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privacy-policy-english Corporate /en/privacy/privacy-policy-english content
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 * S&P Global
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 * Our Company Our Purpose & Values Our People Our History Corporate
   Responsibility Diversity & Inclusion Investor Relations
   From S&P Global
   Press Release: S&P Global and IHS Markit to Merge
   
   On Nov. 30, 2020, S&P Global and IHS Markit announced they have entered into
   a definitive merger agreement to combine in an all-stock transaction which
   values IHS Markit at an enterprise value of $44 billion, including $4.8
   billion of net debt.
   
   Read: 2020 Annual Report
   
   In 2020, our people showed tremendous resilience, responsibility and resolve
   to support one another, our customers, our communities, our suppliers, and in
   doing so, have served our shareholders.
   
   Read: A statement from S&P Global President and CEO Doug Peterson
   
   At S&P Global, we can’t change the world overnight. But we can take action to
   affect change.

 * OUR CAPABILITIES Overview Data & Analytics Research & Commentary Benchmarks
   Credit Ratings ESG Solutions
   OUR DIVISIONS S&P Global Ratings S&P Global Market Intelligence S&P Dow Jones
   Indices S&P Global Platts CRISIL, An S&P Global Company
    
 * Latest Featured Topics Podcasts Measuring the Health of the Global Economy
   Most Popular Insights
   Read: Looking at Latin America
   
   Latin America is performing better than expected in the second half of 2021.
   Households and businesses are adapting quickly to living in a pandemic, and
   lockdowns are having much less of an impact on activity than anticipated.
   
   Read: China’s Road Ahead
   
   As China pushes to achieve ambitious energy goals to reach carbon neutrality
   by 2060, the economy is adapting to a new reality of factors including green
   spending, emission targets, and carbon market trading.
   
   Read: The Big Picture on Broadband
   
   U.S. broadband providers are carrying considerable momentum out of the
   pandemic despite increased competition and impending service maturity with
   penetrations nearing 90% of occupied households.

 * Overview Our Culture Our Commitment Our Work Search for a Job
   
 * Featured Events Featured S&P Global Events Webinar Replays
   Events from our S&P Global Divisions S&P Global Ratings Events S&P Global
   Market Intelligence Events S&P Global Platts Events S&P Dow Jones Indices
   Events


 * Introduction
 * What does S&P Global do?
 * Personal information we collect
 * Sharing of personal information
 * Legal basis for processing personal information
 * Cookies and similar tracking technology
 * Keeping your personal information secure
 * International data transfers
 * Data retention
 * Your data protection rights
 * Use of Personal Information in Products
 * Updates to this Policy
 * Policy changes 1 Jan 2020
 * Policy changes 1 February 2021
 * How to contact us
 * Russian Federation - Additional Provisions
 * People’s Republic of China - Additional Provisions
 * Japan - Additional Provisions
 * State of California, United States - Additional Provisions


GLOBAL CORPORATE PRIVACY POLICY

--------------------------------------------------------------------------------

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View Full Privacy Policy as PDF

Our Privacy Commitment
 * What is this Policy about?
   
   Last Updated: 1 February 2021
   
   
   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 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.
   
   You also may have certain rights with respect to your personal information
   under applicable 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. Please review their policies
   to learn more about their practices.

 * 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
   worldwide. S&P Global's divisions include S&P Global Ratings, S&P Global
   Market Intelligence, S&P Dow Jones Indices and S&P Global Platts. For more
   information about S&P Global, please see the "Who we are"  section of our
   website.

 * 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 or to receive research 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 include:
   
   Types of personal information
   
   Why we collect it
   
   Billing information
   
   To maintain your account with us.
   
   Contact details such as name, telephone numbers (which may include
   cell/mobile numbers), email address and postal address and details of any
   correspondence you send us.
   
   To respond to your correspondence and inquiries, such as when you want to
   learn more about our conferences and webinars.
   
   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 and any personal information
   you provide to us when you create a profile, such as details of your
   education and your gender.
   
