At FICO we are committed to providing you with analytic tools and decision management products and services to meet your needs. Our commitment includes protecting personally identifiable information we obtain about you when you register to use one of our websites or become our customer (“Personal Information”). We want to earn your trust by providing strict safeguards to protect your Personal Information. This Policy applies to members, customers, former customers, users, and applicants.
In the course of our business activities, FICO collects, processes, and shares Personal Information. U.S. law gives individuals the right to limit some but not all sharing. This Policy explains what Personal Information we collect, process, and share. We describe how we do so, and why. The Policy also describes your rights to access and correct your Personal Information in our possession; to limit sharing of your Personal Information under certain circumstances; and to file a complaint or dispute our processing of your Personal Information.
What Personal Information is Collected and Processed?
The types of Personal Information we collect and share depend on the product or service you have with us. This information may include, but not limited to, information from applications, questionnaires, and other forms you submit to us or our clients, such as your contact information (name, home address, email, and telephone number) and your date of birth, Social Security number, social insurance number, passport or other identification number, income, nationality, job title, your company’s name and industry sector, your company’s location (country, state and zip code). We also collect information from your transactions and interactions with us, such as your professional interests, or information you may provide via your interactions with our online forums, blogs, or participation in our online communities.
How is Personal Information Collected?
We collect information from applications, questionnaires, and other forms you submit to us. We may collect information from credit bureaus if it is necessary for the delivery of the services we provide you, and we may access public sources of information, such as census data and real estate records, and private source of information such as business bureau, industry analyst, or market research data. We do not permit other parties to collect Personal Information about your online activities over time and across different Web sites when you use our Web site or service.
In addition, we may use web-based tools when you visit our websites, such as “cookies” to track your online activities, including your registration, submissions, and information requests, in accordance with applicable law. Cookies are small text files placed by a website server on your computer or other device you are using to access the website. Sometimes we collect anonymous information about the pages you have viewed, which is used to assess the website’s performance and allows us to monitor and improve performance. Other cookies track your online activities on this website, including the IP address from which you accessed the website, and may link that information with Personal Information you have provided us through online registration, to help us remember your settings. We may also use your IP address to help diagnose problems with our server and to administer the website. The length of time we may keep a cookie on your device will depend on the nature of the cookie and the reason we have set it. We use “session” cookies, which expire when you close your browser and do not remain on your computer or device. We also use “persistent” cookies, which remain on your computer or device, and which are deleted when they are no longer necessary.
You may enable or disable cookies by using your browser; your web browser may be set to accept cookies automatically, but can be changed to decline them. The Help section of the toolbar on most browsers will tell you how to set your browser to prevent accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Why Do We Need Personal Information?
Collecting Personal Information is necessary for performance of the services and functionalities offered on the website. We use Personal Information to (i) register you with the website, (ii) provide you with requested information or services, and (iii) analyze and research improvements to the website, and our products and services. If you decline to provide the requested Personal Information, we may not be able to process your inquiry, provision access to certain functionality, or fulfill requests.
Disclosures of Personal Information
FICO may disclose Personal Information to third parties as required or permitted by law, under the following circumstances:
- We may collect, use, process, and transfer, in electronic or other form, your Personal Information by and among, as applicable, FICO and its affiliates for the purpose of implementing, administering, and managing your business relationship with FICO, provide the product or service you requested, to contact you in connection with product or service offerings, or for other legitimate business purposes.
- We may disclose certain Personal Information to companies, individuals, and other third party service providers with whom we contract to perform business functions and services on our behalf, as may be selected by FICO in the future. Such business functions may include hosting our web servers, analyzing data, providing legal, accounting and marketing services, and providing other support services.
- We may disclose certain Personal Information to other companies and individuals to help us market our products, including business partners in joint marketing agreements. We require all such parties to maintain the security and confidentiality of the Personal Information, and to process the data in accordance with our instructions.
- We may disclose Personal Information to the extent necessary or appropriate to government agencies, advisors, and other third parties in order to comply with applicable laws, or if such action is necessary to protect the rights or property of FICO or its affiliated companies.
The recipients of your Personal Information may be located in your country or elsewhere, and a recipient’s country (e.g., the United States) may have different data privacy laws and protections than your country. You may request a list with the names and addresses of any potential recipients of your personal data by contacting FICO, as described in this Policy. You may, at any time, view your personal data, request information about the storage and processing of it, require any necessary amendments to it, or refuse or withdraw the consents herein, in any case without cost, by contacting FICO in writing, as described in this Policy. Your personal data will be held only as long as is necessary to implement, administer and manage your business relationship with FICO.
Unless you tell us otherwise, FICO will assume with respect to the disclosures described above that you consent to these disclosures on a purely voluntary basis. If you do not consent, or if you later seek to revoke your consent, your then current status with FICO will not be affected; however, you understand that FICO may no longer thereafter be able to implement, administer, and manage your business relationship with FICO.
Other Uses of Personal Information; Your Right to Limit Our Sharing.
We may also from time to time use your contact information to send you information about FICO and marketing materials via telephone, automated email messages, and direct mail. These email messages may contain web beacons and other features that tell us you received and were able to open the message. We do not honor electronic do-not-track signals sent by your browser when you visit our site or other mechanisms that would give you the ability to exercise choice regarding the collection of Personal Information about your online activities over time and across third party Web sites. However, at any time you may opt out of receiving further email communications from us by clicking the unsubscribe link in the footer of all FICO email messages. You may also opt out of receiving any marketing solicitation from us, including email, direct mail, and phone solicitations, by calling us at 1.888.FICO.EDM (1-888-342-6336) at any time Monday through Friday.
