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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.
* OUR CAPABILITIES
* Overview
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* S&P Global Ratings
* * Overview
* Featured
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War in Ukraine
Most Popular Insights
Read: Inflation Reduction Act: Landmark Legislation Supercharges U.S. Clean
Energy Effort
The Inflation Reduction Act, or IRA, was passed in both houses of Congress
and signed into law by President Joe Biden in August. The bill provides
nearly $370 billion in promoting clean technologies that will drive energy
sector transformation and emissions reduction.
Read: Energy Transition Outlook
Energy security has again risen to the top of governments' priorities in the
face of rising gas and energy prices following Russia's invasion of Ukraine.
This has put the focus squarely on non-fossil-fuel power generation, such as
from renewables (solar, wind, and hydro) and nuclear.
Read: Counting on Coal
Global demand for coal is on the rise while prices for thermal coal and
metallurgical coal have climbed dramatically over the last year. As some
countries have ramped up coal production, others are looking for greener
alternatives.
* * Overview
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* Search for a Job
* Featured Events
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Events from our S&P Global Divisions
* S&P Global Ratings Events
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* Introduction
* What does S&P Global do?
* When did S&P Global and IHS Markit merge?
* 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
* Use of Personal Information in Products
* Updates to this Policy
* How to contact us
* Russian Federation - Additional Provisions
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* Japan - Additional Provisions
* State of California, United States - Additional Provisions
* Brazil – Additional Provisions
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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?
Last Updated: February 28, 2022
S&P Global Inc. and its affiliates (collectively or individually, as
applicable, referred to as "S&P Global", "Company", "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.
* 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 information about S&P Global's
current group companies and other related companies, please see our latest
filings here.
* When did S&P Global and IHS Markit merge?
S&P Global and IHS Markit announced their merger on 30 November 2020 and this
Policy was updated at the time the merger was completed.
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,
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.
For more information about our privacy practices relating to our Digital and
advertising-related services, please see the Advertising Privacy Policy.
* 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 do 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 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 own purpose, as detailed in the product terms of
use.
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
one of S&P Global's corporate customers, 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 and collect images of you
provided that you do not object, for example, at an event
To enable us to send you tailored information on our Services across our
divisions that may interest to 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.
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.
Information we 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 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
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
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's 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 such
information);
- to deliver tailored information on our Services that may be of interest or
value to you and to send you marketing and promotional e-mails 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 "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 endeavour 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 and
delivery 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 and websites, to display within
some of our products. Find out more at "How does S&P Global use personal
information in products?''.
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).
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. To provide you with the functionalities of one of our
apps, the app must access various functions and data on your mobile device.
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 you 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 also automatically collect app logs and usage statistics. For example, we
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 you download one of our mobile apps from Apple's App Store or Google
Play (each, an "App Platform"), you acknowledge and agree that:
• As between S&P Global and the App Platform, S&P Global is solely
responsible for the app.
• The App Platform has no obligation to provide any maintenance and support
services with respect to the app.
• In the event of any failure of our apps to conform to any applicable
warranty: (i) you may notify the App Platform and the App Platform may refund
the purchase price for the app to you (if applicable), (ii) to the maximum
extent permitted by applicable law, the App Platform will have no other
warranty obligation whatsoever with respect to the applications, and (iii)
any other claims, losses, liabilities, damages, costs or expenses
attributable to any failure to conform to any warranty is, as between S&P
Global and the App Platform, S&P Global's responsibility.
• The App Platform is not responsible for addressing any claims you have
relating to the app or your possession and use of the app.
• If a third party claims that an app infringes another party's intellectual
property rights, as between the App Platform and S&P Global, S&P Global is
responsible for the investigation, defense, settlement and discharge of any
such intellectual property infringement claim.
• The App Platform and its subsidiaries are third-party beneficiaries of the
applicable terms of use as they relate to your license to use the app. Upon
your acceptance of the terms and conditions of our terms of use, the App
Platform will have the right (and will be deemed to have accepted the right)
to enforce the terms of use as related to your license of the app against you
as a third-party beneficiary thereof.
• You must also comply with all third-party terms applicable through the App
Platform when using the app.
* When does S&P Global disclose my personal information?
We may disclose your personal information 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
who or that process personal information for purposes consistent with those
described in this Policy or 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 fulfil
its contractual obligations and to provide our products and services; we may
share your personal information with our service providers and business
partners for the purpose of operating our business, honouring a request that
you have made through the products or services, delivering, improving and
customising 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.
