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Home  /  Privacy Policy


PRIVACY POLICY


YOUR PRIVACY IS IMPORTANT TO US – PLEASE FAMILIARIZE YOURSELF WITH OUR POLICY.




FICO PRIVACY POLICY

 

In the course of our business operations, we collect, use, and disclose personal
data (also referred to as “personal information”) about individuals, including
those who become our customers, might be interested in our products, visit our
websites, use our mobile applications, or otherwise interact with our business.
We also process personal data for other companies. When we process personal data
on our own behalf this privacy policy applies. When we process personal data on
behalf of another company, that company’s privacy policy applies.   

 

TABLE OF CONTENTS

Our Business

How We Use and Collect Personal Data

Our Disclosure of Personal Data

Your Rights

Exercising Your Rights

How We Protect Your Personal Data

How Long We Keep Your Personal Data

EU-US Data Privacy Framework, UK Extension to the EU-US DPF and the Swiss-US
DPF.

California Information Sharing Disclosure

Contacting Us

Changes to This Policy

 

 

OUR BUSINESS

This section provides a general overview of our business. FICO has two lines of
business—Scores and Software.

Scores includes our business-to-business operations through which we license to
consumer reporting agencies and other third-party businesses the right to use
our analytic models, including those that generate the well-known FICO® Scores.
For example, consumer reporting agencies apply our analytic models to consumer
report information they assemble and maintain and then calculate and distribute
the output FICO Scores to third parties such as lenders. FICO is not a consumer
reporting agency and does not calculate and distribute FICO Scores to third
parties. When a third-party business uses our analytic models to process
personal data such as consumer reports to calculate FICO Scores, we are acting
as a service provider and the third party’s privacy policy applies. Scores also
includes myFICO, our direct-to-consumer business, which is based in the U.S. and
offers free and paid informational and educational content designed for U.S.
consumers only. If you are a myFICO customer, we may obtain your credit report
or FICO Score from a consumer reporting agency at your direction and on your
behalf. This policy applies to our collection, use, and disclosure of your
personal data if you are a myFICO customer.

Software consists entirely of business-to-business operations through which we
license to third party businesses the rights to use our proprietary software
solutions and in some cases provide associated professional services. These
software solutions may contain analytic models. Companies use our software
solutions for their own business purposes. Some of our solutions are
operational: these solutions are used by companies for their resource planning,
financial projections, and record-keeping, for example. Other solutions are used
by companies to facilitate the processing of personal data of their consumers or
other individuals. These include solutions designed to be used by companies for
a wide range of commercial purposes, including new customer acquisition, credit
and insurance eligibility, account management, customer management and
communications, and financial fraud detection and prevention. We sometimes
deliver our software solutions to third party businesses for installation
locally in their facilities or environment and we sometimes host these software
solutions for them in our cloud platform. When a third-party business uses our
software solutions to process personal data relating to their consumers or other
individuals, we are acting as a service provider, and the third party’s privacy
policy applies.

It is our general practice to collect and use only depersonalized data that
cannot be reasonably linked to an individual person (i.e., deidentified,
anonymized, or aggregated data) when developing, validating, and updating our
analytic models and our software solutions. We will not attempt to
re-personalize (or reidentify) any such depersonalized data.

 

 

