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3. Privacy statement
Last updated: March 16, 2022
PRIVACY STATEMENT
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Print
Your privacy and trust are important to us. This Statement explains how
Refinitiv Limited and Refinitiv US LLC and their respective affiliates and
subsidiaries (collectively “Refinitiv”) and the London Stock Exchange Group of
companies (collectively with Refinitiv, “LSEG”, “we”, “us” or “our”) processes
(e.g., collects, handles, stores, uses, shares or transfers, and protects)
personal information about you as further described below. It also provides
information about your rights and about how you can contact us if you have
questions about how we handle your information.
* Who this statement applies to and what it covers
* Who we are
* Sources of personal information
* What types of personal information we collect
* How we use personal information
* Legitimate interests for use
* Marketing
* How we share personal information
* International transfers
* How we secure personal information
* How long we keep personal information
* Your rights
* California privacy rights
* Cookies and similar technologies policy
* Where to find further privacy information on LSEG’s services
* How to contact us
* Updates to this statement
WHO THIS STATEMENT APPLIES TO AND WHAT IT COVERS
This Statement applies to individuals who access, use, and/or interact with our
products, services, websites, digital properties, platforms, software, and
application(s), including mobile application (“app”) (including third-party
platforms that host our websites and/or content) that hyperlink to this
Statement (we call these our “Services”), attend our events or events hosted at
our premises; to independent contractors or consultants whom we engage to
perform and/or provide a service; and to subcontractors, vendors, suppliers, or
service providers and to the personnel of the same.
This Statement covers the content that forms part of our Services (excluding
World-Check content or information). The Privacy Statement covering World-Check
is available here.
Children’s Privacy. Our Services are not generally aimed at children. We do not
intentionally collect personal information from or about individuals under the
age of thirteen (13); however, in the event that we learn or discover that we
have collected personal information inconsistent with this statement, we will
ensure that the processing of such personal information is for a lawful and
legitimate purpose and we will make reasonable efforts to delete and remove such
personal information following the expiration or termination of the lawful and
legitimate purpose.
Depending on the Service, we may provide additional or different privacy
statements or notices for specific interactions you have with us or to highlight
how we use your personal information for specific Services. Where we do this, it
will be clear which statements apply to which interactions and Services. For
example, if you use one of our mobile apps, we may provide you a separate notice
in relation to a particular data type collected through that app.
Within our Services, there may be links to third-party websites or applications.
We are not responsible for the content or privacy compliance of third-party
websites or applications. You should check those websites or applications for
their privacy statements and terms that apply to them.
This Statement does not apply when we are acting in the role or capacity of a
processor or service provider (or any other similar role or capacity) of
personal information on behalf of a third-party. In such case, we are processing
personal information at the direction and instruction of the third-party and the
third-party’s privacy statement(s) will govern and control.
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WHO WE ARE
LSEG is a global company that is made up of numerous legal entities. Excluding
those companies that have their own, separate privacy statement, this Statement
applies to all companies within the LSEG group undertakings. The term “group
undertakings” has the meaning given in Section 1161 Companies Act 2006. For a
list of group companies, please refer to our most recent annual report which you
can find on our Annual Reports page. For additional information, please contact
us.
For some Services we make decisions on how personal information is used in the
context of a Service (The appropriate entity within LSEG is a controller of
personal information in this case), and for other Services we will only use
personal information as instructed by our customers (LSEG is a processor of
personal information in this case). Below you can find more information on the
cases in which LSEG is a controller of personal information and information on
how to contact us.
To learn more about the Services in which we are a controller of personal
information, please visit this page. If you wish to contact the LSEG entity that
is controller for the Service relevant to you, please contact Refinitiv Limited,
Privacy Office, Five Canada Square, Canary Wharf, London E14 5AQ, England,
United Kingdom or, in the European Economic Area, please contact Refinitiv/LSEG,
Data Protection Officer, Messeturm Friedrich Ebert Anlage 49, Frankfurt 60327 or
we welcome you to contact us.
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SOURCES OF PERSONAL INFORMATION
We collect personal information about you (e.g., your access, use, and/or
interactions with us and our Services) from certain third parties and other
sources.
We obtain personal information from you:
* through your interactions with us and our Services, such as, when you
purchase or use our Services, when you supply or provide services to us,
sign-up to use a Service, request information or to receive marketing or
other communications from us (e.g., marketing emails, alerts, newsletters,
etc.), register for or attend an event, apply for or carry out a regulated
role or position identified in our market rules for one of the companies
listed on our markets or their relevant advisors, or call us for support
(please note that we may record or monitor our telephone calls for compliance
and quality assurance purposes)
* through your system/device and use of our Services. Our servers, logs and
other technologies may automatically collect certain information from or
about you and your systems and devices (e.g., IP address, UserID, etc.) and
usage information to help us administer, protect (i.e., to detect and prevent
fraud and security threats), and improve our Services, analyze usage and
improve users’ experience
* through cookies and similar technologies included on our Services. More
information relating to cookies, and how to control their use can be found
here and information related to Interest-Based and Mobile Advertising can be
found here
* through your engagement with us as an independent contractor/consultant
We may also collect personal information about you from third parties such as:
* the party or person(s) arranging for you to access our Services (e.g., your
employer, subscriber, an organization, group, or association to which you
belong or are associated with) in order to set up a user account or otherwise
to access and/or use our Services
* partners and service providers who work with us in relation to our Services
* companies that provide content or information to be used in our Services
* public domain sources (e.g., sources available to the public and typically
over the internet (e.g., websites available to the general public), available
in or through widely distributed media, and from government databases,
records, and system (e.g., U.S. Securities and Exchange Commission, U.K.