In addition to the purposes described in this Policy, Personal information
handled by our service providers is subject to their terms of use and privacy
policies as notified to you. Please review the service provider’s terms of
use and privacy policies to better understand how they manage your personal
information.
Your employer
We provide personal information to your employer for purposes such as to
fulfil 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 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 exercise, establish or defend our
legal rights, (iv) to protect your vital interests or those of any other
person, or (v) 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.
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 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 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.
Any other person or entity
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.
Also, please be aware that 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. We also may solicit your consent to
share personal information with any other person or entity.
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 site 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.
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?".
* What is our legal basis for processing personal information?
Our legal basis for collecting and using 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.
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, 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?".
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.
* How does S&P Global use cookies and similar tracking technology?
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, 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 interest-based
advertising. These technologies may also allow certain third parties to
collect information about you, 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 withdraw your consent to Cookies, please see our Cookie
Notice.
We 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.
* 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
country in which you are resident. These other jurisdictions may have data
protection laws that are different from the laws of your country (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 store and replicate your personal information
on servers in other countries, 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.
In some jurisdictions, international transfers may take place when there is
an adequate level of protection to the fundamental right of individuals to
data protection. 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 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.
For more information about how long we retain your personal data, please
refer to our privacy commitment here:
https://www.spglobal.com/en/privacy/our-privacy-commitment. 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 withdraw the consent you provided to us as well as the following
data protection rights:
- to access or request deletion of your personal information (where your
personal information is no longer necessary in relation to the purposes for
which we collected it), and to request a copy of your personal information in
a portable format. - to object to our processing of your personal information
if we are: using legitimate interests to justify that processing, using the
personal information for direct marketing purposes, or using the information
for scientific or historical research purposes or statistical purposes.
- to 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.
- to data portability or receiving in a machine-readable format any personal
information that you have provided to us if we are: using consent or
necessity in relation to a contract with you to justify our processing of
that data. In certain jurisdictions, your right to data portability may also
extend to personal information that has been generated in the course of your
association with S&P Global.
- not to be subject to a decision, which may adversely affect you, which is
based on solely automated processing and to have safeguards put in place if
you are being profiled based on your personal information
- to opt-out of marketing and promotional e-mails we send you at any time.
You can exercise this right by clicking on the "unsubscribe" or "opt-out"
link in the marketing e-mails we send you, by visiting our preference centers
here or by using the contact details listed in the section of this Policy
titled, “How can you contact us?”.
- if we collect and process your personal information with your consent, then
you can withdraw your consent at any time. 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.
- not to be discriminated against for exercising any of the above rights.
- to complain to a data protection authority about our collection and use of
your personal information.
For more information, please contact your local data protection authority.
(Contact details for data protection authorities in the EEA, Canada,
Switzerland and the UK are available here.)
Individuals in certain jurisdictions may have other rights. For more
information, see the applicable jurisdiction-specific addendum which forms
part of this Policy.
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 identity information to us. Because your personal information,
for example, your email address is often required to access or use Services,
we retain personal information as long as your account is active. You may
have the opportunity to correct, update, or modify this information by
logging into your account and updating your information online.
Please note that in certain jurisdictions we may be entitled to charge a fee
in connection with the exercise of these rights.
* How does S&P Global use personal information in products?
Some of our products contain personal information about persons who are
directors, officers, managers, significant employees, trustees or material
shareholders or proprietors of companies or businesses. S&P Global obtains
such data from publicly available and other sources.
Some of our products include business contact details, professional history
details, work data, compensation details, education history data,
shareholding and common holding information, information about individuals’
gender, passport and driver’s license data (for identity verification and due
diligence purposes) and information about loans taken out by or secured by
individuals in connection with their business.
We may also receive information about race or ethnicity, derived from
government or official information (such as census data). Any race or
ethnicity information is processed in aggregated, anonymized form and is not
linked to individuals. In the United States, some products may process data
regulated by the Driver’s Privacy Protection Act.
Personal Information in our products is for reference purposes, such as to
identify the officers or shareholders of a particular organization or common
shareholders or officers among otherwise not obviously related corporate
entities and is made available to our customers for such purposes. Customers
are required by contract to comply with applicable data protection laws and
their use of personal information is restricted by their contract with S&P
Global. S&P Global customers are located worldwide, including countries with
data protection laws that may offer lower protections than the laws of your
country.
