Xactware Privacy Notice

Xactware Solutions, Inc. (“Xactware” or “we”) respects your concerns about privacy. This Privacy Notice (the “Notice”) applies to personal data we collect on Xactware.com (the “site”) and in our iOS, Android, and Window’s apps (the “apps”). The Notice describes the types of personal data we obtain, how we use the personal data, and with whom we share it. We also describe the rights you may have and how you can contact us about our privacy practices.

Read our Data Protection Addendum at the following links:

Jurisdiction	Data Protection Addendum
United States	Data Privacy & Protection Addendum for Verisk’s Customers
Canada	Data Protection Addendum for Canadian Personal Information

Visitors to the site and app users are subject to important limitations. Please review our Copyright and Disclaimer Notice, which govern your visit to this site on the World Wide Web and your use of our apps.

1. How We Obtain Information About You

We may collect personal data that you choose to provide to us through the site and apps, including, but not limited to, your first and last name, physical address, email address, photographs, or telephone number, such as when you:

Fill out a form on the site or information entered in the apps;
Sign up to receive direct marketing communications on the site;
Sign up to a feature that we offer on the site and you provide your personal data in connection with that feature;
Attend an event that we [or a Verisk affiliate] has organized;
Communicate with us (for example, on a social media platform or by sending us an email); or
Apply for a job through the Verisk Career Site

When you visit our sites, we also may collect certain information by automated means using technologies such as cookies, non-cookie-based tokens, web server logs, tracking pixels, and web beacons. Cookies are files that websites send to your computer or other Internet-connected device to identify your browser uniquely or to store information or settings in your browser. Your browser may tell you when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our site and may not be able to purchase products that use a “shopping cart.” You can order any product by

telephone by calling Customer Service at 1-800-424-9228. Non-cookie-based tokens are encoded URL-based identifiers that track email click-thru activity or time-sensitive password reset keys and will work in scenarios where cookies are disabled, or a session has not been initiated.

Where permitted by law, we may acquire personal data about you from third parties. This may include personal data shared between Verisk affiliates, publicly-available profile information (such as your preferences and interests) on third party social media sites (such as Facebook and Twitter), and marketing lists acquired from third-party marketing agencies.

We may also collect personal data in other contexts that we will notify you of at the time.

2. Information We Obtain

Information That You Provide to Us

Personal data that you provide directly to us will be apparent from the context in which you provide it, for example:

If you fill out a form on our site or enter information into fields in our apps, you will generally provide your name, contact details and any other information requested by the form or fields, such as the reason for your enquiry or your product preferences
If you sign up to receive electronic marketing communications from us, you will generally provide your name, email address and other contact information, and your product preferences
If you sign up to a feature on our site, you will generally provide your name and contact information and any other information necessary to access the site
In connection with a job application or related inquiry, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities
The ClaimXperience solution allows policyholders to collaborate directly with an insurance carrier to settle insurance claims. While providing this solution we may collect personal information such as photographs of damaged property, name, address, IP address, geo codes, and phone numbers

Each form on our site and field in our apps varies in the information required and collected. In most cases, an asterisk (*) indicates the required information on a form. You may choose to provide additional information within fields that are not required.

Information That We Collect Automatically

Our web servers and apps may log information such as your operating system type, browser or device type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to our sites and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with the sites, such as which pages you visit. Our apps also log which buttons are pressed or screens that users visit. To control which web servers, collect information by automated means, we may place tags called “web beacons” — small files that link web pages to particular web servers and their cookies. We may also collect information from your browser, such as your browsing history, and use it in conjunction with data gathered from forms and emails to help us understand and respond to your needs.

“Do Not Track” Signals

Your browser settings may allow you to transmit a “Do Not Track” signal to websites and online services you visit. Like many other websites and online services, we do not currently process or respond to “Do Not Track” signals from your browser or to other mechanisms that enable choice. Both we and others (such as our service providers) may collect personal data about our visitors’ online activities over time and across third- party websites.

Social Media Widgets

The site includes social media functions, such as the Blog, Twitter, LinkedIn, and Facebook widgets. These widgets may collect information about which pages you visit on the site and the IP address of the device you use to connect to the Internet. The widgets may also set a cookie to ensure the features are functioning properly.

Social media functions and widgets are hosted either by a third party or directly on the site. Your interactions with the social media functions and widgets located on the site are governed by the privacy policies of the companies that provide them. If you use any of the social media functions or widgets on our site, we strongly suggest you review the privacy policies of the companies that provide those functions and features.

LinkedIn Members

If you are a LinkedIn member and you visit our site from LinkedIn, our site may use tracking pixels — transparent graphic images placed on web pages — which, in combination with cookies, collect information contained within your LinkedIn profile as well as your access of and interaction with the web pages that contain the pixels.

Xactware works with LinkedIn to provide Sponsored Updates and advertisements to your LinkedIn news feed. If you complete a form on our site, you will receive Sponsored InMails in your LinkedIn email account based on your visits to the site and your perceived interests. To learn how to opt out of Sponsored InMail, navigate to Privacy &

Settings in your LinkedIn account, choose the "Communications" tab, and then click "Turn on/off Partner InMail" to disable Sponsored InMails.