HOW WE USE AND COLLECT PERSONAL DATA

ContextTypes of DataPrimary Purpose for Collection     
and Use of DatamyFICO account registration and subscriptionIf you create an
online account with myFICO, we collect your name and contact information,
including your address, phone number, and email address, and the account
password you create. We also collect your Social Security number and date of
birth to process your request to obtain a credit report and FICO® Score from a
consumer reporting agency. If you subscribe to a paid myFICO plan, we collect
your billing address and credit card number. We may also collect information
relating to the actions that you perform while logged into your account.We have
a legitimate interest in providing account related functionalities to
individuals who create a myFICO account. We also use the information to fulfill
our agreement with those who have myFICO accounts to provide them with requested
educational and informational content (e.g., to provide them with access to
their credit reports and FICO® Scores), to authenticate identity, and to process
payments.FICO Analytic Cloud or FICO Community account registrationIf you create
an online account with FICO Analytic Cloud or FICO Community, we collect your
name and contact information, including email address, and the account password
you create.We have a legitimate interest in providing account related
functionalities to individuals who create a FICO Analytic Cloud or FICO
Community account. We also use the information to authenticate the identity of
those who have an account and to provide them with information they request
regarding our products and services.Business client informationWe collect the
name and contact information of our clients and their employees with whom we
interact.We have a legitimate interest in contacting our clients and
communicating with them concerning normal business administration such as
projects, services, and billing. We use this personal data to perform our
contract to provide products or services.Cookies and first-party trackingWe use
cookies and other types of tracking technology to improve the performance of our
website, remember visitor preferences and order selections, and to analyze
website behaviors.We have a legitimate interest in understanding the use of our
websites and to make our website operate efficiently and improve user
experience.Cookies and third-party trackingWe may place tracking technology on
our website that collects analytics, records how you interact with our website,
or allows us to participate in behavior-based advertising. This means that a
third party uses technology (e.g., a cookie) to collect information about your
use of our website so that they can report analytics to us or allow us to
provide advertising about products and services tailored to your interests. At
this time, FICO does not respond to the “do not track” header.We use this
information to provide advertising about our products and services based on the
interests of users of our websites. Where required by law, we base the use of
third-party cookies upon consent.Events related informationIf you attend a FICO
hosted or sponsored event, we may collect information about you such as your
name, employer, contact and registration details, sessions attended, and
preferences.We have a legitimate interest in using information that we collect
to administer our events. Where required by law, we may ask for your consent if
we intend to share your personal information with a third party (e.g., an event
sponsor) for their marketing purposes.Online forumsWe may provide online forums,
including myFICO forums for those with myFICO accounts and FICO Community forums
for those with FICO Analytic Cloud accounts, where individuals can post
information or comments. Such information may be publicly available or viewable
to other forum members, and may include name, contact information, and the
substance of any comments depending upon the forum.We have a legitimate interest
in offering discussion forums to the public and to businesses that use or are
interested in using our products or services.Job applicant informationIf you
apply for a job with us, we collect information necessary to process your
application. Providing this information is required to be considered for
employment.We use information about job applicants to make employment decisions.
In some contexts, we are also required by law to collect information about
applicants. (If you become an employee of FICO, you will be provided with a
separate privacy notice which addresses our use and collection of employee
data.)Feedback/     
supportIf you provide us feedback or contact us for support, we will collect
your name and email address, as well as any other content that you send to us,
in order to reply.We have a legitimate interest in receiving and responding to
your feedback or issues to make improvements to, and support your use of, our
website, products, and services. If you use our chat functionality, you will be
interacting with an automated technology and your chat session may be
recorded.Mobile devicesWe collect information from your mobile device such as
unique identifying information broadcast from your device when visiting our
mobile application or when visiting our website.We have a legitimate interest in
identifying unique visitors and in understanding how users interact with our
mobile application.Website interactionsWe use technology, including weblogs, to
monitor how you interact with our website. This may include collecting
information such as your browser type, operating system, Internet Protocol (IP)
address, click-activity, referring website, and/or a date/time stamp for
visitors.We have a legitimate interest in providing functionality of the
website, understanding how you interact with our website to better improve it,
and to detect and prevent fraud.MarketingWe may collect information from you or
from third parties about individuals that may be interested in our products or
services. This may include name, email address, job title, and other employment
information (e.g., name of employer).Where required by law, we receive consent
before using personal data for marketing.Visiting our office locationsWe may
collect information from you if you visit our physical office locations. This
may include your name, contact information, employment information, as well as
video surveillance.We have a legitimate interest in understanding who visits our
offices for security purposes.

 

In addition to the purposes and uses described above, we use personal data in
the following ways:

 1.  To identify you when you visit our websites or mobile application.
 2.  To provide products, services, and subscriptions.
 3.  To improve our websites, services, and product offerings.
 4.  To streamline the processing of transactions.
 5.  To conduct analytics.
 6.  To communicate with you, such as to respond to and/or follow-up on your
     requests, inquiries, issues, or feedback.
 7.  To detect and protect against malicious, deceptive, fraudulent, or illegal
     activity, including violation of our policies and terms and conditions,
     security incidents, and harm to the rights, property, or safety of our
     company and our users, employees, or others.
 8.  To debug, identify, and repair errors that impair existing intended
     functionality of our websites and mobile applications.
 9.  To comply with our legal or regulatory obligations, to establish or
     exercise our rights, and to defend against a legal claim.
 10. For internal administrative purposes, as well as to manage our
     relationships.
 11. For such other purposes as you may consent (from time to time).