   To set up and maintain your user account.
   
   To monitor and enforce compliance with our contract terms.
   
   Employer and employment information such as job title, 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.
   
   To enable us to send you tailored information on our Services across our
   divisions that may interest to you.
   
   Social security/Official identification 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.
   
   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.
   
   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 FROM YOU 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 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.

 * How does S&P Global use and share my personal information?
   
   We may disclose your personal information to the following categories of
   recipients.
   
   Our group companies, service providers, product content providers and
   business partners
   
   We share personal information with our group companies, S&P Global divisions,
   service providers, and business partners 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 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, seek feedback on and promote our
   events. A list of our current group companies is available here  and a list
   of our service providers, content providers and business partners is
   available here.
   
   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 when we believe
   disclosure is necessary (i) as a matter of applicable law or regulation, (ii)
   to exercise, establish or defend our legal rights, or (iii) to protect your
   vital interests or those of any other person.
   
   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.
   
   Our SEC filings set this out in more detail and are available here.
   
   Potential Buyers
   
   We provide personal information to a potential buyer (and its or our agents
   and advisers) in connection with any proposed purchase, merger or acquisition
   of any part of our business. We inform the buyer that it must use your
   personal information only as disclosed in this Policy.
   
   Any other person or entity
   
   Personal information that you disclose on message boards, chat areas or our
   social media pages or in direct messages to other users may be collected and
   used by third parties without our knowledge or control. We encourage you to
   use caution when publicly disclosing your 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, advising you of product
   features or new releases, informing you of product maintenance, or
   undertaking marketing activities).
   
   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 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://www.google.com/policies/privacy/partners/ 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/dlpage/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.

 * 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).
   
   Our servers may be located outside of the jurisdiction where we collected the
   data, such as the United States of America, Canada, United Kingdom (“UK”),
   Republic of Ireland, Germany, the Netherlands, India and Singapore. 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 process
   it in any of the countries in which we do business. Our group companies,
   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 processed by or on behalf of our
   group companies are the United States of America, the United Kingdom,
   Germany, the Republic of Ireland and Singapore. 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 use
   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. 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?
   
   We retain your personal information 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, we follow our applicable information governance policies,
   procedures and standards and retain your information for as long as necessary
   to accomplish the purpose for which it was collected, following which we
   either delete or anonymize your personal information, or if deletion or
   anonymization is not possible, then we pseudonymize and/or securely store
   your personal information and isolate it from any further processing until
   deletion is possible.
   
   Please contact us for more information about the period of time for which we
   will process your personal information.

 * 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, correct, update 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 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 in order to transfer it to another
   controller, 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 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 using the S&P Global
   division-specific contact details below, or by visiting the preference center
   for each division by clicking here:
   
   * S&P Global Market Intelligence preference center
   
   * S&P Dow Jones Indices preference center
   
   * S&P Global Ratings preference center
   
   * S&P Global Platts preference center
   
   - 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.)
   
   Residents of the State of Nevada have the right to opt out of the sale of
   certain pieces of their information to third parties who will sell or license
   their information to others. If you are a Nevada resident and would like to
   make such a request, please email privacy@spglobal.com.
   
   Residents of the State of California have specific rights in relation to
   their personal information. For more information, see our California
   Addendum.
   
   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 and in any event within 30 days. 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 of companies. S&P Global obtains such data from publicly
   available and other sources.
   
   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 (displayed
   at an aggregated level) 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.
   
   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 this purpose. 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 within its
   corporate group, with those parties who provide content to S&P Global and
   with the customers who receive those products. S&P Global will not use your
   personal information for any other purposes than as described above, which is
   within S&P Global's legitimate commercial interests to provide S&P Global
   Services to its customers.
   
   S&P Global updates the information in its products for accuracy on a regular
   basis. S&P Global removes data from its systems when such data becomes
   obsolete or inaccurate and S&P Global operates data 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 note
   the date of the version on the Policy and post the updated version here. We
   will bring any material updates to your attention.

