Privacy Policy of Explore Information Services, LLC
Effective December 31, 2019
INTRODUCTION
Explore Information Services, LLC and its
subsidiaries (herein referred to as “Explore”, “we”, “us” or “our”) understands
your concerns about privacy. We hope
that this policy, which describes our use and protection of personal data, will
help you (also called the “User”) understand how we treat the User Information
that we obtain from you or other sources in the course of providing you with
products and services. A User who
executes a services agreement with Explore is referred to herein as a “CLIENT”. This policy also tells you about your privacy
rights and how the law protects you. Explore
respects your privacy and is committed to protecting your personal data.
Our websites and services are not intended for use by minors under
the age of 16 and we do not knowingly collect data relating to children.
It is important that you read this privacy
policy together with privacy and other notices we may provide on specific
occasions when we are collecting or processing personal data about you so that
you are fully aware of how and why we are using your data. For example, there
are separate privacy notices for employees and job candidates. Those privacy notices supplement this policy. Explore is part of the Solera group of
companies. Other companies in the group
may have their own privacy policy.
1. IMPORTANT
INFORMATION AND WHO WE ARE
CONTACT DETAILS Explore Information
Services, LLC
Attn: Data Privacy Champion
2750 Blue Water Road, Suite 200
Eagan, MN 55121
Email:
explore.info@exploredata.com
website: https://exploredata.com/consumer-inquiries/
Our Data Privacy Champion has been appointed
to ensure that personal data is processed according to law and this
notice. In many jurisdictions, you have
the right to make a complaint at any time to a regulatory agency for data
protection issues or collection and use of personal data. We would, however, appreciate the chance to
deal with your concerns so please contact us first.
Explore acts as a service provider of
personal data to third parties, and as a Consumer Reporting Agency in
connection with some of those services.
CHANGES. This
privacy policy may be updated by us from time to time. We will provide the updated notice on our
website. We realize that it is important
that the personal data we hold about you is accurate and current.
THIRD-PARTY LINKS. Some
of our websites and services may include links to third-party websites,
plug-ins, and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for how they
process personal data. We encourage you
to read the privacy notice of every website you visit.
2. THE
DATA WE COLLECT
Personal data, or personal information, means
any information about an individual from which that person can be identified.
It does not include data where the identity has been removed, such as
de-identified or anonymous data. We
follow the law in each applicable jurisdiction in determining what constitutes
personal data.
We may collect, use, store, and transfer
different kinds of data which we have grouped together as follows:
·
Identification
Data such as a name,
alias, postal address, unique personal identifier, online identifier, email
address, account name, social security number, driver’s license number,
passport number, or other similar identifiers.
·
Commercial
Transaction Information such as records of
personal property, products or services purchased, obtained, or considered, or
other purchasing or consuming histories or tendencies.
·
Vehicle Data such as vehicle registration and licensure, vehicle identification
number, vehicle pictures, damage info and repair and maintenance records.
·
Technical Data such as internet protocol address, login data, browser type and
version, time zone setting, data on devices used to access a website, service
or application, browsing history, search history, and information regarding
interaction with an internet website, application, or advertisement.
·
Usage Data such as how you use our website or service.
·
Geolocation Data such as latitude and longitude for your location.
·
Employment
Information such as
information about employment or a profession.
·
Education Data such as information about education.
·
Inference
Data such as
information drawn from other information reflecting preferences,
characteristics, psychological trends, predispositions, behaviour, attitudes,
intelligence, abilities, and aptitudes.
·
Marketing
and Communications Data such
as your preferences in receiving marketing from us and our third parties and
your communication preferences.
We also collect, use, and share Aggregated
Data such as statistical or demographic data for any purpose. Aggregated
Data may be derived from your personal data but is not considered personal data
in law as it does not directly or indirectly identify you. For example,
we may aggregate Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data
with your personal data so that it can directly or indirectly identify you, we
treat the combined data as personal data which will be used in accordance with
this privacy notice.
We may collect Special Categories of Personal Data about
you, such as sexual orientation, criminal convictions and offences, but only
where required to provide services to you or our customers.