This policy does not apply to the following:

 1. Our collection, use, or disclosure of depersonalized data.
 2. Other websites not owned or operated by FICO that are linked on a FICO
    website. In such situations, the privacy notice of the third-party website
    applies. FICO is not responsible for the privacy practices or the content of
    such third-party websites.
 3. Our collection, use, or disclosure of personal data on behalf of a
    third-party business. In such situations, the privacy notice of the
    third-party business applies.

 

 

OUR DISCLOSURE OF PERSONAL DATA

In addition to the sharing described in the previous section, we may disclose
your personal information to the following third parties:

A.  Service Providers (vendors, contractors, distributors)

We disclose personal data to our service providers who provide technical,
operational, or administrative support.

B.   Affiliates and subsidiaries

We disclose personal data among FICO affiliates and subsidiaries for the purpose
of implementing, administering, and managing your business relationship with
FICO, to provide the product, service, or other content you requested, to
contact you in connection with product or service offerings, or for other
legitimate business purposes.

C.  Regulators and law enforcement

We disclose personal data to government agencies, advisors, and other third
parties where required and appropriate to comply with applicable laws or protect
the rights or property of FICO and its affiliated companies, or its customers.
For example, we may disclose personal data to comply with civil, criminal, or
regulatory inquiries, investigations, subpoenas, or summons by federal, state,
or local authorities. We may also disclose personal data in cooperation with law
enforcement agencies concerning conduct or activity that we reasonably and in
good faith believe may violate federal, state, or local law.

D.  Corporate acquisitions and divestitures

If another company acquires or plans to acquire, or if we divest or plan to
divest to another company, all or part of FICO’s business or assets, we will
share personal data with that company, including at the negotiation stage.

E.   Other third parties

We may disclose your personal data to other third parties when necessary and
appropriate and in accordance with applicable privacy laws.

 

 

YOUR RIGHTS

In some jurisdictions you may have the following rights regarding your personal
data.  Please see the Exercising your rights section of this policy for further
information on how to submit a rights-related request if applicable to you. Note
that we do not discriminate against individuals that exercise statutorily
conferred privacy rights.

A.  Right to delete your personal data

You may have a right to request that we delete any personal data about you that
we have collected from or about you.

B.   Right to access or correct your personal data

You may have the right to ask us to disclose the categories or specific pieces
of personal data that we have collected about you. In certain limited
circumstances, you may also request to receive access to your data in a
portable, machine-readable format.

You may also have the right to ask us to make corrections to your personal data.
If you maintain an online account with us (e.g., an account with myFICO, FICO
Analytic Cloud, or FICO Community) or have otherwise registered with our
websites or to participate in our forums or receive marketing materials from us,
you can usually update your personal data yourself by accessing your account
profile. If you are unable to update your information yourself, you may submit a
request as described below in the Exercising your rights section of this policy.

C.   Revocation of consent and/or objection to certain processing

You may revoke consent to process your personal data or object to our processing
of your personal data, by submitting a request as described below in the
Exercising your rights section of this policy.        

D.   Update or opt out 

If you have registered with us to participate in industry discussions and/or
receive marketing and industry materials you may update your preferences or
unsubscribe at any time by clicking the unsubscribe link in the footer of FICO
email messages, or by submitting a request as described below in the Exercising
your rights section of this policy.

E.  Right to file a complaint. 

You may have a right to file a privacy complaint with us and/or with a
government agency. You may submit a complaint by contacting us as described
below in the Exercising your rights section of this policy.

 

 

EXERCISING YOUR RIGHTS

You can request to exercise your rights described above in the Your rights
section, if applicable to you, by taking the following actions. We honor such
requests where required to do so by law.