Personal Data Security and Confidentiality
We have up-to-date physical safeguards, such as secure areas in buildings; electronic safeguards, such as passwords and encryption; and procedural safeguards, such as customer authentication procedures to prevent ID theft. We restrict access to information about you to only those employees who need to know that information to provide products or services to you. We carefully select and monitor outside service providers, such as mail vendors, who have access to customer information, and we require them to keep it safe and secure. We do not allow them to use or share the information for any purpose other than the job they are hired to do. We train our employees on these security procedures, and we conduct regular audits to check on compliance with the procedures.
The EU-U.S. Privacy Shield Framework and the U.S.-Swiss Safe Harbor Framework
FICO participates in the EU-U.S. Privacy Shield Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and Switzerland. FICO has committed to subject to the Principles of the Privacy Shield all personal data received from the EU in reliance on the Privacy Shield, including (1) notice; (2) choice; (3) accountability for onward transfer to third parties, for which FICO may be liable if we are responsible for the event giving rise to the damage; (4) security; (5) data integrity and purpose limitation; (6) access; and (7) recourse, enforcement and liability.
- Notice. We will notify you about the purposes for which we collect and use information about you. We will provide information about how you can contact us with any inquiries or complaints, the types of third parties to which we disclose the information and the choices and means you have for limiting its use and disclosure.
- Choice. We will not disclose your Personal Information to a third party for a purpose incompatible with the purpose for which it was originally collected, or subsequently authorized by you, without your consent. For sensitive information, we will get your explicit (opt in) consent if the information is to be disclosed to a third party or used for a purpose other than its original purpose or the purpose authorized subsequently by you. You may withdraw your consent at any time by contacting us as described in this Policy.
- Onward Transfer. If we transfer Personal Information to a third party that is acting as an agent, we will (i) transfer such data only for limited and specified purposes; (ii) ascertain that the agent is obligated to provide at least the same level of privacy protection as is required by the Principles; (iii) take reasonable and appropriate steps to ensure that the agent effectively processes the Personal Information transferred in a manner consistent with the organization’s obligations under the Principles; (iv) require the agent to notify the organization if it makes a determination that it can no longer meet its obligation to provide the same level of protection as is required by the Principles; (v) upon notice, including under (iv), take reasonable and appropriate steps to stop and remediate unauthorized processing; and (vi) provide a summary or a representative copy of the relevant privacy provisions of its contract with that agent to the Department of Commerce upon request.
- Security. We will take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data.
- Data Integrity and Purpose Limitation. We will collect and retain Personal Information that is relevant to the purposes of processing, and not in a way incompatible with the purposes for which it has been collected or subsequently authorized by you. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete, and current.
- Access. You will have access to Personal Information about yourself that we hold, and you may correct, amend, or delete that information where it is inaccurate, except where the burden or expense of providing access would be disproportionate to the privacy risks in question, or where the rights of persons other than you would be violated. For security reasons, FICO will take steps to authenticate your identity before providing you with access to Personal Information.
- Recourse, Enforcement and Liability. FICO will maintain a mechanism to provide that your complaints or disputes are investigated and resolved, and damages awarded where applicable law so provides. FICO will remedy problems arising out of its failure to comply with the Principles. If you believe FICO has violated its obligations to you under the Principles, you should first raise the claimed violation directly with us, and we will respond within 45 days of receiving a complaint. If we are unable to resolve your complaint, you should next raise the issue through your Data Protection Authority to the U.S. Department of Commerce and afford the Department of Commerce an opportunity to use best efforts to resolve the issue, at no cost to you. Then, if such violation still remains fully or partially unremedied, you may contact JAMS, which is an international dispute resolution provider, at no cost to you. JAMS may be reached by Internet at @jamsadr.com, phone 800.352.5267, or mail to JAMS, 18881 Von Karman Ave. Suite 350, Irvine, CA 92612. If you are contacting JAMS to lodge a complaint, you must include the following information: the name of company, the alleged privacy violation, your contact information, and whether you would like the particulars of your complaint shared with the company. For information about JAMS or the operation of JAMS’ dispute resolution process, contact Kathleen Pierz, JAMS Global Practice Development Manager, email@example.com, 212.607.2771. The JAMS dispute resolution process shall be conducted in English. For complaints and disputes over human resources data, FICO has agreed to cooperate with Data Protection Authorities.
FICO is subject to the investigatory and enforcement powers of the Federal Trade Commission and other U.S. authorized statutory bodies. FICO will disclose Personal Information to lawful requests by public authorities, including to meet national security or law enforcement requirements. To learn more about the EU-U.S. Privacy Shield and view the List of companies included in the Privacy Shield visit https://www.privacyshield.gov.
If you have a question about our privacy practices, or want to submit a complaint, contact us at:
Vance Gudmundsen, Privacy Officer
903 Falls Bridge Lane
Great Falls, VA 22066 USA
Email Address: firstname.lastname@example.org
Simon Elsom, Senior Director Legal
Cottons Centre 5th Floor
London SE1 2 QP
Email Address: email@example.com
Revisions to the Policy