Companies House, sanctions lists, etc.)
To the extent that any personal information is provided to us by a third-party,
other than the data subject, such third parties are also responsible for their
own compliance with applicable data protection and privacy laws.
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WHAT TYPES OF PERSONAL INFORMATION WE COLLECT
The types and categories of personal information we collect depends on how you
are interacting with us, which Services you are purchasing or using, and on the
type of Service(s).
Depending upon the Services you use or your interactions with us, on the
relevant Service(s), the personal information we collect may include:
* Name and contact data, such as first and last name, email address, postal
address, phone number, and other similar contact data
* Employer and Professional Level data, such as the names of your current
and/or former employers, job title(s), business contact information,
industry, certifications, etc.
* Educational data, such as your education history
* Account credentials, such as passwords and other security information for
authentication and access
* User content, such as communications and files provided by you in relation to
your use of the Services
* Payment information, such as payment card number (credit or debit card), and
the security code associated with your payment instrument, if you make a
payment
* Device information, such as information about your device, such as IP
address, location, device identification numbers, or provider
* Usage information and browsing history, such as, information about how you
navigate within our Services, your browsing history and which elements of our
Services you use the most
* Location data, for Services with location-enhanced features. If we need your
consent to collect geo-location data, we will collect this separately
* Demographic information, such as, your country, and preferred language
* CCTV, if you visit or work from our offices or attend our event
* Images and/or Photographs, if you visit or work from our offices or attend an
event that we sponsor or organize
* Identification documentation, such as copies of passports, drivers’ licenses,
other government issued identification documents, etc., if you submit a data
subject rights request, attend an in-person event, etc.
* Special categories of data or sensitive personal information, such as
information on health/disabilities or religion, as it relates to your use of
or access to our Services or events (e.g., health/disability information
relating to your access to and use of our offices or attending our events,
religious information as it relates to dietary requirements for attending an
event or meeting, etc.)
* Identifiers, such as unique identification numbers, cookie identifiers,
account numbers, social security numbers, national identifiers, etc.
* In addition to the above personal information, which may be sourced from
public sources, additional personal information may be sourced from public
sources, such as personal information (1) originally available to the public
and typically over the internet; (2) that LSEG has a reasonable basis to
believe is lawfully made available to the general public by or from: (i) the
data subject (or consumer or individual to whom the personal information
relates), (ii) widely distributed media, or (iii) from a person to whom the
data subject has disclosed the personal information (provided that LSEG does
not have knowledge that the data subject has restricted the information to a
specific audience); or (3) lawfully made available from records, databases,
and/or systems of government agencies, departments, divisions or other
operating units, in electronic, paper or any other format. Examples include
personal information found on: (i) sanction or watch lists; (ii) law
enforcement, court, regulatory, registry or other governmental websites and
databases; (iii) political websites and publications such as parliamentary,
local government or individual politician websites; (iv) reputable news media
and publications; and (v) information sources made public by an individual
themselves, for example on their website, blog or any social media
application. The public source data may also include or reveal, directly or
indirectly, information about age/date of birth, race, ethnic origin,
political opinions, religious or philosophical beliefs, trade union
membership, genetic data, health data, sex life, sexual orientation, criminal
offense data or family circumstances (e.g. marital status, dependents, etc.).
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HOW WE USE PERSONAL INFORMATION
This section includes details of the purposes for which we use personal
information and also the different legal grounds upon which we process that
personal information. Further information is set out below.
Some laws require us to explain our lawful reason for processing your personal
information. Personal information may be processed under more than one lawful
reason/basis. We process personal information about you on the basis that it is:
* necessary for the performance of a contract: where we have a contract with
you, we will process your personal information in order to fulfil that
contract (i.e., to provide you with Services)
* in our or a third-party’s legitimate interests: details of those legitimate
interests are set out in more detail below (e.g., provision of Services that
we are contractually obliged by a third-party, such as your employer or our
subscriber, to deliver to you)
* substantial public interest on the basis of applicable law (e.g., to help
prevent and detect unlawful acts (e.g., money laundering, terrorism, fraud
and/or other criminal activity (including, without limitation, modern
slavery)))
* where you give us your consent (e.g., signing up to receive marketing and
promotional communications from or about LSEG, competitions administered by
or on behalf of us): we only ask for your consent in relation to specific
uses of personal information where we need to and, if we need it, we will
collect it separately and make it clear that we are asking for consent
* for compliance with a legal obligation (e.g., to respond to a court order or
a regulator; comply with statutory and regulatory requirements within the
jurisdictions within which we operate (including those relating to bribery
and corruption, money laundering and sanctions; sharing personal information
with external organizations (e.g., police, tax authorities, or other public
authorities or government enforcement agencies))
In the limited circumstances where we process sensitive personal information, we
normally do so where:
* necessary in relation to employee obligations
* personal information is within the public domain
* necessary for the establishment, exercise or defence of legal claims or
whenever courts are acting in their judicial capacity
* processing is necessary for reasons of substantial public interest, on the
basis of applicable law
You are welcome to contact us for further information on the legal grounds that
we rely on in relation to any specific processing of your personal information.
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LEGITIMATE INTERESTS FOR USE
We use personal information for a number of legitimate interests. More detailed
information about these legitimate interests is set out below.
