your Personal Data (defined below) on those web sites of Moody's that post or
through offline means, how we use, disclose, and protect such data, and the
choices you have concerning our use of such data. Please read this Privacy
collect or use Personal Data will be highlighted on the homepage of the Site in
advance. Please review the "Last Updated" legend at the
"we", "us", and "our" means Acquire Media U.S.,
LLC and Acquire Media 1 UK Limited.
In some circumstances, you may have the option to decline
to provide us with any Personal Data to visit the Site. However, if you choose
to withhold requested information, you may not be able to visit all sections or
use all features of the Site.
instances, the term "Site" shall include the applicable mobile
application or other Moody's online activity whenever that term is used herein.
of Data Collected
Personal Data and Other Data (as described below).
Collection of Personal Data
Personal data is information that identifies you or can
be used to identify or contact you, e.g.,
your name, email address, address, or phone number ("Personal Data").
We may need to collect and process Personal Data in order to provide requested
information, products or services to you (including the Site) or because we are
legally required to do so.
- Moody's requests Personal Data from you if the Site
requires registration. The registration process requests that you provide Personal
Data, such as your name, business email address, business address or
country/jurisdiction location, business phone number, and company
affiliation, and agree to the User Agreement presented at the time of
- Moody's may receive Personal Data
from social media platforms. For example, if you elect to use your social
media credentials to log-in to your Site account, certain Personal Data
from your social media account will be shared with us, which may include
Personal Data that is part of your social media profile.
- Moody's may collect Personal Data voluntarily
provided by you, including in emails, online forms, order and registration
forms, surveys, promotion participation, online chats, phone calls, and
through other means.
- Moody's may request Personal Data from our customers
to comply with applicable anti-money laundering laws and other applicable
- On some of Moody's Sites you are able to maintain
"portfolios," where, if you are a registered user, you have the
option to list financial instruments in which you have a special interest.
To be useful, this information must be stored on the Site, and is
accessible to anyone with whom you share your username and password. For
this reason, please safeguard your username and password carefully and do
not disclose them to any other person.
may use third-party payment services (each, a "Payment Service") to
collect payments made through the Site. If you wish to make a payment through
the Site, you may be directed to a webpage that is hosted by a Payment Service
(or a Payment Service's service providers) and not by Moody's. Any Personal
Data that you provide through a Payment Service page will be collected by the Payment
Service and not by Moody's, and will be subject to Payment Service's privacy
not responsible for, a Payment Service's use of information collected through a
Payment Service page.
- Moody's collects information through various other means,
including searches online, participation at conferences and events, individual
introductions, from employers that enroll their employees in our services or
provide services to us, and from selected third-party business partners. From
time to time, we may also acquire
from third parties certain lists containing the names and contact information
of individuals who may be interested in our products and services.
- We collect name and professional contacts details of
employees of our service providers, either directly from those third-party
employees or from their employers.
Our news products and services may contain limited Personal Data about
executives, officers, managers, investors, and individual shareholders of
organizations mentioned in news stories. We source this Personal Data directly
and indirectly (via information providers) from public records (such as SEC
filings), corporate disclosures and press releases, publicly available websites,
newsfeeds, newspapers and magazines.
Use of Personal Data Collected
We use Personal Data transparently and
in compliance with applicable law for legitimate business purposes, including
- Fulfillment of Requests. Moody's may use Personal
Data about you to deliver products and services to you, and to provide you
with information about products and services you've ordered. We will
engage in these activities to manage our contractual relationship with you
and to fulfil our contractual obligations.
- Marketing Communications. From time to time, in
compliance with applicable laws, we may use Personal Data about you to
inform you of products, programs, services and promotions that we believe
may be of interest to you. If your employer is a Moody's customer, we may
also inform you of such products, programs, services and promotions using
Personal Data about you that your employer provided to Moody's. We may
also use Personal Data of media contacts for press release distribution or
sharing other newsworthy developments related to our business activities. If
you would prefer that we not send electronic marketing messages to you,
please see the "Your Choices" section below.
- Promotions. We may operate sweepstakes, contests and
similar promotions (collectively, "Promotions"). If you choose
to enter Moody's Promotions, we may require certain Personal Data when you
enter and, if applicable, win a Promotion. You should carefully review the
rules of each Promotion in which you participate, as they may contain
additional important information about our use of Personal Data about you.
To the extent that the terms and conditions of such rules concerning the
this information to operate the Promotions.