S&P Global may share personal information in its products with authorized
personnel within its corporate group, with those parties who provide content
to S&P Global and with the customers who receive those products. The legal
basis for S&P Global's use and disclosure of personal information within its
products in this way is that it is necessary for legitimate commercial
interests pursued by S&P Global to provide Services to its customers to
encourage transparency and well-informed developments in global financial
markets and business, and this is not outweighed by the rights and freedoms
of those persons featured in our products, because the information about them
relates to their business roles and relationships. This personal information
is largely derived from publicly available sources and frequently from
mandated corporate or government disclosures.
S&P Global’s policies, procedures and standards require that the information
in its products is updated for accuracy on a regular basis, and the removal
data from its systems when such data becomes obsolete or inaccurate. S&P
Global has established information governance standards for collection, use
and retention of the personal information.
* 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. We updated our Global Corporate Privacy Policy, effective
January 1, 2020. At a high level, we made the following changes:
• Simplified the Policy language and structure to make it easier to navigate
and find the information you may be looking for;
• Created jurisdiction-specific addenda for you to easily find
jurisdiction-specific information, including relevant information for the
California Consumer Privacy Act (CCPA) and the People’s Republic of China
regulations;
• Specifically call out at the start of the Policy the fact that third
parties that link from our online properties and products, and the third
parties from whom we may collect personal information, have their own privacy
policies that may apply to the information that they collect from
individuals.
We updated our Global Corporate Privacy Policy, effective February 1, 2021.
At a high level, we updated the policy to:
• Provide more details about information we receive from service providers or
their employees and the information we collect automatically
• Provide high level information about the government and regulatory
proceedings, investigations and inquiries to which S&P Global may be
subject
• Provide further details about our international transfers and individuals’
rights
• Publish information about our EU/UK Representative entities in light of
Brexit
• Add more information about local contact details
We last updated our Global Corporate Privacy Policy, effective as at the date
of this document. At a high level, we updated the policy to:
• Incorporate revisions reflecting the merger between S&P Global and IHS
Markit to provide transparency about the combined group’s approach to
collecting, sharing, transferring and using personal information, and how you
can exercise your privacy rights.
• Update the addendum relating to the People’s Republic of China in light of
recent legislative developments.
• Created jurisdiction-specific addenda for Brazil and Columbia for you to
easily find further information about your rights in those jurisdictions (if
applicable).
• Add more information about local and post-merger contact details.
* How can you contact us?
If you have any questions or concerns about our use of your personal
information, please contact our Privacy Center and Data Protection Officer at
privacy@spglobal.com 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
Certain S&P Global Inc. and its applicable affiliates 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, 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
* Russian Federation
This Russian Federation Addendum ("Russian Federation Addendum") applies in
relation to the processing of personal information of Russian citizens by the
Representative Office of the Standard & Poor’s International Services LLC and
Moscow Branch of S&P Global Ratings Europe Limited (each operating
independently and individually and separately) and supplements this Policy.
In case of any inconsistencies between this Russian Federation Addendum and
the rest of this Policy, this Russian Federation Addendum prevails.
Russian Federation Addendum
* People’s Republic of 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 the 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. 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 requests 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., and Standard & Poor's
International LLC, Japan Branch (together "S&P Global Japan"). In case of any
inconsistencies between this Japan Addendum and the rest of this Policy, this
Japan Addendum prevails.
S&P Global Japan 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. The process for dealing with customers' claims is
set out in this Policy.
Use of personal information inside the S&P Global group
S&P Global Japan uses personal information with other entities in the S&P
Global group who may use such information to provide information about our
Services to our clients, conduct certain market research or contact clients.
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 Bruce Christie
Contact information regarding handling of personal information
If you have any questions or concerns about our use of your personal
information, please contact our Privacy Center 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 ("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.
Right to Access Information
You have the right to request access to personal information collected about
you and information regarding the source of that information, the purposes
for which we collect it, and the third parties and service providers with
whom we share it. To protect our customers' personal information, we are
required to verify your identity before we can act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete any
personal information that we have collected directly from you. To protect our
customers' personal information, we are required to verify your identity
before we can act on your request. We may have a reason under the law why we
do not have to comply with your request, or why we may comply with it in a
more limited way than you anticipated. If we do, we will explain that to you
in our response.
Right to Information Regarding Participation in Data Sharing for Financial
Incentives
We will ask you for your consent before collecting your personal information
in connection with offering a financial incentive.
Right to Opt Out of Sale of Personal Information to Third Parties
You have the right to opt out of any sale of your personal information by us
to third parties. Please note that your right to opt out does not apply to
our sharing of personal information with service providers, who are parties
we engage to perform a function on our behalf and are contractually obligated
to use the personal information only for that function.
"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:
(1) For Access and Deletion rights, fill out a Data Request Form.