IF YOU FAIL TO PROVIDE PERSONAL DATA. Where we need to collect personal data by law, or under the terms of a
contract we have with you and you fail to provide that data when requested, we
may not be able to perform the contract we have or are trying to enter into
with you (for example, to provide you with goods or services). In this case, we
may have to cancel a product or service you have with us, but we will notify
you if this is the case at the time.
3. HOW IS DATA COLLECTED?
As a User browses through Explore’s websites (each, a “Site”),
Explore collects no personal information.
You are anonymous as you browse.
If a User is also a CLIENT the terms of the following paragraph apply to
CLIENT use of credentialed sites.
FOR OUR CLIENTS: Explore
does not collect identifying information in order to provide product overviews
on the Site so it does not share information with any other parties. Explore will collect logging information such
as what pages were viewed, what browser was used, and similar information to
help build and update the website. No
data related to the individual browsing the site is collected. Once a CLIENT is registered with Explore to
access any or all online offerings, Explore only collects personal information
required to provide the services requested by our CLIENTS, comply with data
retention requirements under applicable federal law, and prepare accurate and
appropriate billing statements. We treat
CLIENT’s identifying information securely and confidentially. We limit access to personal information to
only those persons who must have and are entitled to the information to provide
our products and services to our CLIENTS.
These persons are trained on the importance of safeguarding this
information and must comply with internal security procedures and applicable
law. We meet strict physical, electronic
and procedural security standards to protect personal information and maintain
internal procedures to maintain the safety of that information.
We want you to know that Explore respects your privacy and
protects your information. We do not
sell CLIENT information. We do not share
CLIENT information with persons, companies, or organizations that would use
that information to contact you or your customers about their own products or
services. Within Explore, we communicate
regarding the need to protect your information to those individuals who may
have access to it, and we’ve established safeguards to protect CLIENT
information.
We use different methods to collect data from and about you
including through:
•
Direct
interactions. You may
give us data by filling in forms or by corresponding with us by post, phone,
email, or otherwise. This includes data you provide when you:
•
apply for, inquire
about, or purchase our products or services;
•
create an account on
our website;
•
subscribe to our
service or publications;
•
request marketing to
be sent to you;
•
enter a competition,
promotion or survey; or
•
give us some
feedback.
•
Automated
technologies or interactions.
As you interact with our websites, we may automatically collect Technical, and
Usage Data among others about your equipment, browsing actions and patterns. We
may collect this personal data by using cookies, server logs, and other similar
technologies. A User may set their web
browser to refuse cookies or alert the User before accepting them. We may also receive Technical and Usage Data
among others about you if you visit other websites employing our cookies.
•
Customers. Customers who use our tools
and services may provide us personal data for use in those services.
•
Third parties or
publicly available sources. We may receive
personal data about you from third parties and public sources.
4. HOW WE USE YOUR
PERSONAL DATA
All information provided is treated as confidential. Explore does not, and will not, pass any
personal information collected through any Site to any other third party. We will only use your personal data when the
law allows us to. Most commonly, we will use your personal data in the
following circumstances:
•
Where
we need to perform the contract we are about to enter into or have entered into
with you.
•
Where it is necessary
for our legitimate interests (or those of a third party) and your interests and
fundamental rights do not override those interests.
•
Where we need to
comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a
legal basis for processing your personal data other than in relation to sending
third party direct marketing communications to you via email or text message.
You have the right to withdraw consent to marketing at any time by contacting
us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA.
Motor vehicle records and other reports used in underwriting
insurance or in employment have been identified as consumer reports. As such, use of these reports must comply
with, to the extent applicable: the Fair
Credit Reporting Act (FCRA), Driver’s Privacy Protection Act (DPPA) and the
Gramm-Leach-Bliley Act (GLB), amongst others.
As a consumer reporting agency, Explore strives to protect the privacy
of consumer information. By agreeing to
the Terms and Conditions of Explore’s Subscription Agreement CLIENTS agree to
not disclose consumer information to a third party. Explore does not sell personal or business
information for marketing or solicitation purposes.
You will receive marketing communications from us if you have
requested information from us or purchased goods or services from us or if you
provided us with your details when you entered a competition or registered for
a promotion and, in each case, you have not opted out of receiving that
marketing. We will get your express opt-in consent
before we share your personal data with any company outside the Solera group of
companies for marketing purposes.
