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PRIVACY PLEDGE INTRO
PRIVACY NOTICE
Last modified: January 20, 2022
Protecting the confidentiality and security of personal information is integral
to the way in which MSCI Inc. and its affiliates ("MSCI", “us” or “we”) conduct
business worldwide.
Generally, MSCI is the “controller” of any personal information that you provide
to us, and this Privacy Notice is intended to cover certain notice requirements
when we determine the purpose and means of processing such personal information
in the regions in which we operate. Where additional provisions required by
local legislation apply, we have addressed those provisions in separate
expanders below.
This Privacy Notice, our Cookie Notice and other legal notices listed on this
website (www.msci.com) (together, with all sub-domains and other websites that
we own or operate "Website") explain our collection, use and disclosure of
personal information collected in the course of our business activities.
This Privacy Notice does not apply to information collected, stored, shared, or
distributed by third party sites. This Privacy Notice does not apply to our
employees, who are covered by our internal notices, policies and procedures.
Please read this Privacy Notice carefully. The summary immediately below
describes only highlights, and we encourage you to read this Privacy Notice
completely.
SUMMARY
MSCI is a multinational corporation, with offices around the world. MSCI’s
clients and prospects are companies, not individuals or consumers. MSCI’s
vendors, service providers and consultants (together “Vendors”) are typically
companies but on occasion may be individuals.
We process personal information that comes from three sources: information you
provide, information we receive from other sources, and information collected
automatically.
The first category, information you provide, includes information that you
provide through our website, through our products or through our client support
portals, through day-to-day interaction with us, in connection with a job
search, and as a visitor to our offices.
The second category, information we receive from other sources, includes
information from public sources, information from our employees, and information
from our clients. The last category, information we collect automatically,
includes information collected when you visit our website or use our IT
systems/networks.
Where required by applicable data protection law, our processing of your
personal information will be justified on a lawful basis. We do not sell or rent
your personal information to third parties. We share data internally among our
corporate affiliates and business units in the ordinary course of our daily
operations. We share personal information with our Vendors in connection with
their performance of services for us, in accordance with our instructions, and
subject to appropriate contractual restrictions and security and confidentiality
obligations. We may be required to disclose your personal information for
legal/regulatory/compliance purposes or in connection with an investigation, or
if we believe it is reasonably necessary to prevent harm or loss. We may also
share your personal information in connection with certain corporate events.
MSCI maintains and applies consistent physical, electronic and procedural
safeguards that aim to protect personal information against loss, misuse, damage
or modification and unauthorized access or disclosure.
Highlights of MSCI’s information security program can be found on our website at
https://www.msci.com/information-security.
We send our marketing emails within the US on an opt-out basis and outside of
the US, we rely on opt-in consent.
If you have legislative access or similar legal rights in your jurisdiction with
respect to your personal information, and you wish to exercise any such rights
as further identified in this Privacy Notice, you can submit your request to us
by completing the web form available at https://www.msci.com/DSR-external-form
Please note that a fee may be charged where laws permit. Please do not use these
web forms to manage your subscriptions to our email groups. Instead, please
follow the instructions below. Please do not use this form if you work for a
current client or Vendor or prospective client or Vendor of MSCI and wish to
have your business contact information updated. You can update that information
by contacting your local MSCI representative directly. If you are a current MSCI
employee, please use the appropriate internal resources provided.
EU/EEA/UK SPECIFIC GDPR RIGHTS
EU/EEA/UK specific GDPR rights
If your data is processed in the EU, EEA or UK, you will have the following
rights under the General Data Protection Regulation (“GDPR”) (including the UK
GDPR):
* Right of Access/Subject Access Request: You are entitled to request
confirmation that your personal information is being processed; access to
your personal information; and other supplementary information that may not
be included in this Privacy Notice.
* Right of Rectification: You are entitled to have any inadequate, incomplete
or incorrect personal information corrected.
* Right to Erasure (the “right to be forgotten”): You are entitled to have your
personal information erased under specific circumstances, such as where you
have withdrawn your consent, where you object to processing based on
legitimate interests and we have no overriding legitimate grounds, or where
personal information is unlawfully processed.
* Right to Restriction Processing: You have the right to restrict our
processing of your personal information (that is, allow only its storage)
where:
* you contest the accuracy of the personal information, until we have taken
sufficient steps to correct or verify its accuracy;
* the processing is unlawful, but you do not want us to erase the personal
information;
* we no longer need your personal information for the purposes of the
processing, but you require such personal information for the
establishment, exercise or defense of legal claims;
* you have objected to processing justified on legitimate interest grounds
(see below), pending verification as to whether we have compelling
legitimate grounds to continue processing; or
* your personal information is subject to restriction, in which case we will
only process it with your consent, for the establishment, exercise or
defense of legal claims, for the protection of the rights of another
person, or for reasons of important public interest.