(2) For the Opt-out right, visit "Do Not Sell My Personal Information".
(3) Call us on 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, the sources of that information, the
purposes for which we collect information, and whether we disclose that
information to external parties. We may use any and 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. The categories we use to describe the
information are those set out in the CCPA.
• Personal Identifiers:
○ Name, alias, phone number, email address, signature, username and contact
address to create an account or register for an event. Individuals with an
account will be assigned one or more unique identifiers to your profile.
○ Payment and billing information when purchasing our products or register
for a paid event.
○ Social security numbers, state identification card number, credit card
numbers and personal financial data collected from individuals or corporate
customers such as structured finance issuers for the purpose of informing our
statistical analysis or to use in providing our Services. Such data will not
be used for purposes other than these, rented or otherwise made available to
third parties for public distribution.
○ Driver's License numbers and Passport numbers in certain limited
circumstances.
○ IP address automatically.
○ Device ID automatically.
• Protected Classifications: Some product platforms allow users to upload
Protected Classifications for their own purposes, this may include age, race,
color, ancestry, national origin, citizenship, religion or creed, marital
status, medical condition, physical or mental disability, sex (including
gender, gender identity), pregnancy or childbirth (and related medical
conditions), sexual orientation, veteran or military status for their own
purpose, as detailed in the product terms of use.
• Commercial Information: Records of goods or services purchased or
considered, as well as purchasing or consuming histories or tendencies.
• Internet or Other Electronic Network Activity Information: Information
about browsing history, search history, and information regarding interaction
with product portals, websites, applications, or advertisements based on use
of our Services.
• Geolocation Data: Automatic collection of an IP address which may enable us
to determine general location. With a user’s agreement, some of our mobile
applications will also collect precise location (e.g., your GPS coordinates),
though users can turn off location tracking in their mobile device settings.
• Audio, electronic, visual, thermal, olfactory, or similar information:
Telephone service calls may be recorded, subject to an announcement at the
beginning of the call; images, for example, at an event. We do not collect
any thermal, olfactory, or similar information.
• Professional or employment-related information: We collect information
about current employer, position, and other aspects of an individual’s
professional history.
• Non-public education information: Information about institutions an
individual has attended or the level of education attained.
• Inferences drawn to create a profile about a consumer reflecting the
consumer's preferences or characteristics: We may analyze actual or likely
preferences through a series of computer processes. On some occasions, we may
add our observations to an individual’s internal profile.
We may share such information with service providers, which are external
parties that we engage for business purposes and are restricted from using
personal information for any purpose that is not related to our engagement.
The categories of service providers with whom we share information and the
services they provide are described here.
The CCPA provides California residents with certain rights in relation to the
"sale" of information to third parties. According to the CCPA, to "sell"
personal information means to disclose it to an external party for monetary
or other benefit where, for example, our contract does not restrict that
party from using such information for other purposes.
S&P Global shares or sells personal information to third parties in very
limited circumstances. For example, S&P Global may share registrant
information to event sponsors for some of its conferences or events, in
certain circumstances, and provide products that help companies identify
appropriate professional contact information by providing companies with the
name, title, and business contact information of key personnel. Below is a
list of brands that sell or 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)
It is important to note that not every product derived under these brands
sells or shares personal information with third parties. Please see the terms
of use for more details about whether the particular product you use sells or
shares personal information with third parties.
We may "sell" information in the following limited circumstances:
• Personal Identifiers:
○ We display contact information in our products, which are accessible by our
subscribers and the subscribers of our business partners.
○ We disclose contact information to our webinar and conferences partners
(i.e., attendee lists).
○ We provide contact information to public safety authorities where
necessary.
○ We provide IP addresses and Device IDs to our advertising partners.
• Protected Classifications: We display age, if available, in our
"Professionals" database, which is accessible by our subscribers and the
subscribers of our business partners. We may display aggregated gender
information in our products, but we do not display individuals' genders.
• Internet or Other Electronic Network Activity Information: We disclose
information about subscribers' interactions with our products to businesses
from which we collect data.
• Professional or employment-related information: We display information
about an individual's current employer, position, compensation details and
other aspects of an individual's professional and education history in our
products, which are accessible by our subscribers and the subscribers of our
business partners.
Records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories, or tendencies.
* 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 data;
• correct incomplete, inaccurate, or out of date data;
• anonymize, block, or delete unnecessary or excessive data or data that is
not being processed in compliance with the LGPD;
• portability of 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
data;
• information about the possibility of denying consent and the consequences
of such denial;
• revoke consent;
• request review of decisions taken solely on the bases of automated
processing of personal data that affects your interests.