We use personal information:
* to set up and administer your account and your use of our Services (including
for access credentialing purposes, provide technical and customer support and
training, verify your identity and perform authentication activities,
facilitate and process transactions, provide suggestions and recommendations
related to our Services, service our customers’ needs (including delivering
the Services) and send important account, subscription and Service
information)
* to administer our relationship with you, our business and our third-party
providers (e.g., to send invoices)
* to understand the patterns, preferences and interests of our customers to
improve and enhance our Services
* to handle enquiries and complaints
* to contact you for participation in, and to conduct, and manage, events,
webinars, seminars, meetings, and/or other related gatherings or similar
activities
* to run or operate competitions, prize draws, promotions, or sweepstakes that
you participate in
* to undertake screening, investigation and enforcement activity in respect of
companies listed on our markets, their officers and their relevant advisors
* to deliver and suggest tailored content such as news, research, reports and
business information. We analyze the way you use our Services to make
suggestions to you for features or Services that we believe you will also be
interested in, and so that we can make our Services more user-friendly
* to personalize your experience with our Services. We may retain your browsing
and usage information to make your searches within our Services more relevant
and use those insights to target advertising to you online on our websites
and apps. Your choices in relation to marketing are explained here. We may
sometimes share your personal information across our Services so that we can
make all of the Services we deliver to you more intuitive (e.g., rather than
requiring you to enter the same data many times)
* to contact you in relation to, and to conduct, surveys, polls or other
research activities and to analyze the data collected for market research
purposes, including, without limitation, related to creating and improving
our Services
* to display information you choose to post, share, upload or make available in
chat rooms, messaging services, and community and event forums (including in
community and event profiles) and for related collaboration, peer connection,
games and information exchange
* to provide any third-party, who has made our Services available to you (e.g.,
your employer or our subscriber), insights about use of the Services
* for internal research and development purposes and to improve, test and
enhance the features and functions of our Services
* to provide you with marketing as permitted by law
* to meet our internal and external audit requirements, including our
information security obligations (and if your employer or our subscriber
provides for your access to our Services, to meet their internal and external
audit requirements)
* for regulatory reporting, oversight and co-operation
* to enforce our terms and conditions
* to protect our rights, privacy, safety, networks, systems and property, or
those of other persons including, without limitation, verifying identity at
our premises (e.g., collecting a personal identification document and related
information) and monitoring our premises for safety and security (e.g., CCTV)
purposes
* for the (i) onboarding of, and management of relationships with,
clients/customers, vendors/service providers, business partners, professional
advisors and/or any other counterparties; (ii) negotiation and finalization
of, and/or participation in, any sale, merger, acquisition, restructure,
joint venture, assignment, transfer or other disposition of all or any
portion of our business, assets or stock (including in connection with any
bankruptcy or similar proceedings) or any similar transaction(s); and (iii)
appointment and periodic review of any individuals in ownership, shareholder,
member, manager, director, officer and/or any other executive-level
positions, roles, or capacities for or with companies within the LSEG group
of companies and in connection with the matters covered in (i) – (iii)
immediately above, to carry out any background and screening checks
(including screening checks performed using our World-Check product.) For the
Privacy Statement for our World-Check product, please click here
* for the prevention, detection or investigation of a crime or other breach of
law or requirement, loss prevention or fraud
* to build, update, supplement and manage content databases made available to
our customers in connection with our Services;
* to comply with requests from courts, law enforcement agencies, regulatory
agencies, and other public and government authorities, including where they
are outside your country of residence
* in order to exercise our rights, and to defend ourselves from claims and to
comply with laws and regulations that apply to us or third parties with whom
we work
Where we rely on legitimate interests as a lawful ground for processing your
personal information, we balance those interests against your interests,
fundamental rights and freedoms. For more information on how this balancing
exercise has been carried out, please contact the Privacy Office.
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MARKETING
We deliver marketing and event communications to you across various platforms
such as email, telephone, text messaging, direct mail and online. Where required
by law, we will ask you to explicitly opt in to receive marketing from us. If we
send you a marketing communication, it will include instructions on how to opt
out of receiving these communications in the future.
Honoring your marketing preferences is important to us. You have the right to
opt out of receiving direct marketing and targeted online advertising.
We use tools and technologies to deliver or display targeted marketing and
advertising content on or through our Services, which may involve the use of
cookies and related technologies, the tracking of IP addresses and/or assigning
and tracking unique identification numbers.
We also may engage in marketing and advertising activities through chat or
messenger functionality available through our Services.
We use email tracking technology including, without limitation, dynamic links
and image files, when we send you marketing communications to review your
engagement and the effectiveness and relevance of the communications.
We use tools and technologies to distinguish known and unknown users of our
Services and to record, review, track and analyse engagement and use of our
Services (e.g., recording or tracking hovers, clicks, key word searches,
personal information entered into forms, etc.).
We may also engage in marketing activities on third-party platforms, including,
without limitation, social media platforms; however, such activities are subject
to the privacy statements and terms and conditions applicable to such
third-party platforms.
HOW TO OPT OUT OF MARKETING
Where we engage in direct marketing activities, including, without limitation,
direct marketing via email, post, and telephone/mobile phone, we provide
individuals the ability to opt-out or unsubscribe from such marketing
activities. You can use the “Contact Us” feature of a particular Service, you
can use the specific opt-out or unsubscribe mechanisms made available to you in
connection with a specific type of marketing communication, you can discuss with
your LSEG contact, or contact the Privacy Office. As an example, for email
marketing activities, we provide several opt-out or unsubscribe options
including, without limitation, via the opt-out/unsubscribe options in emails,
through our email marketing preference center, or through contacting the Privacy
Office.
