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 * PIB Content Privacy Notice

PIB Privacy Notice Sections

 1. INTRODUCTION
 2. WHAT WE COLLECT AND HOW WE USE IT
 3. LEGAL BASES
 4. HOW WE SHARE YOUR PERSONAL DATA
 5. HOW WE PROTECT AND RETAIN PERSONAL DATA
 6. YOUR RIGHTS
 7. OTHER IMPORTANT INFORMATION
 8. CONTACT US


THE PROFESSIONAL INFORMATION BUSINESS CONTENT PRIVACY NOTICE

Effective Date: April 2, 2020

1. INTRODUCTION

Dow Jones & Company, Inc., and its subsidiaries ("Dow Jones") want you to be
familiar with
how we collect, use and disclose Personal Data that is part of the content of
our Services,
because we respect your concerns about privacy, and want to maintain your trust.
This Professional Information Business Content Privacy Notice (“Content Privacy
Notice”)
applies to the content in our subscription only Professional Information
Business
Products, including Factiva, Companies & Executives, Risk & Compliance, and Due
Diligence Reports (“PIB Products”). For our general Privacy Notice applicable to
information
we collect from and about users in connection with our websites, mobile sites,
applications,
widgets, conferences, events, and electronic newsletters or communications,
please click
here.
This Content Privacy Notice describes the types of Personal Data we collect, how
we use it
and for what purposes, and with whom we share it. We also describe the measures
we take
to protect the Personal Data, rights that may be available to you depending on
applicable
law, and how you can contact us, or the supervisory authorities if you are in
the European
Economic Area or Switzerland (collectively “EEA”), about privacy practices.
The entity ultimately responsible as controller for processing Personal Data
within PIB
Products is Dow Jones & Company, Inc. (Contact information provided below in
Contact Us ).
Within the EEA, the primary responsible entity is Factiva Limited, based in the
United
Kingdom.

2. WHAT WE COLLECT AND HOW WE USE IT

"Personal Data" for the purposes of this Content Privacy Notice is the
information that
identifies an individual or relates to an identifiable person.

2.1 Factiva

Description and purpose: Factiva is a global news and information database and
media
archive available by subscription. Dow Jones’ subscribing customers agree to use
the
database to conduct business and academic research, for competitive and trend
analysis,
and as a source of detailed news and information.

Types of individuals included: Individuals referenced in sources contained in
the Factiva
database.

Sources of data: Data is collected from nearly 33,000 news and information
sources,
including The Wall Street Journal, Dow Jones Newswires, MarketWatch, Financial
News,
and Barron’s as well as licensed publications, websites, press releases, blogs,
images and
videos.

What Personal Data may be processed: Factiva may contain a wide range of
Personal Data
about individuals referenced in source material contained in the Factiva
database, as
relevant to and varied depending on the source. Details of the types of Personal
Data
processed in connection with related products are set out in sections 2.2 to 2.4
below.

2.2 Companies & Executives

Description and purpose: Companies & Executives is a component of Factiva that
contains
information on industries, executives, board members, and approximately 20
million public
and private companies or organizations. We provide this content for subscribing
customers
to inform their business research and competitive analyses. Information provided
includes
executive team details, corporate family trees and financial results.

Types of individuals included: Executives and people in management or board
positions.

Sources of data: Data is sourced from third-party providers of business and
financial data
analytics. This data is augmented by information from company websites and
content and
news from other PIB Products.

What Personal Data may be processed: Identifying information such as name and
contact
details within the company or organization, as well as company ownership
information;
biography; career-related information and education details; and compensation.

2.3 Risk & Compliance

Description and purpose: Risk & Compliance is a subscription-only service that
provides
information curated exclusively from publicly available sources. Risk &
Compliance collects
and processes this information, which includes Personal Data available in the
source
material, such as newspaper articles, government and other official websites,
government
directories and other publicly available information, to assist our subscribing
customers (e.g.,
financial institutions, professional services firms and other regulated
entities, governments,
law enforcement agencies, regulators, non-profits, and other organizations) in
performing
due diligence and other screening activities in accordance with their legal or
regulatory
obligations and risk management procedures. The information is only made
available to
subscribing customers who affirm that they require it to mitigate risks and meet
regulatory
requirements relating to, for example, money laundering, bribery and corruption,
sanctions,
due diligence and commercial risk operations.

Risk & Compliance data is not offered for use in determining an individual’s
eligibility for
credit, insurance, employment or for any other eligibility determination
purposes that would
qualify the service as a consumer report under the Fair Credit Reporting Act
(FCRA) or any
other similar laws. Dow Jones does not imply any negative inferences about
individuals or
entities referred to within the Risk & Compliance data merely because of their
inclusion
within the Risk & Compliance service.

Types of individuals included: Individuals on Sanctions Lists or other official
lists (such as
lists issued by national governments, international organizations, law
enforcement agencies
or financial regulators); “Politically Exposed Persons” (a term used in
Anti-Money Laundering
regulations to denote an individual who is or has been entrusted with a
prominent public
function, such as a head of state, a government minister or a board member of a
state-owned company); “Special Interest Persons” (a term used to describe
individuals
reported in sources in Factiva to have been declared wanted, charged with or
arrested on
suspicion of or tried, convicted or sentenced for offences within certain crime
categories);
Relatives and Close Associates of individuals outlined above; individuals
associated with
Marijuana-Related Businesses as owners, shareholders or senior executives;
individuals
who are license holders of money services businesses.

