Privacy Policy of GTS Services, L.L.C.

Effective December 31, 2020 INTRODUCTION This policy of GTS Services, L.L.C. (referred to as “GTS”, “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. GTS 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. GTS 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

1. IMPORTANT INFORMATION AND WHO WE ARE CONTACT DETAILS GTS Services, L.L.C. Attn: Data Privacy Champion 1301 Solana Blvd, Bldg. 2, Suite 2100 Westlake, TX 76262 1-(833)-950-1969 Email address: privacy@solera.com 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. 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:

• 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.
• Financial Data such as bank account, credit card and debit card numbers, and other financial information.
• 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 information and repair and maintenance records.
• Biometric Data such as fingerprints, DNA, pictures of people, and physical characteristics.
• 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.
• Sensing Information such as audio, electronic, visual, thermal, olfactory, or similar info.
• 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, behavior, attitudes, intelligence, abilities, and aptitudes.
• Medical Data such as information on medical conditions and treatment.
• 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 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). For example, we may have to cancel a product or service you have with us, but we will notify you at the time.  

 

3. HOW IS DATA COLLECTED? 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 services 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. 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 We will only use your personal data where the law allows. In most instances, 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. 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 instance, 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, 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 th website may become inaccessible or not function properly. 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 services or products 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
Financial Data	·  Direct Interaction   ·  Use of our services   ·  Customers who use our services   ·  Vendors such as background check companies	·  Provide services to our customers ·  Comply with legal obligations ·  For internal business purposes such as fraud detection	·   Vendors who provided us professional assistance such as lawyers and accountants ·   Government and regulatory agencies
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
Biometric Data	·  Direct Interaction   ·  Customers who used our services	·  Security purposes such as tracking visitors to our offices ·  Incidental to collection of photographs concerning claims	·   Vendors providing the software or services that collects the data ·   Vendors who provide us services such as security
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
Sensing Data	·  Direct interaction through our contact centers   ·  Through devices used by our workforce and at our offices	·  To provide services ·  Security and fraud detection	·   Vendors who provide us services ·   Other companies in the Solera group
Employment Data	·  Direct interaction with our services   ·  Direct interaction with you   ·  Vendors who provide us services	·  To provide services ·  Security and fraud detection ·  To comply with legal obligations ·  For human resources	·   Vendors who provide us professional services ·   Customers of our services ·   Other companies in the Solera group ·   Government and regulatory agencies
Education Data	·  Direct interaction with you   ·  Vendors who provide us services	·  Security and fraud detection ·  To comply with legal obligations ·  For human resources	·   Vendors who provide us professional services ·   Other companies in the Solera group ·   Government and regulatory agencies
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
Medical Data	·  Direct interaction   ·  Employees   ·  Vendors providing services relating to employment benefits and obligations	·  Provide employee benefits and process claims ·  Legal and regulatory obligations	·   Vendors providing employment and benefits services ·   Professional advisors such as insurers and lawyers
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 provide 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.  

 

8. YOUR LEGAL RIGHTS RESIDENTS OF CALIFORNIA (CA) Under certain circumstances, you have the right to:

• Request disclosure of what personal information the business collects, uses, discloses, or sells.
• Request deletion of personal information collected or maintained by us. You must make this type of request through the webform. 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. 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 to make a request. APPLICABLE TO THE EUROPEAN UNION Under certain circumstances, you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third-party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

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.

 

RIGHTS REQUESTS If you wish to exercise any of the rights set out above, please contact us via the webform 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 a 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 for 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.