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S&P Global
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From S&P Global
Press Release: S&P Global Merges With IHS Markit
On February 28, 2022, S&P Global completed its merger with IHS Markit, the
next step in delivering data, technology and expertise that accelerates
progress.
Read: 2021 Annual Report
As great as last year was for our company, in many ways 2022 is shaping up to
be even better. In February, we closed a transformative merger with IHS
Markit. We believe combining our two companies will create substantial
long-term value for all our stakeholders.
Read: S&P Global Foundation
The S&P Global Foundation is about much more than philanthropy—we are about
making a difference by finding and developing essential connections between
the knowledge- and skill-driven work of S&P Global and the needs of society.
* * Overview
* Data & Analytics
* Research & Insights
* Ratings & Benchmarks
* Technology Solutions
* Experts
* S&P Dow Jones Indices
* S&P Global Engineering Solutions
* S&P Global Market Intelligence
* S&P Global Mobility
* S&P Global Commodity Insights
* S&P Global Ratings
* * Overview
* Featured
* Podcasts
* Videos
War in Ukraine
Most Popular Insights
Look Forward
Our economists, analysts, researchers and data experts have surveyed the
current era of instability and connected the dots to explain what it all
means — and what it portends for the future. The S&P Global Research Council
has identified six interconnected themes that have the greatest potential for
large-scale disruption in the coming years.
Read: Sustainability Quarterly Fourth Quarter 2022 Edition: Measuring,
managing climate & nature risks
There is no one-size-fits-all solution to climate and nature challenges. This
research seeks to understand the sustainability challenges different parts of
the world and the economy face — and the solutions to help address these
challenges.
Read: Establishing Energy Security
Global energy markets were rocked after sanctions on Russia and record-level
inflation — leading to concerns about energy security across the globe,
especially as winter nears in the Northern Hemisphere.
* * Overview
* Our Culture
* Our Commitment
* Our Work
* Search for a Job
* * Featured S&P Global Events
* Webinar Replays
* S&P Global Ratings Events
* S&P Global Market Intelligence Events
* S&P Global Commodity Insights Events
* S&P Dow Jones Indices Events
* S&P Global Mobility Events
* Introduction
* What does S&P Global do?
* Personal information we collect
* Sharing of personal information
* Legal basis for processing personal information
* Cookies and similar tracking technology
* Keeping your personal information secure
* International data transfers
* Data retention
* Your data protection rights
* Updates to this Policy
* How to contact us
* Digital and advertising-related services
* Russian Federation - Additional Provisions
* People’s Republic of China - Additional Provisions
* Japan - Additional Provisions
* State of California, United States - Additional Provisions
* Brazil – Additional Provisions
* Colombia – Additional Provisions
* Republic of South Africa – Additional Provisions
GLOBAL CORPORATE PRIVACY POLICY
--------------------------------------------------------------------------------
English | Chinese - Traditional | Chinese - Simplified | French |
German | Italian | Japanese | Korean | Portuguese | Russian |
Spanish | Spanish - Mexican
Download Privacy Policy as PDF
Our Privacy Commitment
* What is this Policy about?
Update Effective: December 30, 2022
S&P Global Inc. and its affiliates (collectively or individually, as
applicable, referred to as "S&P Global", "we", "our", "us") respect your
right to privacy. This global Corporate Privacy Policy (“Policy”) explains
who we are, how we collect, share, transfer and use personal information
about you, and how you can exercise your privacy rights. This Policy applies
to interactions we have with you via our websites, applications and other
products and services including events, where you otherwise contact us and
where we otherwise display or link to this Policy (“Services”) or in the
course of our receipt of products or services from you or your employer.
Please note that some privacy rights and obligations may differ in certain
locations based on applicable local data protection laws. We have included
supplemental information for certain jurisdictions in this Policy.
Third parties that link from or to our Services, or from whom we collect
personal information may have their own privacy policies and practices. This
Policy does not apply to sites or applications offered by other companies or
individuals, including third party products and services, that may be
displayed as content in a search on our website. Please review any
third-party policies to learn more about their practices.
To the extent a notice provided at the time of collection from a website or
specific product conflicts with this Policy, the terms of that specific
notice or supplemental privacy statement will apply.
If you enter into a separate agreement with us which requires, or
contemplates, collecting, sharing, transferring, using or otherwise
processing information about you in a manner that is different than that
which is described in this Policy, the terms of that agreement will apply.
For more about the S&P Global’s commitment to privacy, please see the privacy
mission statement and resources at:
https://www.spglobal.com/en/privacy/our-privacy-commitment.
* What does S&P Global do?
S&P Global is a leading provider of transparent and independent ratings,
benchmarks, analytics and data to the capital and commodity markets,
businesses and governments worldwide. For more about the S&P Global current
group companies and other related companies, please see our latest filing
here.
* What personal information does S&P Global collect and why?
The information that we collect from or about you - some of which is personal
information under applicable data protection laws - falls into the following
broad categories:
1. INFORMATION THAT YOU PROVIDE TO US
As part of our Services, you may provide certain information to us, such as
your contact details, user credentials, and employment information.
A few examples include, when you fill out an on-line form to register to use
our Services, such as to attend an event, to request a free trial or courtesy
newsletter, or to receive research, white papers, product information or
reports through our website. You may also provide us with your business card
information or other contact information as you conduct business with us or
you request information from us. Information we ask you for and why we ask
you for it includes:
Types of personal information
Why we collect it
Billing information (including your payment card information)
To maintain your account with us and to provide you with requested products
and services.
For order processing and to provide transaction documents.
Contact details such as name, telephone numbers (which may include
cell/mobile numbers), email address and postal address and details of any
correspondence between us.
To respond to your communications and inquiries, such as when you want to
learn more about our conferences and webinars.
If requested, to provide product service updates, information and alerts.
To contact you for information verification purposes.
To gather information needed to provide and deliver maintenance, support, and
training for Services requested by you or your employer.
To obtain your feedback regarding our Services, including an event you
attended, such as when we or our agents send you a customer satisfaction
survey.
To receive services from you or the corporate entity you represent.
User credentials including name, email address, signature and any personal
login information you provide to us when you create a profile, such as
details of your education and your gender.
Some product platforms also allow users to upload data themselves including
age, race, color, ancestry, national origin, citizenship, religion or creed,
marital status, sex (including gender, gender identity, pregnancy or
childbirth and related medical conditions), sexual orientation, veteran or
military status, for their updates, information and alerts.
To set up and maintain your user account.
To monitor and enforce compliance with our contract terms.
To enable clients to use our product platforms for their own purposes.
Employer and employment information such as job title, company affiliation,
function, seniority, department and location of your office.
To manage your individual user account when it is covered by an account of an
S&P corporate customer, such as the corporate account of your employer.
Your preferences and interests, such as emails and newsletters you would like
to receive, or have opted out from receiving, or the markets, industries and
conferences that interest you.
We may record (voice or audio) and/or collect images of you, provided that
you do not object (and that you have opted in where required by law), for
example at an in-person or virtual event.
To provide the event content to individuals who were not able to attend the
live event, to promote our events in live recordings, or to otherwise provide
event content. In some instances we may also use technology to create
automated transcriptions.
To enable us to send you tailored information on our Services across our
divisions that may interest you, to allow you to participate voluntarily in
mailings and other events and to allow us to promote our events and
Services.
Social security/Official identification number, state identification card
number, credit card numbers, and personal financial data (such as specific
salary, mortgage details, net worth or individual portfolio information). We
refer to this type of personal information as "Customer Financial Data".
In some cases, our corporate customer, such as a structured finance issuer or
you, may provide Customer Financial Data to us for the purpose of informing
our statistical analysis or for our use in providing our Services. Customer
Financial Data will not be used for purposes other than these and will not be
rented or otherwise made available to third parties for public distribution.
For conducting due diligence activities for financial institutions and other
regulated companies as part of our know-your-client products.
Issues, questions and problems you have when using our Services, your user
preferences and how you use or want to use our Services and information which
you seek to analyse or manipulate within our Services and which you
communicate to our support, maintenance and training staff. We may also
record telephone service calls with you, subject to an announcement at the
beginning of the call. In some instances, we may also use technology to
create automated transcriptions.
To maintain your account with us, provide technical support to that account,
remedy issues or problems with that account, train you in the use of our
Services and keep an auditable record of all such communications and actions
which is accessible to our support, maintenance and training staff globally.
2. Information that we collect automatically
We may collect information automatically from your device, including
information regarding how you use our Services. Where required by law, w will
obtain your consent before we place any cookies on your device that are not
strictly necessary for the functioning of our websites.
Information we may collect automatically includes your log-in events (when,
how and for how long you log into and use certain Services), IP or MAC
address, device make, model and operating system, mobile network information,
internet service provider, unique device identification number, advertising
ID, browser type and language, geographic location (e.g., country or city
level location or time zone) and other technical information. We may collect
"click stream" data, which is information about how your device interacts
with our Services, such as the pages, screens, functions, applications and
products accessed and links clicked.
This information helps us understand users of our Services, such as visitors
to our websites, the pages they visited before and after and what content and
functions interest them. We use this automatically collected information:
- for our analytics purposes, including to enhance our understanding of usage
of our Services;
- to improve the quality and relevance to users of our Services, including
(with consent as applicable) by showing or offering users relevant Services
or content based on their preferences and usage habits;
- to develop or accelerate research, analysis, news and related editorial
content and information collection as part of our Services, or to enable
others to develop/accelerate such content where permitted;
- to offer you support with and training on our Services and to help resolve
any errors or technical issues;
- to develop and update our Services;
- for customer services, such as evaluating our customers' training needs for
our products;
- to satisfy requests from S&P Global corporate customers regarding the
entitlement to and use of our Services by individual users under their
corporate accounts (this information may be offered to clients in an
aggregated form and clients may be required by law to request certain
information);
- to deliver tailored information on our Services that may be of interest or
value to you and to send you marketing and promotional emails with your
consent if required by applicable law;
- occasionally, to identify unauthorized use or unauthorized distribution of
our Services related or unrelated to a security issue;
- where relevant, to review or update pricing agreed with our customers; and
- for billing purposes, so that we or others (such as our content providers)
can bill for the services provided.
Some of this information is collected using cookies, weblogs, web beacons and
similar tracking technology - see "How does S&P Global use cookies and
similar tracking technology?"
3. Information that we obtain from other sources
We may receive personal information about you from other sources (including
your employer or business partner if you use Services covered by a
subscription). Where you register as a user, we will endeavor to check that
these third parties have your consent or are otherwise legally permitted or
required to disclose your personal information to us.
The information we collect from your employer (if you use our Services under
your employer's corporate subscription) consists of your contact details and
employment-related information.
We collect personal information from other third parties, such as marketing
vendors, survey services, social media, conferences and other events that we
or others organize, and other sources to the extent permitted by applicable
law. We use this information to market our Services to you, to maintain and
correct our records, to add data fields, and to enhance the marketing,
delivery, and support of our Services to you.
We collect personal information as part of our content collection process for
some of our products. We obtain this from a variety of sources, including
third-party content providers, public filings, direct communication with your
employer or appointor, and websites to display within some of our products.
Find out more at "How does S&P Global use personal information in products?"
The automotive business collects and compiles motor vehicle registration and
title information to provide products and services to authorized entities
pursuant to 18 U.S.C A. §2721 and similar state laws governing the use of
such information. Consumer information from motor vehicle records is used in
compliance with the governing laws and regulations and thus not used by S&P
Global or provided to other entities by us for direct marketing purposes. To
access or correct your motor vehicle registration and/or title information,
you must contact your state's department of motor vehicles or other state
agency that processes motor vehicle titles and registration. The American
Association of Motor Vehicle Administrators maintains links to state motor
vehicle agency websites, organized by AAMVA regions.
We also may use your personal information for other purposes that we explain
to you at the time we collect your personal information or, if permitted by
applicable data protection laws, that are compatible with the purposes we
have disclosed to you (such as archiving purposes in the public interest,
scientific or historical research purposes, or statistical purposes).
S&P Global policies, procedures and standards require that the information in
its products is updated for accuracy on a regular basis and removed from its
systems when such data becomes obsolete or inaccurate. S&P Global has
established information governance standards for collection, use and
retention of personal information.
To the extent we maintain and use personal information in a deidentified or
anonymized form, we will not attempt to reidentify the information, except
for the purpose of determining whether our deidentification/ anonymization
processes satisfy our legal obligations.
4. OTHER PERSONAL INFORMATION COLLECTED THROUGH OUR MOBILE APPS
When you download, access or otherwise use one of our mobile apps, the
information that we collect depends on your device, in-app and operating
system permissions. Our apps may require access to applications and/or data
on your mobile device to function. When you agree, some of our apps collect
the precise geo-location of your mobile device and some of our apps also
collect information that may be personal information about your or others,
from or about:
• Your calendar
• Your contacts and call information
• The accounts and other apps on your mobile device
• Photos (including date, time, location and contents)
• Media files, metadata and other stored information
We may also automatically collect app logs and usage statistics. For example,
we may record when you open an app so that we can monitor which app is used,
when and how, and if the app stops working, we log the "crash data," such as
whether you have mobile reception, to help us identify and fix the cause.