Information That We Obtain From Third Parties

Information that we collect from third parties will generally consist of publicly-available profile information (such as your preferences and interests), for example from public social media posts.

Third-Party Links:

The site or our apps may contain links to other websites that Xactware does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices, and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every website you visit.

3. How We Use Information That We Obtain

Information That You Provide to Us

We may use personal data that you provide to us to respond to your inquiry, for example, to contact you about your request, ask a question, provide announcements about products and future events, conduct surveys, consider your application for employment, and contact you for other reasons related to offering and improving our services. We use the personal data for these purposes because we have a legitimate business interest in providing services to our customers and other interested individuals that is not overridden by your interests, rights and freedoms to protect personal data about you.

In addition to the uses discussed above, we may also use the personal data you provide on our site or apps to:

operate, evaluate, and improve our business;
develop new products and services;
perform market research;
advertise and market our products and services;
determine the effectiveness of our advertising and marketing;
analyze our products, services, and websites;
administer the site or develop on our behalf.

We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our business that is not overridden by your interests, rights, and freedoms to protect personal data about you.

We may also use the information to protect against and prevent fraud, claims, and other liabilities and to comply with or enforce applicable legal requirements, industry standards, and our policies and terms. We use personal data for these purposes when it is necessary to protect, exercise, or defend our legal rights or when we are required to do so by law that applies to us.

Information That We Collect Automatically

We use personal data that we collect automatically through cookies, non-cookie-based tokens, web beacons, and other automated means for purposes such as customizing and enhancing our visitors’ visits to the site, facilitating use of the sites, collecting statistics about your visits to the site, and understanding the manner in which our visitors browse the site. Our apps also log which buttons are pressed or screens that users visit. We also use the information to help diagnose technical and service problems, administer the site, and identify visitors to the site. We use clickstream data to determine how much time visitors spend on web pages of the site, how visitors navigate through the site, and how we may tailor the site to meet the needs of our visitors. We use the personal data for the purposes described above because we have a legitimate interest in operating and improving our site and developing and improving our apps that is not overridden by your interests, rights, and freedoms to protect personal data about you.

We also use third-party web analytic services on our site, such as those of Eloqua and Google Analytics. The service providers that administer those services may use cookies and web beacons to help us analyze how users use the site. The information collected by the cookies and web beacons (including your IP address) is available to the service providers, which use the information to evaluate your use of the site.

To learn how to opt out of Google Analytics, visit: https://tools.google.com/dlpage/gaoptout.

To learn how to opt out of Eloqua web analytics, visit: http://www.eloqua.com/about/privacy/opt_status/.

To learn more about the cookies that Xactware uses on this site, as well as to control your cookie settings on this site, please read our Cookie Policy.

Other Uses of Information

In addition to the uses described above, we may use personal data that you provide to us or that we collect for other purposes. Where that is the case, we will provide an

additional privacy notice to you that describes the purposes for which we will use the personal data and our legal basis for doing so.

4. Information We Share

We do not sell or otherwise disclose personal data that you provide to us or that we collect on our site or in our apps, except as described here. We may share personal data you provide to us or that we collect on the site or via our apps with:

Other Xactware entities;
Other companies in the Verisk group; and
service providers that perform services on our

Details of the other companies in the Verisk group, including the countries in which they are located can be found here.

We may share personal data with service providers that perform services on our behalf such as payment service providers, analytics providers, hosting providers, and advisers. All service providers have entered into legally binding agreements requiring them to use or disclose personal data only as necessary to perform services on our behalf or comply with applicable legal requirements. Our service providers may be located outside the country, state, province in which you reside (which may, include transfer of personal data outside of the country, state, or province in which you reside).

In addition, we may disclose personal data about you (a) if we are required or permitted to do so by law or legal process — for example, due to a court order or a request from a law enforcement agency, (b) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (c) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (c) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation). Your personal information may also be disclosed where necessary for the establishment, exercise, or defense of a legal claim and to investigate or prevent actual or suspect loss or harm to persons or property.

Where a disclosure of our customers’ information is required by applicable law, we notify our customer prior to comply with such requirements (to the extent we are not prohibited from doing so) and co-operate with our customer’s instruction with respect to our response.

5. Data Transfers

We may transfer the personal data that we collect about you to recipients in countries other than the country in which the personal data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal data. When we transfer your personal data to recipients in other countries (such as the U.S.), we will protect that personal data as described in this Notice.

If you are located in the European Economic Area (“EEA”) and the United Kingdom, we will comply with applicable legal requirements providing adequate protection for the transfer of personal data to recipients in countries outside of the EEA, the United Kingdom, and Switzerland. In all such cases, we will only transfer your personal data if:

The country to which the personal data will be transferred has been granted a European Commission adequacy decision;
We have put in place appropriate safeguards in respect of the transfer, for example the EU Model Contracts.

