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BREADCRUMB

Home / Privacy Statement
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PRIVACY STATEMENT

LAST UPDATED: 16 March 2022

Privacy statement

Your privacy and trust are important to us. This Statement explains how LCH
Limited and the London Stock Exchange Group of companies (“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    
 * 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, attend, and/or interact
with our products, services, websites, events, 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”); 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.

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. 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 (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.

LSEG is a controller of personal information in respect of Services provided
unless stated otherwise. To learn more about our Services please visit
www.lseg.com If you wish to contact the LSEG entity that is controller for the
Service relevant to you, please contact LSEG,  Privacy Office, 10 Paternoster
Square, London EC4M 7LS, 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
using the contact information below.

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
   in our Cookies Statement here, and information related to Interest-Based and
   Mobile Advertising can be found in this Privacy Statement below.
 * 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.

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 one of our events
 * 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.).

 

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.

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.

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 below. 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 us using the contact details set
out below.

 

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 us using the contact information below. 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 us using the contact information below.

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 (IBA)

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 (www.iab.com). 

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. You may also go to the Digital Advertising Alliance ("DAA")
Consumer Choice Page for information about opting out of interest-based
advertising and their choices regarding having information used by DAA
companies. 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.

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)

 

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 using the contact information below.

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 or the European Commission.

The areas in which these recipients are located will vary from time to time, but
include the United States, Europe, Canada, and Asia (including Australia, 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 us using the contact information below.

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.

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

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 where:
   * the accuracy of the personal data is contested;
   * the processing is unlawful but you object to the erasure of the personal
     data; or
   * we no longer require the personal data, but it is still required for the
     establishment, exercise or defense of a legal claim.
 * 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
 * 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 contact us using the contact information
below.

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
via the contact information below.

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 Freidrich Ebert Anlage 29
Frankfurt 60327
Germany

Contact us

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, LSEG, 10 Paternoster Square, London EC4M
7LS, England, United Kingdom.

Contact the LSEG 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/.

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.

 

an LSEG business


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 * Disclaimer
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 * Whistleblowing

 
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