To learn more about the specific information collected by any of our mobile
apps, please check your device settings or review the platform from which you
downloaded it. To stop collection of all information through one of our apps,
please uninstall the app.
* When does S&P Global disclose my personal information?
The categories of personal information listed in the S&P Global "What
personal information does S&P Global collect and why?" section above may be
disclosed to the following categories of recipients:
Our group companies and our joint venture companies where applicable, service
providers including without limitation professional advisers or consultants
such as lawyers, bankers, auditors, accountants and insurers providing
consultancy, legal, banking, audit, accounting or insurance services,
financial institutions providing finance to us, external auditors, product
content providers, business partners and any organization that arranges your
access to our products or services (if that is not you).
We share personal information with those authorized parties referred to above
for purposes consistent with those described in this Policy or as notified to
you when your personal information is collected. For example, we may share
your personal information with the organization that arranges your access to
our products or services to fulfill its contractual obligations and to
provide our products and services, support, and training for them. We may
share your personal information with our service providers and business
partners for the purpose of operating our business, honoring a request that
you have made through the products or services, delivering, improving and
customizing our products or Services, sending marketing and communications
related to our business, payment processing, and for other legitimate
purposes permitted by applicable law or otherwise with your consent. We may
share the contact information you provide when registering for an event and
share event attendee lists between our S&P Global divisions and with our
webinar and conference partners, to ensure that your contact information is
up to date and to administer, secure, and seek feedback on and promote our
events.
For a list of our current group companies and related companies, please see
our latest filings here. A list of our service providers, content providers
and business partners is available here. For information about the disclosure
of the California enumerated categories please see the California
jurisdictional section below.
In addition to the purposes described in this Policy, personal information
handled by our service providers may be subject to their terms of use and
privacy policies, which if applicable, will be provided to you. Please review
any applicable service provider’s terms of use and privacy policies to better
understand how they manage your personal information.
Your employer
We may provide personal information to your employer for purposes such as to
fulfill and enforce our contract with them, to inform them of potential group
training needs, to inform them of Service use by certain categories of users
and for pricing purposes.
Competent law enforcement bodies, regulatory, government agency, court or
other third parties
We may provide personal information to any competent law enforcement body,
regulatory, government agency, court or other third party in accordance with
applicable law and regulation when we believe disclosure is necessary (i) as
a matter of applicable law or regulation, (ii) to protect against fraud or
for risk management purposes, (iii) to cooperate with relevant agencies for
the investigation and prevention of crimes such as insider trading, (iv) to
exercise, establish or defend our legal rights, (v) to protect your vital
interests or those of any other person, or (vi) to protect the interests,
rights, safety or property of us or others.
S&P Global is regulated by various federal and state agencies, authorities
and similar regulatory bodies internationally and, in the normal course of
business, both in the United States of America and abroad, is the subject of
government and regulatory proceedings, investigations and inquiries. We may
therefore disclose your information to comply with a court order, government
request or other legal or regulatory process, sometimes without prior notice
to you.
Our SEC filings set this out in more detail and are available here.
Potential Buyers
We may provide personal information to a potential buyer or a target (and
that third party’s or our agents and advisers) in connection with any
proposed sale, purchase, merger, transfer, acquisition or liquidation or
similar event, of all or any part of our businesses. If such a change happens
to our business, the buyer or target will use your personal information in
the same way as set out in this Policy or will inform you about how it will
use your personal information as required by applicable law.
Other third parties
Personal information that you disclose on message boards, chat areas or
social media pages or in direct messages to other users of these platforms
may be collected and used by third parties to contact you, to send you
unsolicited messages or for other purposes without our knowledge or control.
Social media forums and chat rooms not operated by us may have additional
rules and conditions. We are not responsible for the personal information or
any other information you choose to submit on these forums that are not
controlled by us.
The Services may offer you the ability to share personal information through
a social networking site (e.g., Facebook, Twitter) using integrated tools
(e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such
integrated tools enables you to share personal information about yourself
with other individuals or the public, depending on the settings that you have
established with such social networking site. For more information about the
purpose and scope of data collection and use in connection with such social
networking sites or a site’s integrated tools, please visit the privacy
policies of the entities that provide these social networking sites.
We encourage you to use caution when publicly disclosing your personal
information.
We may ask for your consent to share your information with other unaffiliated
third parties who are not described elsewhere in this Policy.
For more information about how and why we disclose the personal information
that features in our products, please see "How does S&P Global use personal
information in products?" below.
* What is our legal basis for processing personal information?
Our legal basis for collecting and processing personal information depends on
the personal information concerned, the context in which we collect it and
the applicable laws and regulations.
Generally, we collect personal information from you where: we have your
consent to do so; we need the personal information to perform a contract with
you (for example, your subscription to one of our products) where permitted
under applicable data protection laws; or, in some jurisdictions such as the
European Economic Area (“EEA”), the processing is in our legitimate interests
and not overridden by your data protection interests or fundamental rights
and freedoms or the processing is otherwise consistent with applicable law.
In some cases, we are required by law to collect personal information from
you.
If we ask you to provide personal information to comply with a legal
requirement or to perform a contract with you, we will inform you whether the
provision of your personal information is mandatory and the possible
consequences if you do not provide your personal information.
Where we send you marketing or promotional e-mails regarding our Services
from our different divisions and affiliates, we do so based on your consent,
if required by applicable law.
Generally, if we collect and use your personal information in reliance on our
legitimate interests (or those of a third party), this interest is to provide
our Services to you and for our legitimate commercial interest (e.g., when
responding to your queries, improving our Services, processing payments,
advising you of product features or new releases, providing training,
informing you of product maintenance, or undertaking marketing activities).
For the legal basis on which we rely in relation to personal information in
our products, please see "How does S&P Global use personal information in
products?".
* How does S&P Global use cookies and similar tracking technology?
Generally, we use cookies and similar tracking technology (collectively,
"Cookies") in certain Services (in particular our websites and some mobile
applications) to collect and use personal information about you, in order to
better understand and improve the usability, performance, and effectiveness
of our Services, to help us tailor content or offers for you, and to serve
our targeted, interest-based advertising. These technologies may also allow
certain third parties to collect information about you over time and across
different websites, such as information about you clicking on advertisements
or installing our Services. Where permitted by applicable law, we will deploy
first party performance or analytics Cookies automatically when you visit our
websites. Where required by applicable law, we will obtain your consent
before we place any Cookies on your device that are not strictly necessary
for the functioning of our websites. To learn more, including about how to
consent to or opt-out and withdraw your consent to Cookies, please see our
Cookie Notice.
We may use Google Analytics to better understand how visitors use our
Services. Google Analytics provides us with information about users of our
Services. Google Analytics uses Cookies that Google or its affiliate
DoubleClick recognizes when you visit other websites and applications. For
more information about how Google collects, uses, and shares your
information, including information collected through our Services, please
visit the Google Privacy Policy - Partners website at
https://policies.google.com/technologies/partner-sites or see Google’s own
Privacy Policy at https://policies.google.com/privacy.
Google Analytics uses Cookies to help us analyze how users use our Services.
Personal information generated by these Cookies about your use of our
Services (including your IP address) will be transmitted to and stored by
Google on servers in the United States of America. On our behalf, Google will
use this information to evaluate your use of our Services and will compile
reports on your activity for us.
If you want to opt out of Google Analytics, you can download and install the
opt-out browser add-on developed by Google for your web browser. For more
information about Google Analytics' currently available opt-outs, please see
https://tools.google.com/dlpaqe/gaoptout.
For more information about our privacy practices relating to our advertising
services, please see the Digital and advertising-related services section of
this Policy.
* How does S&P Global keep my personal information secure?
We protect personal information that we process with appropriate technical
and organizational measures designed to provide a level of security
appropriate to the risk of processing your personal information. We will
notify you about any security incident involving your personal information
through email, correspondence, telephone, push notification or other means,
as required by applicable law. If you think your data is the subject of a
security incident and we have not notified you, or if you are concerned about
the security of your data, please contact our dedicated security team at
security@spglobal.com.
* How does S&P Global treat international data transfers?
Your personal information may be transferred to, and processed outside, the
jurisdiction in which you reside. These other jurisdictions may have data
protection laws that are different from the laws of the jurisdiction of your
residence (and, in some cases, not as protective).
S&P Global is a multi-national group with headquarters in New York, United
States of America. Our servers may be located outside of the jurisdiction
where we collected the data. We may store and replicate your personal
information on servers in other jurisdictions, in order to provide speed of
access, robustness and protection against server failure.
When we collect your personal information, we may transfer it to or from any
of the countries in which we do business. Our group companies, related
companies, any organization that arranges your access to our products or
services service providers, product content providers and business partners,
with whom we may share personal information, are located in and transfer
personal information to various jurisdictions around the world. The principal
jurisdictions where personal information is hosted by or on behalf of S&P
Global are the United States of America, Canada, the United Kingdom, Germany,
the Republic of Ireland, Italy, France, Switzerland, the Netherlands, India
and Singapore. In some cases, your personal information may also be accessed
from outside of the jurisdiction where we collected the data, such as the
Philippines, India and Pakistan, where our back-office support personnel are
located for certain Divisions.
Where your personal information is transferred by us or on our behalf, we
implement appropriate safeguards to protect your personal information in
accordance with this Policy. These safeguards include implementing applicable
standard contractual clauses for transfers of personal information between
our group companies, which require group companies to protect personal
information they transfer from the jurisdiction in which it was collected in
accordance with applicable data protection law.
Where required by applicable law, international transfers take place only
when there is an adequate level of protection to the fundamental data
protection rights of individuals. In some circumstances, we may choose to
rely upon an adequacy decision to lawfully transfer personal information.
Standard contractual clauses are one of several mechanisms that allow for
personal information to be transferred across jurisdictional borders and we
my rely on these for transfers to and from our affiliates, vendors and
business partners where applicable. Additional safeguards may also be
implemented where personal information is transferred. Please contact us to
request a copy of our appropriate safeguards.
* For how long does S&P Global retain personal information?
Our applicable information governance policies, procedures and standards
require that personal information be retained for as long as we have an
ongoing legitimate business need to do so (for example, to provide you with a
Service you have requested, or to comply with applicable legal, tax or
accounting requirements).
Once we no longer have a legitimate business need to process your personal
information, our applicable information governance policies, procedures and
standards require that we either delete or anonymize your personal
information, or if deletion or anonymization is not possible, then
pseudonymize and/or securely store your personal information and isolate it
from any further processing until deletion is possible.
If you have any questions or require any further information about the period
of time for which we will process your personal information, please contact
us using the contact details set out below.
* What are your data protection rights?
Depending on which laws apply to your personal information, you may have the
right to make the following requests regarding your personal information:
- Access to Your Personal Information. You may request access to your
personal information or confirmation that we have information about you. In
certain limited circumstances, you may also request to receive access to your
data in a portable, machine-readable format.
- Deletion Of Your Personal Information. You may request that we delete your
personal information. If required by law, we will grant a request to delete
information, but you should note that in many situations we must keep to
comply with our legal obligations, resolve disputes, enforce our agreements,
or for another business purposes.
- Corrections To Your Personal Information. We rely on you to update and
correct your personal information. Where your personal information is
required to access or use Services, you may have the opportunity to correct,
update, or modify this information by logging into your account and updating
your information online. You may ask us to correct information that is
inaccurate or incomplete. Note that we may keep historical information in our
backup files as permitted by law.
- Objection to Certain Processing. You may object to our use or disclosure of
your personal information by contacting us at the address described below.
- Opt-out of Targeted Advertising You may opt-out of online tracking based
targeted advertising or cross-context behavioral advertising (e.g., cookies)
by clicking the cookie settings link on the footer of our websites. Please
note that if you change browsers or computers, or if you clear your browser’s
cache, you may need to click the link again to apply your preference.
- Opt-out of Sale. You may opt-out of the sale of your personal information
by clicking here or the “Do Not Sell My Personal Information” link on our
homepage.
- Restrict Processing. You may request that we restrict our processing of
your personal information under certain circumstances, such as when you
contest the accuracy of our records about you, or you make an objection.
- Promotional Emails. You may choose to provide us with your email address
for the purpose of allowing us to send free newsletters, surveys, offers, and
other promotional materials to you, as well as targeted offers from third
parties. You can stop receiving promotional emails by following the
unsubscribe or “opt-out” instructions in emails that you receive, by visiting
our preference center here or by using the contact details listed on this
page. If you decide not to receive promotional emails, we may still send you
service-related communications.
- Revocation Of Consent. Where we process your personal information based
upon consent, you may revoke consent. Withdrawing your consent will not
affect the lawfulness of any processing we conducted before withdrawal, nor
will it affect processing of your personal information conducted in reliance
on lawful processing grounds other than consent. Please note, if you revoke
your consent for the processing of personal information then we may no longer
be able to provide you services.
