Privacy Policy of The Cole Group
Last Updated: 04/28/2026
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information in connection with https://www.thecolegroup.com/ and our other affiliated websites. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request. We collect, use, and are responsible for certain personal information about you. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA). We are responsible for your personal information as a “business” under the CCPA/CPRA. For consumers in Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia, we are subject to relevant privacy laws of those states respectively (see Consumers in other States: Your Rights). Differences in privacy laws will be illustrated throughout. This policy applies to information we collect on the Website and communications originating from the Website and does not apply to information collected by us offline. If you do not agree with our policies and practices, your choice is not to use the Website. By accessing or using the Website, you agree to this privacy policy. This policy may change from time to time (see Changes To This Privacy Policy). Your continued use of the Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
1. Key Terms. It would be helpful to start by explaining some key terms used in this policy:
| We, us, our | The Cole Group |
| Our website | https://www.thecolegroup.com/ |
| Personal information | Any information relating to an identified or identifiable individual |
| Sensitive Personal Information | Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status |
| Our Products and Services | We conduct background screenings on people applying for employment to our clients and provide the results of the background screening to our clients via consumer report(s). |
2. Personal Information We Collect About You. We conduct background screenings on people applying for employment to our clients and provide the results of the background screening to our clients via consumer report(s).
| Categories of Personal Information | Specific Types of Personal Information Collected |
| Identifiers (e.g., areal name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers) | We collect information such as your name, telephone number, social security number, and email addressfrom our client to begin the background screening process. We also may collect this information when you contact us and to create accounts for the background screening process. |
| Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | We may collect information such as your name, telephone number, company to which you are affiliated, and email address from you when you contact us on our website or from our client to begin the background screening process. We also may collect this information such as driver's license (or state identification card number), employment, employment history, criminal history, and other financial information (e.g., credit history) on you during the background screening process. |
| Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. | Some job applicants for non-profit entities may pay for their own background screening. All information used for this payment is entered after redirected to a third party, authorized.net, we do not store your information you give to authorized.net and you are subject to their privacy policy regarding this data. |
| Characteristics of protected classifications under California or federal law | Information may be collected that falls into protected classifications during the background screening process; however, The Cole Group does not inquire into or disseminate information related to a job applicant's physical and mental medical condition and medical history, impairments, diagnoses, family medical history, injuries, workers' compensation claims, civil rights, or personal injury lawsuits. |
| Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies) | We may collect this information (e.g., credit history) on you during the background screening process. |
| Biometric information | None |
| Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement) | In the event you contact us, your telephone call or email message may be recorded, and any other method of contact may be archived, for quality assurance purposes. We may track your IP address while on our Website for quality purposes as detailed in our Cookie Statement. We also may use your IP address to authenticate your signature on documents during the background screening process. |
| Geolocation data | We also may use your
location while signing documents during the background screening process to
authenticate your signature. |
| Audio, electronic,
visual, thermal, olfactory, or similar information | None |
| Professional or
employment-related information | We may collect this
information (e.g., employment history) on you during the background screening
process. |
| Education
information, defined as information that is not publicly available personally
identifiable information as defined in the Family Educational Rights and
Privacy Act (FERPA) | We may ask about your highest level of education completed during the background screening process and we may verify this information by requesting proof of a diploma from an educational institution you provide directly or using third parties such as National Student Clearing House. |
| Inferences drawn from many of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes | None |
| Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status | None |
| Contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication | None |
| Genetic data | None |
| Processing of biometric information to uniquely identifying a consumer | None |
| Health information | While we do not attempt to collect this information, if you send it to us during the background screening process it will be stored with your other information |
| Sex life or sexual
orientation | None |
If you do not provide personal information required to provide Our Products and Services to you, it may delay or prevent us from providing Our Products and Services to you.
3. How Your Personal Information is Collected. We collect personal information from the following categories of sources:
- You, directly in person, by telephone, text, or email and/or via our website (e.g., during an interview with you or from a form you fill out during the background screening process) including information we did not request that you send to us
- Cookies on our website placed by us and third parties, see our Cookie Notice
- From government agencies, former employers and financial institutions with your consent including employment history information, driving records, criminal history, and credit history, and
- Our IT and security systems, including:
- Automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email, and instant messaging systems
4. How and Why We Use Your Personal Information. Under data protection laws, we can only use your personal information if we have a proper reason for doing so. As described further in Section 5 below, when we need to share your personal information for limited reasons described in this Section 4, we only share your personal information (as necessary) with the third parties specified in Section 5. Some examples of how we use your personal information are as follows:
- To comply with our legal and regulatory obligations
- For the performance of our contract with you or to take steps at your request before entering into a contract (e.g., providing information to you on Our Products and Services prior to entering into an agreement for Our Products and Services)
- To generate a report at the end of the background screening process to be sent to our client to whom you applied for employment
- For our legitimate interests or those of a third party –or–
- Where you have given consent
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. The table below explains what we use (process) your personal information for and our reasons for doing so:
| What we use your personal information for | Our reasons |
| To prevent and detect fraud against you or The Cole Group | For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you |
| Gathering and providing information required by or relating to audits, inquiries, or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| Ensuring business policies are adhered to, e.g., policies covering security and internet use | For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you |
| Operational reasons, such as improving efficiency, improving Our Products and Services, training, and quality control | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
| Ensuring the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information
To comply with our legal and regulatory obligations |
| Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures | For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price |
| Preventing unauthorized access and modifications to systems | For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you.