* Right to Data Portability: Where we are relying (as the legal basis for
processing) upon your consent, or the fact that the processing is necessary
to perform a contract to which you are party or to take steps at your request
prior to entering a contract, and the personal information is processed by
automatic means, you have the right to receive all such personal information
which you have provided to us in a structured, commonly used and
machine-readable format, and also to require us to transmit it to another
controller where this is technically feasible.
* Right to Object: You have the right to object to:
* Processing (including profiling) based on legitimate interest grounds: :
Where we are relying upon legitimate interests to process personal
information, you have the right to object to that processing. If you
object, we must stop that processing unless we can demonstrate compelling
legitimate grounds for the processing that override your interests, rights
and freedoms, or we need to process the personal information for the
establishment, exercise or defense of legal claims. Where we rely upon
legitimate interests as a basis for processing, we believe that we can
demonstrate such compelling legitimate grounds, but we will consider each
case on an individual basis.
* Direct marketing (including profiling): You have the right to object to our
use of your personal information (including profiling) for direct marketing
purposes, such as when we use your personal information to invite you to
our promotional events.
* Rights in Relation to Automated Decision Making and Profiling: You have the
right not to be subject to a decision based solely on automated processing,
including profiling, which produces legal effects concerning you or similarly
significantly affects you. Please note, we do not use your personal
information for automated decision making, including profiling.
EXERCISING YOUR EU SPECIFIC GDPR RIGHTS
If you wish to exercise any of the foregoing rights, please submit your request
to us by completing the web form available at
https://www.msci.com/DSR-external-form.
CERTAIN DATA TRANSFERS
If your personal information is transferred outside the EU/EEA/UK to other MSCI
group companies or to Vendors, we will take steps to ensure that your personal
information receives the same level of protection as if it remained within the
EU/EEA/UK, including by entering into data transfer agreements, using the
European Commission approved Standard Contractual Clauses, or by relying on
certification schemes and/or other currently valid mechanisms for transfers. For
transfers to MSCI in the US, a country that does not benefit from an adequacy
decision by the European Commission, and for other transfers within the MSCI
group, we have put in place European Commission approved Standard Contractual
Clauses, which protect personal information transferred between MSCI entities.
If your data is processed in the EU/EEA/UK, you have a right to obtain details
of the mechanism under which your personal information is transferred outside of
the EU/EEA/UK by completing the web form available at
https://www.msci.com/DSR-external-form.
COMPLAINTS
If your data is processed in the EU/EEA, you have the right to lodge a complaint
with the supervisory authority of your habitual residence, place of work or
place of alleged infringement, if you consider that the processing of your
personal information infringes applicable law. A list of data protection
supervisory authorities is available at
http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080 (opens in
a new tab)
If your data is processed in the UK, the UK is your habitual residence, place of
work or place of alleged infringement, and if you consider that the processing
of your personal information infringes applicable law you have the right to
lodge a complaint with the UK Information Commissioners Office
(https://ico.org.uk/global/contact-us/ (opens in a new tab)).
ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
ADDITIONAL PRIVACY INFORMATION FOR CALIFORNIA RESIDENTS
This notice provides information for certain California residents, as currently
required under California privacy laws, including the California Consumer
Privacy Act (“CCPA”). California privacy laws require that we provide California
residents information about how we use their personal information, whether
collected online or offline, and this document is intended to satisfy that
requirement.
Under the CCPA, “personal information” is any information that identifies,
relates to, describes, is reasonably capable of being associated with, or could
reasonably be linked, directly or indirectly, with a particular California
resident or household.
Except for the right to opt-out and the right of non-discrimination, this
section does not apply to California residents with whom we transact or
communicate solely in the context of providing or receiving a product or service
to or from a company that employs such residents or engages such residents as
contractors. This section generally does not apply to personal information we
collect about job applicants, independent contractors, or current or former
full-time, part-time and temporary employees and staff, officers, directors or
owners of MSCI.
CATEGORIES OF PERSONAL INFORMATION THAT WE COLLECT AND/OR DISCLOSE
Please find the categories of personal information about California residents
that we collect and/or disclose to third parties or service providers for a
business purpose. We collect these categories of personal information from the
sources described in MSCI’s main Privacy Notice above and for the purposes
described therein. Our collection use and disclosure of personal information
about a California resident will vary depending upon the circumstances and
nature of our interactions or relationship with such resident.