 * Policy changes 1 Jan 2020
   We are updating our Global Corporate Privacy Policy, effective January 1,
   2020. At a high level, we have 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.

 * Policy changes 1 February 2021
   We are updating our Global Corporate Privacy Policy, effective February 1,
   2021. At a high level, we have 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

 * How can you contact us?
   
   If you have any questions or concerns about our use of your personal
   information, please contact our Chief Privacy Officer 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
   
   For the Philippines, you may also use email DPOPhilippines@spglobal.com.
   
   European Union Contact Details for non-European Union S&P Global affiliates
   
   Certain S&P Global 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
   
   
   S&P Global Ratings Europe Limited
   Fourth Floor, Waterways House
   Grand Canal Quay
   Dublin 2, Ireland
   RatingsGDPR@spglobal.com
   
   S&P Global Market Intelligence
   
   
   S&P Global Indices UK Limited, Irish branch
   Fourth Floor, Waterways House
   Grand Canal Quay
   Dublin 2, Republic of Ireland
   MlPrivacyOfficer@spglobal.com
   
   S&P Dow Jones Indices
   
   
   S&P Global Indices UK Limited, Irish branch
   Fourth Floor, Waterways House
   Grand Canal Quay
   Dublin 2, Republic of Ireland
   spdjiGDPR@spglobal.com
   
   S&P Global Platts
   
   
   S&P Global Indices UK Limited, Irish branch
   Fourth Floor, Waterways House
   Grand Canal Quay
   Dublin 2, Republic of Ireland
   PlattsGDPR@spglobal.com
   
    
   
   UK Contact Details for non-UK S&P Global affiliates
   
   Certain S&P Global 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
   
   
   S&P Global Ratings UK Limited
   20 Canada Square
   Canary Wharf
   London
   E14 5LH
   RatingsGDPR@spglobal.com
   
   S&P Global Market Intelligence
   
   
   S&P Global UK Limited
   20 Canada Square
   Canary Wharf
   London
   E14 5LH
   MlPrivacyOfficer@spglobal.com
   
   S&P Dow Jones Indices
   
   
   
   S&P Global Indices UK Limited
   20 Canada Square
   Canary Wharf
   London
   E14 5LH
   spdjiGDPR@spglobal.com
   
   S&P Global Platts
   
   
   
   Platts (U.K.) Limited
   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 S&P
   Global affiliates registered in the Russian Federation 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 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 lead to discriminatory treatment or serious damage to
       personal or property safety, including national identification card
       number, financial accounts, and personal whereabouts 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 transfer any personal information when we sell
       or transfer all or a portion of our business or assets to a third party
       such as in the event of merger, acquisition, liquidation or similar
       event. We will require such third party to continue to comply with this
       Policy including this China Addendum or 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.
    4. Closure of a registered account. If you want to close an account which is
       registered with S&P Global, please contact our Chief Privacy Officer at
       privacy@spglobal.com or DPOChina@spglobal.com or Chief Privacy Officer,
       at: 49/F, Fortune Financial Center, No.5, Dongsanhuan Zhong Rd, Chaoyang
       District, Beijing. We will handle your request and close your account
       within 15 business days.

 * Japan
   
   This Japan Addendum ("Japan Addendum") 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") and supplements this Policy. 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.
   
   Anonymously Processed Information provided to S&P Global Ratings Japan Inc.
   and S&P Global SF Japan Inc. and shared by S&P Global Ratings Japan Inc. and
   S&P Global SF Japan Inc. with other companies in the S&P Global group
   
   S&P Global Ratings Japan Inc. and S&P Global SF Japan Inc. share anonymously
   processed information with other companies in the S&P Global group on an
   ongoing basis in the context of its structured finance business. The
   "information items relating to individuals" included in the anonymously
   processed information shared with those companies and the "method of sharing"
   those items are set out below.
   