Please note, not all of the rights described above are absolute, and they do
not apply in all circumstances. In some cases, we may limit or deny your
request because the law permits or requires us to do so, because a right is
not granted by the laws that apply to a specific person, or if we are unable
to adequately verify your identity. Individuals in certain jurisdictions may
have other rights. For more information, see the applicable
jurisdiction-specific addendum which forms part of this Policy. We will not
discriminate against individuals who exercise their privacy rights under
applicable law.
You may use this Personal Information Request Form or call us on
1-855-529-1761 to exercise any of your rights. If you disagree with how we
handled a request, you may appeal our decision by contacting us with the
subject line “Appeal,” at privacy@spglobal.com.
We respond to requests we receive from individuals wishing to exercise their
data protection rights or express any concern in accordance with applicable
data protection laws, which typically require a response within 30 days.
Please be aware that in order to accommodate some requests, we must verify
your identity before we can respond, and this may require you to provide
photographic or other forms of identification to us.
In some circumstances, you may designate an authorized agent to submit
requests to exercise certain privacy rights on your behalf. If you are an
authorized agent submitting a request on behalf of an individual, you must
provide all requested information establishing your authorization as an agent
to act on another person’s behalf.
If you are not satisfied with our response, and are in the European Union or
United Kingdom, you may have a right to lodge a complaint with your local
supervisory authority. Contact details for data protection authorities in the
EEA, Canada, Switzerland and the UK are available here.
Please note that in certain jurisdictions we may be entitled to charge a fee
in connection with the exercise of these rights, which will be communicated
to you if applicable.
* What happens if this Corporate Privacy Policy is updated?
We review and update this Policy from time to time. When we do, we will bring
those updates to your attention, for example, by noting the date of the
version on the Policy, posting the updated version here or sending you a
notification. To the extent that this Policy changes in a material way, the
Policy that was in place at the time that you submitted personal information
to us will generally govern that information unless we receive your consent
to the new policy.
* How can you contact us?
If you have any questions or concerns about our use of your personal
information, or if you need to access this Privacy Policy in an alternative
format due to having a disability, please contact our Privacy Compliance team
at privacy@spglobal.com, 1-855-529-1761, or 55 Water Street, New York, NY
10041.
You may also use this personal data request form to contact us or exercise
any of your rights.
In some of our locations, we also have local contact details that you may
prefer to use as set out in the following jurisdictional supplements:
• Russian Federation
• People’s Republic of China
• Japan
• State of California, United States of America
• Brazil
• Colombia
For the Philippines, you may also use email DPOPhilippines@spglobal.com.
European Union Contact Details for non-European Union S&P Global Entities and
Affiliates
Certain S&P Global entities located outside the European Union (“EU”) have
appointed representatives within the EU. If you are an EU resident, you may
choose to contact the relevant EU representative for any data
protection-related enquiries in addition to, or instead of, the contact
details above. Please use the applicable contact details below.
S&P Global Ratings
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
RatingsGDPR@spglobal.com
S&P Global Market Intelligence
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
MlPrivacyOfficer@spglobal.com
S&P Dow Jones Indices
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
spdjiGDPR@spglobal.com
S&P Global Commodity Insights
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
PlattsGDPR@spglobal.com
S&P Global Engineering Solutions
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
PlattsGDPR@spglobal.com
S&P Global Mobility
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
PlattsGDPR@spglobal.com
UK Contact Details for non-UK S&P Global
Certain S&P Global Inc. and its applicable affiliates located outside the UK
have appointed representatives within the UK. If you are a UK resident, you
may choose to contact the relevant UK representative for any data
protection-related enquiries in addition to, or instead of, the contact
details above. Please use the contact details below by division.
S&P Global Ratings
20 Canada Square
Canary Wharf
London
E14 5LH
RatingsGDPR@spglobal.com
S&P Global Market Intelligence
20 Canada Square
Canary Wharf
London
E14 5LH
MlPrivacyOfficer@spglobal.com
S&P Dow Jones Indices
20 Canada Square
Canary Wharf
London
E14 5LH
spdjiGDPR@spglobal.com
S&P Global Commodity Insights
20 Canada Square
Canary Wharf
London
E14 5LH
PlattsGDPR@spglobal.com
S&P Global Engineering Solutions
20 Canada Square
Canary Wharf
London
E14 5LH
PlattsGDPR@spglobal.com
S&P Global Mobility
20 Canada Square
Canary Wharf
London
E14 5LH
PlattsGDPR@spglobal.com
* Digital and advertising-related services
S&P Global’s Markit Digital advertising services (Markit Digital Advertising)
provide ad serving and marketing optimization solutions for the financial
services sector. Markit Digital's advertising services never collect
financial account information or any Directly Identifying
Personal-Information for advertising purposes.
In some circumstances, Markit Digital collects information for use in
tailored ads shown within the same browser. Markit Digital is a member of the
NAI (Network Advertising Initiative) and the IAB (Internet Advertising
Bureau) and abides by the NAI code of conduct and IAB requirements.
COLLECTION AND USE OF PERSONAL INFORMATION
Advertisements served from our advertising domain, ad.wsod.com, do not
collect Directly Identifying Personal-Information.
COLLECTION, USE AND SHARING OF NON-PERSONAL INFORMATION
While advertisements served from ad.wsod.com do not collect information that
can directly identify an individual, the system does collect information
including the time and date of an ad served, the type of browser and
operating system used, the visitor's IP address, and the URL visited.
Additional information may be provided by publishers, advertisers, or third
parties. This information is not used to identify anyone personally; it is
used for aggregated analytic reports, targeting a Tailored Advertising
experience, and for the purpose of site administration and diagnostics.
This information may be shared with advertising clients or their business
partners at their direction.
COLLECTION OF NON-PERSONAL INFORMATION ON MOBILE DEVICES
Markit Digital may receive non-personal information, such as device
information and cookie identification from third party sources, including
Apple IDFA, Google AdID, and Android ID. Use of Cookies.
Advertisements served from ad.wsod.com set and use cookies and local storage,
when appropriate. The ad server uses cookies/local storage to avoid
additional database look-ups, but does not use any other systems for
persistently identifying users between views and visits. Cookies and all data
collected from ad.wsod.com is advertiser-specific and is not shared between
multiple advertisers, who may also be serving ads from the domain. An
advertiser's data belongs to that advertiser, as the system used to serve ads
from ad.wsod.com merely collects and temporarily stores that data for
Tailored Advertising. Attribution cookies from Markit Digital's advertising
services expire 30 days after the user's last attribution event. Tracking
cookies expire after 60 days; after that time a tracking cookie is no longer
valid and a new one is created. Opt-out settings in any cookies, along with
assigned segments, expire after five years (less intervening leap-year days).
DATA RETENTION
Markit Digital retains unidentifiable user-level information collected by our
advertising system for up to 2 years in both aggregated and un-aggregated
forms.
INFORMATION RELATING TO CHILDREN
Our products and services are designed for those 16 years of age and older.
We do not knowingly collect information from anyone under the age of 16. If
we are made aware that we have received information from someone under 16, we
will use reasonable efforts to remove that information from our records.
OPTING OUT OF TAILORED ADVERTISING (TA)
Tailored Advertising (TA), also known as Interest-based Advertising (IBA) or
Online Behavioral Advertising (OBA) – is the process of targeting specific
advertisements to each individual user, based on browsing history. If you
opt-out of Tailored Advertising from our service using the tools below, the
cookie and any local storage we use to contain this information will be
emptied and changed to a placeholder signaling that you have opted-out. If
you delete the placeholder cookie or locally-stored code, clear all cookies
or local storage, or reset or reinstall your browser, you will need to
opt-out again. Cookies and local storage data are browser- and
device-specific, so you will need to opt-out from within each browser and
computer/device, if you regularly use more than one. After opting-out, you
may continue to see digital advertising from us, but it will no longer be
targeted to you based on your browsing history. Opting-out does not
necessarily delete or replace all cookies or local storage from our domain;
some may remain which are used for aggregate reporting on the performance of
the advertisements we serve.
CONSUMER OPT-OUT
The Network Advertising Initiative (NAI) provides information to help you
learn more about online advertising
(http://www.networkadvertising.org/understanding-online-advertising), as well
as a service to help you opt out of interest-based advertising from many
organizations (http://www.networkadvertising.org/choices/). Markit Digital
does not sell personal information as defined by the California Consumer
Privacy Act (CCPA). However, Markit Digital still participates in services
allowing all site visitors to control the use of Interest-based Advertising.
Visit privacyrights.info to learn more about CCPA and how you may opt-out
from other organizations' use of your data. By selecting the below opt-out,
Markit Digital will respect your choices for this browser, and they will be
reflected here until you clear this browser's cookies.
OPTING OUT ON YOUR MOBILE DEVICE
For information on Opting Out on Mobile Devices, please visit
https://www.networkadvertising.org/mobile-choice.
PRIVACY INQUIRIES
If you use our webform to correspond with us
( https://privacyportal.onetrust.com/webform/5cb57702-8ef7-437e-a62b-408fe78cd310/a2d05665-f8c3-44a2-ae58-d2015af31754),
S&P Global will receive your name, email and your country of residence. S&P
Global’s Markit Digital Advertising services never use this personal
information or any Directly Identifiable Personal Information for advertising
purposes.
INDUSTRY ASSOCIATIONS AND COMPLIANCE
Markit Digital participates in the Interactive Advertising Bureau's
Self-Regulatory Program for Online Behavioral Advertising
(http://www.iab.net/public_policy/self-reg).
Markit Digital adheres to and is annually reviewed for compliance with the
Network Advertising Initiative's Code of Conduct
(https://www.networkadvertising.org/code-enforcement/code).
Markit Digital adheres to the Digital Advertising Alliance's Self-Regulatory
Principles for Online Behavioral Advertising
(http://www.aboutads.info/obaprinciples).
* Russian Federation
As of 30 September 2022, S&P Global has suspended operations in the Russian
Federation. Some processing of personal data may occur in relation to any
regulatory or legal obligations in the Russian Federation, such as for the
purpose of fulfilling tax, employment, and any other legal obligations. Any
ongoing processing of personal information of Russian citizens is executed
the Schneider Group, on behalf of Standard & Poor’s International Services
LLC and Moscow Branch of S&P Global Ratings Europe Limited. For any questions
about this processing, please see the Schneider Group's Privacy Policy or
contact info@schneider-group.com.
* China
This China Addendum (“China Addendum”) applies to the processing of your
personal information only if you are located in the People’s Republic of
China (“China”) and supplements this Policy. In case of any inconsistencies
between this China Addendum and the rest of this Policy, this China Addendum
prevails.
1. Sensitive Personal Information. Your personal information whose leakage or
unlawful use may easily infringe the dignity of a natural person, or cause
harm to the personal safety or property security, including biometric
characteristics, religious beliefs, specially designated status, medical
health, financial accounts, personal whereabouts and personal information of
minors under the age of 14 may be considered as sensitive personal
information in accordance with applicable Chinese law and regulations
("Sensitive Personal Information"). To the extent we collect this Sensitive
Personal Information, we will only process it to the extent necessary for
fulfilling the purposes as stated in this Policy and will take measures for
its security. Where required by applicable Chinese law and regulations, we
will obtain your separate consent before we process your sensitive personal
information.
2. Sale of business. We may provide personal information to a potential buyer
or target (and that third party’s or our agents and advisers) in connection
with any proposed purchase, merger, transfer, acquisition or liquidation or
similar event of all or any part of our business. If such a change happens to
our business, the buyer or target will use your personal information as in
the same way as set out in this Policy including this China Addendum or will
inform you about how it will use your personal information as required by
applicable law, or (where applicable) require such third party to obtain your
consent again.
3. Notifications. We cannot absolutely guarantee the security of any
information or data you provide online. In the event of a security incident,
we will take mitigation measures in accordance with our incident response
plan and report to competent regulators in China as required by applicable
law. In the event of a security incident affecting your personal information,
we will notify you as required by applicable law through email,
correspondence, telephone, push notification or other means. If you think
your data is the subject of a security incident and we have not notified you,
or if you are concerned about the security of your data, please contact our
dedicated security team at security@spglobal.com.
4. Contact Information of our China DPO. You may contact our China Data
Protection Officer at privacy@spglobal.com or DPOChina@spglobal.com or, at:
49/F, Fortune Financial Center, No.5, Dongsanhuan Zhong Rd, Chaoyang
District, Beijing. You may also exercise your rights in relation to personal
information transferred overseas or request closure of an account which is
registered with S&P Global through the method specified under the section of
this Policy titled, “What are your data protection rights?”
* Japan
This Japan Addendum ("Japan Addendum") supplements this Policy to the extent
that the Act on the Protection of Personal Information (Japan) applies in
relation to the processing of personal information in Japan by S&P Global
Ratings Japan Inc., S&P Global SF Japan Inc., Standard & Poor's International
LLC, Japan Branch, IHS Markit Japan GK (together "S&P Global Japan") and/or
S&P Global entities located outside Japan. If there are any inconsistencies
between this Japan Addendum and the rest of this Policy in relation to S&P
Global's process of personal information subject to the APPI, this Japan
Addendum prevails.