Even if you opt out of receiving marketing communications, we may still send you
service communications or important transactional information related to your
accounts, subscriptions and applicable products (for purposes such as providing
customer support).
INTEREST-BASED ADVERTISING
Interest-based advertising (“IBA”) allows us to deliver targeted advertising to
users of our Services. IBA works by showing you advertisements, or sending you
marketing emails, that are based on the type of content you access or read. For
example, as you browse our Services, one of the cookies placed on your device
will be an advertising cookie so we can better understand what sort of pages or
content you are interested in. The information collected about your device
enables us to group you with other devices that have shown similar interests. We
can then display advertising to categories of users that is based on common
interests. For more information about IBA, you can visit the Internet
Advertising Bureau here.
OPTING OUT OF IBA
If you want to opt out of receiving interest-based advertising, it does not mean
that you will no longer receive advertising when you are using our Services. It
just means that we will not use your personal information for IBA and that any
advertising you see will not be customized to you. You can exercise your online
advertising choices here or by clicking the AdChoices icon in an ad and
following the instructions. You may also opt out of receiving interest-based ads
from many sites through the Network Advertising Initiative’s (NAI) Opt Out Tool
and in the EU. If you delete cookies, use a different device, or change web
browsers, you may need to opt out again.
ADVERTISING ON MOBILE DEVICES
Mobile devices have an identifier that gives companies the ability to serve
targeted ads to a specific mobile device. In many cases, you can turn off mobile
device ad tracking or you can reset the advertising identifier at any time
within your mobile device privacy settings. Another tool you can use to control
advertising on your mobile device is the AppChoices App. You may also choose to
turn off location tracking on your mobile device. If you turn off ad tracking or
location tracking, we will no longer use information collected from your
device’s advertising identifier for the purposes of advertising. You may still
see the same number of ads but they may be less relevant because they will not
be based on your interests. Where we need your consent to gather information
about your location we will obtain this from you.
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HOW WE SHARE PERSONAL INFORMATION
We share personal information with various parties and persons including within
the LSEG group of companies, with our business partners and third-party service
providers, the party or person providing your access to our Services (if that is
not you), in accordance with law and as otherwise described in this Statement.
Our third-party service providers are not permitted to share or use personal
information we make available to them for any purpose other than to provide
services to us. In connection with the sharing of personal information,
additional notice may be provided, and consent obtained, as required under
applicable law.
We share your information for the purposes set out in this Statement, with the
following categories of recipients:
* LSEG group of companies to be used as described in this Statement
* the person providing your access to our Services (e.g., your employer or our
subscriber)
* business partners with whom we deliver co-branded Services; business partners
with whom we engage in product or service co-selling activities; business
partners with whom we provide content, or to host events, conferences and
seminars
* third parties that help us deliver Services or act on our behalf (e.g.,
vendors, service providers, subcontractors, processors)
* our customers who are purchasing or using our Services or the service
providers or vendors of our customers for the purpose of facilitating our
customers’ use of our Services
* third parties where we have a duty to or are permitted to disclose your
personal information by law (e.g., government agencies, law enforcement,
courts and other public authorities)
* third parties in order to participate in, or be the subject of, any sale,
merger, acquisition, restructure, joint venture, assignment, transfer or
other disposition of all or any portion of our business, assets or stock
(including in connection with any bankruptcy or similar proceedings) or other
similar transaction(s), in which case we may disclose your personal data to
prospective buyers, sellers, advisers or partners and your data may be a
transferred asset in a business sale
* third parties where reasonably required to protect our rights, users, systems
and Services (e.g., legal counsel and information security professionals)
* any person you have asked us to share information with (e.g., if you upload
information into a public forum it is shared publicly)
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INTERNATIONAL TRANSFERS
LSEG is a global organization and your personal information may be stored and
processed outside of your home country, including in countries that may not
offer the same level of protection for your personal information as your home
country. We have measures in place to ensure that when your personal information
is transferred internationally, it is subject to appropriate safeguards in
accordance with data protection laws. Often, these include contractual
safeguards. More information about these safeguards (including copies, where
relevant) can be obtained by contacting us here.
LSEG has networks, databases, servers, systems, support and helpdesks around the
world. We collaborate with third parties like cloud hosting services, suppliers
and technology support located around the world to serve the needs of our
business, workforce and customers. We take appropriate steps to ensure that
personal information is processed, secured and transferred according to
applicable law. In some cases, we may need to disclose or transfer your personal
information within LSEG or to third parties in areas outside of your home
country, including to countries that have not been declared adequate for the
purposes of data protection by data protection regulators/supervisory
authorities, including, without limitation, the UK and the European Commission.
The areas in which these recipients are located will vary from time to time, but
include the United States, Europe, Canada, Asia (including Australia and India)
Sri Lanka and Malaysia, and all other countries where LSEG has a business
presence.
When we transfer personal information internationally, we put in place
safeguards in accordance with applicable law (including Articles 44 to 50 of the
EU General Data Protection Regulation). If you would like to know more about our
data transfer practices and obtain copies of any relevant safeguarding measures,
please contact the Privacy Office.
