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Privacy Policy

Effective December 31, 2021

INTRODUCTION

This policy of Solera Holdings, LLC. (referred to as “Solera”, “we”, “us” or “our”) explains our policy concerning the collection and processing of personal data, and tells you about your privacy rights and how the law protects you. Solera respects your privacy and is committed to protecting your personal data.

Solera Holdings, Inc. is part of an international group of companies providing services. Solera 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. Solera is part of the Solera group of companies. Other companies in the group may have their own privacy policy.

You can click through to the specific areas set out below.

  1. IMPORTANT INFORMATION AND WHO WE ARE
  2. THE DATA WE COLLECT ABOUT YOU
  3. HOW IS YOUR PERSONAL DATA COLLECTED
  4. HOW WE USE YOUR PERSONAL DATA
  5. DISCLOSURES OF YOUR PERSONAL DATA
  6. OUR ACTIONS OVER THE PAST TWELVE MONTHS
  7. DATA SECURITY
  8. YOUR LEGAL RIGHTS
  9. RIGHTS REQUESTS

1. IMPORTANT INFORMATION AND WHO WE ARE

CONTACT DETAILS

Solera Holdings, LLC.
Attn: Data Privacy Champion
1301 Solana Blvd, Bldg. 2, Suite 2100
Westlake, TX 76262
Email address: privacy@solera.com
Toll-free phone: 1 (855) 839-8020

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 supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns, so please contact us first.

Solera acts both as a controller and processor of personal data. For questions relevant to the EU, contact our data privacy champion, Marco Iriarte, at the address above. You may have a right to make a complaint to regulatory agencies about collection and use of personal data, but we would appreciate that you contact us first.

CHANGES. This privacy policy may be updated by us from time to time. We will provide the updated notice on our website and a summary of material changes. Please keep us informed if your personal data changes during your relationship with us. 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:

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 collect Special Categories of Personal Data about you, such as race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, criminal convictions and offenses 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?

We use different methods to collect data from and about you including through:

4. HOW WE USE YOUR PERSONAL DATA

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. We use personal data when necessary to perform contracts, provide you services and to comply with our legal obligations or form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you.

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.

We may provide additional notices to you of the purpose of and basis for collecting the data. In general, we collect information for purposes and on the basis shown below:

Purpose of CollectionLawful basis for processing
To provide services to you or your employerPerformance of a contract Our legitimate business interests
To manage payments and recover money owed to usPerformance of a contract Our legitimate business interests
To display interactive contentPerformance of a service or contract
To provide customer servicePerformance of a service or contract Our legitimate business interests (recording service provided) Comply with legal obligations
To enable you to participate in competitions and other marketing activityPerformance of a contract Our legitimate business interests (improve our services and analytics) Comply with legal obligations
Administer and protect our businessOur legitimate business interests Comply with legal obligations
Data analyticsOur legitimate business interests (to improve our products and services)
To make recommendations to you about goods and services that may be of interestOur legitimate business interests (to develop our products and services and grow our business)
To provide promotional offersTo fulfill your requests

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, warranty registration, 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:

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 collectedCategories of Sources of such Personal InformationPurpose for which the Personal Information was collectedCategories of third parties with whom the Personal Information is shared
Identification DataDirect interaction with you Customers for whom we provide services, and their agents Vendors who provide us services Other companies in the Solera groupProvide you or our customers with services Comply with legal obligationsCustomers 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
Financial DataDirect Interaction Use of our service Customers who use our services Vendors such as background check companiesProvide services to our customers Comply with legal obligations For internal business purposes such as fraud detectionVendors who provided us professional assistance such as lawyers and accountants Government and regulatory agencies
Commercial Transaction DataDirect Interaction Customers who use our servicesProvide our services Comply with legal obligationsVendors who provided us services Vendors who provided an element of our services
Vehicle DataDirect Interaction Customers who used our services Other companies in the Solera group Vendors who provide us servicesProvide services to our customers Comply with legal obligations AnalyticsCustomers 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
Biometric DataDirect Interaction Customers who used our servicesSecurity purposes such as tracking visitors to our offices Incidental to collection of photographs concerning claimsVendors providing the software or service that collects the data Vendors who provide us services such as security
Technical DataInteraction with devices that accessed our services Other companies in the Solera group Vendors who provide analytics and other servicesSecurity and troubleshooting To perform services To improve our products and servicesVendors who provide us services Customers of our services Other companies in the Solera group
Usage DataInteraction with our services Vendors who provide analytics and other servicesSecurity and troubleshooting To improve our products and servicesOther companies in the Solera group Vendors who provide us services including analytics
Geolocation DataDirect Interaction through our services Through content uploaded in our services From devices used by our employees and dedicated contractorsSecurity and fraud detection To provide services To improve our products and services To provide analyticsVendors who provide an element of our services Vendors who provide professional services such as security and fraud detection Other companies in the Solera group
Sensing DataDirect interaction through our contact centers Through devices used by our workforce and at our officesTo provide services Security and fraud detectionVendors who provide us services Other companies in the Solera group
Employment DataDirect interaction with our services Direct interaction with you Vendors who provide us servicesTo provide services Security and fraud detection To comply with legal obligations For human resourcesVendors who provide us professional services Customers of our services Other companies in the Solera group Government and regulatory agencies
Education DataDirect interaction with you Vendors who provide us servicesSecurity and fraud detection To comply with legal obligations For human resourcesVendors who provide us professional services Other companies in the Solera group Government and regulatory agencies
Inference DataThrough our services Direct interaction with youTo provide analytics To improve our products and servicesCustomers of our services Vendors who provide us professional services Other companies in the Solera group
Medical DataDirect interaction Employees Vendors providing services relating to employment benefits and obligationsProvide employee benefits and process claims Legal and regulatory obligationsVendors providing employment and benefits services Professional advisors such as insurers and lawyers
Marketing and Communications DataDirect interaction with you Customers for whom we provide services, and their agents Other companies in the Solera groupProvide you or our customers with services or information requested Comply with legal obligationsVendors 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 unauthorized 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.

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 to make a request.

European Union

Under certain circumstances, you have the right to:

DATA RETENTION: How Long Will You Use My Personal Data?

We will only retain your personal data for as long as necessary to fulfill 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 unauthorized 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.

NOTICE RE: INTERNATIONAL TRANSFERS: Personal Data may be transferred from the EU and Switzerland to the United States, Mexico, and India for processing.

Other Jurisdictions

You may have rights under data protection laws in relation to your personal data. Contact us for more information.

9. RIGHTS REQUESTS

If you wish to exercise any of the rights set out above, please contact us via the webform provided or through the contact information set out above.

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 policy; updated date and links to webform.

v.3. December 31, 2021 Reviewed notice; updated date; legal form “Inc.” replaced by “LLC”.