Collecting Personal Information
We collect Personal Information from applications, questionnaires, and other forms you submit to us, such as your name, contact information (address, email, and telephone number), income, job title, Social Security Number, company's name and location (country, state and zip code), and industry sector. We collect information from your transactions and interactions with us, such as your professional interests.
We may collect Personal 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 sources of information such as market research data. Note: this Web site may be hosted by a third party service provider on servers located in the United States.
When you visit this Web site we may collect and store, either directly or through the use of a third party tracking system, the IP address of the computer making the request (this may not be the IP address of your personal computer, but the IP address assigned to your Internet connection by your Internet service provider or company network); the URL that is being requested; the date and time of the request; the browser type and operating system used to make the request; and the referring URL. We also may collect aggregate search terms from search engine referrals to determine what information visitors are searching for when they find our Web Sites. We do not permit other parties to collect personally identifiable information about your online activities over time and across different Web sites when you use our Web site or service.
Web Beacons. Web beacons (sometimes called transparent GIFs, clear GIFs, or web bugs) are small strings of code that provide a way for us to deliver a small graphic image (usually invisible) on a web page or in an email. Web beacons can recognize certain types of information on your computer such as cookies, the time and date a page is viewed, and a description of the page where the web beacon is placed. We use web beacons to improve your experience on our Web Sites, including to provide you with content customized to your interests and to understand whether users read email messages and click on links contained within those messages so that we can deliver relevant content and offers. Our web beacons may collect some contact information (for example, the email address associated with an email message that contains a web beacon).
Decline Cookies. 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. Please note that if you decline to accept cookies, the functionality of myFICO and Free FICO Score Web sites will be very limited: you will not be able to log into your account or purchase products.
Using Personal Information
Personal Information collected from you is often necessary for the performance of the services and functionalities offered on the Web site. Information gathered from Web-based tools may be used to (i) administer and improve our Web Sites and your user experience, by gathering statistical information about how our Web site is used, and diagnosing any technical problems which may occur with our servers; and (ii) identify individual users who have registered for certain products, and track their online activities, including their registration, submissions, and information requests, in accordance with applicable law.
Send Offers. We use Personal Information to register you with the Web site and provide you with requested information or services. 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. 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. This Web site contains links to other Web sites: Fair Isaac is not responsible for the privacy practices or the content of other Web sites.
Use By Third Parties. If you submit Personal Information to us as part of a request to be contacted by a lender or lenders, we will supply your personal information to the lender(s), and one or more lender(s) will use the information you have provided to contact you regarding the specific product which you have requested. We do not have control over the use of your personal information once we provide it to the lenders, and we are not responsible for their privacy practices. Your rights with respect to their treatment of your information will be governed by their own policies.
FICO® Forums. If you choose to use the forum on this Web site, any information you submit there can be read, collected, or distributed to other users of this and other myFICO forums, and could be used to send you unsolicited messages.
Disclosing Personal Information
FICO may disclose Personal Information to third parties as required or permitted by law, under the following circumstances:
To companies in our corporate group as necessary or appropriate to provide the product or service you requested, to contact you in connection with product or service offerings, or for other legitimate business purposes;
To companies and individuals with whom we contract to perform business functions and services on our behalf, e.g., hosting our web servers, analyzing data, providing legal, accounting and marketing services, and providing other support services;
To financial service providers such as credit bureaus, insurance companies who help us market our products, including business partners in joint marketing agreements (CA residents: we will not disclose information about you to other financial service providers in joint marketing agreements, other than as required by law, unless you authorize us to do so), provided such parties maintain the security and confidentiality of the Personal Information, and process the data in accordance with our instructions;
To government agencies, advisors, and other third parties in order to comply with applicable laws, law (e.g., in response to subpoenas or government investigations), to assert or defend legal claims, and in order to investigate or respond to actual or suspected illegal activities, fraud, and threats of physical harm, or to protect the rights or property of FICO or its affiliated companies,
To carefully selected business partners (e.g., so they can alert you to valuable products and services;
To non-financial service providers, such as retailers, online and offline advertisers, non-profit organizations, and third parties when you direct us to share information about you: and
If FICO is in negotiations to be acquired by or merged with another company, or if the business of the Free FICO score or myFICO divisions of FICO is acquired by another company, to the acquiring company.