S&P Global will comply with applicable Japanese data protection laws and
regulations, and not use personal information for purposes which are not set
forth in this Policy or otherwise communicated to the data subject. The
process for submitting a claim or request is set out in this Policy.
Joint-use of personal information inside of S&P Global Group
S&P Global Japan jointly uses personal information with other entities in the
S&P Global group who may use personal information to provide information
about our Services to our clients and related support and training, conduct
certain market research, contact clients, or engage in other activities
detailed in this policy. S&P Global Japan may also have certain products that
collect business information about individuals in Japan. Such information
includes: address, name, company name, department name, job title, phone
number, fax number, e-mail address, billing information, history of personnel
changes and professional employment history, records of job interviews with
S&P Global Japan, your areas of interest, etc.
A list of our group companies is available here.
Name, address and name of representative of the person responsible for the
management of said personal data
S&P Global Ratings Japan Inc, S&P Global SF Japan Inc.
Marunouchi Kitaguchi Bldg. 28th Floor, 1-6-5 Marunouchi, Chiyoda-ku, Tokyo
100- 0005
Representative Director Takenari Yamamoto
Standard & Poor’s International LLC Japan Branch
Marunouchi Kitaguchi Bldg. 28th Floor, 1-6-5 Marunouchi, Chiyoda-ku, Tokyo
100- 0005
Representative in Japan Sachiko Katayama
IHS Markit Japan GK
3-1-1 Kyobashi, Chuo-ku, Tokyo 104-0031
Contact information regarding handling of personal information
If you have any questions or concerns about our disclosure, correction,
deletion, utilization, or other processing of your personal information
(including how we secure your personal information), please contact our
Privacy Compliance Team via email at privacy@spglobal.com or
Japanprivacy@spglobal.com or via mail, at: Marunouchi Kitaguchi Bldg. 28th
Floor, 1-6-5 Marunouchi, Chiyoda-ku, Tokyo 100- 0005, Tel:
+81-(0)3-4550-8000.
* State of California, United States of America
This State of California, United States of America Addendum ("California
Addendum") supplements this Policy to the extent the California Consumer
Privacy Act as amended by the California Privacy Rights Act ("CCPA") applies
in relation to the processing of personal information of residents of the
State of California in the United States of America by S&P Global. In case of
any inconsistencies between this California Addendum and the rest of this
Policy, this California Addendum prevails.
Certain information we collect may be exempt from the CCPA because it is
considered public information (i.e., it is made available by a government
entity) or covered by a federal privacy law, such as the Gramm-Leach-Bliley
Act, the Health Insurance Portability and Accountability Act, the Fair Credit
Reporting Act or the Driver Privacy Protection Act.
"Shine the Light" Law
Residents of the State of California also have the right to request
information regarding third parties to whom the company has disclosed certain
categories of personal information during the preceding year for the third
parties' direct marketing purposes.
How to Submit a Request
To submit a request to exercise your rights (or to submit a request on behalf
of a consumer as an authorized agent):
(1) For right to know, access, correct, or deletion requests, complete and
submit the Data Request Form.
(2) For the opt-out of sale requests, visit "Do Not Sell My Personal
Information" or call us at 1-855-529-1761.
For information about the requests we receive, including the number of
requests and the average number of days we’ve taken to respond to requests,
please click here.
The following is a summary of our data collection practices, including the
personal information we collect, whether we disclose that information for
business purpose, and whether we "sell" and/or "share" (as those terms are
defined by California law). We may use all of the information for any of the
purposes described in the Policy unless limitations are listed. S&P Global
"shares" or "sells" personal information to third parties in very limited
circumstances. To learn more about what brands share or sell personal
information, please see below. As discussed elsewhere in the Privacy Policy,
we use cookies and similar tracking technologies for purposes of targeted
advertising. For more information, please see our Cookie Notice. The
categories we use to describe the information are those set out in the CCPA.
Category of Personal Information
Category of Recipients
Disclosures for a Business Purpose
Sharing for Cross-Context Behavioral Advertising
Sales
Identifiers – this may include real name, alias, postal address, unique
personal identifier, online identifier, email address, account name, or other
similar identifiers.
* Affiliates or subsidiaries
* Business partners
* Data analytics providers
* Data brokers
* Internet service providers
* Joint marketing partners
* Operating systems and platforms
* Other Service Providers
* Payment processors and financial institutions
* Professional services organizations, this may include auditors and law
firms
* Social networks
* Advertising networks
* Business partners
* Data analytics providers
* Data brokers
* Advertising networks
Government Issued Identification – this may include social security number,
driver’s license number, or state issued identification number, passport
number.
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
Not sold.
Financial Information – this may include bank account number, credit card
number, debit card number, and other financial information.
* Affiliates or subsidiaries
* Business partners
* Payment processors and financial institutions
* Other Service Providers
Not shared.
Not sold.
Characteristics of protected classifications – this may include age, sex,
race, ethnicity, physical, or mental handicap, etc.
* Affiliates or subsidiaries
* Business partners
Not shared.
* Business partners
* Data analytics providers
* Data brokers
Advertising networks
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
* Business partners
* Data analytics providers
* Data brokers
* Other Service Providers
* Advertising networks
* Business partners
* Data analytics providers
* Data brokers
* Advertising networks
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
* Business partners
* Data analytics providers
* Internet service providers
* Operating systems and platforms
* Other Service Providers
Not shared.
* Business partners
* Data analytics providers
* Data brokers
* Advertising networks
Geolocation data
* Affiliates or subsidiaries
* Business partners
* Data analytics providers
* Operating systems and platforms
* Other Service Providers
Not shared.
Not sold.
Audio, electronic, visual, thermal, olfactory, or similar information
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
Not sold.
Professional or employment-related information
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
* Business partners
* Advertising networks
Non-public education information (as defined in the Family Educational Rights
and Privacy Act)
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
Not sold.
Inferences drawn from any of the information listed above
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
Not sold.
Additional categories of personal information described in
the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) – this
may include signature, physical characteristics, or description, insurance
policy number.
* Affiliates or subsidiaries
* Business partners
* Payment processors and financial institutions
* Other Service Providers
Not shared.
Not sold.
California Sensitive Information Disclosure. We collect the following
categories of sensitive personal information (as defined under California
law): Social security, driver’s license, state identification card, or
passport number; precise geolocation; Racial or ethnic origin, religious, or
philosophical beliefs, or union membership; health information; and sex life
or sexual orientation. This information is collected in order to process
transactions, comply with laws, manage our business, or provide you with
services. Note that we do not use such information for any purposes that are
not identified within the California Privacy Rights Act Section 1798.121. We
do not “sell” or “share” sensitive personal information for purposes of
cross-context behavioral advertising.
Below is a list of brands that sell of share personal information with third
parties:
• Polk (https://ihsmarkit.com/products/polk-automotive-solutions.html)
• Ipreo (https://ihsmarkit.com/products/brst-bd-advanced.html)
• Money Market Directories (https://products.mmdwebaccess.com/)
• Capital IQ Pro (https://www.capitaliq.spglobal.com/)
• Capital IQ (https://www.capitaliq.com/)
• XpressFeed
(https://www.spglobal.com/marketintelligence/en/solutions/xpressfeedtm)
• Panjiva Platform (https://panjiva.com/platform)
S&P Global has no actual knowledge that it sells or shares the personal
information of consumers under 16 years of age.
* Brazil
This Brazil Addendum ("Brazil Addendum") supplements this Policy to the
extent that the General Data Protection Law of Brazil ("LGPD") applies in
relation to the processing of personal information by S&P Global. In case of
any inconsistencies between this Brazil Addendum and the rest of this Policy,
this Brazil Addendum prevails.
Under the LGPD, you have the right to:
• confirm the existence of processing of your personal data;
• access your personal data;
• correct incomplete, inaccurate, or out of date personal data;
• anonymize, block, or delete unnecessary or excessive personal data or
personal data that is not being processed in compliance with the LGPD;
• portability of your personal data to another service or product provider,
by means of an express request;
• delete personal data processed with your consent;
• information about public and private entities with which we have shared
your personal data;
• information about the possibility of denying consent and the consequences
of such denial;
• revoke consent;
• request review of decisions taken solely on the basis of automated
processing of personal data that affects your interests.
You or an authorized agent may exercise your rights through the Personal Data
Request Form. The LGPD also provides that you may file a complaint regarding
your data directly with the Brazilian data protection regulator.
Data Protection Officer
c/o Commercial Legal
Rua do Passeio 38/40
Rio de Janeiro
Brazil
* Colombia – Additional Provisions
This Colombia Addendum ("Colombia Addendum") supplements this Policy to the
extent that the law of Colombia applies in relation to the processing of
personal information by S&P Global. In case of any inconsistencies between
this Colombia Addendum and the rest of this Policy, this Colombia Addendum
prevails.
Data Subject Rights
Subject to applicable law, you have the right to:
• freely access your personal information;
• know, update, and correct personal information when data is inexact,
incomplete, fragmented, misleading, or where processing is not authorized or
prohibited;
• request proof of authorization to process your personal information, unless
exempted under applicable law;
• bring complaints to the Superintendent of Industry and Commerce;
• revoke authorization and/or require the deletion of personal information
when there is not a legal or contractual reason to keep the personal
information; and
• decline authorization for the processing of sensitive personal information.
The provision of sensitive personal information or the personal information
of minors is optional.
Principal Place of Business
S&P Global Colombia SAS (NIT #900.505.649-2) has its principal place of
business at Carrera 19A No 90 – 13 Bogotá, Colombia.
* Republic of South Africa Addendum
This South African Addendum (“South African Addendum”) applies in relation to
the processing of personal information by the S&P Global responsible parties
listed below in the Republic of South Africa and supplements the information
set out above in this Policy. In case of any inconsistencies between this
South African Addendum and the rest of this Policy, this South African
Addendum prevails.
1. Responsible Parties.
S&P Global responsible parties that may process personal information from
time to time include:
• SPGI Indices UK (Incorporated in United Kingdom) External Profit Company
South Africa, registration number 2013/147353/10
• SPGI UK (Incorporated in England) External Profit Company, registration
number 2012/065136/10
• S&P Global Ratings Europe Limited (Incorporated in Ireland) External Profit
Company, registration number 2017/655416/10
• S&P Global Ipreo Limited (Incorporated in United Kingdom) External Profit
Company, registration number 2005/035402/07
2. Personal information of juristic persons
In addition to the individual’s personal information collected as set out in
this Policy, we process information relating to South African juristic
persons, which may constitute personal information for purposes of the
Protection of Personal Information Act of South Africa. The personal
information relating to South African juristic persons we process includes:
• A company’s or other juristic person’s name, address, telephone number,
email address, company registration number, and company contact’s name;
• A company’s or other juristic person’s incorporation documents, tax
numbers, audited financial statements, B-BBEE certificates, and bank account
records;
• A company’s or other juristic person’s representative’s details, including
their name, email, telephone numbers, job title, job function and details
relating to the area of work;
• A company’s or other juristic person’s product or specification
requirements; and
• Information related to product support interaction and product training
information, to the extent that this information is identifiable.
We collect the information directly from the juristic person concerned or its
representatives during negotiation, when preparing and concluding agreements
and during implementation or use of products/services for their users. We may
also collect the information from the client’s employee users when they
register and use products/services or obtain the information that has been
made publicly available via the internet and website searches or when the
client’s employee user otherwise gives S&P Global their contact details.
3. Purposes and legal basis for the processing of personal information of
juristic persons
The purposes of the processing of the abovementioned personal information
include:
• To identify clients and prospective customers;
• To market and sell products to clients;
• To negotiate and enter into contracts with clients;
• To obtain permission from clients and their users;
• To conduct training and to provide support to clients/users;
• To record client engagements and conversations;
• To invoice and collect from clients and account for client revenue;
• To comply with applicable statutory obligations;
• To carry out and manage our business operations and for any other
legitimate business purposes; and
• In connection with our products and services.
Generally, we process the above personal information for purposes of the
performance of a contract with a client, or where we have the consent of the
client or the juristic person concerned, or on the basis that it is in our
legitimate interests or that of a third party to whom the information is
supplied for purposes of, amongst other things, marketing and selling our
products and services, supporting client access to and use of our products,
providing training to users of our products, responding to client or user
queries, improving products and services, advising users of product features,
new releases or maintenance.
The personal information of juristic persons may be shared with third parties
and transferred to countries outside of South Africa. Please see the relevant
provisions of the Policy in this regard.
4. Laws authorizing or requiring the collection of the personal information.
The legislation in terms of which personal information of individuals or
juristic persons may be required to be processed includes:
• The Financial Intelligence Centre Act, 2001;
• The Income Tax Act, 1962; and
• The Company’s Act, 2008.
5. Sensitive Personal Information.
To the extent applicable, information relating to an individual’s religious
or philosophical beliefs, race or ethnic origin, trade union membership,
political persuasion, health or sex life, biometric information or criminal
behavior, including any photographs or video recordings of may be considered
as sensitive/special personal information in accordance with applicable South
African law and regulations. We will use an individual’s special personal
information for the purposes as stated in this Privacy Policy, or as
otherwise as notified to you from time to time.
