PRIVACY POLICY & NOTICE: INTRODUCTION
IMPORTANT INFORMATION & WHO WE ARE
THE DATA WE COLLECT
HOW WE USE YOUR DATA
DISCLOSURES OF YOUR PERSONAL DATA
SECURITY
NOTICE REGARDING INTERNATIONAL TRANSFERS (US CERTIFICATION)
DATA RETENTION
YOUR PRIVACY CHOICES
JURISDICTION SPECIFIC INFORMATION
UNITED STATES
OTHER JURISDICTIONS
RIGHTS REQUESTS
OUR ACTIONS OVER THE PAST TWELVE MONTHS
NOTICE ABOUT PROCESSING OF DATA ON THIS SITE
DOCUMENT CHANGE HISTORY
PRIVACY POLICY & NOTICE: INTRODUCTION
Claims Services Group, APU Solutions, LLC (collectively referred to as "APU Solutions" "we,"
or "us") is part of the Solera group of companies. This Privacy Policy and Notice explains our policy
concerning the collection and processing of personal data and describes privacy rights and how the law
protects data subjects. We respect privacy and are 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 other notices we may provide on specific
occasions when we are collecting or processing personal data 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.
You can review specific sections of our policy by selecting a heading using the sidebar to the left or scroll
through our entire policy.
IMPORTANT INFORMATION & WHO WE ARE
CONTACT DETAILS
APU Solutions, LLC
1500 Solana Blvd, Bldg. 6, Suite 6300, Westlake, TX 76262 Email address: privacy@solera.com Toll-free phone:
+1 (855) 839-8020
CHANGES. This privacy policy may be updated from time to time. We will provide the updated policy 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.
THE DATA WE COLLECT
The types of personal data we obtain about you depends on how you interact with us and our products and
services. 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 anonymous
data. We follow the law in each applicable jurisdiction in determining what constitutes personal data. The
following are the categories and specific types of personal data that you provide to us directly or that we
collect automatically.
When you use our public websites such as the website where you accessed this policy: We may collect
Internet or other technical and usage data including but not limited to IP address, browsing history, and
referring websites. Some collection is through cookies. You may also choose to provide your contact
information for us to communicate with you about our products and services.
When you use our products or services including websites that require a log-in:
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, phone number, address, unique
identifiers, 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.
• Technical and Usage Data such as internet protocol address, login data,
browser type and version, data on devices used to access a website, service or application, browsing history,
and search history. how you use our website or service.
• Geolocation Data such as latitude and longitude of your location.
• Sensing Information such as audio, electronic, visual, thermal, olfactory, or
similar info.
• Employment Information such as work experience or profession
• Education Data such as information about schooling, training and professional
certifications
• Inference Data such as information drawn from other information reflecting
preferences, characteristics,
psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes.
• Medical Data such as information on health conditions and treatment.
• Marketing and Communications Data such as your preferences in receiving
marketing from us and third parties and your communication preferences.
• Vehicle Data such as vehicle registration and licence, vehicle identification
number, vehicle pictures, damage info and repair and maintenance records.
We also collect, use, and share data that is derived from personal data but does not identify a natural
person. For example, we may aggregate Technical and Usage Data to calculate the percentage of users accessing
a specific website feature or we may share data about vehicles as long as sharing such data does not identify
a natural person. However, if we combine or connect data that identifies a natural person, we treat the
combined data as personal data which will be used in accordance with this privacy policy. More information
may be provided with specific processing activities.
We collect Special Categories of Personal Data, such as precise geolocation, trade union membership,
criminal conviction and offenses, race or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, or political opinions, only where required to provide services or comply with a legal obligation.
For example, special categories of data may be processed for recruitment or employee benefit services. More
information will be provided in a Privacy Notice for the processing activity.
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 do not provide that data, we may not be able to enter into or perform a
contract with you. 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.