- Other Business Purposes. We may also use Personal
Data about you for other business purposes, such as data analysis (for
example, to improve the efficiency of our services), editorial and
feedback purposes, providing customer support, customizing and improving
the content and layout of the Site, completing business transactions (for
example, to confirm content requested is received by customers),
development and delivery of marketing and promotion plans and materials,
statistical analysis of user behavior (for example, to understand what
parts of the Site are of most interest to users), product development, conducting
surveys, receipt of services from you or your employer, and market
research, and administering individual accounts. We use name and
professional contacts details of employees of our service providers to as
part of executing and managing our contracts with them and paying their
- Administrative Communications. Moody's reserves the
right to use Personal Data to send to you important information regarding
the Site, products, services, your account status, the User Agreement,
relevant to your use of the Site, products and/or services. Because this
information may be important to your use of the Site, products and/or
services, you may not opt-out of receiving such communications. We will
engage in this activity to manage our contractual relationship with you
and/or to comply with a legal obligation.
- Compliance with law and regulation. We may use
Personal Data as necessary to comply with applicable legal and regulatory
requirements such as sales tax collection, audits, etc.
- Moody's uses Personal Data for purposes compatible
applicable privacy notice, and in accordance with applicable law. Where
required by applicable law, we will only use Personal Data with your consent.
and Use of
We and our service providers may also
as "Other Data":
- Monitoring Data. Moody's and its service providers may collect and/or track other
information such as demographic information, domain names, computer type,
browser types, screen resolution, and other statistical data involving the
use of the Site ("Monitoring Data"). We use Monitoring Data to
help us understand who uses the Site and to improve and market it, as well
as our other web sites and services.
combined with Personal Data, Monitoring Data does not personally identify you
or any other user, and we may use it for any purpose.
- Aggregated Data. We may aggregate Personal Data in a
manner such that the end-product does not personally identify you or any
other user of the Site, for example, by using information to calculate the
percentage of our users who have a particular telephone area code. Such
aggregate information may also be used for any purpose.
- Cookies. To enhance the Internet experience on the
Site, Moody's and our service providers may use 'cookies' on the Site. Cookies
are data that a web server transfers to an individual's computer for
facilitate users' ongoing access to and use of our Site. If you do not
procedure in most browsers that allows you to automatically decline
cookies, or to be given the choice of declining or accepting the transfer
of a particular cookie, or cookies from a particular web site, to your
computer. If cookies are disabled, however, all features of the Site may
not operate as intended. Information about disabling cookies can be found
on your Internet browser provider's web site.
- We and our service providers may also use various
common Internet tools such as 'pixel tags,' 'action tags,' 'web beacons,'
"Tools") in connection with Site pages and email messages in
certain formats to, among other things, track the actions of Site users
and email recipients, to determine the success of marketing campaigns and
to compile statistics about Site usage and response rates. Tools allow us
to count users who have visited certain pages of the Site, to deliver
services, and to help determine the effectiveness of promotional or
advertising campaigns. When used in email messages in certain formats,
Tools can tell the sender whether and when the email has been opened.
is used and to customize and enhance the Internet experience of individual
users. When you revisit the Site, Moody's may recognize you by a Tool and
customize your experience. For example, once you have completed the registration
process, a cookie and/or Tool will be used to avoid having you register again. We
believe cookies and Tools add value to the user experience.
technologies, to collect and analyze information about Site use and to report
on activities and trends. The service may also collect information
regarding the use of other websites, apps and online resources. You can learn
about Google's practices by going to https://policies.google.com/privacy/partners, and
opt out of them by downloading the Google Analytics opt-out browser add-on,
available at https://tools.google.com/dlpage/gaoptout.
- We do not respond to browser do-not-track signals at this
We may use
third-party services to verify that you are a human user. Any information
third-party service provider.
Addresses. When you visit and interact with the Site, we and our
third-party service providers may collect Internet Protocol (IP)
addresses. Your IP address is a number that is automatically assigned to
the computer that you are using by your Internet Service Provider (ISP). This
number is identified and logged automatically in our server log files
whenever you visit the Site, along with the time(s) of your visit(s) and
the page(s) that you
visited. We use IP addresses to understand how the Site is used by our
users, to improve the Site and to enhance user experience of the Site. We may also derive your
approximate location from your IP address.