   "Information items relating to individuals to be shared with other companies
   in the S&P Global group":
   
   • Information in relation to borrowers and joint guarantors (borrower code
   allocated by a creditor, age-related information, gender, address-related
   information, occupation- related information, annual income, account balance
   etc)
   
   • Loan information relating to the individual borrower (category, loan
   amount, loan period, information-related to property location and evaluation
   amount).
   
   
   
   "Method of sharing the anonymously processed information":
   
   By such means as uploading or sending by e-mail to a server that only
   authorized S&P Global group personnel may access.
   
   If you have any questions or concerns about our use of your personal
   information, please contact our Chief Privacy Officer 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") 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 as required by the California Consumer Privacy Act ("CCPA") and
   supplements this Policy. 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, or the Fair
   Credit Reporting 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 identify 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 identify
   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.
   
   The following is a description 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. The categories we use to describe the information are those set out
   in the CCPA.
   
   • Personal Identifiers:
   
   o We collect your name, phone number, email address, and contact address when
   you create an account or register for an event, an account or event
   registration is created for you or you complete a transaction. If you choose
   to create an account, you will also be asked to create a username, and we
   will assign one or more unique identifiers to your profile.
   
   o You provide us with payment and billing information when you purchase one
   of our products or register for a paid event.
   
   o We collect social security numbers, credit card numbers and personal
   financial data from you 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.
   
   o We do not collect your Driver's License number or Passport number.
   
   o We do not collect any medical information or health information about you.
   
   o We collect your IP address automatically.
   
   o We collect your Device ID automatically.
   
   • Protected Classifications: We collect your age and gender.
   
   • Commercial Information: When you engage in transactions with us, we create
   records of goods or services purchased or considered, as well as purchasing
   or consuming histories or tendencies. • Biometric Information: We do not
   collect information about your physiological, biological, or behavioral
   characteristics.
   
   • Internet or Other Electronic Network Activity Information: We collect
   information about your browsing history, search history, and information
   regarding your interaction with product portals, websites, applications, or
   advertisements automatically when you use our Services.
   
   • Geolocation Data: As described above, we collect your IP address
   automatically. We may be able to determine your general location based on the
   IP address. When you agree, some of our mobile applications will also collect
   your 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: If
   you contact us via phone, we may record the call. We will notify you if a
   call is being recorded at the beginning of the call. We may collect your
   image. We do not collect any thermal, olfactory, or similar information.
   
   • Professional or employment-related information: We collect information
   about your current employer, position, and other aspects of your professional
   history.
   
   • Education information: We collect information about the institutions you
   have attended or the level of education you have attained.
   
   • Inferences drawn to create a profile about a consumer reflecting the
   consumer's preferences or characteristics: We may analyze your actual or
   likely preferences through a series of computer processes. On some occasions,
   we may add our observations to your 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. We may "sell"
   information in the following limited circumstances:
   
   • Personal Identifiers:
   
   o We display contact information in our products, which are accessible by our
   subscribers and the subscribers of our business partners.
   
   o We disclose contact information to our webinar and conferences partners
   (i.e., attendee lists).
   
   o We provide contact information to public safety authorities where
   necessary.
   
   o 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.
   
   • Inferences drawn to create a profile about a consumer reflecting the
   consumer's preferences or characteristics: Third parties such as advertising
   partners may collect personal information using Cookies or other tracking
   technologies as disclosed in our Cookie Notice.


GLOBAL CORPORATE PRIVACY POLICY

--------------------------------------------------------------------------------

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View Full Privacy Policy as PDF

Our Privacy Commitment
 * Introduction
   
   * INTRODUCTION
     
      * What is this Policy about?
        
        Last Updated: 1 February 2021
        
        
        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 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.
        
        You also may have certain rights with respect to your personal
        information under applicable 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.
        Please review their policies to learn more about their practices.
 * 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
        worldwide. S&P Global's divisions include S&P Global Ratings, S&P Global
        Market Intelligence, S&P Dow Jones Indices and S&P Global Platts. For
        more information about S&P Global, please see the "Who we are"  section
        of our website.
 * 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 or to receive research
        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 include:
        
        Types of personal information
        
        Why we collect it
        
        Billing information
        
        To maintain your account with us.
        