6. Contact us. If you have any questions or concerns about this Addendum or
the Policy you may contact the Information Officer at privacy@spglobal.com,
or in accordance with the information provided in the Policy under “How to
contact us”. We will reply to your request within reasonable period of time
and in any event within 30 days. We may require you to verify your identity.
GLOBAL CORPORATE PRIVACY POLICY
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Download Privacy Policy as PDF
Our Privacy Commitment
* Introduction
* INTRODUCTION
* What is this Policy about?
Update Effective: December 30, 2022
S&P Global Inc. and its affiliates (collectively or individually, as
applicable, referred to as "S&P Global", "we", "our", "us") respect your
right to privacy. This global Corporate Privacy Policy (“Policy”)
explains who we are, how we collect, share, transfer and use personal
information about you, and how you can exercise your privacy rights.
This Policy applies to interactions we have with you via our websites,
applications and other products and services including events, where you
otherwise contact us and where we otherwise display or link to this
Policy (“Services”) or in the course of our receipt of products or
services from you or your employer.
Please note that some privacy rights and obligations may differ in
certain locations based on applicable local data protection laws. We
have included supplemental information for certain jurisdictions in this
Policy.
Third parties that link from or to our Services, or from whom we collect
personal information may have their own privacy policies and practices.
This Policy does not apply to sites or applications offered by other
companies or individuals, including third party products and services,
that may be displayed as content in a search on our website. Please
review any third-party policies to learn more about their practices.
To the extent a notice provided at the time of collection from a website
or specific product conflicts with this Policy, the terms of that
specific notice or supplemental privacy statement will apply.
If you enter into a separate agreement with us which requires, or
contemplates, collecting, sharing, transferring, using or otherwise
processing information about you in a manner that is different than that
which is described in this Policy, the terms of that agreement will
apply.
For more about the S&P Global’s commitment to privacy, please see the
privacy mission statement and resources at:
https://www.spglobal.com/en/privacy/our-privacy-commitment.
* What does S&P Global do?
* WHAT DOES S&P GLOBAL DO?
* What does S&P Global do?
S&P Global is a leading provider of transparent and independent ratings,
benchmarks, analytics and data to the capital and commodity markets,
businesses and governments worldwide. For more about the S&P Global
current group companies and other related companies, please see our
latest filing here.
* Personal information we collect
* PERSONAL INFORMATION WE COLLECT
* What personal information does S&P Global collect and why?
The information that we collect from or about you - some of which is
personal information under applicable data protection laws - falls into
the following broad categories:
1. INFORMATION THAT YOU PROVIDE TO US
As part of our Services, you may provide certain information to us, such
as your contact details, user credentials, and employment information.
A few examples include, when you fill out an on-line form to register
to use our Services, such as to attend an event, to request a free trial
or courtesy newsletter, or to receive research, white papers, product
information or reports through our website. You may also provide us with
your business card information or other contact information as you
conduct business with us or you request information from us. Information
we ask you for and why we ask you for it includes:
Types of personal information
Why we collect it
Billing information (including your payment card information)
To maintain your account with us and to provide you with requested
products and services.
For order processing and to provide transaction documents.
Contact details such as name, telephone numbers (which may include
cell/mobile numbers), email address and postal address and details of
any correspondence between us.
To respond to your communications and inquiries, such as when you want
to learn more about our conferences and webinars.
If requested, to provide product service updates, information and
alerts.
To contact you for information verification purposes.
To gather information needed to provide and deliver maintenance,
support, and training for Services requested by you or your employer.
To obtain your feedback regarding our Services, including an event you
attended, such as when we or our agents send you a customer satisfaction
survey.
To receive services from you or the corporate entity you represent.
User credentials including name, email address, signature and any
personal login information you provide to us when you create a profile,
such as details of your education and your gender.
Some product platforms also allow users to upload data themselves
including age, race, color, ancestry, national origin, citizenship,
religion or creed, marital status, sex (including gender, gender
identity, pregnancy or childbirth and related medical conditions),
sexual orientation, veteran or military status, for their updates,
information and alerts.
To set up and maintain your user account.
To monitor and enforce compliance with our contract terms.
To enable clients to use our product platforms for their own purposes.
Employer and employment information such as job title, company
affiliation, function, seniority, department and location of your
office.
To manage your individual user account when it is covered by an account
of an S&P corporate customer, such as the corporate account of your
employer.
Your preferences and interests, such as emails and newsletters you would
like to receive, or have opted out from receiving, or the markets,
industries and conferences that interest you.
We may record (voice or audio) and/or collect images of you, provided
that you do not object (and that you have opted in where required by
law), for example at an in-person or virtual event.
To provide the event content to individuals who were not able to attend
the live event, to promote our events in live recordings, or to
otherwise provide event content. In some instances we may also use
technology to create automated transcriptions.
To enable us to send you tailored information on our Services across our
divisions that may interest you, to allow you to participate voluntarily
in mailings and other events and to allow us to promote our events and
Services.
Social security/Official identification number, state identification
card number, credit card numbers, and personal financial data (such as
specific salary, mortgage details, net worth or individual portfolio
information). We refer to this type of personal information as "Customer
Financial Data".
In some cases, our corporate customer, such as a structured finance
issuer or you, may provide Customer Financial Data to us for the purpose
of informing our statistical analysis or for our use in providing our
Services. Customer Financial Data will not be used for purposes other
than these and will not be rented or otherwise made available to third
parties for public distribution.
For conducting due diligence activities for financial institutions and
other regulated companies as part of our know-your-client products.
Issues, questions and problems you have when using our Services, your
user preferences and how you use or want to use our Services and
information which you seek to analyse or manipulate within our Services
and which you communicate to our support, maintenance and training
staff. We may also record telephone service calls with you, subject to
an announcement at the beginning of the call. In some instances, we may
also use technology to create automated transcriptions.
To maintain your account with us, provide technical support to that
account, remedy issues or problems with that account, train you in the
use of our Services and keep an auditable record of all such
communications and actions which is accessible to our support,
maintenance and training staff globally.
2. Information that we collect automatically
We may collect information automatically from your device, including
information regarding how you use our Services. Where required by law, w
will obtain your consent before we place any cookies on your device that
are not strictly necessary for the functioning of our websites.
Information we may collect automatically includes your log-in events
(when, how and for how long you log into and use certain Services), IP
or MAC address, device make, model and operating system, mobile network
information, internet service provider, unique device identification
number, advertising ID, browser type and language, geographic location
(e.g., country or city level location or time zone) and other technical
information. We may collect "click stream" data, which is information
about how your device interacts with our Services, such as the pages,
screens, functions, applications and products accessed and links
clicked.
This information helps us understand users of our Services, such as
visitors to our websites, the pages they visited before and after and
what content and functions interest them. We use this automatically
collected information:
- for our analytics purposes, including to enhance our understanding of
usage of our Services;
- to improve the quality and relevance to users of our Services,
including (with consent as applicable) by showing or offering users
relevant Services or content based on their preferences and usage
habits;
- to develop or accelerate research, analysis, news and related
editorial content and information collection as part of our Services, or
to enable others to develop/accelerate such content where permitted;
- to offer you support with and training on our Services and to help
resolve any errors or technical issues;
- to develop and update our Services;
- for customer services, such as evaluating our customers' training
needs for our products;
- to satisfy requests from S&P Global corporate customers regarding the
entitlement to and use of our Services by individual users under their
corporate accounts (this information may be offered to clients in an
aggregated form and clients may be required by law to request certain
information);
- to deliver tailored information on our Services that may be of
interest or value to you and to send you marketing and promotional
emails with your consent if required by applicable law;
- occasionally, to identify unauthorized use or unauthorized
distribution of our Services related or unrelated to a security issue;
- where relevant, to review or update pricing agreed with our customers;
and
- for billing purposes, so that we or others (such as our content
providers) can bill for the services provided.
Some of this information is collected using cookies, weblogs, web
beacons and similar tracking technology - see "How does S&P Global use
cookies and similar tracking technology?"
3. Information that we obtain from other sources
We may receive personal information about you from other sources
(including your employer or business partner if you use Services covered
by a subscription). Where you register as a user, we will endeavor to
check that these third parties have your consent or are otherwise
legally permitted or required to disclose your personal information to
us.
The information we collect from your employer (if you use our Services
under your employer's corporate subscription) consists of your contact
details and employment-related information.
We collect personal information from other third parties, such as
marketing vendors, survey services, social media, conferences and other
events that we or others organize, and other sources to the extent
permitted by applicable law. We use this information to market our
Services to you, to maintain and correct our records, to add data
fields, and to enhance the marketing, delivery, and support of our
Services to you.
We collect personal information as part of our content collection
process for some of our products. We obtain this from a variety of
sources, including third-party content providers, public filings, direct
communication with your employer or appointor, and websites to display
within some of our products. Find out more at "How does S&P Global use
personal information in products?"
The automotive business collects and compiles motor vehicle registration
and title information to provide products and services to authorized
entities pursuant to 18 U.S.C A. §2721 and similar state laws governing
the use of such information. Consumer information from motor vehicle
records is used in compliance with the governing laws and regulations
and thus not used by S&P Global or provided to other entities by us for
direct marketing purposes. To access or correct your motor vehicle
registration and/or title information, you must contact your state's
department of motor vehicles or other state agency that processes motor
vehicle titles and registration. The American Association of Motor
Vehicle Administrators maintains links to state motor vehicle agency
websites, organized by AAMVA regions.
We also may use your personal information for other purposes that we
explain to you at the time we collect your personal information or, if
permitted by applicable data protection laws, that are compatible with
the purposes we have disclosed to you (such as archiving purposes in the
public interest, scientific or historical research purposes, or
statistical purposes).
S&P Global policies, procedures and standards require that the
information in its products is updated for accuracy on a regular basis
and removed from its systems when such data becomes obsolete or
inaccurate. S&P Global has established information governance standards
for collection, use and retention of personal information.
To the extent we maintain and use personal information in a deidentified
or anonymized form, we will not attempt to reidentify the information,
except for the purpose of determining whether our deidentification/
anonymization processes satisfy our legal obligations.
4. OTHER PERSONAL INFORMATION COLLECTED THROUGH OUR MOBILE APPS
When you download, access or otherwise use one of our mobile apps, the
information that we collect depends on your device, in-app and operating
system permissions. Our apps may require access to applications and/or
data on your mobile device to function. When you agree, some of our apps
collect the precise geo-location of your mobile device and some of our
apps also collect information that may be personal information about
your or others, from or about:
• Your calendar
• Your contacts and call information
• The accounts and other apps on your mobile device
• Photos (including date, time, location and contents)
• Media files, metadata and other stored information
We may also automatically collect app logs and usage statistics. For
example, we may record when you open an app so that we can monitor which
app is used, when and how, and if the app stops working, we log the
"crash data," such as whether you have mobile reception, to help us
identify and fix the cause.
To learn more about the specific information collected by any of our
mobile apps, please check your device settings or review the platform
from which you downloaded it. To stop collection of all information
through one of our apps, please uninstall the app.
* Sharing of personal information
* SHARING OF PERSONAL INFORMATION
* When does S&P Global disclose my personal information?
The categories of personal information listed in the S&P Global "What
personal information does S&P Global collect and why?" section above may
be disclosed to the following categories of recipients:
Our group companies and our joint venture companies where applicable,
service providers including without limitation professional advisers or
consultants such as lawyers, bankers, auditors, accountants and insurers
providing consultancy, legal, banking, audit, accounting or insurance
services, financial institutions providing finance to us, external
auditors, product content providers, business partners and any
organization that arranges your access to our products or services (if
that is not you).
We share personal information with those authorized parties referred to
above for purposes consistent with those described in this Policy or as
notified to you when your personal information is collected. For
example, we may share your personal information with the organization
that arranges your access to our products or services to fulfill its
contractual obligations and to provide our products and services,
support, and training for them. We may share your personal information
with our service providers and business partners for the purpose of
operating our business, honoring a request that you have made through
the products or services, delivering, improving and customizing our
products or Services, sending marketing and communications related to
our business, payment processing, and for other legitimate purposes
permitted by applicable law or otherwise with your consent. We may share
the contact information you provide when registering for an event and
share event attendee lists between our S&P Global divisions and with our
webinar and conference partners, to ensure that your contact information
is up to date and to administer, secure, and seek feedback on and
promote our events.
For a list of our current group companies and related companies, please
see our latest filings here. A list of our service providers, content
providers and business partners is available here. For information about
the disclosure of the California enumerated categories please see the
California jurisdictional section below.
In addition to the purposes described in this Policy, personal
information handled by our service providers may be subject to their
terms of use and privacy policies, which if applicable, will be provided
to you. Please review any applicable service provider’s terms of use and
privacy policies to better understand how they manage your personal
information.
Your employer
We may provide personal information to your employer for purposes such
as to fulfill and enforce our contract with them, to inform them of
potential group training needs, to inform them of Service use by certain
categories of users and for pricing purposes.