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HOW WE SECURE PERSONAL INFORMATION
LSEG takes the security of personal information seriously and we use appropriate
technologies, security controls, and procedures to protect personal information
(including administrative, technical and physical safeguards) according to the
risk level and the service provided.
We have in place a global cyber information security team, led by our Chief
Information Security Officer, which is responsible for implementing secure data
handling practices at LSEG.
Our information security policies and procedures are closely aligned with widely
accepted international standards and are reviewed regularly and updated as
necessary to meet the sensitivity of the personal information we handle, our
business needs, changes in technology and regulatory requirements. While we use
reasonable means to protect your security as described above, data transmission
over the internet cannot always be guaranteed to be one hundred percent (100%)
secure. We cannot and do not warrant the security of any personal information
you transmit, and all such transmissions are done at your own risk.
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HOW LONG WE KEEP PERSONAL INFORMATION
We retain your information in accordance with the applicable records retention
schedules/policies. These schedules/policies may be company and/or Service
specific. You can find more information on the criteria used to calculate the
retention periods set out below.
LSEG has a Data Governance Office that works in conjunction with the Privacy
Office to implement policies and rules relating to the retention of personal
information. We have a records retention process that is based upon a
classification scheme consisting of business functions, record classes, and
record types.
We calculate retention periods for your personal information in accordance with
the following criteria:
* the length of time necessary to fulfill the purposes we collected it for
* when you or your employer (or other subscriber providing for your access to
our Services) cease to use our Services
* the length of time it is reasonable to keep records to demonstrate that we
have fulfilled our duties and obligations
* any limitation periods within which claims might be made
* any retention periods prescribed by law or recommended by regulators,
professional bodies or associations
* the existence of any relevant proceedings
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YOUR RIGHTS
You may have rights under UK, European and other laws to have access to your
personal information and to ask us to rectify, erase and restrict use of, your
personal information. You may also have rights to object to your personal
information being used, to ask for the transfer of personal information you have
made available to us and to withdraw consent to the use of your personal
information. Further information on how to exercise your rights is set out
below.
We will honor your rights under applicable data protection laws. You have the
following rights under UK and European laws, and may have similar rights under
the laws of other countries.
* Right of subject access: The right to make a written request for details of
your personal information and a copy of that personal information
* Right to rectification: The right to have inaccurate information about you
corrected or removed
* Right to erasure (‘right to be forgotten’): The right to have certain
personal information about you erased
* Right to restriction of processing: The right to request that your personal
information is only used for restricted purposes where:
* the accuracy of personal information is contested;
* the processing is unlawful, but you object to the erasure of the personal
information; or
* we no longer require the personal information, but it is still required for
the establishment, exercise, or defense of a legal claim.
* Right to opt out of marketing: The right to request that you not receive
marketing communications from us, which can be for a specific type of
marketing communication or for all marketing communications
* Right to object: The right to object to processing of your personal
information in cases where our processing is based on the performance of a
task carried out in the public interest or we have let you know the
processing is necessary for our or a third-party’s legitimate interests
* Right to data portability: The right to ask for the personal information you
have made available to us to be transferred to you or a third-party in
machine-readable format
* Right to withdraw consent: The right to withdraw any consent you have
previously given us to handle your personal information. If you withdraw your
consent, this will not affect the lawfulness of our use of your personal
information prior to the withdrawal of your consent
These rights are not absolute and they do not always apply in all cases.
In response to a request, we will ask you to verify your identity if we need to,
and to provide information that helps us to understand your request better. If
we do not comply with your request, whether in whole or in part, we will explain
why.
In order to exercise your rights please visit this site.
SOUTH AFRICA – ACCESS TO INFORMATION.
Refinitiv have established processes and procedures to allow appropriate data
subjects to exercise their rights under South Africa’s Protection of Personal
Information Act. If you wish to exercise your rights, please visit here. For
more information on our processes and procedures, and your rights, you can visit
our Promotion of Access to Information Manual.
BRAZIL PRIVACY RIGHTS
For information and disclosures applicable to data subjects covered under the
Lei Geral de Proteção de Dados, please visit here.
CALIFORNIA PRIVACY RIGHTS
The California Consumer Privacy Notice supplements this Statement and applies
solely to California consumers.
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COOKIES AND SIMILAR TECHNOLOGIES POLICY
LSEG sets and uses first-party and third-party cookies and similar or related
technologies (collectively referred to as “cookies”) to allow for the proper
functioning of our Services, store and manage user preferences, deliver targeted
advertising, engage in marketing activities, enable personalized content, and
gather, analyze and report on analytic and usage data. The use of cookies may
occur across websites and apps through which information is collected about your
online activities across applications, websites, or other services. More
information about how we use cookies and similar technologies and how you can
control and manage them is set forth below.
Through the use of cookies, we and our third-party providers may process (e.g.,
store or retrieve) information on or from your browser, including identifiers
(e.g., cookie IDs and other unique identification numbers), which may be used:
(i) to enable your use of our Services and the proper functioning of our
Services;
(ii) to record, track and reviewing your activity, interactions and
communications with, about, or on LSEG and Services for the purposes of:
(a) analyzing and reporting on website and content usage, marketing campaigns,
and interest in our Services;
(b) creating, personalizing and delivering marketing and advertising content;
(c) connecting data from different databases, systems, and/or websites for
various purposes including, without limitation, creating, personalizing and
delivering content (including marketing content) and analyzing and reporting on
the use of our Services; and
(d) creating look-a-like models and segments for the purpose of engaging in
marketing, advertising, and promotional activities on or through our Services
and/or third party platforms and services (e.g., social media sites, etc.) that
are directed to, or targeting individuals or data subjects who fall within such
look-a-like models or segments.