We may transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition, or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Xactware or as part of a corporate reorganization or other change in corporate control involving Xactware or the Verisk Group of Companies.

You may request a copy of the safeguards that we have put in place in respect of transfers of personal data by contacting us as described in the How To Contact Us section below.

6. How Long We Keep Information

The time period for which we keep personal data depends on the purpose for which we collected it. In all cases, we keep it for as long as necessary to fulfil the purposes for which we collected it. We will then delete the personal data, unless we are legally required to retain it or if we need to retain it in order to comply with our legal obligations (for example, for tax and accounting purposes).

Subject to any applicable legal requirements, we typically retain personal data as follows:

Personal data you provide to us through our site and our apps: we keep this personal data for as long as necessary in order to respond to your request, and for a short further period in case you send us further requests.
Personal data you provide when you sign up to receive direct marketing communications: we keep most of this personal data for the duration of our relationship with you until you opt out or we do not have any contact with you for a long period of time.
Personal data collected for analytics purposes: we keep this personal data for a short period of time necessary for us to carry out the analytics.
Website logs: we keep site audit logs, which may contain your personal data, for as long as necessary to fulfil the purpose for which it was collected.

We have implemented reasonable administrative, technical and physical measures in an effort to safeguard the personal information in our custody and control against theft, loss and unauthorized access, use, modification and disclosure. We restrict access to personal information on a need-to-know basis to employees and authorized service providers who require access to fulfil their job requirements.

7. Your Rights and Choices

If you have signed-up to receive our email communications, you can unsubscribe any time by clicking the “unsubscribe” link included at the bottom of the email. Alternatively, you can opt-out of receiving our marketing communications by contacting us at contact information under “How to Contact Us” below.

If we receive a request from you to access or update personal information we maintain on behalf of a customer, we will direct you to the relevant customer. We will assist our customers wherever possible in responding to individual access requests.

Subject to limited exceptions under applicable law, you have the right to access, update and correct inaccuracies in your personal information in our custody or control, and to withdraw your consent to our collection, use or disclosure of your personal information (subject to legal and contractual restrictions). You may request access, updating and corrections of inaccuracies in your personal information in our custody or control, or withdraw your consent, by emailing or writing to us at the contact information set out below. We may request certain personal information for the purpose of verifying the identity of the individual seeking access to his or her personal information records.

Residents of the European Economic Area (“EEA”), the United Kingdom, or Switzerland, have certain rights in relation to personal data or information that we hold about you that may include:

To request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
To request that we rectify or update your personal data that is inaccurate, incomplete, or outdated.
To request that we erase your personal data in certain circumstances, such as where we collected personal data on the basis of your consent and you withdraw your consent;
To request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted — for example, a request that we update your personal data;
Where you have given us consent to process your personal data, to withdraw your consent; and
To request that we provide a copy of your personal data to you in a structured, commonly used and machine-readable format in certain circumstances.

You may contact us by email or as described in the “How to Contact Us” section below

to exercise your rights described above.

You also have the right to lodge a complaint with the data protection supervisory authority in your country. You can find the contact information of the data protection supervisory authority in your country here.

8. Updates to Our Online Privacy Notice

We may update this Notice periodically and without prior notice to you to reflect changes in our personal data practices or relevant laws. We will post the updated version and indicate at the top of the notice when it was most recently updated.

9. How to Contact Us Regarding Privacy Inquiries

If you have any questions or comments about this Notice or any issue relating to how we collect, use, or disclose personal data, or if you would like us to update information we have about you or your preferences, you may contact us.

Please include your name and the name of the business Xactware to which your request refers.

By email at:
privacy@verisk.com

In writing at:
Verisk Analytics
Attn: Privacy Inquiries
2nd Floor, Linea House
Harvest Crescent
Fleet
Hampshire
GU51 2UZ

Our EU Representative

If you are located in the European Union (“EU”) and have any questions or comments about this Notice, any issue relating to your personal data, or if you would like us to update your preferences, you may contact our EU representative.

Please include your name and the name of the business (Xactware) to which your request refers.

By email at:
privacy@verisk.com

In writing at:
Verisk – Insurance Solutions
Level 1, Unit 1A
3 Custom House Plaza Harbour
Master Place
I.F.S.C
Dublin 1 Ireland

Our UK Representative

If you are located in the United Kingdom (“UK”) and have any questions or comments about this Notice, any issue relating to your personal data, or if you would like us to update your preferences, you may contact our UK representative.

Please include your name and the name of the business (Xactware) to which your request refers.

By email at:
privacy@verisk.com

In writing at:
Verisk
Attention: Privacy Inquiries
22 Bishopsgate London
EC2N 4BQ
United Kingdom

If you are located in Canada and have any questions or comments about this Notice, any issue relating to your personal data, or if you would like us to update your preferences, you may contact our Privacy Officer. Please include your name and the name of the business (Xactware) to which your request refers.

Samantha Vaughan
Chief Privacy Officer
Email: privacy@verisk.com