HOW WE USE YOUR DATA
Personal Information collected through our public websites such as the website where you accessed this
policy: We will use the personal data we collect to administer our websites, for internal operations,
data
analysis and to improve our websites. We may also use personal information for direct marketing or other
specific purposes made clear to you at the time you submit your personal information on our website. Our use
of your Personal Information may be based on our legitimate interests to ensure network, information security,
and business performance improvement. Our direct marketing purposes are based on your consent. We may also
rely on our legitimate interests to improve business and marketing practices or contact you to offer similar
Services or products that you may have bought from us, requested a demo, or negotiated with us.
Personal Information collected by our Products and Services including websites that require log-in: We
will
only use your personal data as permitted by law. Most commonly, 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 a legitimate interest 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 marketing communications.. 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 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 bases shown
below:
Purpose of Collection |
Lawful basis for processing |
To provide services to you or your employer |
Performance of a contract
Our legitimate business interests (to contact you in relation to a contract with your employer)
|
To manage payments and recover money owed to us |
Performance of a contract
Our legitimate business interests (to recover claims)
|
To display interactive content |
Performance of a contract |
To provide customer service |
Performance of a contract
Our legitimate business interests (to record service provided)
Comply with legal obligations
|
For marketing activity and to enable you to participate in competitions |
Performance of a contract
Our legitimate business interests (to improve our services and analytics)
Comply with legal obligations
Consent
|
Administer and protect our business |
Our legitimate business interests (to conduct and manage our business in a secure way and to give you
the best services and the best and most secure experience)
Comply with legal obligations
|
Data analytics |
Our legitimate business interests (to improve our products and services) |
To make recommendations to you about goods and services that may be of interest |
Our legitimate business interests (to develop our products and services and grow our business) |
To provide promotional offers |
In order to take steps at your request prior to entering into a contract
Consent
|
• Legitimate business interest means the interest of our business that does not
override your interests or fundamental rights and freedoms. We make sure to consider and balance any
potential impact on you (both positive and negative) and your rights before we process your personal data
for our legitimate interests. You can obtain further information about how we assess our legitimate
interests against any potential impact on you in respect of specific activities by contacting us.
• Performance of Contract means processing your data where it is necessary
for the performance of a contract to which you or your employer are a party or to take steps at your
request before entering into such a contract.
• Comply with a legal obligation means processing your data where it is
necessary for compliance with a legal or regulatory obligation that we are subject to.
MARKETING COMMUNICATIONS: 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 where required by law.
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 purpose that is compatible with the original
purpose. For an explanation, 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. We may process your personal data without your knowledge or consent as
permitted by law.
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
service or product or provide IT and system administration services and information reporting.
• Our customers who are providing services to you.
• Our service providers who provide IT and system administration services or product
support.
• Our professional advisers such as lawyers, bankers, auditors, and insurers.
• Government agencies, when required by law
• Third parties to whom we sell, transfer, or merge parts of our business or our
assets or where seek to acquire other businesses or merge with them. If a change happens to our business, the
new owners may use your personal data in the same way as set out in this privacy policy.
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.
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.
NOTICE REGARDING INTERNATIONAL TRANSFERS (US CERTIFICATION)
Personal data may be transferred from the country where it was collected to other countries where Solera's
group of companies operate. This means, for instance, that personal data may be transferred from the EEA, UK,
Switzerland, and Brazil to the United States, Mexico, and India for processing. Any transfers will be in
compliance with applicable law. We will be liable for onward transfers to third parties.
If the processing of your personal data is subject to data protection regulations concerning international
transfers, we will ensure that any international or onward transfer is consistent with applicable law such as
standard contractual clauses approved by an appropriate regulatory authority. We may also rely on an adequacy
decision of the regulatory authority such as the European Commission confirming an adequate level of data
protection in the jurisdiction of the party receiving the information.