we are required to treat Other Data as Personal Data under applicable law, then
we may use and disclose it for the purposes described above, as well as for the
purposes for which we use and disclose Personal Data as detailed in this
We may use third-party
advertising companies to serve advertisements regarding products and services
that may be of interest to you when you access and use the Site, our apps and
other websites or online services, based on information relating to your access
to and use of the Site and other websites or online services on any of your
devices, as well as on information received from third parties. To do so, these
companies may place or recognize a unique cookie on your browser (including
through the use of pixel tags). They may also use these technologies, along
with information they collect about your online use, to recognize you across
the devices you use, such as a mobile phone and a laptop. If you would like
more information about this practice, and to learn how to opt out of it in
desktop and mobile browsers on the particular device on which you are accessing
download the AppChoices app at www.aboutads.info/appchoices to opt out of this practice in
Disclosure of Personal Data Collected
We may disclose Personal Data for the following
- Third-Party Service Providers. We may provide
Personal Data to third-party service providers, who provide services to
us, including but not limited to, data analysis, order fulfillment,
payment processing, and other services.
- Affiliate Communications. In compliance with
applicable laws, Moody's may transfer Personal Data among our affiliates (a
list of which is available at www.moodys.com/Affiliates_of_Moodys) to allow our affiliates to contact you regarding products, programs,
services and promotions that they believe may be of interest to you, and
such affiliates may otherwise use your Personal Data in accordance with the
policy applicable to them as
specified in the referenced above in this bullet. If you would prefer
not to receive marketing communications from Moody's or our affiliates,
please see the "Your
Choices" section below. Moody's Corporation will be the
party responsible for jointly used Personal Data.
- Strategic Partners and
Co-Branded Sites. From time to time, we may enter into a special
relationship with another company that is not owned by or affiliated with
Moody's to provide or promote joint products, services, applications, or
features (together, "Jointly Offered Items"). These special
relationships may include co-branded web sites ("co-branded pages").
Any information, including Personal Data, that you provide in connection
with one of these Jointly Offered Items, and/or on one of these co-branded
pages, will be shared with our third-party partners. You should check
these third parties' web sites for information regarding their privacy
practices. PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT ADDRESS THE
PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want
Personal Data about you shared with such third parties, please do not
provide Personal Data in connection with the Jointly Offered Items and/or
- Third-Party Data Providers. If you subscribe to a
Moody's product or service that contains third-party data, we may be
required to provide your Personal Data to the third party as part of our
reporting obligations. We will only do so if a third-party data provider
conditions your receipt of their data on knowing your identity.
- Conferences and Events. When you attend a conference
or event organized by Moody's, your name and contact information may be
shared with other attendees and co-hosts of the conference or event.
- Promotions. We may share the Personal Data you
provide in connection with Promotions with third-party sponsors of such
Promotions (irrespective of whether such Promotions are hosted by us), or
otherwise in accordance with the rules applicable to those Promotions.
- Assignment. We may disclose or transfer any and all
Personal Data that we collect to an affiliated entity or a third party
(and their respective advisors) in the event of any reorganization,
merger, sale, joint venture, assignment, transfer or other disposition of
all or any portion of our business, assets or stock (including without
limitation in connection with any bankruptcy or similar proceedings).
- Law Enforcement; Emergencies; Compliance. We may use and
disclose Personal Data about you to others as we believe to be appropriate: (a)
in compliance with laws, rules, or regulations in any country in which Moody's
operates, including laws outside your country of residence; (b) to comply with
legal process; (c) to respond to requests from government or public
authorities, including government and public authorities outside your country
those of any affiliated entities; (f) to protect the rights, privacy, safety or
property of Moody's, its affiliated entities, you, or others; and (g) to permit
us to pursue available remedies or limit the damages that we may sustain. For
example, we may, to the fullest extent the law allows, disclose Personal Data
about you to law enforcement agencies to assist them in identifying individuals
who have been or may be engaged in unlawful activities. Where we receive
requests for Personal Data from domestic or foreign government or public
authorities, we will resist, narrow or challenge such requests as appropriate
and to the extent permitted by applicable law.
you would like to receive more information on the third parties with whom we
share your Personal Data, please contact us by using the information provided
in the "Contact Information for Moody's" section below.
We give you choices regarding our use and
disclosure of your Personal Data for marketing purposes.
- If you no longer want to receive marketing-related emails from us on
a going-forward basis, you may stop receiving these marketing-related
sending an e-mail to firstname.lastname@example.org.
- If you would
prefer that we do not share your Personal Data on a going-forward basis
with our affiliates or with unaffiliated third parties for their marketing
purposes, you may cease this sharing by
sending an e-mail to email@example.com.