More information about how we use cookies and how you can control and manage
them is below and in the applicable cookie preference center for a website or
domain.
Certain websites or domains are part of the same or similar domain structure and
deploy and use the same cookies, and cookie preferences set on or for one
website or domain within the group applies to all websites or domains within the
group. For the list of websites or domains that are covered under the same user
cookie preference settings please click here. After the cookie preferences are
set for one website or domain within the group, the user will not see another
banner addressing, and/or will not be required to consent to (where applicable),
the deployment of cookies on or for the other websites or domains within the
group unless the user clears the applicable cookie cache. Clearing the
applicable cookie cache will delete or remove the cookie containing the user’s
preferences.
WHAT IS A COOKIE?
A cookie is a small text file that is placed on a computer or other device and
is used to identify the user or device and to collect information. Cookies are
typically assigned to one of five categories, depending on their function and
intended purpose: strictly necessary cookies, performance cookies, functional
cookies, targeting cookies and social media cookies. Some cookies may fulfill
more than one purpose.
TYPES OF COOKIES AND WHY WE USE THEM
Strictly necessary cookies: These cookies are necessary for websites to function
and cannot be switched off through the applicable cookie preference center. They
are usually only set in response to actions made by you which amount to a
request for services, such as setting your privacy preferences, logging in or
filling in forms.
Performance cookies: These cookies collect information, including analytics,
about how you use our Services. Information collected includes, for example, the
Internet browsers and operating systems used, the domain name of the website
previously visited, the number of visits, average duration of visit, actions
taken, and pages viewed. These cookies may be used to record or track your
interaction and/or use of our web and/or mobile sites, platforms and/or digital
properties. Performance cookies help us measure the activity on our Services,
create reports and statistics about the performance of our Services, improve the
user-friendliness of the Services and improve the quality of our Services. These
types of cookies typically stay active on your computer until they are deleted
or until the cookies expire (as applicable).
Functional cookies: These cookies allow the website to remember information
about you (e.g., your username or ID,) and the choices you make (e.g., your
language preference, or the area or region you are in) and provide enhanced,
more personalized features or content to you. These cookies can also be used to
remember changes you have made to text size, fonts, and other customizable parts
of web pages. They may also be used to provide Services you have asked for, such
as watching a video or commenting on a blog. If you do not allow these cookies
or if you toggle these cookies off, then some or all of these Services may not
function properly. These cookies cannot track your browsing activity on other
websites.
Targeting cookies: These cookies track browsing habits (on and off of our
websites and digital properties) and are used to deliver targeted
(interest-based) advertising. They are also used to limit the number of times
you see an ad and to measure the effectiveness of advertising campaigns. They
remember that you have visited a website and this information may be shared with
other organizations, such as advertisers and LSEG’s advertising partners, who
might use it with information about how you use other websites, including
identifying shared interests and behaviors across groups of users who visit our
(and other) websites. In connection with this type of cookies, your activities
may be tracked or reviewed using identifiers (e.g., a cookie ID). These types of
cookies will typically stay on your computer until they are deleted or until
they expire (if applicable).
SOCIAL MEDIA COOKIES
These cookies are set by third-party social media services that we have added to
the site to enable you to share our content with your friends and networks and
to log-in to, and share information with, LSEG’s Services.
Some of our Services may include social networking features, such as the
Facebook® “Like” button and widgets, “Share” buttons, and interactive
mini-programs. Additionally, you may choose to use your own social networking
logins from, for example, Facebook or LinkedIn®, to log into some of our
Services. If you choose to connect to our Services using a social networking or
similar service, we may receive and store authentication information from that
social media service to enable you to log in and other information that you may
choose to share when you connect with these Services. These Services may collect
information such as the web pages you visited and IP addresses for various
purposes and may set cookies to enable features to function properly.
LSEG is not responsible for the security and privacy practices of the third
parties who set or deploy cookies in connection with social media services. You
should review the applicable third-party privacy statements carefully to
understand their collection and processing of personal information. If you do
not want your personal information shared with your social media account
provider or other users of the social media service, please do not connect your
social media account with your account for the Services and do not participate
in social sharing on or in connection with the Services.
Certain cookies deployed by social media services may be listed under the
Targeting Cookies category in the preference center available through the Cookie
Settings. All references to “Cookie Setting” means that cookie preference center
for each applicable website or domain, which is available on or through each
applicable website or domain. If there is no “Cookie Settings” functionality for
a website and you wish to opt-out of, or remove, Cookies please clear or delete
cookies through your browser settings.
MANAGING COOKIES
You can manage cookies through your browser settings, and our preference center
available through the Cookie Settings. The preference center available through
the Cookie Settings on our Services allow you to enable or disable cookies that
are not strictly necessary. If you disable or do not accept certain cookies, you
may find that certain functions and features will not work as intended on the
Services. All browser settings are slightly different, so to manage cookies, you
should refer to the relevant settings within your browser. Please note that
changing your cookie preferences in or for one browser does not change your
cookie preferences for all browsers. Please note that a preference cookie will
be set in connection with our cookie banner and preference center to record and
honor your preferences. Please note that if you delete or clear your cookies,
you will delete the preference cookie and clear your recorded preferences.