You or an authorized agent may exercise your rights through the [Privacy
Request Page]. 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
IHS Markit Colombia SAS (NIT #900.505.649-2) has its principal place of
business at Calle 72 No 10 – 07 Of. 1106, Bogotá, Republic of 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’s 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
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 information 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 relation 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; and
• To carry out and manage our business operations and for any other
legitimate business purposes.
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?
Last Updated: February 28, 2022
S&P Global Inc. and its affiliates (collectively or individually, as
applicable, referred to as "S&P Global", "Company", "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.
* 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 information about S&P
Global's current group companies and other related companies, please see
our latest filings here.
* When did S&P Global and IHS Markit merge?
* WHEN DID S&P GLOBAL AND IHS MARKIT MERGE?
* When did S&P Global and IHS Markit merge?
S&P Global and IHS Markit announced their merger on 30 November 2020 and
this Policy was updated at the time the merger was completed.
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, 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.
For more information about our privacy practices relating to our Digital
and advertising-related services, please see the Advertising Privacy
Policy.
* 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 do
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 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 own purpose,
as detailed in the product terms of use.
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 one of S&P Global's corporate customers, 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 and collect
images of you provided that you do not object, for example, at an event
To enable us to send you tailored information on our Services across our
divisions that may interest to 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.
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.
Information we 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 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 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 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's 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 such
information);
- to deliver tailored information on our Services that may be of
interest or value to you and to send you marketing and promotional
e-mails 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 "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 endeavour 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 and delivery 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 and
websites, to display within some of our products. Find out more at "How
does S&P Global use personal information in products?''.
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).
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. To provide you with the functionalities of one of
our apps, the app must access various functions and data on your mobile
device.
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 you 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 also automatically collect app logs and usage statistics. For
example, we 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 you download one of our mobile apps from Apple's App Store or
Google Play (each, an "App Platform"), you acknowledge and agree that:
• As between S&P Global and the App Platform, S&P Global is solely
responsible for the app.
• The App Platform has no obligation to provide any maintenance and
support services with respect to the app.
• In the event of any failure of our apps to conform to any applicable
warranty: (i) you may notify the App Platform and the App Platform may
refund the purchase price for the app to you (if applicable), (ii) to
the maximum extent permitted by applicable law, the App Platform will
have no other warranty obligation whatsoever with respect to the
applications, and (iii) any other claims, losses, liabilities, damages,
costs or expenses attributable to any failure to conform to any warranty
is, as between S&P Global and the App Platform, S&P Global's
responsibility.
• The App Platform is not responsible for addressing any claims you have
relating to the app or your possession and use of the app.
• If a third party claims that an app infringes another party's
intellectual property rights, as between the App Platform and S&P
Global, S&P Global is responsible for the investigation, defense,
settlement and discharge of any such intellectual property infringement
claim.
• The App Platform and its subsidiaries are third-party beneficiaries of
the applicable terms of use as they relate to your license to use the
app. Upon your acceptance of the terms and conditions of our terms of
use, the App Platform will have the right (and will be deemed to have
accepted the right) to enforce the terms of use as related to your
license of the app against you as a third-party beneficiary thereof.
• You must also comply with all third-party terms applicable through the
App Platform when using the app.
* Sharing of personal information
* SHARING OF PERSONAL INFORMATION
* When does S&P Global disclose my personal information?
We may disclose your personal information 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 who or that process personal information for purposes consistent
with those described in this Policy or 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 fulfil its contractual obligations and to
provide our products and services; we may share your personal
information with our service providers and business partners for the
purpose of operating our business, honouring a request that you have
made through the products or services, delivering, improving and
customising 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.
In addition to the purposes described in this Policy, Personal
information handled by our service providers is subject to their terms
of use and privacy policies as notified to you. Please review the
service provider’s terms of use and privacy policies to better
understand how they manage your personal information.
Your employer
We provide personal information to your employer for purposes such as to
fulfil 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 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
exercise, establish or defend our legal rights, (iv) to protect your
vital interests or those of any other person, or (v) 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.
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 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 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.
Any other person or entity
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. Also, please be aware that 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. We also may solicit your consent to share personal information
with any other person or entity.
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 site
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.
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?".
* 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 using 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.
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,
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?".
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.
* Cookies and similar tracking technology
* COOKIES AND SIMILAR TRACKING TECHNOLOGY
* How does S&P Global use cookies and similar tracking technology?