 * If you have a current account with FICO (e.g., an  account with myFICO, FICO
   Analytic Cloud, or FICO Community), you may request to exercise your rights
   by contacting us through the FICO Trust Center, using the options provided in
   the Manage your Privacy Preferences section. For your protection when you
   request deletion, access, or correction, we will expect you to verify your
   identity by accessing your password-protected account.
 * If you do not have a current account with FICO, but you have interacted with
   FICO online or offline, or otherwise have a privacy concern, you may request
   to exercise your rights by contacting us through the FICO Trust Center, using
   the options provided in the Manage your Privacy Preferences section. We will
   provide the information you request by mail or electronically at your option,
   and to the extent reasonable and technically feasible we will provide the
   information in a portable and readily useable format. For your protection
   when you request deletion, access, or correction, we will expect you to
   verify your identity.
 * If we receive from you a request relating to personal data that we maintain
   in our capacity as a service provider on behalf of another company, we will
   deny your request.
 * You may designate an authorized agent to make a request to exercise your
   rights on your behalf, but we will require that (i) you provide the
   authorized agent written permission to do so; and (ii) you verify your
   identity directly with us.

If you are unable to submit or resolve your request to exercise your rights
through the FICO Trust Center, you may also make your request by contacting as
described below in the Contact us section of this policy.

 

 

HOW WE PROTECT YOUR PERSONAL DATA

FICO uses reasonable safeguards to protect your personal data, including
physical safeguards, such as secure areas in buildings; electronic and
technological safeguards, such as passwords and encryption; and procedural
safeguards, such as customer authentication procedures designed to help prevent
ID theft. We restrict access to your personal data to only those employees who
need to know that information to provide products, services, or other content to
you.

Some of our websites permit you to create an account. When you do so, you will
be prompted to create a password. You are responsible for maintaining the
confidentiality of your password, and you are responsible for any access to or
use of your account by someone else that has obtained your password, whether or
not such access or use has been authorized by you. You should notify us of any
unauthorized use of your password or account.

While we use reasonable efforts to protect your personal data from unauthorized
access, use, or disclosure, no method of transmission over the Internet, or
method of electronic storage, is fully secure, and we cannot guarantee the
security of your personal data. In the event we are required to inform you of a
breach to your personal data we may notify you electronically, in writing, or by
telephone, if permitted to do so by law.

 

 

HOW LONG WE KEEP YOUR PERSONAL DATA

Your personal data will be held only as long as necessary to fulfill the
purposes outlined in this policy, unless a longer time period is required or
permitted by law.

 

 

EU-US DATA PRIVACY FRAMEWORK, UK EXTENSION TO THE EU-US DPF AND THE SWISS-US
DPF.

FICO complies 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. FICO has
certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data
Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the
processing of personal data received from the European Union in reliance on the
EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK
Extension to the EU-U.S. DPF. FICO has certified to the U.S. Department of
Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles
(Swiss-U.S. DPF Principles) with regard to the processing of personal data
received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any
conflict between the terms in this privacy policy and the EU-U.S. DPF Principles
and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more
about the Data Privacy Framework (DPF) program, and to view our certification,
please visit https://www.dataprivacyframework.gov/.

FICO uses Standard Contractual Clauses approved by regulatory authorities in the
EU, UK, and Switzerland where required for such transfers and does not rely
solely on the Data Privacy Framework Principles. Our certification with the U.S.
Department of Commerce and the DPF Principles can be viewed at this website
https://www.dataprivacyframework.gov/s/.

If you are an EU, UK, or Swiss individual and believe we have violated our
obligations to you under the Data Privacy Framework, you may submit a complaint
directly with us through the FICO Trust Center, using the options provided in
the Manage your Privacy Preferences section, and we will respond within 45 days.
You may also raise your complaint with your Data Protection Authority which may
refer your complaint to the U.S. Department of Commerce to work with us on a
resolution, at no cost to you. If you still have an unresolved complaint that we
have not addressed satisfactorily, you may lodge a complaint with JAMS, which is
an international dispute resolution provider, at no cost to you, at
https://www.jamsadr.com/file-a-dpf-claim For information about JAMS and its
dispute resolution process, you may contact JAMS at
https://www.jamsadr.com/dpf-dispute-resolution. If your complaint remains
unresolved after the JAMS dispute resolution process, you may, under certain
conditions, invoke binding arbitration through the DPF. Additional information
on how to submit a complaint or pursue binding arbitration is available on the
DPF website at
https://www.dataprivacyframework.gov/s/article/How-to-Submit-a-Complaint-Relating-to-a-Participating-Organization-s-Compliance-with-the-DPF-Principles-dpf.