Sources of data: Data is collected from a variety of publicly available sources,
including
government and other official websites, government directories, Factiva, other
online
newspapers and periodicals, print or online directories and company websites.
What Personal Data may be processed: Identifying information such as name,
alias, date of
birth or age, gender, place of birth, personal identification numbers;
photographic images;
politically exposed roles; information about relatives and close personal
associations;
inclusion on Sanctions Lists or other official lists; Information about
ownership of companies
(Ultimate Beneficial Ownership data is provided by Dun & Bradstreet as data
controller);
Information from public sources about specific types of crime or criminal
allegations.
The amount of Personal Data processed will vary depending on the publicly
available
information for the individual and the reason the individual is included in Risk
& Compliance.
As a result, not all of the categories listed above may be included for an
individual.

2.4 Due Diligence Reports

Description and purpose: Due Diligence Reports are commissioned by subscribing
customers to help them identify potential legal or regulatory risks associated
with their
suppliers, customers or third parties. Subscribing customers are provided the
reports to
determine risk levels in a business relationship and mitigate against those
risks. Due
Diligence Reports are not offered for use in determining an individual’s
eligibility for credit,
insurance, employment or for any other eligibility determination purposes that
would qualify
the service as a consumer report under the Fair Credit Reporting Act (FCRA) or
any other
similar laws.

Types of individuals included: As determined by the Dow Jones customer.

Sources of data: Data is collected from a variety of publicly available sources
as well as from
company and litigation information providers with whom we have contracts.
Sources include
government and other official websites, government directories, Factiva and Risk
&
Compliance as well as other online sources and registers.

What Personal Data may be processed: Identifying information such as name, date
of birth
or age, place of birth, personal identification numbers; information about
family members
should they have any links to government or be involved in adverse or noteworthy
issues;
career-related information and education details; public and professional roles
and personal
affiliations; politically exposed roles; information about ownership of
companies; financial
information such as bankruptcy or insolvency filings; inclusion on Sanctions
Lists;
information from public sources about specific types of financial crime and
related
proceedings.

The amount of Personal Data processed will vary depending on the publicly
available
information for the individual and the type of report requested. As a result,
not all of the
categories listed above may be included for an individual.

3. LEGAL BASES

The processing is necessary for the purposes of legitimate interests pursued by
us or
asserted by our subscribing customers (for example, our customers have a
legitimate
interest in seeking to meet their legal obligations, to reduce their compliance
risks, to carry
out business, for the purpose of journalism, or to conduct academic research).
Depending on
the product, the processing may also be necessary for a task carried out in the
public
interest (for example, the public interest in preventing crime, financial crime,
and fraud). As
regards special categories of data and criminal data that may be in certain of
these products
as described above, the legal bases are as described above, as well as because
the
processing is necessary for reasons of substantial public interest (including
for the purposes
of journalism and academic research), or the processing is authorized under
applicable
Member State laws for various reasons, including the prevention of unlawful
acts,
dishonesty, terrorism, and fraud.

4. HOW WE SHARE YOUR PERSONAL DATA

We may disclose your Personal Data to the subscribing customers of our PIB
Products for
the purposes listed above.

Dow Jones & Company, Inc., and its subsidiaries may share your Personal Data
with one
another for the purposes described in this Content Privacy Notice, including to
support the
PIB Products or to provide related products or services to the relevant
subscriber. Dow
Jones may also share your Personal Data with Dow Jones Affiliates. A list of Dow
Jones
subsidiaries and Affiliates is available in annual reports here.

We may disclose your Personal Data to third parties in compliance with
applicable law. This
may include: competent regulatory or governmental authorities in order to comply
with
requests for information; third party service providers for technical support
and maintenance
in relation to the Services (including to ensure that there are appropriate
technical,
organizational and security measures to protect your information); our
professional advisers,
including legal service providers and accountants in the context of taking
professional
advice, protecting our rights and as otherwise described above.

Further, there may be instances when Dow Jones may disclose your Personal Data,
including situations where we have a good faith belief that such disclosure is
necessary in
order to: protect, enforce, or defend the legal rights, privacy, safety, or
property of Dow
Jones, our Dow Jones Affiliates or their employees, agents and contractors
(including
enforcement of our agreements and our terms of use); protect the safety,
privacy, and
security of users of our products and services or members of the public; protect
against
fraud and other unlawful activity or for risk management purposes; comply with
and enforce
the law or legal process, including laws outside your country of residence,
contractual
obligations, and our policies; or respond to requests from public and government
authorities,
including public and government authorities outside your country of residence,
to the extent
permitted by applicable law.

If Dow Jones sells all or part of its business or assets, or is otherwise
involved in a merger,
reorganization, dissolution, liquidation, or transfer of all or part of its
business, as part of that
transaction Dow Jones may transfer your Personal Data to the party or parties
and their
advisors involved in the transaction.