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, 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 interest-based advertising. These technologies may
also allow certain third parties to collect information about you, 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 withdraw your consent to Cookies, please see
our Cookie Notice.
We 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.
* 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 country in which you are resident. These other jurisdictions may
have data protection laws that are different from the laws of your
country (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 store and replicate your
personal information on servers in other countries, 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.
In some jurisdictions, international transfers may take place when there
is an adequate level of protection to the fundamental right of
individuals to data protection. 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 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.
For more information about how long we retain your personal data, please
refer to our privacy commitment here:
https://www.spglobal.com/en/privacy/our-privacy-commitment. 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 withdraw the consent you provided to us as well as the
following data protection rights:
- to access or request deletion of your personal information (where your
personal information is no longer necessary in relation to the purposes
for which we collected it), and to request a copy of your personal
information in a portable format. - to object to our processing of your
personal information if we are: using legitimate interests to justify
that processing, using the personal information for direct marketing
purposes, or using the information for scientific or historical research
purposes or statistical purposes.
- to 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.
- to data portability or receiving in a machine-readable format any
personal information that you have provided to us if we are: using
consent or necessity in relation to a contract with you to justify our
processing of that data. In certain jurisdictions, your right to data
portability may also extend to personal information that has been
generated in the course of your association with S&P Global.
- not to be subject to a decision, which may adversely affect you, which
is based on solely automated processing and to have safeguards put in
place if you are being profiled based on your personal information
- to opt-out of marketing and promotional e-mails we send you at any
time. You can exercise this right by clicking on the "unsubscribe" or
"opt-out" link in the marketing e-mails we send you, by visiting our
preference centers here or by using the contact details listed in the
section of this Policy titled, “How can you contact us?”.
- if we collect and process your personal information with your consent,
then you can withdraw your consent at any time. 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.
- not to be discriminated against for exercising any of the above
rights.
- to complain to a data protection authority about our collection and
use of your personal information.
For more information, please contact your local data protection
authority. (Contact details for data protection authorities in the EEA,
Canada, Switzerland and the UK are available here.)
Individuals in certain jurisdictions may have other rights. For more
information, see the applicable jurisdiction-specific addendum which
forms part of this Policy.
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 identity information to us.
Because your personal information, for example, your email address is
often required to access or use Services, we retain personal information
as long as your account is active. You may have the opportunity to
correct, update, or modify this information by logging into your account
and updating your information online.
Please note that in certain jurisdictions we may be entitled to charge a
fee in connection with the exercise of these rights.
* Use of Personal Information in Products
* USE OF PERSONAL INFORMATION IN PRODUCTS
* How does S&P Global use personal information in products?
Some of our products contain personal information about persons who are
directors, officers, managers, significant employees, trustees or
material shareholders or proprietors of companies or businesses. S&P
Global obtains such data from publicly available and other sources.
Some of our products include business contact details, professional
history details, work data, compensation details, education history
data, shareholding and common holding information, information about
individuals’ gender, passport and driver’s license data (for identity
verification and due diligence purposes) and information about loans
taken out by or secured by individuals in connection with their
business.
We may also receive information about race or ethnicity, derived from
government or official information (such as census data). Any race or
ethnicity information is processed in aggregated, anonymized form and is
not linked to individuals. In the United States, some products may
process data regulated by the Driver’s Privacy Protection Act.
Personal Information in our products is for reference purposes, such as
to identify the officers or shareholders of a particular organization or
common shareholders or officers among otherwise not obviously related
corporate entities and is made available to our customers for such
purposes. Customers are required by contract to comply with applicable
data protection laws and their use of personal information is restricted
by their contract with S&P Global. S&P Global customers are located
worldwide, including countries with data protection laws that may offer
lower protections than the laws of your country.
S&P Global may share personal information in its products with
authorized personnel within its corporate group, with those parties who
provide content to S&P Global and with the customers who receive those
products. The legal basis for S&P Global's use and disclosure of
personal information within its products in this way is that it is
necessary for legitimate commercial interests pursued by S&P Global to
provide Services to its customers to encourage transparency and
well-informed developments in global financial markets and business, and
this is not outweighed by the rights and freedoms of those persons
featured in our products, because the information about them relates to
their business roles and relationships. This personal information is
largely derived from publicly available sources and frequently from
mandated corporate or government disclosures.
S&P Global’s policies, procedures and standards require that the
information in its products is updated for accuracy on a regular basis,
and the removal data from its systems when such data becomes obsolete or
inaccurate. S&P Global has established information governance standards
for collection, use and retention of the personal information.