- Legitimate business interest means the
interest of our business in conducting and managing our business to enable
us to give you and the market place the best service and products and the
best and most secure experience. We make sure to consider and balance any
potential impact on you (both positive and negative) and your rights
before we process your personal data for our legitimate interests. We do
not use your personal data for activities where our interests are
overridden by the impact on you (unless we have your consent or are
otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any
potential impact on you in respect of specific activities by contacting
us.
- Performance of Contract means
processing your data where it is necessary for the performance of a
contract to which you or your employer are a party or to take steps at
your request before entering into such a contract.
- Comply with a legal obligation means processing your data where it is necessary for compliance
with a legal or regulatory obligation that we are subject to.
OPTING OUT. You can ask us or third parties to stop
sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not
affect our processing of your personal data for other non-marketing purposes
such as providing a product or service to you, the product or service
experience, or other transactions.
COOKIES. You can make choices about what cookies collect
information on our websites. You may
be able to set your browser to refuse all or some browser cookies. If you disable or refuse certain cookies, some
parts of the website may become inaccessible or not function properly.
CHANGE OF PURPOSE. We will only use your personal data for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose. If you wish to
get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we
will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal
data without your knowledge or consent, in compliance with the above rules,
where this is required or permitted by law.
5. DISCLOSURES OF
YOUR PERSONAL DATA
We may share your personal data with:
·
Other
companies in the Solera group of companies who are involved in providing the service
or product or provide IT and system administration services and undertake
information reporting.
·
Our
customers who are providing services to you.
- Our service providers who provide IT and
system administration services.
- Our
professional advisers such as our lawyers, bankers, auditors, and
insurers.
- Government agencies that require
reporting of processing, financial, or transaction activities, but only as
required by law.
- Third parties to whom we may choose to
sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them.
If a change happens to our business, then the new owners may use your
personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your
personal data and to treat it in accordance with the law. We do not allow our
third-party service providers to use your personal data for their own purposes
and only permit them to process your personal data for specified purposes and
in accordance with our instructions.
6. OUR
ACTIONS OVER THE PAST TWELVE MONTHS
The following table provides additional information on the
personal information collected in the last twelve months:
Categories of Personal
Information collected
|
Categories of Sources of such
Personal Information
|
Purpose for which the Personal
Information was collected
|
Categories of third parties
with whom the Personal Information is shared
|
Identification Data
|
· Direct interaction with you
· Customers for whom we provide services, and their agents
· Vendors who provide us services
· Other companies in the Solera group
|
· Provide you or our customers with services
· Comply with legal obligations
|
· Customers for whom we are a service provider
· Vendors who provided us services
· Vendors who provided an element of our services
· Other companies in the Solera group
· Industry organizations who required it to provide
information used in our services
|
Commercial Transaction Data
|
· Direct Interaction
· Customers who use our services
|
· Provide our services
· Comply with legal obligations
|
· Vendors who provided us services
· Vendors who provided an element of our services
|
Vehicle Data
|
· Direct Interaction
· Customers who used our services
· Other companies in the Solera group
· Vendors who provide us services
|
· Provide services to our customers
· Comply with legal obligations
· Analytics
|
· Customers for whom we are a service provider
· Vendors who provided us services
· Vendors who provided an element of our services
· Other companies in the Solera group
· Government agencies who provide information required for
our services or for legal compliance
|
Technical Data
|
· Interaction with devices that accessed our services
· Other companies in the Solera group
· Vendors who provide analytics and other services
|
· Security and troubleshooting
· To perform services
· To improve our products and services
|
· Vendors who provide us services
· Customers of our services
· Other companies in the Solera group
|
Usage Data
|
· Interaction with our services
· Vendors who provide analytics and other services
|
· Security and troubleshooting
· To improve our products and services
|
· Other companies in the Solera group
· Vendors who provide us services including analytics
|
Geolocation Data
|
· Direct Interaction through our services
· Through content uploaded in our services
· From devices used by our employees and dedicated
contractors
|
· Security and fraud detection
· To provide services
· To improve our products and services
· To provide analytics
|
· Vendors who provide an element of our services
· Vendors who provide professional services such as security
and fraud detection
· Other companies in the Solera group
|
Inference Data
|
· Through our services
· Direct interaction with you
|
· To provide analytics
· To improve our products and services
|
· Customers of our services
· Vendors who provide us professional services
· Other companies in the Solera group
|
Marketing and Communications Data
|
· Direct interaction with you
· Customers for whom we provide services, and their agents
· Other companies in the Solera group
|
· Provide you or our customers with services or information
requested
· Comply with legal obligations
|
· Vendors who provided us services
· Other companies in the Solera group
|
7. DATA SECURITY
We have put in place appropriate security measures
to prevent your personal data from being accidentally lost, used or accessed in
an unauthorised way, altered, or disclosed. In addition, we limit access to
your personal data to those employees, agents, contractors, and other third
parties who have a business need-to-know. They will only process your personal
data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected
personal data breach and will notify you and any applicable regulator of a
breach where we are legally required to do so.