Competent law enforcement bodies, regulatory, government agency, court
or other third parties
We may provide personal information to any competent law enforcement
body, regulatory, government agency, court or other third party in
accordance with applicable law and regulation when we believe disclosure
is necessary (i) as a matter of applicable law or regulation, (ii) to
protect against fraud or for risk management purposes, (iii) to
cooperate with relevant agencies for the investigation and prevention of
crimes such as insider trading, (iv) to exercise, establish or defend
our legal rights, (v) to protect your vital interests or those of any
other person, or (vi) to protect the interests, rights, safety or
property of us or others.
S&P Global is regulated by various federal and state agencies,
authorities and similar regulatory bodies internationally and, in the
normal course of business, both in the United States of America and
abroad, is the subject of government and regulatory proceedings,
investigations and inquiries. We may therefore disclose your information
to comply with a court order, government request or other legal or
regulatory process, sometimes without prior notice to you.
Our SEC filings set this out in more detail and are available here.
Potential Buyers
We may provide personal information to a potential buyer or a target
(and that third party’s or our agents and advisers) in connection with
any proposed sale, purchase, merger, transfer, acquisition or
liquidation or similar event, of all or any part of our businesses. If
such a change happens to our business, the buyer or target will use your
personal information in the same way as set out in this Policy or will
inform you about how it will use your personal information as required
by applicable law.
Other third parties
Personal information that you disclose on message boards, chat areas or
social media pages or in direct messages to other users of these
platforms may be collected and used by third parties to contact you, to
send you unsolicited messages or for other purposes without our
knowledge or control. Social media forums and chat rooms not operated by
us may have additional rules and conditions. We are not responsible for
the personal information or any other information you choose to submit
on these forums that are not controlled by us.
The Services may offer you the ability to share personal information
through a social networking site (e.g., Facebook, Twitter) using
integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet”
button). The use of such integrated tools enables you to share personal
information about yourself with other individuals or the public,
depending on the settings that you have established with such social
networking site. For more information about the purpose and scope of
data collection and use in connection with such social networking sites
or a site’s integrated tools, please visit the privacy policies of the
entities that provide these social networking sites.
We encourage you to use caution when publicly disclosing your personal
information.
We may ask for your consent to share your information with other
unaffiliated third parties who are not described elsewhere in this
Policy.
For more information about how and why we disclose the personal
information that features in our products, please see "How does S&P
Global use personal information in products?" below.
* Legal basis for processing personal information
* LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
* What is our legal basis for processing personal information?
Our legal basis for collecting and processing personal information
depends on the personal information concerned, the context in which we
collect it and the applicable laws and regulations.
Generally, we collect personal information from you where: we have your
consent to do so; we need the personal information to perform a contract
with you (for example, your subscription to one of our products) where
permitted under applicable data protection laws; or, in some
jurisdictions such as the European Economic Area (“EEA”), the processing
is in our legitimate interests and not overridden by your data
protection interests or fundamental rights and freedoms or the
processing is otherwise consistent with applicable law. In some cases,
we are required by law to collect personal information from you.
If we ask you to provide personal information to comply with a legal
requirement or to perform a contract with you, we will inform you
whether the provision of your personal information is mandatory and the
possible consequences if you do not provide your personal information.
Where we send you marketing or promotional e-mails regarding our
Services from our different divisions and affiliates, we do so based on
your consent, if required by applicable law.
Generally, if we collect and use your personal information in reliance
on our legitimate interests (or those of a third party), this interest
is to provide our Services to you and for our legitimate commercial
interest (e.g., when responding to your queries, improving our Services,
processing payments, advising you of product features or new releases,
providing training, informing you of product maintenance, or undertaking
marketing activities). For the legal basis on which we rely in relation
to personal information in our products, please see "How does S&P Global
use personal information in products?".
* Cookies and similar tracking technology
* COOKIES AND SIMILAR TRACKING TECHNOLOGY
* How does S&P Global use cookies and similar tracking technology?
Generally, we use cookies and similar tracking technology (collectively,
"Cookies") in certain Services (in particular our websites and some
mobile applications) to collect and use personal information about you,
in order to better understand and improve the usability, performance,
and effectiveness of our Services, to help us tailor content or offers
for you, and to serve our targeted, interest-based advertising. These
technologies may also allow certain third parties to collect information
about you over time and across different websites, such as information
about you clicking on advertisements or installing our Services. Where
permitted by applicable law, we will deploy first party performance or
analytics Cookies automatically when you visit our websites. Where
required by applicable law, we will obtain your consent before we place
any Cookies on your device that are not strictly necessary for the
functioning of our websites. To learn more, including about how to
consent to or opt-out and withdraw your consent to Cookies, please see
our Cookie Notice.
We may use Google Analytics to better understand how visitors use our
Services. Google Analytics provides us with information about users of
our Services. Google Analytics uses Cookies that Google or its affiliate
DoubleClick recognizes when you visit other websites and applications.
For more information about how Google collects, uses, and shares your
information, including information collected through our Services,
please visit the Google Privacy Policy - Partners website at
https://policies.google.com/technologies/partner-sites or see Google’s
own Privacy Policy at https://policies.google.com/privacy.
Google Analytics uses Cookies to help us analyze how users use our
Services. Personal information generated by these Cookies about your use
of our Services (including your IP address) will be transmitted to and
stored by Google on servers in the United States of America. On our
behalf, Google will use this information to evaluate your use of our
Services and will compile reports on your activity for us.
If you want to opt out of Google Analytics, you can download and install
the opt-out browser add-on developed by Google for your web browser. For
more information about Google Analytics' currently available opt-outs,
please see https://tools.google.com/dlpaqe/gaoptout.
For more information about our privacy practices relating to our
advertising services, please see the Digital and advertising-related
services section of this Policy.
* Keeping your personal information secure
* KEEPING YOUR PERSONAL INFORMATION SECURE
* How does S&P Global keep my personal information secure?
We protect personal information that we process with appropriate
technical and organizational measures designed to provide a level of
security appropriate to the risk of processing your personal
information. We will notify you about any security incident involving
your personal information through email, correspondence, telephone, push
notification or other means, as required by applicable law. If you think
your data is the subject of a security incident and we have not notified
you, or if you are concerned about the security of your data, please
contact our dedicated security team at security@spglobal.com.
* International data transfers
* INTERNATIONAL DATA TRANSFERS
* How does S&P Global treat international data transfers?
Your personal information may be transferred to, and processed outside,
the jurisdiction in which you reside. These other jurisdictions may have
data protection laws that are different from the laws of the
jurisdiction of your residence (and, in some cases, not as protective).
S&P Global is a multi-national group with headquarters in New York,
United States of America. Our servers may be located outside of the
jurisdiction where we collected the data. We may store and replicate
your personal information on servers in other jurisdictions, in order to
provide speed of access, robustness and protection against server
failure.
When we collect your personal information, we may transfer it to or from
any of the countries in which we do business. Our group companies,
related companies, any organization that arranges your access to our
products or services service providers, product content providers and
business partners, with whom we may share personal information, are
located in and transfer personal information to various jurisdictions
around the world. The principal jurisdictions where personal information
is hosted by or on behalf of S&P Global are the United States of
America, Canada, the United Kingdom, Germany, the Republic of Ireland,
Italy, France, Switzerland, the Netherlands, India and Singapore. In
some cases, your personal information may also be accessed from outside
of the jurisdiction where we collected the data, such as the
Philippines, India and Pakistan, where our back-office support personnel
are located for certain Divisions.
Where your personal information is transferred by us or on our behalf,
we implement appropriate safeguards to protect your personal information
in accordance with this Policy. These safeguards include implementing
applicable standard contractual clauses for transfers of personal
information between our group companies, which require group companies
to protect personal information they transfer from the jurisdiction in
which it was collected in accordance with applicable data protection
law.
Where required by applicable law, international transfers take place
only when there is an adequate level of protection to the fundamental
data protection rights of individuals. In some circumstances, we may
choose to rely upon an adequacy decision to lawfully transfer personal
information. Standard contractual clauses are one of several mechanisms
that allow for personal information to be transferred across
jurisdictional borders and we my rely on these for transfers to and from
our affiliates, vendors and business partners where applicable.
Additional safeguards may also be implemented where personal information
is transferred. Please contact us to request a copy of our appropriate
safeguards.
* Data retention
* DATA RETENTION
* For how long does S&P Global retain personal information?
Our applicable information governance policies, procedures and standards
require that personal information be retained for as long as we have an
ongoing legitimate business need to do so (for example, to provide you
with a Service you have requested, or to comply with applicable legal,
tax or accounting requirements).
Once we no longer have a legitimate business need to process your
personal information, our applicable information governance policies,
procedures and standards require that we either delete or anonymize your
personal information, or if deletion or anonymization is not possible,
then pseudonymize and/or securely store your personal information and
isolate it from any further processing until deletion is possible.
If you have any questions or require any further information about the
period of time for which we will process your personal information,
please contact us using the contact details set out below.
* Your data protection rights
* YOUR DATA PROTECTION RIGHTS
* What are your data protection rights?
Depending on which laws apply to your personal information, you may have
the right to make the following requests regarding your personal
information:
- Access to Your Personal Information. You may request access to your
personal information or confirmation that we have information about you.
In certain limited circumstances, you may also request to receive access
to your data in a portable, machine-readable format.
- Deletion Of Your Personal Information. You may request that we delete
your personal information. If required by law, we will grant a request
to delete information, but you should note that in many situations we
must keep to comply with our legal obligations, resolve disputes,
enforce our agreements, or for another business purposes.
- Corrections To Your Personal Information. We rely on you to update and
correct your personal information. Where your personal information is
required to access or use Services, you may have the opportunity to
correct, update, or modify this information by logging into your account
and updating your information online. You may ask us to correct
information that is inaccurate or incomplete. Note that we may keep
historical information in our backup files as permitted by law.
- Objection to Certain Processing. You may object to our use or
disclosure of your personal information by contacting us at the address
described below.
- Opt-out of Targeted Advertising You may opt-out of online tracking
based targeted advertising or cross-context behavioral advertising
(e.g., cookies) by clicking the cookie settings link on the footer of
our websites. Please note that if you change browsers or computers, or
if you clear your browser’s cache, you may need to click the link again
to apply your preference.
- Opt-out of Sale. You may opt-out of the sale of your personal
information by clicking here or the “Do Not Sell My Personal
Information” link on our homepage.
- Restrict Processing. You may request that we restrict our processing
of your personal information under certain circumstances, such as when
you contest the accuracy of our records about you, or you make an
objection.
- Promotional Emails. You may choose to provide us with your email
address for the purpose of allowing us to send free newsletters,
surveys, offers, and other promotional materials to you, as well as
targeted offers from third parties. You can stop receiving promotional
emails by following the unsubscribe or “opt-out” instructions in emails
that you receive, by visiting our preference center here or by using the
contact details listed on this page. If you decide not to receive
promotional emails, we may still send you service-related
communications.
- Revocation Of Consent. Where we process your personal information
based upon consent, you may revoke consent. Withdrawing your consent
will not affect the lawfulness of any processing we conducted before
withdrawal, nor will it affect processing of your personal information
conducted in reliance on lawful processing grounds other than consent.
Please note, if you revoke your consent for the processing of personal
information then we may no longer be able to provide you services.
Please note, not all of the rights described above are absolute, and
they do not apply in all circumstances. In some cases, we may limit or
deny your request because the law permits or requires us to do so,
because a right is not granted by the laws that apply to a specific
person, or if we are unable to adequately verify your identity.
Individuals in certain jurisdictions may have other rights. For more
information, see the applicable jurisdiction-specific addendum which
forms part of this Policy. We will not discriminate against individuals
who exercise their privacy rights under applicable law.
You may use this Personal Information Request Form or call us on
1-855-529-1761 to exercise any of your rights. If you disagree with how
we handled a request, you may appeal our decision by contacting us with
the subject line “Appeal,” at privacy@spglobal.com.
We respond to requests we receive from individuals wishing to exercise
their data protection rights or express any concern in accordance with
applicable data protection laws, which typically require a response
within 30 days. Please be aware that in order to accommodate some
requests, we must verify your identity before we can respond, and this
may require you to provide photographic or other forms of identification
to us.
In some circumstances, you may designate an authorized agent to submit
requests to exercise certain privacy rights on your behalf. If you are
an authorized agent submitting a request on behalf of an individual, you
must provide all requested information establishing your authorization
as an agent to act on another person’s behalf.
If you are not satisfied with our response, and are in the European
Union or United Kingdom, you may have a right to lodge a complaint with
your local supervisory authority. Contact details for data protection
authorities in the EEA, Canada, Switzerland and the UK are available
here.
Please note that in certain jurisdictions we may be entitled to charge a
fee in connection with the exercise of these rights, which will be
communicated to you if applicable.
* Updates to this Policy
* UPDATES TO THIS POLICY
* What happens if this Corporate Privacy Policy is updated?
