Privacy Policy of Explore Information Services, LLC
Effective December 31, 2021
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.
CONTACT DETAILS
Explore Information Services, LLC
Attn: Data Privacy Champion
2750 Blue Water Road, Suite 200
Eagan, MN 55121
Email: [email protected]
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.
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:
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.
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:
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:
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.
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.
We may share your personal data with:
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.
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 |
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.
California
Under certain circumstances, you have the right to:
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 anonymize 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.
RESIDENTS OF NEVADA
Nevada residents have the right to opt out of the sale of their personally identifiable information. While we do not intend to sell personal information, Nevada customers have the legal right to opt out even if their information is not currently being sold. Use the webform at https://privacyportal-cdn.onetrust.com/dsarwebform/20bbc57b-6134-4535-8062-a1745b771851/f0bee87d-1bc8-4f1a-92c1-a52b1e0338f9.html to make a request.
Other Jurisdictions
You may have rights under data protection laws in relation to your personal data. Contact us for more information.
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.
DOCUMENT CHANGE HISTORY
Version Number | Version Date | Changes made from Previous Version |
v.1. | December 31, 2019 | — |
v.2. | December 31, 2020 | Reviewed notice; updated date and links to webform. |
v.3. | December 31, 2021 | Reviewed notice; updated date and “Residents of Nevada” Section added |