* 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. We updated our Global Corporate Privacy
Policy, effective January 1, 2020. At a high level, we made the
following changes:
• Simplified the Policy language and structure to make it easier to
navigate and find the information you may be looking for;
• Created jurisdiction-specific addenda for you to easily find
jurisdiction-specific information, including relevant information for
the California Consumer Privacy Act (CCPA) and the People’s Republic of
China regulations;
• Specifically call out at the start of the Policy the fact that third
parties that link from our online properties and products, and the third
parties from whom we may collect personal information, have their own
privacy policies that may apply to the information that they collect
from individuals.
We updated our Global Corporate Privacy Policy, effective February 1,
2021. At a high level, we updated the policy to:
• Provide more details about information we receive from service
providers or their employees and the information we collect
automatically
• Provide high level information about the government and regulatory
proceedings, investigations and inquiries to which S&P Global may be
subject
• Provide further details about our international transfers and
individuals’ rights
• Publish information about our EU/UK Representative entities in light
of Brexit
• Add more information about local contact details
We last updated our Global Corporate Privacy Policy, effective as at the
date of this document. At a high level, we updated the policy to:
• Incorporate revisions reflecting the merger between S&P Global and IHS
Markit to provide transparency about the combined group’s approach to
collecting, sharing, transferring and using personal information, and
how you can exercise your privacy rights.
• Update the addendum relating to the People’s Republic of China in
light of recent legislative developments.
• Created jurisdiction-specific addenda for Brazil and Columbia for you
to easily find further information about your rights in those
jurisdictions (if applicable).
• Add more information about local and post-merger contact details.
* 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, please contact our Privacy Center and Data Protection
Officer at privacy@spglobal.com 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
Certain S&P Global Inc. and its applicable affiliates 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, 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
* Russian Federation - Additional Provisions
* RUSSIAN FEDERATION - ADDITIONAL PROVISIONS
* Russian Federation
This Russian Federation Addendum ("Russian Federation Addendum") applies
in relation to the processing of personal information of Russian
citizens by the Representative Office of the Standard & Poor’s
International Services LLC and Moscow Branch of S&P Global Ratings
Europe Limited (each operating independently and individually and
separately) and supplements this Policy. In case of any inconsistencies
between this Russian Federation Addendum and the rest of this Policy,
this Russian Federation Addendum prevails.
Russian Federation Addendum
* People’s Republic of China - Additional Provisions
* PEOPLE’S REPUBLIC OF CHINA - ADDITIONAL PROVISIONS
* People’s Republic of 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 the 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. 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 requests 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., and Standard
& Poor's International LLC, Japan Branch (together "S&P Global Japan").
In case of any inconsistencies between this Japan Addendum and the rest
of this Policy, this Japan Addendum prevails.
S&P Global Japan 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. The process for dealing with
customers' claims is set out in this Policy.
Use of personal information inside the S&P Global group
S&P Global Japan uses personal information with other entities in the
S&P Global group who may use such information to provide information
about our Services to our clients, conduct certain market research or
contact clients. 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 Bruce Christie
Contact information regarding handling of personal information
If you have any questions or concerns about our use of your personal
information, please contact our Privacy Center 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 ("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.
Right to Access Information
You have the right to request access to personal information collected
about you and information regarding the source of that information, the
purposes for which we collect it, and the third parties and service
providers with whom we share it. To protect our customers' personal
information, we are required to verify your identity before we can act
on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete
any personal information that we have collected directly from you. To
protect our customers' personal information, we are required to verify
your identity before we can act on your request. We may have a reason
under the law why we do not have to comply with your request, or why we
may comply with it in a more limited way than you anticipated. If we do,
we will explain that to you in our response.
Right to Information Regarding Participation in Data Sharing for
Financial Incentives
We will ask you for your consent before collecting your personal
information in connection with offering a financial incentive.
Right to Opt Out of Sale of Personal Information to Third Parties
You have the right to opt out of any sale of your personal information
by us to third parties. Please note that your right to opt out does not
apply to our sharing of personal information with service providers, who
are parties we engage to perform a function on our behalf and are
contractually obligated to use the personal information only for that
function.
"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:
(1) For Access and Deletion rights, fill out a Data Request Form.
(2) For the Opt-out right, visit "Do Not Sell My Personal Information".
(3) Call us on 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, the sources of that information,
the purposes for which we collect information, and whether we disclose
that information to external parties. We may use any and 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. The
categories we use to describe the information are those set out in the
CCPA.
• Personal Identifiers:
○ Name, alias, phone number, email address, signature, username and
contact address to create an account or register for an event.