We comply with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and
the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. We
have certified to the U.S. Department of Commerce that we adhere to the Data Privacy Framework Principles with
regard to the processing of personal data received from the European Union, the UK (and Gibraltar) and
Switzerland. If there is any conflict between the terms in this privacy policy and the relevant Data Privacy
Framework Principles, the Principles shall govern. To learn more about the Data Privacy Framework program, and
to view our certification, visit the U.S. Department of Commerce's Data Privacy Framework website. The U.S.
affiliates of Solera, namely Audatex North America, LLC, Claims Services Group, LLC, DealerSocket, LLC,
Distribution Service Technologies, LLC, DMEautomotive LLC, eDriving Fleet LLC, eDriving LLC, eDriving
Telematics LLC, Enservio, LLC, Explore Information Services, LLC, GTS Services, LLC, Hollander, LLC,
HyperQuest, LLC, Identifix, LLC, LYNX Services, LLC, Mobile Productivity, LLC, Omnitracs, LLC, RedCap
Technologies, LLC, Roadnet Technologies, Inc., SmartDrive Systems, Inc., Solera Merchant Services, LLC,
Spireon, Inc., Title Technologies, LLC, Transportation Performance, LLC, XRS Corporation, also adhere to the
EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data
Privacy Framework.
We commit to resolve DPF Principles-related complaints about our collection and use of your personal data.
EU and UK individuals and Swiss individuals with inquiries or complaints regarding our handling of personal
data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF
should first contact us via our web form. You have an option to invoke binding arbitration by delivering
notice to us and following the procedures and subject to conditions set forth in Annex I of the Data Privacy
Framework Principles.
We commit to cooperate and comply respectively with the advice of the panel established by the EU Data
Protection Authorities and the UK Information Commissioner's Office and the Swiss Federal Data Protection and
Information Commissioner with regard to unresolved complaints concerning our handling of personal data
received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).
DATA RETENTION
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.
YOUR PRIVACY CHOICES
You may opt not to disclose information to us. Some of your information, however, may be required in order to
use our products or services.
MARKETING COMMUNICATIONS. You can ask us to stop sending you marketing messages at any time. Opting
out of marketing messages will not affect our processing of your personal data for 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.
JURISDICTION SPECIFIC INFORMATION
You may have certain rights available to you when it comes to your personal information. Below is a summary
of those rights.
UNITED STATES
In some States, you may have certain rights when it comes to your personal data including:
• The right to access the personal data we have collected about you over the
last 12 months and the way we use and disclose your information and confirm our processing of your
information
• The right to request a copy of the personal data we have collected about you
• The right to delete data we have collected about you
• The right to correct the personal data we have collected about you
• The right to port or transfer a copy of the personal data we have collected
about you in a structured, commonly used and machine-readable format
• The right to opt-out of automated decision-making which significantly impact
your rights where a decision is made using an electronic system without human involvement. No decision will
be made by us about you solely on the basis of automated decision making which has a significant impact on
you
• The right to be free from discrimination for exercising your rights
(non-discrimination)
• The right to appeal our decision related to your rights request by sending us
an email marked "Appeal"
We do not currently respond to "Do Not Track" signals.
Under certain circumstances, California residents may also have right to use an authorized agent to make a
request under CPRA 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 REGARDING SALE & SHARING OF PERSONAL DATA FOR TARGETED ADVERTISING
In some states, residents have the right to opt-out of having their personal data sold or shared for targeted
advertising purposes. We do not sell or share personal information as defined under applicable data protection
laws and have not done so within the last 12 months.
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 fill out the webform
Exercise Your Rights. California residents may also contact us using the contact information above. See
Privacy Requests Statistics for how we
handle California privacy requests.
When you make a Rights Request, 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.
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.
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 service
• 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 service 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 provided us services
• Other companies in the Solera group
|
NOTICE ABOUT PROCESSING OF DATA ON THIS SITE
This notice explains how we collect and process personal data through your use of this website. This notice
should be read in conjunction with our Privacy Statement above and may be updated by us from time to time.
This site may collect personal data through cookies or other technology. You can make choices about what
cookies are allowed to collect and process information by clicking on the "Cookie Preferences" button at the
bottom of the website. This website may also offer you the opportunity to learn more about products by
providing your contact information through a webform. Any contact information you enter may be used to contact
you about our products and services. More information about processing personal data may be provided on
certain website pages.
DOCUMENT CHANGE HISTORY
December 2024: This is a new version of the Privacy Statement containing expanded information in all
sections, updated applicability, content information, a link to California Disclosure and links to the
webform.
|