Categories of personal information Do we collect? Do we disclose for business
purposes? Do we sell? Name, contact information and related personal
identifiers. YES YES NO Customer records containing personal information. YES
YES NO Legally protected classifications, such as race, color, sex, age,
religion, national origin, disability, citizenship status, and genetic
information. YES YES NO Commercial purchase history and tendencies. YES YES NO
Biometric information that can be used to establish individual identity. N/A N/A
NO Internet or other electronic network activity or usage Data. YES YES NO
Precise geographic location information about a particular individual or device.
NO NO NO Audio/visual or similar personal information. YES YES NO
Employment-related history. YES YES NO Personal, non-public education
information. YES YES NO Profiles/inferences created from personal information.
N/A N/A NO
CALIFORNIA RESIDENTS’ RIGHTS
California law grants California residents’ certain rights and imposes
restrictions on business practices as set forth below.
Do-Not-Sell: California residents have the right to opt-out of our sale of their
personal information. We do not sell your personal information.
Notice at Collection: We are required to notify California residents, at or
before the point of collection of their personal information, the categories of
personal information collected and the purposes for which such information is
used, and this notice and the main Privacy Notice above serves this purpose.
Verifiable Requests for Right to Delete, Right to Copy and Right to Know.
Subject to certain exceptions, California residents have the right to make the
following requests free of charge:
Request to Delete: California residents have the right to request deletion of
their personal information that we have collected about them, subject to certain
exemptions, and to have such personal information deleted, except where
necessary that we maintain such personal information in order to:
* Complete the transaction for which the personal information was collected,
provide a good or service requested by the California resident, or reasonably
anticipated within the context of a business’s ongoing business relationship
with the California resident, or otherwise perform a contract between the
business and the California resident.
* Detect security incidents, protect against malicious, deceptive, fraudulent,
or illegal activity; or prosecute those responsible for that activity.
* Debug to identify and repair errors that impair existing intended
functionality.
* Exercise free speech ensure the right of another California resident to
exercise his or her right of free speech, or exercise another right provided
for by law.
* Comply with the California Electronic Communications Privacy Act pursuant to
Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal
Code.
* Engage in public or peer-reviewed scientific, historical, or statistical
research in the public interest that adheres to all other applicable ethics
and privacy laws, when the businesses’ deletion of the information is likely
to render impossible or seriously impair the achievement of such research, if
the California resident has provided informed consent.
* Enable solely internal uses that are reasonably aligned with the expectations
of the California resident based on the consumer’s relationship with the
business.
* Comply with a legal obligation.
* Otherwise use the California resident’s personal information, internally, in
a lawful manner that is compatible with the context in which the California
resident provided the information.
Request for a Copy: California residents have the right to request a copy of the
specific pieces of personal information that we have collected about them in the
prior 12 months, up to twice every 12 months, and to have this delivered either
(a) by mail or (b) electronically in a portable and, to the extent technically
feasible, readily useable format that allows the individual to transmit this
information to another entity without hindrance.
Request to Know: California residents have the right to request that we provide
them certain information, up to twice every 12 months, about how we have handled
their personal information in the prior 12 months, including the:
* categories of personal information collected;
* categories of sources of personal information;
* business and/or commercial purposes for collecting and selling their personal
information;
* categories of third parties/with whom we have disclosed or shared their
personal information;
* categories of personal information that we have disclosed or shared with a
third party for a business purpose;
* categories of personal information collected; and
* categories of third parties to whom the residents’ personal information has
been sold and the specific categories of personal information sold to each
category of third party.
Submitting Requests. Requests to delete, for a copy, and/or to know may be
submitted by contacting us at (833)-548-0230 (toll free) or by completing the
web form available at https://www.msci.com/DSR-external-form. We will respond to
verifiable requests received from California consumers as required by law.
Incentives and Discrimination. The CCPA prohibits discrimination against
California residents for exercising their rights under the CCPA and imposes
requirements on any financial incentives offered to California residents related
to their personal information.
Discrimination: Businesses may not discriminate against residents who exercise
their rights under CCPA. Discrimination may exist where a business denies or
provides a different level or quality of goods or services, or charges (or
suggests that it will charge) different prices or rates or impose penalties on
residents who exercise their CCPA rights, unless doing so is reasonably related
to the value provided to the business by the residents’ data.
Disclosure of Incentives: If businesses offer financial incentives for the
collection, sale or deletion of California residents’ personal information,
residents have the right to be notified of any financial incentives offers and
their material terms, the right not be included in such offers without prior
informed opt-in consent, and the right to be able to opt-out of such offers at
any time. Businesses may not offer unjust, unreasonable, coercive, or usurious
financial incentives. We do not offer any incentives.