8. YOUR LEGAL RIGHTS
California
Under certain circumstances, you have the right to:
·
Request
disclosure of what
personal information the business collects, uses, discloses, or sells. You
make this type of request through the webform at http://exploredata.com, CCPA exercise
your rights
·
Request deletion of personal information collected or maintained by us. You must make this type of request through
the webform at https://exploredata.com,
CCPA exercise your rights. We will ask you to verify that you have
requested deletion of all or certain personal information.
·
Non-discrimination. Your exercise
of privacy rights conferred under the California Consumer Privacy Act (“CCPA”)
will not result in discriminatory treatment.
·
Use
an authorized agent. California law allows you to use an
authorized agent to make a request under CCPA on your behalf. You must provide us with written
documentation that the agent is authorized to act on your behalf or a power of
attorney. We may also contact you
directly to verify your identity.
NOTICE TO CA RESIDENTS: Where we receive valuable
consideration for the provision of personal data to third parties, we do so as
a service provider for a third party. We
do not sell information that identifies a person to other businesses. We have
not sold personal information within the last twelve months.
DATA RETENTION: How Long Will You Use My Personal Data?
In compliance with the law, Explore must retain a CLIENT’S
business identity and related reports use for a minimum of five years. Explore must be able to identify the end user
of a consumer report to federal or state jurisdiction and upon request will provide
the information to the requesting jurisdiction.
We will only retain your personal data for as long as necessary to
fulfil the purposes we collected it for, including for the purposes of
satisfying any legal, accounting, or reporting requirements. To determine the
appropriate retention period for personal data, we consider the amount, nature,
and sensitivity of the personal data, the potential risk of harm from
unauthorised use or disclosure of your personal data, the purposes for which we
process your personal data and whether we can achieve those purposes through
other means, and the applicable legal requirements.
Details of retention periods for different aspects of your
personal data are available in our retention policy which you can request from
us by contacting us. More specifically, and without limiting the generality of
the foregoing, by law we have to keep basic information about our customers for
at least 5 years after they cease being customers for tax, financial auditing,
and record keeping purposes.
We may anonymise your personal data (so that it can no
longer be associated with you) for research or statistical purposes in which
case we may use this information indefinitely without further notice to you.
Other Jurisdictions
You may have rights under data protection laws in relation to your
personal data. Contact us for more information.
9. RIGHTS REQUESTS
For general inquiries, please contact us at the Contact Information set
forth in Section 1 of this Policy or via the webform provided at https://exploredata.com/consumer-inquiries/. For California CCPA-related inquiries,
reference the California-specific information in Section 8 of this Policy.
We may need to request specific information
from you to help us confirm your identity and ensure your right to access your
personal data (or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any person who has no
right to receive it. If your request
provides an email address, or our records contain your email address, we may ask
you to verify your identity through such address. Where additional information is required, we
try to ask only information that can be corroborated through our records. We may also ask you for further information
in relation to your request to speed up our response.
You will not have to pay a fee to access your
personal data (or to exercise any of the other rights). However, we may charge
a reasonable fee if your request is clearly unfounded, repetitive, or
excessive. Alternatively, we may refuse to comply with your request in these
circumstances.
We try to respond to all legitimate requests within forty-five
days (or thirty days for residents in the EU). Occasionally it may take us longer. If so, we
will notify you and keep you updated. If we deny your request, we will explain the
basis for such denial. We will keep a
record of rights requests and responses for at least twenty-four months in a
log that will not be used for any purpose other than for record-keeping and
analytics.