5. HOW WE PROTECT AND RETAIN PERSONAL DATA

Dow Jones uses a combination of administrative, technical, personnel and
physical
measures to safeguard Personal Data in its possession against accidental,
unlawful or
unauthorized loss, use, access, disclosure or modification. We make reasonable
efforts to
ensure a level of security appropriate to the risk of the processing, taking
into account the
costs of implementation and nature of the processing of Personal Data.

We keep your Personal Data for as long as needed in light of the purpose(s) for
which it is
processed, unless a longer retention period is required or allowed by law. The
criteria used
to determine our retention periods include (i) as long as the information is
relevant to the
purposes of processing; (ii) as required by a legal obligation to which Dow
Jones is subject;
(iii) and as needed to defend or enforce Dow Jones’ legal rights.

6. YOUR RIGHTS

Depending on the applicable jurisdiction, you may have certain rights in
relation to the
Personal Data we hold about you: you may have the right to request access to
Personal
Data we hold about you, ask us to update, correct or remove Personal Data we
hold about
you, or object to or ask us to restrict our processing of your Personal Data.
See the Contact
Us section below for more details. Note that if your request relates to the
processing of
Personal Data by a PIB Products subscriber, we will refer your request to the
relevant
subscriber. We may ask you to provide further information about the basis for
your request
before we respond. For example, we may ask you to specify the reasons why you
believe
the Personal Data we hold about you is incorrect, incomplete or not processed in
accordance with applicable data protection law.

For your protection, we may need to verify your identity before implementing
your request.
For example, we may request additional information to verify your identity
depending on the
nature of the request and the sensitivity of the information sought. You can use
an
authorized agent to submit your request. If you use an authorized agent, in
addition to
verifying the request itself (see above), we will also verify the authorized
agent’s ability to act
on your behalf (they should submit written permission to act on your behalf or a
power of
attorney).

We will try to comply with your request as soon as reasonably practicable. To
the extent
permitted by applicable law, we may charge a reasonable fee to comply with your
Privacy
Request. You should be aware that we may not be required to comply (or fully
comply) with
your request. In those circumstances, we will write to you explaining why we are
unable to
comply.

You may have the right to lodge a complaint with a supervisory authority,
depending on
where you are located. For information on supervisory authority contacts, see
the Contact
Us section, below.

In addition, subject to certain limitations, California Law permits our
customers who are
California residents to request certain information regarding our disclosure of
Personal Data
during the preceding calendar year. To make such a request, California residents
can write
to us at privacypolicy@dowjones.com, Attn: Privacy Team, and include your name
and the
address to which you would like us to respond.

7. OTHER IMPORTANT INFORMATION
7.1 Notice Updates

Dow Jones may periodically update this Content Privacy Notice without prior
notice, to
reflect changes in our practices. Please look at the Effective Date at the top
of this Content
Privacy Notice to see when this Content Privacy Notice was last revised. Any
changes to this
Content Privacy Notice will become effective when we post the revised Content
Privacy
Notice. We will notify you by posting a prominent notice indicating we have
updated this
Content Privacy Notice.

7.2 Transfers

Your Personal Data may be stored, transferred to, and processed in any country
where we
have facilities or in which we engage service providers. These countries, which
may include
the United States, may be outside your country of residence, and may have
different data
protection laws than in your country.

If you are located in the EEA or another jurisdiction with data transfer
restrictions, we will
implement appropriate safeguards to protect your Personal Data as required if we
transfer it
outside the EEA or your non-EEA country to a country that is not considered to
provide an
adequate level of data protection by the European Commission. In these cases we
have put
in place adequate measures, such as standard contractual clauses adopted by the
European Commission, to protect your Personal Data. To obtain a copy of our
safeguards
for such transfers, please communicate your request using the information shown
below in
Contact Us.

8. CONTACT US

If you have any questions about this Content Privacy Notice or how we handle
your Personal
Data, or if you want to contact us in relation to your rights referred to in
sections 6 or 7
above, please contact our Chief Privacy Officer and Data Protection Officers at
riskandcompliance.support@dowjones.com.

Or you may write to either:

Attention: Privacy
Dow Jones & Company, Inc.
4300 U.S. Route 1 North
Monmouth Junction, NJ 08852
United States of America
Email:
riskandcompliance.support@dowjones.com. Factiva Limited
The News Building, 7th Floor
1 London Bridge Street
SE1 9GF London
England
Attention: Data Protection Officer
Email:
riskandcompliance.support@dowjones.com.

We will respond to your questions and complaints about our processing of your
Personal
Data. If you are not satisfied with our response, depending on where you are
located you
can contact a supervisory authority or your state’s attorney general. A list of
supervisory
authorities in the European Union can be accessed here, as well as our lead
supervisory
authority the United Kingdom Information Commissioner’s Office.

Please avoid unnecessarily disclosing sensitive Personal Data (e.g., information
related to
racial or ethnic origin, political opinions, religion or other beliefs, health,
or trade union
membership), social security numbers, or criminal background information when
contacting
us.


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