To comply with our legal and regulatory obligations |
| Updating and enhancing customer records | To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products |
Marketing ou rservices and those of selected third parties to: - Existing and former customers
- Third parties who have previously expressed an interest in our services
- Third parties with whom we have had no previous dealings
| For our legitimate interests or those of a third party, i.e., to promote our business to existing and former customers as far as legally permitted. Otherwise, we only process your data if we have your consent. |
5. Who We Share Your Personal Information With. We routinely share personal information with:
- Our affiliates
- Other third parties we use to help us run our business, such as marketing agencies or website hosts
- Third parties approved by you (e.g., our clients in reports from background screening process as highlighted in Our Products and Services)
We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.
6. Personal Information We Sold or Shared. WE DO NOT SELL, RENT, OR TRADE YOUR PERSONAL INFORMATION TO THIRD PARTIES FOR THEIR COMMERCIAL PURPOSES.
7. Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we may have disclosed the following categories of personal information for a business purpose:
- Identifiers
- Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, telephone, email address, driver's license (or state identification card number), employment, employment history, criminal history, and other financial information (e.g., credit history) for Consumer Report(s)
- Professional or employment-related information such as employment history
- Commercial information such as credit history
- Internet or other electronic network activity information
- Professional or employment-related information
- Education Information
8. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing Our Products and Services to you. Thereafter, we will keep your personal information for as long as is necessary, unless you have consented for us to retain your personal information for longer:
- To respond to any questions, complaints or claims made by you or on your behalf
- To show that we treated you fairly –or–
- To keep records required by applicable national laws and/or regulations
We will not retain your personal information for longer than necessary for the purposes set out in this policy.
Different retention periods apply for different types of personal information.
When it is no longer necessary to retain your personal information, we will delete or anonymize it.
9. California Consumers: Your Rights Under the CCPA/CPRA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge. However, certain information covered under the federal Fair Credit Reporting Act (FCRA) may preempt these rights for that information. Information covered by the FCRA relates to information gathered in the background screening process. Additional information on the FCRA will be given to you at the beginning of the background screening process.
| Disclosure of Personal Information We Collect About You | You have the right to know, and request disclosure of: - The categories of personal information we have collected about you, including sensitive personal information
- The categories of sources from which the personal information is collected
- The categories of third parties to whom we disclose personal information, if any –and–
- The specific pieces of personal information we have collected about you
Please note that we are not required to: - Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained
- Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–
- Provide the personal information to you more than twice in a 12-month period
|
| Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose | In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know: - The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–
- The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose
You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information. |
| Right to Limit Use of Sensitive Personal Information | You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to: - Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
- To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, if the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) 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, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–
- As authorized by further regulations
You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. |
| Right to Deletion | Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: - Delete your personal information from our records –and–
- Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort
Please note that we may not delete your personal information if it is reasonably necessary to: - Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us
- Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes
- Debug to identify and repair errors that impair existing intended functionality
- Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law
- Comply with the California Electronic Communications Privacy Act
- Comply with the Federal law such as the FCRA
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent
- Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
- Comply with an existing legal obligation –or–
- Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information
|
| Right of Correction | If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information. |
| Protection Against Retaliation | You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things: - Deny goods or services to you
- Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
- Provide a different level or quality of goods or services to you –or–
- Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services
Please note that we may charge a different price or rate or provide a different level or quality of Our Products and Services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information. |
| Right to Non-Discrimination | You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA. |
10. Consumers in other States: Your Rights. Residents of the following states have similar rights as California Residents with differences highlighted below. As with California, certain information covered under the FCRA may preempt these rights for that information as discussed above.