Individuals with an account will be assigned one or more unique
identifiers to your profile.
○ Payment and billing information when purchasing our products or
register for a paid event.
○ Social security numbers, state identification card number, credit card
numbers and personal financial data collected from individuals or
corporate customers such as structured finance issuers for the purpose
of informing our statistical analysis or to use in providing our
Services. Such data will not be used for purposes other than these,
rented or otherwise made available to third parties for public
distribution.
○ Driver's License numbers and Passport numbers in certain limited
circumstances.
○ IP address automatically.
○ Device ID automatically.
• Protected Classifications: Some product platforms allow users to
upload Protected Classifications for their own purposes, this may
include age, race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity), pregnancy or
childbirth (and related medical conditions), sexual orientation, veteran
or military status for their own purpose, as detailed in the product
terms of use.
• Commercial Information: Records of goods or services purchased or
considered, as well as purchasing or consuming histories or tendencies.
• Internet or Other Electronic Network Activity Information: Information
about browsing history, search history, and information regarding
interaction with product portals, websites, applications, or
advertisements based on use of our Services.
• Geolocation Data: Automatic collection of an IP address which may
enable us to determine general location. With a user’s agreement, some
of our mobile applications will also collect precise location (e.g.,
your GPS coordinates), though users can turn off location tracking in
their mobile device settings.
• Audio, electronic, visual, thermal, olfactory, or similar information:
Telephone service calls may be recorded, subject to an announcement at
the beginning of the call; images, for example, at an event. We do not
collect any thermal, olfactory, or similar information.
• Professional or employment-related information: We collect information
about current employer, position, and other aspects of an individual’s
professional history.
• Non-public education information: Information about institutions an
individual has attended or the level of education attained.
• Inferences drawn to create a profile about a consumer reflecting the
consumer's preferences or characteristics: We may analyze actual or
likely preferences through a series of computer processes. On some
occasions, we may add our observations to an individual’s internal
profile.
We may share such information with service providers, which are external
parties that we engage for business purposes and are restricted from
using personal information for any purpose that is not related to our
engagement. The categories of service providers with whom we share
information and the services they provide are described here.
The CCPA provides California residents with certain rights in relation
to the "sale" of information to third parties. According to the CCPA, to
"sell" personal information means to disclose it to an external party
for monetary or other benefit where, for example, our contract does not
restrict that party from using such information for other purposes.
S&P Global shares or sells personal information to third parties in very
limited circumstances. For example, S&P Global may share registrant
information to event sponsors for some of its conferences or events, in
certain circumstances, and provide products that help companies identify
appropriate professional contact information by providing companies with
the name, title, and business contact information of key personnel.
Below is a list of brands that sell or 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)
It is important to note that not every product derived under these
brands sells or shares personal information with third parties. Please
see the terms of use for more details about whether the particular
product you use sells or shares personal information with third parties.
We may "sell" information in the following limited circumstances:
• Personal Identifiers:
○ We display contact information in our products, which are accessible
by our subscribers and the subscribers of our business partners.
○ We disclose contact information to our webinar and conferences
partners (i.e., attendee lists).
○ We provide contact information to public safety authorities where
necessary.
○ We provide IP addresses and Device IDs to our advertising partners.
• Protected Classifications: We display age, if available, in our
"Professionals" database, which is accessible by our subscribers and the
subscribers of our business partners. We may display aggregated gender
information in our products, but we do not display individuals' genders.
• Internet or Other Electronic Network Activity Information: We disclose
information about subscribers' interactions with our products to
businesses from which we collect data.
• Professional or employment-related information: We display information
about an individual's current employer, position, compensation details
and other aspects of an individual's professional and education history
in our products, which are accessible by our subscribers and the
subscribers of our business partners.
Records of personal property, products or services purchased, obtained,
or considered, or other purchasing or consuming histories, or
tendencies.
* 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 data;
• correct incomplete, inaccurate, or out of date data;
• anonymize, block, or delete unnecessary or excessive data or data that
is not being processed in compliance with the LGPD;
• portability of 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 data;
• information about the possibility of denying consent and the
consequences of such denial;
• revoke consent;
• request review of decisions taken solely on the bases of automated
processing of personal data that affects your interests.
You or an authorized agent may exercise your rights through the [Privacy
Request Page]. 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
IHS Markit Colombia SAS (NIT #900.505.649-2) has its principal place of
business at Calle 72 No 10 – 07 Of. 1106, Bogotá, Republic of 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’s 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
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 information 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 relation 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; and
• To carry out and manage our business operations and for any other
legitimate business purposes.
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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