We understand that you may want to know more about cookies. Here are some useful
resources that provide detailed information about types of cookies, how they are
used, and how you can manage your cookie
preferences: www.aboutcookies.org or www.allaboutcookies.org. Please click
below for detailed information on how to disable and delete cookies in some
commonly used browsers:
* Mozilla Firefox®
* Microsoft® Internet Explorer
* Google Chrome™
* Safari®
* Microsoft® Edge
Subject to compliance with the applicable notice and consent requirements, we
may use certain other similar or related technologies in addition to traditional
cookies:
* Local shared objects/Flash cookies: Flash cookies, also known as local shared
objects, are designed to support browser content supported by Adobe® Flash.
They are usually used to enable ads and video content on websites. Like other
cookies, they will store information on your device, some of which will be
specific to the Flash-enabled content. Flash cookies can only be deleted
within Adobe Flash rather than via your browser. Please refer to the
following help page for information on how to manage your privacy settings
and about the deletion of Flash cookies.
* HTML Web Storage: With web storage, web applications can store data locally
within a user’s browser. We utilize two types of web storage; Session Storage
Object (“SSO”) and Local Storage Object (“LSO”). SSO stores data only until
the browser session ends and then all data is removed/deleted. LSO stores
data without an expiration date. Web storage can be used for various
purposes, including displaying the last page viewed by a user when the user
logs back into a website, keeping a session active (i.e., keeping a user
logged-in), and providing more website accessibility features to a user. The
web storage is categorized in the same manner as traditional cookies and you
can toggle on or off the categories of cookies under which web storage data
is categorized.
* Web beacons: Our web pages may contain electronic images known as web beacons
(also called single-pixel gifs and transparent graphic images) that we use to
help deliver cookies on our sites, count users who have visited those sites,
record or track your interactions with LSEG’s web and mobile sites,
platforms, and/or properties, deliver Services, and analyze the effectiveness
of our promotional campaigns, for example. We may also include web beacons in
our marketing email messages or newsletters to determine whether an email is
opened or if links are clicked. Web beacons are also used to deliver
you interest-based advertising.
* Web server & application logs: Our servers automatically collect certain
information to help us administer and protect the security of the Services,
analyze usage, and improve the quality, performance, and personalization of
the Services. The information collected includes:
* IP address and browser type
* Device information including Unique Device Identifier, MAC address,
Identifier For Advertisers, and similar identifiers we or others may assign
* Device operating system and other technical facts
* The city, state, and country from which you access our website
* Pages visited and content viewed, stored, and purchased
* Information or text entered
* Links and buttons clicked
* URLs visited before and after you use our Services
Certain of these tracking technologies may be listed under the Performance,
Functional or Targeting Cookies categories in the Cookie Settings. If you do not
wish these technologies to be deployed on the Services, you should adjust your
Cookie Settings accordingly.
"DO NOT TRACK" SIGNALS
Some browsers transmit Do Not Track (“DNT”) signals to websites. Some of the
cookies deployed, set, or utilized by or on behalf LSEG may respond to DNT
requests or signals from these browsers. Please note that if we respond to DNT
requests, this may alter our services and therefore may limit functionality and
use of our websites. We continue to monitor industry activity in this area and
reassess our DNT practices as necessary.
DURATION
Certain of the cookies used on or in connection with our Services expire after a
period of time. Please refer to the “Cookie Details” section of our Cookie
Settings for information regarding the duration of each cookie.
THIRD-PARTY COOKIES
The cookies described in this Policy include third-party cookies which may
enable third parties to access to the information collected. The identity of
these third parties is included in the “Cookie Details” section of our Cookie
Settings.
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WHERE TO FIND FURTHER PRIVACY INFORMATION ON LSEG’S SERVICES
RISK PRODUCTS
LSEG provides Services to financial industry, compliance and risk professionals,
helping them with efficiency tools and data to assess and improve risk and
compliance management, analyze and access financial transactions, and create
efficient, reliable business infrastructure. Such Services will process personal
information entered by our customers as well as provide data from public sources
about individuals to assist customers with governance, risk and compliance
activities. A few of our Risk-related products include the following:
1. World-Check: This Statement does not cover or address the information
contained in, and the data processing activities associated with, our
World-Check product. To access the Privacy Statement for World-Check please
click here.
2. Enhanced Due Diligence (“EDD”): EDD is a detailed integrity and advanced
background checks service that provides information to assist organizations
identify and protect against any regulatory and/or reputational risks that
might arise in connection with entering into relationships and/or
transactions with individuals and/or entities. The information processed in
connection with EDD may involve both personal information provided to us by
a customer who is engaging us to conduct a search or check through EDD
(e.g., passport information, resumes/CVs, etc.) and information sourced by
us from various public data sources. LSEG’s processing of information
provided or supplied to us by a customer is done so with LSEG in the role or
capacity of a processor (or other similar term) and therefore such
processing activities are not subject to this Statement. LSEG’s processing
of information sourced through public sources is done so with LSEG in the
role or capacity of a controller (or other similar term) and such processing
activities are subject to this Statement. EDD is to be used for internal
compliance purposes in connection with a customer’s legal or regulatory
obligations connected to preventing or detecting unlawful acts (such as
money laundering, terrorism, fraud and modern slavery).
For more information about how your bank, counterparty or finance or risk
professional handles your personal information, please contact them directly.