Your Opt-Out Choices
With respect to Personal Information, 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, but you have the ability to opt out of certain types of information sharing and communications. You may tell us not to:
Disclose information about you outside our corporate group of companies, except we may disclose information as required or permitted by law. Required disclosures are made, for example, to outside auditors and banking regulators. Permitted disclosures are made, for example, to vendors assisting us in opening, maintaining or servicing your account. (CA, ND, and VT Residents: We will not disclose information about you outside our corporate group of companies, other than as required or permitted by law, unless you authorize us to do so.) You may opt out of our disclosing this information by emailing SharingOptOut@FICO.com.
Disclose credit data (i.e., financial data we get from credit bureaus or from you that helps us determine your eligibility for credit) about you within our corporate group of companies; we do not disclose credit data outside our corporate group of companies. (VT Residents: We will not disclose credit information about you within our corporate group of companies, other than as required or permitted by law, unless you authorize us to do so.) You may opt out of our disclosing this information by emailing SharingOptOut@FICO.com.
Solicit you by mail, telephone or e-mail for products and services that are not directly related to your account and that are outside our regular communications with you (such as your monthly statement, customer service e-mails or when you call our customer service center). If you tell us not to solicit you, we will not disclose information about you within our corporate group of companies for that purpose. You may opt out of receiving these communications and information when you create your myFICO and/or free FICO score account by following the instruction for opting out of the communication programs. You may also opt out at any time by logging into your account at www.myFICO.com and/or www.FreeFICOScore.com, clicking on "Contact Preferences", and editing your preferences to opt out of the communication programs. If you receive an email from us you may opt out of further email communications by following the opt-out link contained in the email. (NV residents: you may also contact the Attorney General at 100 N Carson St. Carson City, NV 89701-4717 or by telephone at 775-684-1100.)
Please note that your decision to opt out will not apply to certain disclosures that are required for us to deliver the Products you have ordered or that are specifically permitted or required by law. For example, the Products cannot operate unless we transmit data to companies that help us provide the Products, such as by providing us with credit reports or processing credit card charges. Your general opt-out instructions also will not apply to specific disclosures or communications to which you consent.
Personal Information Access and Correction.
FICO will provide you access to Personal Information about you in accordance with applicable law, so you can correct or delete the Personal Information. You may have additional rights in non-U.S. countries, such as objecting to and blocking the processing of your Personal Information. For security reasons, FICO will take steps to verify your identity before providing you with access to Personal Information.
Personal Data Security and Confidentiality
We have up-to-date physical safeguards, such as secure areas in buildings; electronic safeguards, such as passwords, internal and external firewalls, and encryption; and procedural safeguards, such as customer authentication procedures to prevent ID theft. Information you provide to us when you register for and order our products is transmitted to us through a secure sockets layer (SSL) transmission. 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. Of course, you must do your part to ensure the security of your information. For example, you must guard your logon ID and password and not permit unauthorized use of your account. No security measures can provide absolute protection of data, but we will strive to provide a superior level of protection for your information.
Info Vault. Information you enter in the InfoVault feature of the Suze Orman FICO® Kit is
treated differently from other information we may collect from you. The InfoVault is intended for you
to store private information, including personally identifiable data regarding your accounts, contact
information, social security number, medical records, and other sensitive information that you decide
to store there. That information will be available to you on our site as long as your Suze Orman FICO®
Kit is active. It is your personal information and, notwithstanding anything to the contrary in this
third party without your consent or as required by law. However, we recommend that you be extremely
careful about the information you decide to store in the InfoVault.
The EU-U.S. Privacy Shield Framework and the Swiss-US. Privacy Shield Framework
FICO (including myFICO and FICO’s wholly owned subsidiary, Infoglide Software Corporation) participates in the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield 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.
1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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. You may, under certain conditions, invoke binding arbitration.
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