        Contact details such as name, telephone numbers (which may include
        cell/mobile numbers), email address and postal address and details of
        any correspondence you send us.
        
        To respond to your correspondence and inquiries, such as when you want
        to learn more about our conferences and webinars.
        
        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 and any personal
        information you provide to us when you create a profile, such as details
        of your education and your gender.
        
        To set up and maintain your user account.
        
        To monitor and enforce compliance with our contract terms.
        
        Employer and employment information such as job title, 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.
        
        To enable us to send you tailored information on our Services across our
        divisions that may interest to you.
        
        Social security/Official identification 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.
        
        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.
        
        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 FROM YOU 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 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
     
      * How does S&P Global use and share my personal information?
        
        We may disclose your personal information to the following categories of
        recipients.
        
        Our group companies, service providers, product content providers and
        business partners
        
        We share personal information with our group companies, S&P Global
        divisions, service providers, and business partners 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 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, seek feedback on and promote our events. A list of our current
        group companies is available here  and a list of our service providers,
        content providers and business partners is available here.
        
        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 when we
        believe disclosure is necessary (i) as a matter of applicable law or
        regulation, (ii) to exercise, establish or defend our legal rights, or
        (iii) to protect your vital interests or those of any other person.
        
        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.
        
        Our SEC filings set this out in more detail and are available here.
        
        Potential Buyers
        
        We provide personal information to a potential buyer (and its or our
        agents and advisers) in connection with any proposed purchase, merger or
        acquisition of any part of our business. We inform the buyer that it
        must use your personal information only as disclosed in this Policy.
        
        Any other person or entity
        
        Personal information that you disclose on message boards, chat areas or
        our social media pages or in direct messages to other users may be
        collected and used by third parties without our knowledge or control. We
        encourage you to use caution when publicly disclosing your personal
        information.
 * 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,
        advising you of product features or new releases, informing you of
        product maintenance, or undertaking marketing activities).
        
        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 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://www.google.com/policies/privacy/partners/ 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/dlpage/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.
 * 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).
        
        Our servers may be located outside of the jurisdiction where we
        collected the data, such as the United States of America, Canada, United
        Kingdom (“UK”), Republic of Ireland, Germany, the Netherlands, India and
        Singapore. 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
        process it in any of the countries in which we do business. Our group
        companies, 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
        processed by or on behalf of our group companies are the United States
        of America, the United Kingdom, Germany, the Republic of Ireland and
        Singapore. 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 use 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. 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?
        
        We retain your personal information 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, we follow our applicable information governance
        policies, procedures and standards and retain your information for as
        long as necessary to accomplish the purpose for which it was collected,
        following which we either delete or anonymize your personal information,
        or if deletion or anonymization is not possible, then we pseudonymize
        and/or securely store your personal information and isolate it from any
        further processing until deletion is possible.
        
        Please contact us for more information about the period of time for
        which we will process your personal information.
 * 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, correct, update 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
        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 in order to transfer
        it to another controller, 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 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 using the S&P
        Global division-specific contact details below, or by visiting the
        preference center for each division by clicking here:
        
        * S&P Global Market Intelligence preference center
        
        * S&P Dow Jones Indices preference center
        
        * S&P Global Ratings preference center
        
        * S&P Global Platts preference center
        
        - 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.)
        
        Residents of the State of Nevada have the right to opt out of the sale
        of certain pieces of their information to third parties who will sell or
        license their information to others. If you are a Nevada resident and
        would like to make such a request, please email privacy@spglobal.com.
        
        Residents of the State of California have specific rights in relation to
        their personal information. For more information, see our California
        Addendum.
        
        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 and in any event within 30 days. 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 of companies. S&P Global obtains such data from
        publicly available and other sources.
        
        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 (displayed at an aggregated level) 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.
        