CALIFORNIA PRIVACY RIGHTS UNDER CALIFORNIA’S SHINE-THE-LIGHT LAW
Under California’s “Shine the Light” law (Cal. Civ. Code § 1798.83), California
residents who provide us certain personal information are entitled to request
and obtain from us information about the personal information (if any) we have
shared with third parties for their own direct marketing (see MSCI’s main
privacy notice) use. Such requests may be made once per calendar year for
information about any relevant third party sharing in the prior calendar year.
California residents who would like to make such a request may submit a request
in writing by emailing us at privacy@msci.com. The request should attest to the
fact that the requester is a California resident, and provide a current
California address.
ADDITIONAL PRIVACY INFORMATION FOR RESIDENTS OF SOUTH AFRICA
ADDITIONAL PRIVACY INFORMATION FOR RESIDENTS OF SOUTH AFRICA
This Notice provides information for residents of South Africa, in accordance
with the requirements of the Protection of Personal Information Act (“POPIA”).
Generally, MSCI is the “responsible party” of any personal information that you
provide to us and addition to the information detailed in our Privacy Notice.
POPIA requires that we provide an identifiable, natural person, and where
applicable, an identifiable, existing juristic person (data subject) with
certain rights.
RIGHTS FOR RESIDENTS’ OF SOUTH AFRICA
A data subject has the right to have its personal information processed in
accordance with the conditions for the lawful processing of personal
information, including:
* Right to be Notified that personal information is being collected; or where
personal information has been accessed or acquired by an unauthorized person.
You are entitled to:
* the Right to Request Access to personal information
* You are entitled to establish whether a responsible party holds your
personal information and to request access to your personal information.
* Right to Request, where necessary, the correction, destruction, or deletion
of personal information
* You are entitled to have any inadequate, incomplete, or incorrect personal
information corrected.
* You are entitled to have your personal information erased under specific
circumstances, such as where you have withdrawn your consent, where you
object to processing based on legitimate interests and we have no
overriding legitimate grounds, or where personal information is unlawfully
processed.
* Right to Object, on reasonable grounds relating to the processing of your
personal information
* You are entitled to object if processing does not occur in the prescribed
manner, on reasonable grounds, unless legislation provides for such
processing;
If you object, we must stop that processing unless we can demonstrate legal
grounds for the processing that override your interests, rights and
freedoms, or we need to process the personal information for the
establishment, exercise or defence of legal claims. We will consider each
case on an individual basis.
* You are entitled to object to the processing of personal information for
the purposes of direct marketing, and not to have personal information
processed for purposes of direct marketing by means of unsolicited
electronic communications
* Right not to be subject, under certain circumstances, to a decision which is
based solely on the automated processing of personal information
* You have the right not to be subject, under certain circumstances, to a
decision which is based solely based on the automated processing your
personal information intended to provide a profile. Please note, we do not
use your personal information for automated decision making, including
profiling.
Submitting Requests: Requests to correct, delete, destroy or for a copy, and/or
to object may be submitted by completing the web form available at
https://www.msci.com/DSR-external-form. We will respond to verifiable requests
from residents of South Africa as required by law.
ADDITIONAL PRIVACY INFORMATION FOR RESIDENTS OF BRAZIL
ADDITIONAL PRIVACY INFORMATION FOR RESIDENTS OF BRAZIL
This notice provides certain additional information about how MSCI uses and
treats personal information, specifically with respect to the General Data
Protection Law (“LGPD”) of Brazil.
The data we collect, and the purposes of use, are further set forth below. If
your personal information is processed in Brazil, please note the following
additional rights with respect to the LGPD:
SHARING OF PERSONAL INFORMATION
We do not disclose, sell or make available your personal information outside the
scope of the purposes described in this Privacy Notice or in disaccord with
applicable legislation.
We maintain necessary security procedures and measures in treating the data
obtained and shared, according to the requirements of applicable law.
INTERNATIONAL TRANSFER
In view of the possibility of operating in multiple countries and the
possibility of computer systems with global scope, including cloud data storage
services, we or related third parties can store and treat personal information
in other countries. you are aware that your personal information may be stored
and processed in different countries, and that other analytic tracking
technologies or cookies can be applied, as described in this Privacy Notice.
We will take the measures necessary so that your personal information receive an
adequate level of protection, as required by applicable law, so that this
transfer shall observe the LGPD, either through the use of the standard
contractual clauses required by applicable law or by means of other safeguards,
as applicable. After you provide us with your personal information, we may
transfer, transmit and/or forward your personal information to other
jurisdictions. We adopt appropriate measures for adequate protection of the
right to privacy of our Users with respect to the personal information we
transfer outside the country of origin, according to applicable legislation.