We review and update this Policy from time to time. When we do, we will
bring those updates to your attention, for example, by noting the date
of the version on the Policy, posting the updated version here or
sending you a notification. To the extent that this Policy changes in a
material way, the Policy that was in place at the time that you
submitted personal information to us will generally govern that
information unless we receive your consent to the new policy.
* How to contact us
* HOW TO CONTACT US
* How can you contact us?
If you have any questions or concerns about our use of your personal
information, or if you need to access this Privacy Policy in an
alternative format due to having a disability, please contact our
Privacy Compliance team at privacy@spglobal.com, 1-855-529-1761, or 55
Water Street, New York, NY 10041.
You may also use this personal data request form to contact us or
exercise any of your rights.
In some of our locations, we also have local contact details that you
may prefer to use as set out in the following jurisdictional
supplements:
• Russian Federation
• People’s Republic of China
• Japan
• State of California, United States of America
• Brazil
• Colombia
For the Philippines, you may also use email DPOPhilippines@spglobal.com.
European Union Contact Details for non-European Union S&P Global
Entities and Affiliates
Certain S&P Global entities located outside the European Union (“EU”)
have appointed representatives within the EU. If you are an EU resident,
you may choose to contact the relevant EU representative for any data
protection-related enquiries in addition to, or instead of, the contact
details above. Please use the applicable contact details below.
S&P Global Ratings
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
RatingsGDPR@spglobal.com
S&P Global Market Intelligence
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
MlPrivacyOfficer@spglobal.com
S&P Dow Jones Indices
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
spdjiGDPR@spglobal.com
S&P Global Commodity Insights
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
PlattsGDPR@spglobal.com
S&P Global Engineering Solutions
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
PlattsGDPR@spglobal.com
S&P Global Mobility
Fourth Floor, Waterways House
Grand Canal Quay
Dublin 2, Republic of Ireland
PlattsGDPR@spglobal.com
UK Contact Details for non-UK S&P Global
Certain S&P Global Inc. and its applicable affiliates located outside
the UK have appointed representatives within the UK. If you are a UK
resident, you may choose to contact the relevant UK representative for
any data protection-related enquiries in addition to, or instead of, the
contact details above. Please use the contact details below by
division.
S&P Global Ratings
20 Canada Square
Canary Wharf
London
E14 5LH
RatingsGDPR@spglobal.com
S&P Global Market Intelligence
20 Canada Square
Canary Wharf
London
E14 5LH
MlPrivacyOfficer@spglobal.com
S&P Dow Jones Indices
20 Canada Square
Canary Wharf
London
E14 5LH
spdjiGDPR@spglobal.com
S&P Global Commodity Insights
20 Canada Square
Canary Wharf
London
E14 5LH
PlattsGDPR@spglobal.com
S&P Global Engineering Solutions
20 Canada Square
Canary Wharf
London
E14 5LH
PlattsGDPR@spglobal.com
S&P Global Mobility
20 Canada Square
Canary Wharf
London
E14 5LH
PlattsGDPR@spglobal.com
* Digital and advertising-related services
* DIGITAL AND ADVERTISING-RELATED SERVICES
* Digital and advertising-related services
S&P Global’s Markit Digital advertising services (Markit Digital
Advertising) provide ad serving and marketing optimization solutions for
the financial services sector. Markit Digital's advertising services
never collect financial account information or any Directly Identifying
Personal-Information for advertising purposes.
In some circumstances, Markit Digital collects information for use in
tailored ads shown within the same browser. Markit Digital is a member
of the NAI (Network Advertising Initiative) and the IAB (Internet
Advertising Bureau) and abides by the NAI code of conduct and IAB
requirements.
COLLECTION AND USE OF PERSONAL INFORMATION
Advertisements served from our advertising domain, ad.wsod.com, do not
collect Directly Identifying Personal-Information.
COLLECTION, USE AND SHARING OF NON-PERSONAL INFORMATION
While advertisements served from ad.wsod.com do not collect information
that can directly identify an individual, the system does collect
information including the time and date of an ad served, the type of
browser and operating system used, the visitor's IP address, and the URL
visited. Additional information may be provided by publishers,
advertisers, or third parties. This information is not used to identify
anyone personally; it is used for aggregated analytic reports, targeting
a Tailored Advertising experience, and for the purpose of site
administration and diagnostics.
This information may be shared with advertising clients or their
business partners at their direction.
COLLECTION OF NON-PERSONAL INFORMATION ON MOBILE DEVICES
Markit Digital may receive non-personal information, such as device
information and cookie identification from third party sources,
including Apple IDFA, Google AdID, and Android ID. Use of Cookies.
Advertisements served from ad.wsod.com set and use cookies and local
storage, when appropriate. The ad server uses cookies/local storage to
avoid additional database look-ups, but does not use any other systems
for persistently identifying users between views and visits. Cookies and
all data collected from ad.wsod.com is advertiser-specific and is not
shared between multiple advertisers, who may also be serving ads from
the domain. An advertiser's data belongs to that advertiser, as the
system used to serve ads from ad.wsod.com merely collects and
temporarily stores that data for Tailored Advertising. Attribution
cookies from Markit Digital's advertising services expire 30 days after
the user's last attribution event. Tracking cookies expire after 60
days; after that time a tracking cookie is no longer valid and a new one
is created. Opt-out settings in any cookies, along with assigned
segments, expire after five years (less intervening leap-year days).
DATA RETENTION
Markit Digital retains unidentifiable user-level information collected
by our advertising system for up to 2 years in both aggregated and
un-aggregated forms.
INFORMATION RELATING TO CHILDREN
Our products and services are designed for those 16 years of age and
older. We do not knowingly collect information from anyone under the age
of 16. If we are made aware that we have received information from
someone under 16, we will use reasonable efforts to remove that
information from our records.
OPTING OUT OF TAILORED ADVERTISING (TA)
Tailored Advertising (TA), also known as Interest-based Advertising
(IBA) or Online Behavioral Advertising (OBA) – is the process of
targeting specific advertisements to each individual user, based on
browsing history. If you opt-out of Tailored Advertising from our
service using the tools below, the cookie and any local storage we use
to contain this information will be emptied and changed to a placeholder
signaling that you have opted-out. If you delete the placeholder cookie
or locally-stored code, clear all cookies or local storage, or reset or
reinstall your browser, you will need to opt-out again. Cookies and
local storage data are browser- and device-specific, so you will need to
opt-out from within each browser and computer/device, if you regularly
use more than one. After opting-out, you may continue to see digital
advertising from us, but it will no longer be targeted to you based on
your browsing history. Opting-out does not necessarily delete or replace
all cookies or local storage from our domain; some may remain which are
used for aggregate reporting on the performance of the advertisements we
serve.
CONSUMER OPT-OUT
The Network Advertising Initiative (NAI) provides information to help
you learn more about online advertising
(http://www.networkadvertising.org/understanding-online-advertising), as
well as a service to help you opt out of interest-based advertising from
many organizations (http://www.networkadvertising.org/choices/). Markit
Digital does not sell personal information as defined by the California
Consumer Privacy Act (CCPA). However, Markit Digital still participates
in services allowing all site visitors to control the use of
Interest-based Advertising. Visit privacyrights.info to learn more about
CCPA and how you may opt-out from other organizations' use of your data.
By selecting the below opt-out, Markit Digital will respect your choices
for this browser, and they will be reflected here until you clear this
browser's cookies.
OPTING OUT ON YOUR MOBILE DEVICE
For information on Opting Out on Mobile Devices, please visit
https://www.networkadvertising.org/mobile-choice.
PRIVACY INQUIRIES
If you use our webform to correspond with us
( https://privacyportal.onetrust.com/webform/5cb57702-8ef7-437e-a62b-408fe78cd310/a2d05665-f8c3-44a2-ae58-d2015af31754),
S&P Global will receive your name, email and your country of residence.
S&P Global’s Markit Digital Advertising services never use this personal
information or any Directly Identifiable Personal Information for
advertising purposes.
INDUSTRY ASSOCIATIONS AND COMPLIANCE
Markit Digital participates in the Interactive Advertising Bureau's
Self-Regulatory Program for Online Behavioral Advertising
(http://www.iab.net/public_policy/self-reg).
Markit Digital adheres to and is annually reviewed for compliance with
the Network Advertising Initiative's Code of Conduct
(https://www.networkadvertising.org/code-enforcement/code).
Markit Digital adheres to the Digital Advertising Alliance's
Self-Regulatory Principles for Online Behavioral Advertising
(http://www.aboutads.info/obaprinciples).
* Russian Federation - Additional Provisions
* RUSSIAN FEDERATION - ADDITIONAL PROVISIONS
* Russian Federation
As of 30 September 2022, S&P Global has suspended operations in the
Russian Federation. Some processing of personal data may occur in
relation to any regulatory or legal obligations in the Russian
Federation, such as for the purpose of fulfilling tax, employment, and
any other legal obligations. Any ongoing processing of personal
information of Russian citizens is executed the Schneider Group, on
behalf of Standard & Poor’s International Services LLC and Moscow Branch
of S&P Global Ratings Europe Limited. For any questions about this
processing, please see the Schneider Group's Privacy Policy or contact
info@schneider-group.com.
* People’s Republic of China - Additional Provisions
* PEOPLE’S REPUBLIC OF CHINA - ADDITIONAL PROVISIONS
* China
This China Addendum (“China Addendum”) applies to the processing of your
personal information only if you are located in the People’s Republic of
China (“China”) and supplements this Policy. In case of any
inconsistencies between this China Addendum and the rest of this Policy,
this China Addendum prevails.
1. Sensitive Personal Information. Your personal information whose
leakage or unlawful use may easily infringe the dignity of a natural
person, or cause harm to the personal safety or property security,
including biometric characteristics, religious beliefs, specially
designated status, medical health, financial accounts, personal
whereabouts and personal information of minors under the age of 14 may
be considered as sensitive personal information in accordance with
applicable Chinese law and regulations ("Sensitive Personal
Information"). To the extent we collect this Sensitive Personal
Information, we will only process it to the extent necessary for
fulfilling the purposes as stated in this Policy and will take measures
for its security. Where required by applicable Chinese law and
regulations, we will obtain your separate consent before we process your
sensitive personal information.
2. Sale of business. We may provide personal information to a potential
buyer or target (and that third party’s or our agents and advisers) in
connection with any proposed purchase, merger, transfer, acquisition or
liquidation or similar event of all or any part of our business. If such
a change happens to our business, the buyer or target will use your
personal information as in the same way as set out in this Policy
including this China Addendum or will inform you about how it will use
your personal information as required by applicable law, or (where
applicable) require such third party to obtain your consent again.
3. Notifications. We cannot absolutely guarantee the security of any
information or data you provide online. In the event of a security
incident, we will take mitigation measures in accordance with our
incident response plan and report to competent regulators in China as
required by applicable law. In the event of a security incident
affecting your personal information, we will notify you as required by
applicable law through email, correspondence, telephone, push
notification or other means. If you think your data is the subject of a
security incident and we have not notified you, or if you are concerned
about the security of your data, please contact our dedicated security
team at security@spglobal.com.
4. Contact Information of our China DPO. You may contact our China Data
Protection Officer at privacy@spglobal.com or DPOChina@spglobal.com or,
at: 49/F, Fortune Financial Center, No.5, Dongsanhuan Zhong Rd, Chaoyang
District, Beijing. You may also exercise your rights in relation to
personal information transferred overseas or request closure of an
account which is registered with S&P Global through the method specified
under the section of this Policy titled, “What are your data protection
rights?”
* Japan - Additional Provisions
* JAPAN - ADDITIONAL PROVISIONS
* Japan
This Japan Addendum ("Japan Addendum") supplements this Policy to the
extent that the Act on the Protection of Personal Information (Japan)
applies in relation to the processing of personal information in Japan
by S&P Global Ratings Japan Inc., S&P Global SF Japan Inc., Standard &
Poor's International LLC, Japan Branch, IHS Markit Japan GK (together
"S&P Global Japan") and/or S&P Global entities located outside Japan. If
there are any inconsistencies between this Japan Addendum and the rest
of this Policy in relation to S&P Global's process of personal
information subject to the APPI, this Japan Addendum prevails.
S&P Global will comply with applicable Japanese data protection laws and
regulations, and not use personal information for purposes which are not
set forth in this Policy or otherwise communicated to the data subject.
The process for submitting a claim or request is set out in this Policy.
Joint-use of personal information inside of S&P Global Group
S&P Global Japan jointly uses personal information with other entities
in the S&P Global group who may use personal information to provide
information about our Services to our clients and related support and
training, conduct certain market research, contact clients, or engage in
other activities detailed in this policy. S&P Global Japan may also have
certain products that collect business information about individuals in
Japan. Such information includes: address, name, company name,
department name, job title, phone number, fax number, e-mail address,
billing information, history of personnel changes and professional
employment history, records of job interviews with S&P Global Japan,
your areas of interest, etc.
A list of our group companies is available here.
Name, address and name of representative of the person responsible for
the management of said personal data
S&P Global Ratings Japan Inc, S&P Global SF Japan Inc.