        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 this
        purpose. 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 within its
        corporate group, with those parties who provide content to S&P Global
        and with the customers who receive those products. S&P Global will not
        use your personal information for any other purposes than as described
        above, which is within S&P Global's legitimate commercial interests to
        provide S&P Global Services to its customers.
        
        S&P Global updates the information in its products for accuracy on a
        regular basis. S&P Global removes data from its systems when such data
        becomes obsolete or inaccurate and S&P Global operates data 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
        note the date of the version on the Policy and post the updated version
        here. We will bring any material updates to your attention.
 * Policy changes 1 Jan 2020
   
   * POLICY CHANGES 1 JAN 2020
     
      * Policy changes 1 Jan 2020
        We are updating our Global Corporate Privacy Policy, effective January
        1, 2020. At a high level, we have 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.
 * Policy changes 1 February 2021
   
   * POLICY CHANGES 1 FEBRUARY 2021
     
      * Policy changes 1 February 2021
        We are updating our Global Corporate Privacy Policy, effective February
        1, 2021. At a high level, we have 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
 * 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 Chief Privacy Officer 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
        
        For the Philippines, you may also use email DPOPhilippines@spglobal.com.
        
        European Union Contact Details for non-European Union S&P Global
        affiliates
        
        Certain S&P Global 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
        
        
        S&P Global Ratings Europe Limited
        Fourth Floor, Waterways House
        Grand Canal Quay
        Dublin 2, Ireland
        RatingsGDPR@spglobal.com
        
        S&P Global Market Intelligence
        
        
        S&P Global Indices UK Limited, Irish branch
        Fourth Floor, Waterways House
        Grand Canal Quay
        Dublin 2, Republic of Ireland
        MlPrivacyOfficer@spglobal.com
        
        S&P Dow Jones Indices
        
        
        S&P Global Indices UK Limited, Irish branch
        Fourth Floor, Waterways House
        Grand Canal Quay
        Dublin 2, Republic of Ireland
        spdjiGDPR@spglobal.com
        
        S&P Global Platts
        
        
        S&P Global Indices UK Limited, Irish branch
        Fourth Floor, Waterways House
        Grand Canal Quay
        Dublin 2, Republic of Ireland
        PlattsGDPR@spglobal.com
        
         
        
        UK Contact Details for non-UK S&P Global affiliates
        
        Certain S&P Global 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
        
        
        S&P Global Ratings UK Limited
        20 Canada Square
        Canary Wharf
        London
        E14 5LH
        RatingsGDPR@spglobal.com
        
        S&P Global Market Intelligence
        
        
        S&P Global UK Limited
        20 Canada Square
        Canary Wharf
        London
        E14 5LH
        MlPrivacyOfficer@spglobal.com
        
        S&P Dow Jones Indices
        
        
        
        S&P Global Indices UK Limited
        20 Canada Square
        Canary Wharf
        London
        E14 5LH
        spdjiGDPR@spglobal.com
        
        S&P Global Platts
        
        
        
        Platts (U.K.) Limited
        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 S&P Global affiliates registered in the Russian Federation
        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 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 lead to discriminatory treatment or
            serious damage to personal or property safety, including national
            identification card number, financial accounts, and personal
            whereabouts 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 transfer any personal information when we
            sell or transfer all or a portion of our business or assets to a
            third party such as in the event of merger, acquisition, liquidation
            or similar event. We will require such third party to continue to
            comply with this Policy including this China Addendum or 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.
         4. Closure of a registered account. If you want to close an account
            which is registered with S&P Global, please contact our Chief
            Privacy Officer at privacy@spglobal.com or DPOChina@spglobal.com or
            Chief Privacy Officer, at: 49/F, Fortune Financial Center, No.5,
            Dongsanhuan Zhong Rd, Chaoyang District, Beijing. We will handle
            your request and close your account within 15 business days.
 * Japan - Additional Provisions
   
   * JAPAN - ADDITIONAL PROVISIONS
     
      * Japan
        
        This Japan Addendum ("Japan Addendum") 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") and supplements this Policy.
        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.
        