In the absence of specific or complementary regulation on the theme from the
competent authority under the LFPD (in this case, the National Authority of Data
Protection), we can utilize model clauses and rely on models or instructions
utilized in European regulations.
RETENTION OF DATA AND DURATION OF TREATMENT
We will store the personal information only for the time legally required or as
necessary to realize the purposes mentioned in this Privacy Notice, in
conformity with the determinations of any applicable legislation, and as further
set forth below.
YOUR LGPD RIGHTS
As a data owner, you have various rights as specified in applicable law,
including specifically the rights contained in Article 18 of the LGPD, and in
accordance with the time frames and under the terms indicated in applicable
regulations, to the extent fitting and upon your request:
* Right of Confirmation and Access: Confirmation of the existence of treatment
and access to your data, including about the public and private entities with
which we engage in shared use of your data.
* Right of Correction: Correction of incomplete, inaccurate or outdated data,
so that you can update, correct or delete personal information by into
contact with us. We recommend that you seek to update or correct your
personal information whenever necessary.
* Right or Elimination: It is possible to request anonymization, blocking or
elimination of personal information if they are unnecessary, excessive or
treated outside of conformity with the LGPD.
* Rights Associated with Consent: If the treatment is based on your consent,
you have the right not to supply or to revoke such consent. However, in this
case, you may only have limited access to the Website and its content,
because we are unable to assure continuity of use. You also have the right to
solicit elimination of personal information treated with consent, as
permitted by applicable law.
* Right of Review: You have the right to solicit review of decisions made
solely based on automated treatment of personal information that affect your
interests, including decisions intended to define your personal and
professional profile or aspects of your personhood (if any).
* Right of Data Portability: You can exercise your right to transfer your
personal information to another controller, by express requisition and
observing our trade and industrial secrets, according to the regulations of
the National Authority of Data Protection and applicable legislation.
* Other Rights: To the extent we base treatment on other hypotheses than your
consent to use your personal information, you have the right to oppose such
use in violation of applicable law. You also have the right to receive
certain information about the third parties with which we engage in shared
use of your personal information, besides the right to complain to the
competent authorities.
Submitting Requests: If you wish to exercise any of the foregoing rights or
correct your personal information, please submit your request to us by
completing the web form available at https://www.msci.com/DSR-external-form.
INFORMATION YOU PROVIDE
INFORMATION YOU PROVIDE
You may provide us with personal information when you communicate with us. You
are responsible for providing us with accurate, complete and up-to-date
information on a lawful basis.
Information you provide through day-to-day interaction with us: You may provide
us with personal information through day-to-day interactions, including
in-person or through various communications technologies, as necessary to
develop or support our business relationship. Such relationships may include
employees and other personnel of our clients and prospects, directors, Vendors,
consultants, and other professional advisors. Personal Information here
typically consists of business contact details but could include other
information appropriate to the business relationship. For example, Vendors who
are individuals may also provide payment details and professional
qualifications.
Information you provide through our Website: You may provide us with personal
information whenever you fill out a form on our Website, for example, to ask us
a question, or request that we contact you about our products and services,
research or events; to subscribe to our marketing, careers or investor relations
emails; to download content; to register for events; or to submit a website form
to us for any other reason (including, for example, to exercise privacy rights
where they apply). The information that you provide to us may include your
contact details, and any other information collected on the form to allow us to
fulfil the request.
Information you provide as an employee of a client, through our products or
through our client support portals: When you log in to use our products or into
our client support portal, you provide us with your name, email address,
username and password, and we log your product use. Your login credentials may
have been created by you or assigned to you either by MSCI or your firm with
whom we have a direct contractual relationship.
Information you provide in connection with a job search: When you apply for a
job through our career portal, we collect your username and password, contact
details and resume/CV. If you apply through a social media platform (e.g.,
LinkedIn), then depending on the platform you use, we will receive either the
information contained in your online profile or the resume/CV that you submit.
We also collect information that you provide to us at job fairs and during the
interview process. Finally, we may require a background check as a condition of
employment, where required or permitted by the applicable law of your
jurisdiction. Background checks may include credit reports and criminal records,
and references in relation to recruitment for specific roles.
INFORMATION WE RECEIVE FROM OTHER SOURCES
Information from public sources: We collect information from the public domain
about individuals who work at companies with whom we are seeking to build a
business relationship, for purposes of generating leads. In some cases, and
where permitted by law, we use third party services that perform these online
searches for us. This information typically consists of business contact
details.
As part of our recruitment process, we collect information from the public
domain that individuals post on professional networking sites and job boards
(e.g., LinkedIn).
