the Commonwealth of Massachusetts.

Sensitive subject information and background screening reports are retained for a minimum of six (6) years in accordance with FCRA limitation of liability time frames. Subjects may opt out of Orange Tree receiving information about them by not consenting to the background screening report for our Client (for example, you yourself, or your current or prospective employer).  In general, once a subject has consented to such a report, Orange Tree retains the information on file for the six (6) year period.

Information sources that may be used in producing Consumer Reports are not maintained by Orange Tree, therefore Orange Tree cannot guarantee that the information from such sources is current or accurate.   

A subject may exercise their right to access and correct information in their file or dispute information in their file, as allowed by state law, the federal FCRA law, the General Data Protection Regulation (GDPR) or other applicable law. 

The Consumer Financial Protection Bureau’s Summary of Rights document provides a list of US consumer rights, and the Fair and Accurate Credit Transaction Act (FACT Act) also includes additional rights.  See the Consumer Financial Protection Bureau’s Summary of Rights document. 

To request access to or correct the information in your consumer file (as allowed by applicable law) or to make a request for a free annual file disclosure (as allowed by the FCRA) contact Orange Tree toll free at 877-458-7137. 

If you are a subject and you believe your personal information has been compromised, please contact Heidi Seaton, Vice President of Compliance at hseaton@otes.com or by phone toll free 800-886-4777, extension 7121 for assistance or information.

If you are a European Union Data subject, you have the right to have your personal information erased under some circumstances.  Contact the employer (our Client) that requested we prepare a background screening reports about you to request erasure.  If you need help contacting the employer (our Client), please contact Heidi Seaton, Vice President of Compliance at hseaton@otes.com or by phone toll free 800-886-4777, extension 7121 for assistance or information.

This California Privacy Notice (“Notice”) is intended for to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”). This Notice is limited to the data practices of Orange Tree in California.

This Notice covers our collection, use, and disclosure of California Consumers’ “Personal Information” (“PI”) as defined by the CCPA, for the twelve months preceding the Effective Date. This Notice also covers rights California Consumers have under the CCPA, as well other notices to Californians that may be required by certain other laws. Terms defined in the CCPA that are used in this Notice shall have the same meaning as in the CCPA.

1. PI We Collect

2. Sources of PI.

We may collect your PI directly from you or your device, or from our clients, service providers, vendors and suppliers, our affiliates, or other individuals and businesses as well as public sources of data.

3. Use of PI

Generally, we collect, retain, use, and share your PI for the purposes described in the Notice and Purpose Section of this Privacy Policy.

In addition, we may collect, use and share the PI we collect for one or more of the following business purposes:

• Processing Interactions and Transactions
• Managing Interactions and Transactions
• Performing Services
• Security and Integrity, including (without limitation) protecting against security incidents and fraudulent, malicious, illegal, or wrongful conduct
• Debugging
• Short-term, transient use, including non-personalized advertising
• Enabling our service providers and business partners (and their service providers and/or subcontractors) to provide services to us

4. Sharing of PI

We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work.  We have contracts in places with our vendors that are designed to help safeguard your personal information, including that they may not do anything further with your personal information unless we have instructed them to do it.  They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.  The categories of the third parties we may share personal information with include: government entities, vendors, contractors and sales and marketing tool service providers.

We may also need to share your person information in connection with a merger, sale of company assets, or acquisition of all or a portion of our business to another company.

Orange Tree has not sold any personal information to third parties for business or commercial purposes in the preceding twelve (12) months.

5. California Privacy Rights

We provide California Consumers the privacy rights described in this section. You may also exercise these rights via an authorized agent who meets the agency requirements of the CCPA. As required by the CCPA, any request you submit to us is subject to a verification process. To verify your request, you must provide your name, email, and state of residence, along with any other information we may require to verify your identity or your request. We may not fulfill your CCPA request unless you have provided sufficient information for us to appropriately verify you and your request.  Submit requests as directed below in the Contact Us section.

A. The Right to Know and Have Access to Data

You have the right to obtain a copy of the specific pieces of PI that we have collected about you. You may request that we correct PI that we maintain about you that is inaccurate. Submit requests as directed below in the Contact Us section.

B. Right to Limit

You have the right to direct us to use your sensitive personal information for limited purposes.  Note, that we only collect and use sensitive information to complete services that you or our client may have requested about you, so requests to further limit this use may result in us being unable to complete such services. Submit requests as directed below in the Contact Us section.

C. Right to Delete

You may request that we delete your PI that we have collected from you. Please note that even if you make a request to delete your PI, it may result in us being unable to complete services that you or our client may have requested about you.  Applicable law may permit or require us to retain PI that was collected to comply with law, to exercise or defend legal claims, and to cooperate with law enforcement.  Submit requests as directed below in the Contact Us section.

D. Right to Correct

You may request that we correct PI that we maintain about you that is inaccurate. Submit requests as directed below in the Contact Us section.

E. Right to Opt Out of Sale or Sharing

You may opt out of “sales” or “sharing” of PI (as defined under applicable law) by submitting such a request as directed below in the Contact Us section.

F. Non-Discrimination

As required by the CCPA, we will not discriminate against you because you exercise your CCPA rights. However, exercise of some rights may result in us being unable to complete services that you or our client may have requested about you.

G. Authorized Agents

As permitted by the CCPA, any request you submit to us is subject to an identification and verification process, and confirmation of the agent’s authority, which may include attestation under penalty of perjury. 

Orange Tree commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact Orange Tree at:

By phone: 800-886-4777, ext. 7121

By email: hseaton@otes.com

By mail:

Orange Tree Employment Screening

Attn: Heidi Seaton          

7275 Ohms Lane

Minneapolis, MN 55439