With respect to the Data Privacy Framework, FICO is subject to the regulatory
enforcement powers of the U.S. Federal Trade Commission.

 

 

CALIFORNIA INFORMATION SHARING DISCLOSURE

For California residents, California requires that we disclose specific
categories of personal data that we collect, and the types of entities with whom
we share it. The chart below includes the “sensitive” personal information that
we collect under California law, such as Social Security number and credit card
number for myFICO customers. The purposes for that collection are described in
the first section of this policy. Because we collect different personal data
from different people depending on the context and the applicable part of our
business, information discussed below may not specifically apply to you. Please
also note, in addition to the recipients identified below, we may disclose any
of the categories of personal data we collect with government entities or other
third parties as required to comply with law or prevent illegal activity. We do
not sell personal data and have not sold personal data during the last 12
months. For details regarding how we use personal data, please see the How we
use personal data section of this policy. For information regarding how long we
retain personal data, please refer to the How we protect your personal data
section and the How long we keep your personal data section of this policy.

Category of personal data we collectCategory of recipients     
Disclosures for a business purposeIdentifiers – this may include name, alias,
postal address, unique personal identifier, online identifier, email address,
account name, or other similar identifiers.

Affiliates or subsidiaries

Data analytics providers

Internet service providers

Operating systems and platforms

Other service providers

Payment processors and financial institutions

Professional services organizations, this may include auditors and law firms

Social networks

Government issued identification – this may include social security number
(e.g., as part of myFICO), driver’s license number, or state issued
identification number, passport number.

Affiliates or subsidiaries

Other service providers

Financial information – this may include bank account number, credit card
number, debit card number, and other financial information.  For example, we may
collect this information if you are a myFICO customer.

Affiliates or subsidiaries

Other service providers

Payment processors and financial institutions

Characteristics of protected classifications – this may include age if you have
a myFICO account and we collect your date of birth.

Affiliates or subsidiaries

Other Service Providers

Commercial information – this may include information about products or services
purchased, obtained, or considered, or other purchasing or consuming histories
or tendencies.

Affiliates or subsidiaries

Data analytics providers

Other service providers

Internet or other electronic network activity information – this may include
browsing history, search history, and information regarding an individual’s
interaction with an internet website, application, or advertisement.

Affiliates or subsidiaries

Data analytics providers

Internet service providers

Operating systems and platforms

Other service providers

Audio, electronic, visual, thermal, olfactory, or similar information

Affiliates or subsidiaries

Other service providers

Professional or employment-related information (e.g., if you apply for a job)

Affiliates or subsidiaries

Payment processors and financial institutions

Other service providers

Inferences drawn from any of the information listed above

Affiliates or subsidiaries

Data analytics providers

Other service providers

Additional categories of personal information described in
the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this may
include signature.

Affiliates or subsidiaries

Other Service Providers

 

 

CONTACTING US

If you have a question about our privacy policy or practices, or want to submit
a complaint, you may contact FICO’s Privacy Team through the FICO Trust Center.
We have appointed EU Rep as our Representative under Article 27 of the EU
General Data Protection Regulation (“GDPR”). GDPR queries from EU Data Subjects
or Data Protection Authorities should be addressed to EU Rep at
privacy@eurep.ie. The registered office for EU Rep is: BizLegal Ltd trading as
EU Rep, 27 Cork Road, Middleton Co. Cork, Ireland. The company number is:
635921.

You may also contact the FICO Privacy Team at the following:

United States     
Vickie Miller, Data Protection Officer     
181 Metro Drive     
San Jose, CA 95110     
Tel. (858) 369-8101     
Email Address: privacyteam@fico.com

United Kingdom     
Max Garth, Head of Legal, EMEA     
Cottons Centre 5th Floor     
Hays Lane     
London SE1 2 QP     
United Kingdom     
Email Address: privacyteam@fico.com

European Union     
Alexander Bugl     
Bugl & Kollegen GmbH      
Sedanstraße 7       
93055 Regensburg, Germany     
E-Mail: privacyteam@fico.com

 

 

CHANGES TO THIS POLICY

If we change this policy, we will post the changes here. This policy was last
updated and is effective as of September 2023.


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