Additionally, as part of the production of our ESG products, we collect and
publish information from the public domain (e.g., public filings, Websites,
press releases, etc.), which may include information about the officers,
directors and other senior managers of corporations that are the subject of our
ESG ratings and reports. In the limited circumstances where we believe it to be
reasonably justified in order to comply with any transparency and record keeping
obligations, we rely on relevant exemptions provided under the GDPR in relation
to such processing for a special purpose.
In relation to the calculation and maintenance of our equity indexes, we collect
and use information from public sources about company shareholding and
ownership.
Information from our employees: In furtherance of our employment relationship
with our employees, our employee benefit plans and our legal, regulatory and
compliance requirements, employees may provide personal information about their
spouses/domestic partners, emergency contacts, dependents and other family
members. Depending on the purpose, this information may include, for example,
name, contact information, age, date of birth, relationship to the employee,
gender, account information and social security number or other government
issued identifier. This information may pertain to dependent children under the
age of 16.
Information from our clients and other third parties: We receive information
from our clients and prospects about their personnel for purposes of enabling
access to our products, client support portal or other communications portals,
and managing our business relationship. This information typically consists of
business contact details and login credentials for our products, client support
portal or other communications portals.
Clients sometimes include limited personal information in submissions to us,
although we do not require such information for our products. We discard or
limit internal access to this information, and if used, we seek to anonymize.
INFORMATION WE COLLECT AUTOMATICALLY
Cookies
We use cookies to automatically collect information about you when you visit and
take action on our Website, which may in some cases constitute personal
information under applicable data protection law, including but not limited to:
* your domain;
* your IP address;
* your date, time and duration of your visit;
* your browser type;
* your operating system;
* your page visits;
* information from third parties;
* other information about your computer or device; and
* Internet traffic.
Detailed information about our use of cookies can be found in our Cookie Notice
at https://www.msci.com/cookie-policy
Email Engagement of Clients and Prospects
We may use web beacons (also known as web bugs, pixel tags or clear GIFs)
allowing us to receive interaction information about clients and prospects
(opening of emails, clicking of links and associated actions).
Our emails may include links to open attachments, visit pages on our Website,
download content, launch surveys or take other actions. If you are in our client
or prospect contact database, or have previously interacted with us online, then
metadata in these links may enable us to identify you as the person clicking the
link.
MSCI Product Usage Statistics
Where available, we collect aggregated and individually identifiable product
usage data, which includes product type, login date/time, pages and features
used, client accounts viewed, reports generated and other similar product
metrics.
Office Visitor Use of MSCI Guest Wi-Fi
If you visit our offices and use our guest Wi-Fi, we automatically collect
information about your mobile device, including IP and MAC address, and store /
log your online activities. Use of our Wi-Fi is subject to our Wi-Fi Acceptable
Use Policy, which you must accept to connect to our guest Wi-Fi.
Video Monitoring
We employ video surveillance (CCTV), for purposes of office access, safety and
security.
USE OF PERSONAL INFORMATION
How we use personal information we collect about you depends, in large part, on
the purpose for which it is provided to us. The specific purposes for which we
process such personal information include:
* managing our relationships with our clients and prospects, including:
* providing our products and services to our clients, prospects and others;
* using information, you submit to us online for purposes of creating leads
and generating sales;
* correlating data in our CRM systems about our clients’ and prospects’
personnel with Website data, including product and client support site
login data, for purposes of creating leads and generating sales, which we
may perform through the use of cookies that enable us to monitor and
analyze Website login data, usage and trends;
* responding to your inquiries and requests, including:
* responding to your questions about our products and services, research or
events;
* adding you to our email lists, including marketing, careers and investor
relations (subject to your consent, where required by applicable law);
* resolving your product or other support related issues (which in some
cases may involve our use of your administrative log in credentials for
client support and quality cases);
* processing, evaluating and completing transactions and requests involving
the Website and content available through the Website, and more generally
transactions involving MSCI's products and services, research and events;
and
* providing you with other information and content you have requested;
* organizing, hosting and managing events, including without limitation,
handling registrations, distributing participant lists, providing reasonable
accommodations (e.g., dietary requests), and using photos / videos taken at
the event on our Website and other marketing materials in relation to the
event;
* operating, maintaining, developing, improving and customizing our Website,
including:
* the content and features accessible on our Website;
* enabling your access to and use of restricted portions of our Website,
including our products, careers site, client support site and email
preferences center; and
* logging, understanding and analyzing your use of our Website, for the
purpose of improving our Website (and content and features on our Website)
and your experience on our Website, which we may perform through the use of
cookies that enable us to monitor and analyze Website login data, usage and
trends;
* developing, producing, operating, and maintaining our products and services;
* improving our products and services, including through the use of client
satisfaction surveys and aggregated product usage data, and using such data
for research and analysis;
* managing our relationships with our Vendors;
* managing our relationships with our external advisors, board members, etc.;
* recruiting staff, including:
* managing our recruitment, work placement and internship processes,
including considering applications for employment / placement and making
offers; and
* evaluating candidates for future job opportunities (subject to your
consent, where required by applicable law);
* managing our relationships with our employees, including:
* performing our obligations as employers;
* managing talent management and employee engagement programs;
* managing talent management and employee engagement programs;
* complying with our legal and compliance requirements;
* managing visitor access to our offices / facilities, and protecting the
safety and security of MSCI personnel, office visitors, and our offices /
facilities;
* protecting the security, confidentiality and integrity of our Website, IT
systems, hardware and networks, and information (including personal
information of MSCI, its clients and prospects, Vendors, personnel and
others);
* complying with applicable laws, rules and regulations, and in furtherance of
our related internal policies, including compliance policies and records
retention requirements;
* responding to your inquiries and requests that are based on legal rights that
you may have (e.g., data access rights); and
* managing, protecting against and investigating fraud, risk exposure, claims
and other liabilities, including but not limited to violations of our
contract terms or laws or regulations.
