Experian's consumer app ("Experian: Credit Report, Score") and CreditWorks membership are operated by Experian Consumer Services, also known legally as ConsumerInfo.com, Inc. — the same entity named in a 2023 FTC enforcement action — a California-based subsidiary of the publicly traded, London Stock Exchange-listed Experian plc. Experian's own privacy-policy pages (experian.com/privacy/*) returned an automated bot-interstitial under repeated live fetches and could not be cited directly in this research; findings instead rely on the app's Apple App Store privacy label, the FTC's own complaint page, and Experian plc's investor site. The App Store label self-declares that Identifiers and Usage Data are used to track users across apps and websites owned by other companies, and that a wide set of linked data (location, contact info, purchase history, advertising data) is used for the developer's own advertising/marketing. In August 2023 the FTC required Experian Consumer Services to pay $650,000 to settle a CAN-SPAM complaint alleging it sent account holders unsolicited marketing emails (for upsell products like Experian Boost and a paid 'Dark Web' scan) without a working opt-out, which under this methodology caps the track-record pillar at 0-24 regardless of other findings.