| Colorado | Residents of Colorado are covered by the Colorado Privacy Act. The Colorado Privacy Act includes the rights under the CCPA/CPRA with the following differences. The right to opt-out of certain processing is limited to processing data for profiling and targeted advertising purposes. Consumers will be asked to opt-in prior to processing of sensitive data. |
| Connecticut | Residents of Connecticut are covered by the Connecticut Data Privacy Act, which tracks the Colorado Privacy Act. |
| Delaware | Residents of Delaware are covered by the Delaware Personal Data Privacy Act, which tracks the Colorado Privacy Act. |
| Indiana | Residents of Indiana are covered by the Indiana Consumer Data Protection Act, which goes into effect January 1, 2026. The Indiana Consumer Data Protection Act tracks the Colorado Consumer Data Protection Act. |
| Iowa | Residents of Iowa are covered by the Iowa Consumer Data Protection Act, which tracks the Colorado Privacy Act without the Right to Correct, the right to opt-out of certain processing, and the right to opt-in for sensitive data processing. |
| Kentucky | Residents of Kentucky are covered by the Kentucky Consumer Data Protection Act, which goes into effect January 1, 2026. Kentucky Consumer Data Protection Act tracks the Colorado Consumer Data Protection Act. |
| Maryland | Residents of Maryland are covered by the Maryland Online Data Privacy Act, which is effective 1 October 2025. The Maryland Online Data Privacy Act tracks the Colorado Privacy Act. |
| Minnesota | Residents of Minnesota are covered by the Minnesota Consumer Data Privacy Act, which tracks the Colorado Privacy Act. |
| Montana | Residents of Montana are covered by the Montana Consumer Data Privacy Act, which tracks the Colorado Privacy Act. |
| Nebraska | Residents of Nebraska are covered by the Nebraska Data Privacy Act, which tracks the Colorado Privacy Act. |
| New Hampshire | Residents of New Hampshire are covered by the New Hampshire Senate Bill 255, which tracks the Colorado Privacy Act. |
| New Jersey | Residents of New Jersey are covered by the New Jersey Senate Bill 332, which tracks the Colorado Privacy Act. |
| Oregon | Residents of Oregon are covered by the Oregon Consumer Privacy Act, which tracks the Colorado Privacy Act. |
| Rhode Island | Residents of Rhode Island are covered by the Rhode Island Data Transparency and Privacy Protection Act, which goes into effect January 1, 2026. The Rhode Island Data Transparency and Privacy Protection Act tracks the Colorado Consumer Data Protection Act. |
| Tennessee | Residents of Tennessee are covered by the Tennessee Information Protection Act. The Tennessee Information Protection Act tracks the Colorado Privacy Act. |
| Texas | Residents of Texas are covered by the Texas Data Privacy and Security Act, which tracks the Colorado Privacy Act. |
| Utah | Residents of Utah are covered by the Utah Consumer Privacy Act, which tracks the Colorado Privacy Act with a few exceptions. The Utah Consumer Privacy Act does not have a Right of Correction or an opt-in prior to processing of sensitive data. |
| Virginia | Residents of Virginia are covered by the Virginia Consumer Data Protection Act, which tracks the Colorado Privacy Act. |
11. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy you may also call us at toll-free phone number: (713)880-9494, or email us at privacy@thecolegroup.com.
- Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period. For other jurisdictions in the United States as listed above, the consumer has a right to request personal information be disclosed in a common file format at least once within the 12-month period.
- If you choose to contact us directly by website/email/phone/in writing, you will need to provide us with:
- Enough information to identify you
- Proof of your identity and address –and–
- A description of what right you want to exercise and the information to which your request relates
- We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
- Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.
12. Privacy Rights of Minors (Ages 13-15). We do not sell the personal information of individuals under the age of 16, between the ages of 13 and 15. We may share personal information of minors aged 13–15 with third parties only for limited ,non-commercial purposes, such as providing services on our behalf, complying with legal obligations, or protecting the security and integrity of our website. We do not permit third parties to use such personal information for their own commercial purposes. Children aged 13–15 have the same rights asother consumers under the applicable state law, subject to certain legal exceptions. Children in California under 16 must opt in to allowing their data to be sold. In Delaware, children under 18 must opt in for their data to be sold. We do not discriminate against individuals for exercising these rights. For more information or to exercise your privacy rights, please contact us using the information provided in the “Contact Us” section of this Privacy Policy.
13. Keeping Your Personal Information Secure. We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. While we have employed security technologies and procedures to assist safeguarding your personal information, no system or network can be guaranteed to be 100% secure.
14. Text Message Communications. By providing your mobile phone number to us (via our client you applied to for employment), you consent to receive text messages from us or our service providers regarding the background screening process. These text messages maybe sent using automated dialing systems. You understand that message and data rates may apply based on your mobile service plan, and you are responsible for any charges incurred. You may opt out of receiving text messages at any time by replying “STOP” to any text message you receive from us, or by contacting us using the methods provided in this policy. After opting out, you may continue to receive text messages for a brief period while your request is processed. Your consent to receive text messages is not a condition of the background screening process, and you may revoke this consent at any time without affecting the background screening process. Standard message frequency may vary based on your interactions with us and business needs.
15. Changes to This Privacy Policy. We may change this privacy policy from time to time–when we do, we will inform you via our website by updating the privacy policy on this page and change the data at the top of this page.
16. How to Contact Us. Please contact us by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you. Our contact details are shown below:
17. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).