        Anonymously Processed Information provided to S&P Global Ratings Japan
        Inc. and S&P Global SF Japan Inc. and shared by S&P Global Ratings Japan
        Inc. and S&P Global SF Japan Inc. with other companies in the S&P Global
        group
        
        S&P Global Ratings Japan Inc. and S&P Global SF Japan Inc. share
        anonymously processed information with other companies in the S&P Global
        group on an ongoing basis in the context of its structured finance
        business. The "information items relating to individuals" included in
        the anonymously processed information shared with those companies and
        the "method of sharing" those items are set out below.
        
        "Information items relating to individuals to be shared with other
        companies in the S&P Global group":
        
        • Information in relation to borrowers and joint guarantors (borrower
        code allocated by a creditor, age-related information, gender,
        address-related information, occupation- related information, annual
        income, account balance etc)
        
        • Loan information relating to the individual borrower (category, loan
        amount, loan period, information-related to property location and
        evaluation amount).
        
        
        
        "Method of sharing the anonymously processed information":
        
        By such means as uploading or sending by e-mail to a server that only
        authorized S&P Global group personnel may access.
        
        If you have any questions or concerns about our use of your personal
        information, please contact our Chief Privacy Officer 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") 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 as required by the California Consumer Privacy Act
        ("CCPA") and supplements this Policy. 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, or the Fair Credit Reporting 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 identify 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 identify 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.
        
        The following is a description 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. The categories we use to describe the
        information are those set out in the CCPA.
        
        • Personal Identifiers:
        
        o We collect your name, phone number, email address, and contact address
        when you create an account or register for an event, an account or event
        registration is created for you or you complete a transaction. If you
        choose to create an account, you will also be asked to create a
        username, and we will assign one or more unique identifiers to your
        profile.
        
        o You provide us with payment and billing information when you purchase
        one of our products or register for a paid event.
        
        o We collect social security numbers, credit card numbers and personal
        financial data from you 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.
        
        o We do not collect your Driver's License number or Passport number.
        
        o We do not collect any medical information or health information about
        you.
        
        o We collect your IP address automatically.
        
        o We collect your Device ID automatically.
        
        • Protected Classifications: We collect your age and gender.
        
        • Commercial Information: When you engage in transactions with us, we
        create records of goods or services purchased or considered, as well as
        purchasing or consuming histories or tendencies. • Biometric
        Information: We do not collect information about your physiological,
        biological, or behavioral characteristics.
        
        • Internet or Other Electronic Network Activity Information: We collect
        information about your browsing history, search history, and information
        regarding your interaction with product portals, websites, applications,
        or advertisements automatically when you use our Services.
        
        • Geolocation Data: As described above, we collect your IP address
        automatically. We may be able to determine your general location based
        on the IP address. When you agree, some of our mobile applications will
        also collect your 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:
        If you contact us via phone, we may record the call. We will notify you
        if a call is being recorded at the beginning of the call. We may collect
        your image. We do not collect any thermal, olfactory, or similar
        information.
        
        • Professional or employment-related information: We collect information
        about your current employer, position, and other aspects of your
        professional history.
        
        • Education information: We collect information about the institutions
        you have attended or the level of education you have attained.
        
        • Inferences drawn to create a profile about a consumer reflecting the
        consumer's preferences or characteristics: We may analyze your actual or
        likely preferences through a series of computer processes. On some
        occasions, we may add our observations to your 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. We
        may "sell" information in the following limited circumstances:
        
        • Personal Identifiers:
        
        o We display contact information in our products, which are accessible
        by our subscribers and the subscribers of our business partners.
        
        o We disclose contact information to our webinar and conferences
        partners (i.e., attendee lists).
        
        o We provide contact information to public safety authorities where
        necessary.
        
        o 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.
        
        • Inferences drawn to create a profile about a consumer reflecting the
        consumer's preferences or characteristics: Third parties such as
        advertising partners may collect personal information using Cookies or
        other tracking technologies as disclosed in our Cookie Notice.

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