We do not track your online activities across the Internet. We do not use your
personal information for automated decision making, including profiling. We do
not sell or rent your personal information to third parties.
If you do not provide us with your personal information or refuse to provide or
withdraw consent (where applicable), we may not be able to perform some or all
of the above-described actions.
LEGAL BASIS FOR PROCESSING
Where required by applicable data protection law our processing of your personal
information will be justified on a lawful basis, such as:
* the processing is necessary to perform a contract with you, or take steps to
enter into a contract at your request;
* the processing is necessary for us to comply with a relevant legal
obligation;
* the processing is in our legitimate interests, and our interests are not
overridden by your interests, fundamental rights or freedoms; or
* you have consented to the processing.
We process personal information on the basis of our legitimate interests, unless
we are performing a contract with you (or taking steps to enter into a contract
with you at your request), processing to comply with a legal obligation or
relying on your consent. For example, we process personal information on the
basis of our legitimate interests when operating our Website; managing our
relationships with our clients, prospects and Vendors; creating leads and
generating sales; managing product and client support logins; IT systems
monitoring and network security; building security and safety; and managing our
compliance policies/legal/regulatory obligations.
We process personal information on the basis of consent only with respect to
email marketing, events registration (including reasonable accommodations (e.g.,
dietary requests)), use of cookies, use of photos/videos, and retention of job
application data for future consideration. Please see “Marketing Emails”, below,
to read about how we obtain consent for marketing emails.
DISCLOSURE OF PERSONAL INFORMATION
MSCI is a multinational corporation, with offices around the globe. We share
data internally among our corporate affiliates and business units in the
ordinary course of our daily operations. For a current listing of our global
offices, please visit the Contact Us page of our Website at
https://www.msci.com/contact-us.
We share personal information with our Vendors (or our Vendors may collect
personal information directly on our behalf), in connection with their
performance of services for us. For example, our Vendors assist us in conducting
and managing our business; fulfilling our obligations under our agreements;
managing our Website, and the content and features available on our Website;
managing, providing and improving our products, research, services and client
support; providing information to you and responding to your requests. Our
Vendors process personal information in accordance with our instructions and are
subject to appropriate contractual restrictions and security and confidentiality
obligations. Generally, the countries in which our service providers are located
are the same counties in which we operate.
If you work for a client, we may provide information about your product usage to
your firm with whom we have a direct contractual relationship.
If you attend our events, we may share your name in our participant
list/brochure, and we may include photographs/videos taken of you at the event
on our Website and in our marketing materials.
We may be required to disclose your personal information to comply with any
applicable legal or regulatory requirements, or where we believe that the
disclosure will further an investigation of suspected or actual illegal
activities; to enforce our legal rights; or if we believe it is reasonably
necessary to prevent harm or loss.
We may share your personal information with third parties in connection with
potential or actual sale of our company or any of our assets, or those of any
affiliated company, including through mergers and acquisitions, changes of
control or divestitures, or in connection with bankruptcy or insolvency, in
which case personal information held by us about our users may be one of the
transferred assets. Where appropriate, we will take reasonable measures to
require the recipient of your personal information to treat it in accordance
with this Privacy Notice. MSCI reserves the right to share any information that
you provide which is not deemed personal information or is not otherwise subject
to contractual restrictions.