DATA CONTENT PRODUCTS
In connection with our Services, LSEG builds, supplements and manages various
content databases, which include personal information of or about certain data
subjects (e.g., officers and directors; ownership and shareholders; investment
professionals; research analysts). The information contained in these databases
are collected from various sources, including, without limitation, from public
sources (e.g., corporate websites), approved financial publications, from data
subjects, from government records or databases (e.g., U.S. Securities and
Exchange Commission, Companies House in the U.K.), and from third parties (e.g.,
business partners, colleagues of the data subject). We build and manage these
content databases to provide a directory service to users of the content and the
users of the content are solely responsible for ensuring that they process the
content in accordance with applicable data protection, privacy and marketing
laws.
The personal information available in the content databases may be used for
several purposes including, without limitation, conducting research and
performing due diligence activities, engaging in contact mapping, verifying
existing contact information, and facilitating discussions or communications
regarding business opportunities.
The sources from which the personal information may be received or collected are
responsible for their own compliance with applicable data protection/privacy
laws and for ensuring the accuracy and completeness of the personal information
maintained by such third parties or persons.
If you have any enquiries or wish to exercise your rights under data protection
and privacy laws or would like to make further inquiries about how personal
information is used within a specific Service, please contact the Privacy
Office.
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HOW TO CONTACT US
If you have any questions, comments, complaints or suggestions in relation to
data protection or this Statement, or any other concerns about the way in which
we process information about you, please contact the Privacy Office as follows:
Refinitiv
Five Canada Square
Canary Wharf
London E14 5AQ
England
United Kingdom
LSEG
10 Paternoster Square
London EC4M 7LS
England
United Kingdom
For questions, comments, complaints or suggestions from EU data subjects, please
contact:
Refinitiv/LSEG
Data Protection Officer
Messeturm Friedrich Ebert Anlage 49,
Frankfurt 60327
Germany
Contact the Privacy Office
If you are not satisfied with the response, we encourage you to escalate your
query to our Data Protection Officer via clicking on the link below and sending
an email, or at Data Protection Officer, Refinitiv/LSEG, Five Canada Square,
Canary Wharf, London E14 5AQ, England, United Kingdom.
Contact the Data Protection Officer
Filing a Complaint. If you are not content with how LSEG manages your personal
information, you can lodge a complaint with a privacy supervisory authority. In
the European Economic Area, the relevant supervisory authority is the one in the
country or territory where:
* you are resident
* you work, or
* the alleged infringement took place
A list of National Data Protection Authorities in the European Economic Area can
be found here. For the Information Commissioner’s Office in the United Kingdom,
please visit https://ico.org.uk/.
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UPDATES TO THIS STATEMENT
This Statement may be subject to updates. Any material future changes or
additions to the processing of personal information as described in this
Statement affecting you will be communicated to you through an appropriate
channel. For example, we may place a prominent notice on a product site or email
you to let you know of an updated Statement.
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Refinitiv
* Cookie policy
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OUR USE OF COOKIES
Refinitiv websites use cookies and similar technologies for various purposes
including functionality, performance, targeting, social media, and for the
proper functioning of websites. The cookies and similar technologies may include
those deployed by third parties for providing services to us and they may use
the same to improve, enhance, and deliver their services to all of their
customers. To access a list of the websites covered by this banner review the
cookie settings. By clicking “Accept all cookies,” you agree to the storing and
reading of cookies and other similar technologies. You can change your
preferences at any time through our Cookie Settings tool. Please read our
Privacy and Cookie Statement.
Cookie settings Reject All Accept All Cookies
PRIVACY PREFERENCE CENTER
This preference center applies to all websites within the www.refinitiv.com
domain/sub-domain group. To view a list of the websites visit
https://www.refinitiv.com/privacy-center-common-domains. When you visit these
websites, information may be stored or retrieved on or from your browser, mostly
in the form of or through cookies (e.g., first-party and third-party) and
similar technologies (e.g., local storage, web beacons, etc.) ("cookies"). This
information might be about you, your preferences and/or your device. All
references to "Services" refers to Refinitiv's products, services, websites,
digital properties, platforms, software and applications (including mobile
applications).
The cookies may include those deployed by third parties providing services to
us. These third parties may use these cookies and the information collected in
connection therewith (including information collected on and off of our
websites), for providing services to us and also to improve, enhance and deliver
their services to all of their customers. If you opt-out of, or toggle off,
cookies through this preference center, this action will only apply to the
applicable Refinitiv websites covered by this preference center and will not
impact cookies deployed, and data collection, through non-Refinitiv websites. In
order to opt-out of the tracking and data collection by these third parties
completely, you must either go to the websites for such third parties to
exercise your preference or use the preferences/choices mechanism available
through the advertisements that these third parties may display.
Because we respect your right to privacy, you can choose not to allow some types
of cookies. You can use the features in this preference center to block or allow
these types of cookies. Toggle "on" to allow cookies and toggle "off" to block
specific categories of cookies. For your reference, if the toggle is blue, then
you have allowed cookies and if the toggle is gray, then you have blocked
cookies. Blocking some types of cookies may impact your experience of the site
and the services we are able to offer. A preference cookie will be set, which
will contain your preferences of blocking or allowing cookies.
Please note that if you clear your cookies, the preference cookie will be
deleted for all websites within the group and this will clear your preference
and when you first re-enter or re-access Refinitiv's services (e.g., websites),
you will be asked to consent to cookies being deployed. When presented with the
option to accept all cookies, if you want to allow or block certain categories
of cookies, you will have to access Refinitiv’s cookie preference center again
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