Marunouchi Kitaguchi Bldg. 28th Floor, 1-6-5 Marunouchi, Chiyoda-ku,
Tokyo 100- 0005
Representative Director Takenari Yamamoto
Standard & Poor’s International LLC Japan Branch
Marunouchi Kitaguchi Bldg. 28th Floor, 1-6-5 Marunouchi, Chiyoda-ku,
Tokyo 100- 0005
Representative in Japan Sachiko Katayama
IHS Markit Japan GK
3-1-1 Kyobashi, Chuo-ku, Tokyo 104-0031
Contact information regarding handling of personal information
If you have any questions or concerns about our disclosure, correction,
deletion, utilization, or other processing of your personal information
(including how we secure your personal information), please contact our
Privacy Compliance Team via email at privacy@spglobal.com or
Japanprivacy@spglobal.com or via mail, at: Marunouchi Kitaguchi Bldg.
28th Floor, 1-6-5 Marunouchi, Chiyoda-ku, Tokyo 100- 0005, Tel:
+81-(0)3-4550-8000.
* State of California, United States - Additional Provisions
* STATE OF CALIFORNIA, UNITED STATES - ADDITIONAL PROVISIONS
* State of California, United States of America
This State of California, United States of America Addendum ("California
Addendum") supplements this Policy to the extent the California Consumer
Privacy Act as amended by the California Privacy Rights Act ("CCPA")
applies in relation to the processing of personal information of
residents of the State of California in the United States of America by
S&P Global. In case of any inconsistencies between this California
Addendum and the rest of this Policy, this California Addendum prevails.
Certain information we collect may be exempt from the CCPA because it is
considered public information (i.e., it is made available by a
government entity) or covered by a federal privacy law, such as the
Gramm-Leach-Bliley Act, the Health Insurance Portability and
Accountability Act, the Fair Credit Reporting Act or the Driver Privacy
Protection Act.
"Shine the Light" Law
Residents of the State of California also have the right to request
information regarding third parties to whom the company has disclosed
certain categories of personal information during the preceding year for
the third parties' direct marketing purposes.
How to Submit a Request
To submit a request to exercise your rights (or to submit a request on
behalf of a consumer as an authorized agent):
(1) For right to know, access, correct, or deletion requests, complete
and submit the Data Request Form.
(2) For the opt-out of sale requests, visit "Do Not Sell My Personal
Information" or call us at 1-855-529-1761.
For information about the requests we receive, including the number of
requests and the average number of days we’ve taken to respond to
requests, please click here.
The following is a summary of our data collection practices, including
the personal information we collect, whether we disclose that
information for business purpose, and whether we "sell" and/or "share"
(as those terms are defined by California law). We may use all of the
information for any of the purposes described in the Policy unless
limitations are listed. S&P Global "shares" or "sells" personal
information to third parties in very limited circumstances. To learn
more about what brands share or sell personal information, please see
below. As discussed elsewhere in the Privacy Policy, we use cookies and
similar tracking technologies for purposes of targeted advertising. For
more information, please see our Cookie Notice. The categories we use to
describe the information are those set out in the CCPA.
Category of Personal Information
Category of Recipients
Disclosures for a Business Purpose
Sharing for Cross-Context Behavioral Advertising
Sales
Identifiers – this may include real name, alias, postal address, unique
personal identifier, online identifier, email address, account name, or
other similar identifiers.
* Affiliates or subsidiaries
* Business partners
* Data analytics providers
* Data brokers
* Internet service providers
* Joint marketing partners
* Operating systems and platforms
* Other Service Providers
* Payment processors and financial institutions
* Professional services organizations, this may include auditors and
law firms
* Social networks
* Advertising networks
* Business partners
* Data analytics providers
* Data brokers
* Advertising networks
Government Issued Identification – this may include social security
number, driver’s license number, or state issued identification number,
passport number.
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
Not sold.
Financial Information – this may include bank account number, credit
card number, debit card number, and other financial information.
* Affiliates or subsidiaries
* Business partners
* Payment processors and financial institutions
* Other Service Providers
Not shared.
Not sold.
Characteristics of protected classifications – this may include age,
sex, race, ethnicity, physical, or mental handicap, etc.
* Affiliates or subsidiaries
* Business partners
Not shared.
* Business partners
* Data analytics providers
* Data brokers
Advertising networks
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
* Business partners
* Data analytics providers
* Data brokers
* Other Service Providers
* Advertising networks
* Business partners
* Data analytics providers
* Data brokers
* Advertising networks
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
* Business partners
* Data analytics providers
* Internet service providers
* Operating systems and platforms
* Other Service Providers
Not shared.
* Business partners
* Data analytics providers
* Data brokers
* Advertising networks
Geolocation data
* Affiliates or subsidiaries
* Business partners
* Data analytics providers
* Operating systems and platforms
* Other Service Providers
Not shared.
Not sold.
Audio, electronic, visual, thermal, olfactory, or similar information
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
Not sold.
Professional or employment-related information
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
* Business partners
* Advertising networks
Non-public education information (as defined in the Family Educational
Rights and Privacy Act)
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
Not sold.
Inferences drawn from any of the information listed above
* Affiliates or subsidiaries
* Business partners
* Other Service Providers
Not shared.
Not sold.
Additional categories of personal information described in
the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) –
this may include signature, physical characteristics, or description,
insurance policy number.
* Affiliates or subsidiaries
* Business partners
* Payment processors and financial institutions
* Other Service Providers
Not shared.
Not sold.
California Sensitive Information Disclosure. We collect the following
categories of sensitive personal information (as defined under
California law): Social security, driver’s license, state identification
card, or passport number; precise geolocation; Racial or ethnic origin,
religious, or philosophical beliefs, or union membership; health
information; and sex life or sexual orientation. This information is
collected in order to process transactions, comply with laws, manage our
business, or provide you with services. Note that we do not use such
information for any purposes that are not identified within the
California Privacy Rights Act Section 1798.121. We do not “sell” or
“share” sensitive personal information for purposes of cross-context
behavioral advertising.
Below is a list of brands that sell of share personal information with
third parties:
• Polk (https://ihsmarkit.com/products/polk-automotive-solutions.html)
• Ipreo (https://ihsmarkit.com/products/brst-bd-advanced.html)
• Money Market Directories (https://products.mmdwebaccess.com/)
• Capital IQ Pro (https://www.capitaliq.spglobal.com/)
• Capital IQ (https://www.capitaliq.com/)
• XpressFeed
(https://www.spglobal.com/marketintelligence/en/solutions/xpressfeedtm)
• Panjiva Platform (https://panjiva.com/platform)
S&P Global has no actual knowledge that it sells or shares the personal
information of consumers under 16 years of age.
* Brazil – Additional Provisions
* BRAZIL – ADDITIONAL PROVISIONS
* Brazil
This Brazil Addendum ("Brazil Addendum") supplements this Policy to the
extent that the General Data Protection Law of Brazil ("LGPD") applies
in relation to the processing of personal information by S&P Global. In
case of any inconsistencies between this Brazil Addendum and the rest of
this Policy, this Brazil Addendum prevails.
Under the LGPD, you have the right to:
• confirm the existence of processing of your personal data;
• access your personal data;
• correct incomplete, inaccurate, or out of date personal data;
• anonymize, block, or delete unnecessary or excessive personal data or
personal data that is not being processed in compliance with the LGPD;
• portability of your personal data to another service or product
provider, by means of an express request;
• delete personal data processed with your consent;
• information about public and private entities with which we have
shared your personal data;
• information about the possibility of denying consent and the
consequences of such denial;
• revoke consent;
• request review of decisions taken solely on the basis of automated
processing of personal data that affects your interests.
You or an authorized agent may exercise your rights through the Personal
Data Request Form. The LGPD also provides that you may file a complaint
regarding your data directly with the Brazilian data protection
regulator.
Data Protection Officer
c/o Commercial Legal
Rua do Passeio 38/40
Rio de Janeiro
Brazil
* Colombia – Additional Provisions
* COLOMBIA – ADDITIONAL PROVISIONS
* Colombia – Additional Provisions
This Colombia Addendum ("Colombia Addendum") supplements this Policy to
the extent that the law of Colombia applies in relation to the
processing of personal information by S&P Global. In case of any
inconsistencies between this Colombia Addendum and the rest of this
Policy, this Colombia Addendum prevails.
Data Subject Rights
Subject to applicable law, you have the right to:
• freely access your personal information;
• know, update, and correct personal information when data is inexact,
incomplete, fragmented, misleading, or where processing is not
authorized or prohibited;
• request proof of authorization to process your personal information,
unless exempted under applicable law;
• bring complaints to the Superintendent of Industry and Commerce;
• revoke authorization and/or require the deletion of personal
information when there is not a legal or contractual reason to keep the
personal information; and
• decline authorization for the processing of sensitive personal
information. The provision of sensitive personal information or the
personal information of minors is optional.
Principal Place of Business
S&P Global Colombia SAS (NIT #900.505.649-2) has its principal place of
business at Carrera 19A No 90 – 13 Bogotá, Colombia.
* Republic of South Africa – Additional Provisions
* REPUBLIC OF SOUTH AFRICA – ADDITIONAL PROVISIONS
* Republic of South Africa Addendum
This South African Addendum (“South African Addendum”) applies in
relation to the processing of personal information by the S&P Global
responsible parties listed below in the Republic of South Africa and
supplements the information set out above in this Policy. In case of any
inconsistencies between this South African Addendum and the rest of this
Policy, this South African Addendum prevails.
1. Responsible Parties.
S&P Global responsible parties that may process personal information
from time to time include:
• SPGI Indices UK (Incorporated in United Kingdom) External Profit
Company South Africa, registration number 2013/147353/10
• SPGI UK (Incorporated in England) External Profit Company,
registration number 2012/065136/10
• S&P Global Ratings Europe Limited (Incorporated in Ireland) External
Profit Company, registration number 2017/655416/10
• S&P Global Ipreo Limited (Incorporated in United Kingdom) External
Profit Company, registration number 2005/035402/07
2. Personal information of juristic persons
In addition to the individual’s personal information collected as set
out in this Policy, we process information relating to South African
juristic persons, which may constitute personal information for purposes
of the Protection of Personal Information Act of South Africa. The
personal information relating to South African juristic persons we
process includes:
• A company’s or other juristic person’s name, address, telephone
number, email address, company registration number, and company
contact’s name;
• A company’s or other juristic person’s incorporation documents, tax
numbers, audited financial statements, B-BBEE certificates, and bank
account records;
• A company’s or other juristic person’s representative’s details,
including their name, email, telephone numbers, job title, job function
and details relating to the area of work;
• A company’s or other juristic person’s product or specification
requirements; and
• Information related to product support interaction and product
training information, to the extent that this information is
identifiable.
We collect the information directly from the juristic person concerned
or its representatives during negotiation, when preparing and concluding
agreements and during implementation or use of products/services for
their users. We may also collect the information from the client’s
employee users when they register and use products/services or obtain
the information that has been made publicly available via the internet
and website searches or when the client’s employee user otherwise gives
S&P Global their contact details.
3. Purposes and legal basis for the processing of personal information
of juristic persons
The purposes of the processing of the abovementioned personal
information include:
• To identify clients and prospective customers;
• To market and sell products to clients;
• To negotiate and enter into contracts with clients;
• To obtain permission from clients and their users;
• To conduct training and to provide support to clients/users;
• To record client engagements and conversations;
• To invoice and collect from clients and account for client revenue;
• To comply with applicable statutory obligations;
• To carry out and manage our business operations and for any other
legitimate business purposes; and
• In connection with our products and services.
Generally, we process the above personal information for purposes of the
performance of a contract with a client, or where we have the consent of
the client or the juristic person concerned, or on the basis that it is
in our legitimate interests or that of a third party to whom the
information is supplied for purposes of, amongst other things, marketing
and selling our products and services, supporting client access to and
use of our products, providing training to users of our products,
responding to client or user queries, improving products and services,
advising users of product features, new releases or maintenance.
The personal information of juristic persons may be shared with third
parties and transferred to countries outside of South Africa. Please see
the relevant provisions of the Policy in this regard.
4. Laws authorizing or requiring the collection of the personal
information.
The legislation in terms of which personal information of individuals or
juristic persons may be required to be processed includes:
• The Financial Intelligence Centre Act, 2001;
• The Income Tax Act, 1962; and
• The Company’s Act, 2008.
5. Sensitive Personal Information.
To the extent applicable, information relating to an individual’s
religious or philosophical beliefs, race or ethnic origin, trade union
membership, political persuasion, health or sex life, biometric
information or criminal behavior, including any photographs or video
recordings of may be considered as sensitive/special personal
information in accordance with applicable South African law and
regulations. We will use an individual’s special personal information
for the purposes as stated in this Privacy Policy, or as otherwise as
notified to you from time to time.
6. Contact us. If you have any questions or concerns about this Addendum
or the Policy you may contact the Information Officer
at privacy@spglobal.com, or in accordance with the information provided
in the Policy under “How to contact us”. We will reply to your request
within reasonable period of time and in any event within 30 days. We may
require you to verify your identity.
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