SECURITY
MSCI maintains physical, technical and organizational safeguards designed to
protect personal information against unauthorized disclosure or access, and
accidental or unlawful destruction, loss or alteration. Highlights of MSCI’s
information security program can be found on our Website at
https://www.msci.com/information-security.
While MSCI aims to safeguard and protect your personal information from
unauthorized access, improper use or disclosure, unauthorized modification or
unlawful destruction or accidental loss, and MSCI utilizes and maintains certain
reasonable processes, systems, and technologies to do so, you acknowledge that
no transmission over the Internet is completely secure or error-free, and that
these processes, systems, and technologies utilized and maintained by MSCI may
be subject to compromise. Accordingly, we cannot be held responsible for
unauthorized or unintended access that is beyond our control.
RETENTION OF YOUR PERSONAL INFORMATION
While we generally aim to retain your personal information for the period during
which we have a relationship with you, there are many reasons why we may need to
retain your data for longer. For example, we may need to retain your personal
information if the purpose for which we collected it extends beyond the term of
our relationship. We may also retain your personal information for a term that
corresponds to a statute of limitations, to establish, exercise or defend legal
claims, or as otherwise permitted or required by law, so that in each case we
have an accurate record of your dealings with us in the event of any complaints
or challenges. We may also retain your personal information for compliance or
regulatory purposes, where we are required to do so in accordance with legal,
regulatory, tax and/or accounting requirements, or to support a legal or
regulatory process, audits, or requests or requirements of a legal or regulatory
authority or other governmental entity having authority to make the request.
CHILDREN
The Website is not for use by children under the age of 16 years. Except as
described in this Privacy Notice with respect to information that employees
provide to us about their beneficiaries and dependents in connection with our
employment relationship with our employees and our employee benefit plans, MSCI
does not knowingly collect, store, share or use the personal information of
children under 16 years. If you are under the age of 16 years, please do not
provide any personal information, even if prompted by the Website to do so. If
you are under the age of 16 years and you have provided personal information,
please ask your parent(s) or guardian(s) to notify MSCI and MSCI will take
appropriate steps to delete all such personal information.
MARKETING EMAILS
We send our marketing emails within the US on an opt-out basis and outside of
the US, we rely on opt-in consent. We offer multiple ways to manage your email
subscriptions, including an online preference center, unsubscribe mechanisms,
and direct client support.
MANAGING YOUR SUBSCRIPTION TO OUR EMAIL GROUPS
You can unsubscribe from our emails and update your communication preferences
and personal information as follows:
Marketing / Client Support: You can unsubscribe from our marketing emails or
update your marketing preferences at any time by clicking the “unsubscribe” or
“change preferences” link provided in such emails. If you work for an existing
client, you can update your marketing preferences on our client support site,
located at https://support.msci.com/marketing-preferences (opens in a new tab),
or by contacting our client support team directly. You can also contact our
client support team to update your contact information or opt out of marketing
emails at any time.
Talent Network / Careers: You can unsubscribe from our Talent Network emails at
any time by clicking the “unsubscribe” link provided in such emails. In
addition, if you have applied for a job but did not receive an offer of
employment, we may retain your job application and personal information in order
to consider you for future opportunities, subject to your consent where required
by applicable law. You can contact our Talent Acquisition team to update your
contact information at any time.
Investor Relations: You can unsubscribe from our investor relations emails at
any time by clicking the “unsubscribe” link provided in such emails. You can
also opt out and update your email preferences on our Investor Relations
site (opens in a new tab).
EXTERNAL LINKS
The Website may contain links to third party sites. Since MSCI does not control
nor is responsible for the privacy practices of those websites, we encourage you
to review the privacy policies of these third party sites. This Privacy Notice
applies solely to personal information collected by our Websites or during our
business activities.
HOW TO CONTACT US
If you have any questions in relation to this Privacy Notice or our processing
of your personal information (other than in relation to a specific information
or data subjects rights request), you can contact us at either:
MSCI Inc.
7 World Trade Center
250 Greenwich Street, 49th Floor
New York, NY 10007 USA
Attn: Legal Department
Email: privacy@msci.com
-OR-
MSCI Limited
Ninth Floor, Ten Bishops Square, Spitalfields
London E1 6EG UK
Attn: Privacy Officer
Email: privacy@msci.com
Our external data protection officer for IPD Investment Property Databank GmbH
and Barra International, LLC Niederlassung Deutschland is:
ePrivacy GmbH
represented by Prof. Dr. Christoph Bauer
Große Bleichen 21
20354 Hamburg
CHANGES TO THIS NOTICE
This Privacy Notice may be changed from time to time to reflect changes in our
practices concerning the collection and use of personal information. Please
check back frequently to see any updates or changes to this Privacy Notice.
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