We will comply with your request(s) as soon as
reasonably practicable, and in accordance with applicable law. Further, please
note that requesting us not to share your Personal Data with affiliates or
unaffiliated third parties may result in you no longer receiving any marketing
emails from Moody's. Please also note that if you choose not to receive
marketing-related messages from us, we may still send you important
administrative messages, and you cannot elect to stop receiving such
administrative messages, unless you choose to stop receiving services from us.
may also indicate your choices regarding marketing-related emails by contacting
us via postal mail or telephone using the information in the "Contact
Information for Moody's" section below, or if you have a Site
profile/account, by changing your preferences on your Site profile/account at
How you can
access, change or suppress your Personal Data
If you would like to request to review,
correct, update, suppress, delete or otherwise limit our use of your Personal
Data that has been previously provided to us, or if you would like to request to
receive an electronic copy of your Personal Data for purposes of transmitting
it to another company (to the extent this right to data portability is provided
to you by applicable law), you may make a request by contacting us using the information
provided in the "Contact Information for Moody's" section below.
We will respond to your request consistent
with applicable law. For your protection, we may only implement requests with
respect to the Personal Data associated with the particular email address that
you use to send us your request, and we may need to verify your identity before
implementing your request. We will try to comply with your request as
soon as reasonably practicable and consistent with applicable law. Please note
that we may need to retain certain information for recordkeeping purposes
and/or to complete any transactions that you began prior to requesting the
change or deletion.
Site may contain links to other Internet web sites, including social
media sites and third-party hosted collaboration tools.
These linked sites are not under Moody's control. We provide links only as a
convenience, and Moody's does not endorse or control, and is not responsible
for, the privacy practices or the content of these linked sites. If you provide
any Personal Data through any third-party web site, or choose to communicate
with us using third-party collaboration tools or other social media platforms,
your transaction will occur on that third party's web site (not the Site) and
the Personal Data you provide will be collected by, and controlled by the
with the privacy policies and practices of any such third parties. PLEASE NOTE
OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES THAT
has established appropriate organizational and technical measures to protect
Personal Data within our organization from loss, misuse, or unauthorized
access, disclosure, alteration or destruction. Moody's has processes and
procedures for suspected privacy breaches to notify regulators and affected
individuals where required in accordance with applicable law. Moody's requires
applicable vendors that process Personal Data on its behalf to complete privacy
and security assessments and be bound by contractual terms.
will use Personal Data only in ways that are compatible with the purposes for
you. Moody's will take reasonable steps to ensure that Personal Data is
relevant to its intended use, and is accurate, complete, and current (as
provided by you). Moody's depends on you to update or correct your Personal
Data whenever necessary.
will retain Personal Data about you for as long as needed or permitted in light of the
purpose(s) for which it was obtained and consistent with applicable law. The
criteria used to determine our retention periods include: (i)
the length of time we have an ongoing relationship with you; (ii) whether there
is a legal obligation to which we are subject; and (iii) whether retention is
advisable in light of our legal position (such as in regard to applicable
statutes of limitations, litigation or regulatory investigations).
Cross Border Transfer of
Your Personal Data may be stored and processed
in any country where we have facilities or in which we engage service
providers. In certain circumstances, courts, law enforcement agencies,
regulatory agencies, or security authorities in those other countries may be
entitled to access your Personal Data.
We ensure that we have appropriate legal
grounds to perform cross-border transfers of your Personal Data.
If you are located in the European Economic Area ("EEA")
or the UK: Some of the non-EEA
countries are recognized by the European Commission as providing an adequate
level of data protection according to EEA standards (the full list of these
countries is available on the EU Commission's adequacy list online at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the UK and the EEA to countries not
considered adequate by the European Commission, we have put in place adequate
measures, such as standard contractual clauses adopted by the European
Commission and the UK, to
protect your Personal Data. You may obtain a copy of these measures by contacting us
using the information provided in the "Contact
Information for Moody's" section below.
Use of this Site by Minors
This Site is not directed to
individuals under the age of eighteen (18), and we request that these
individuals do not provide Personal Data through this Site.
Personal Data Restriction
Unless we specifically request for information
to comply with applicable anti-money laundering laws and other applicable laws,
we ask that you not send
us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, passport numbers, information
related to racial or ethnic origin, political opinions, religion or other
beliefs, health, biometrics or genetic characteristics, criminal background or
trade union membership) on or through this
Site or otherwise to us.
Contact Information for Moody's
or concerns regarding Moody's data protection practices should be addressed to:
7 World Trade Center at 250 Greenwich Street
New York, NY 10007
Phone: +1-212-553-1653 or 1-866-995-9659
please mark the subject heading of your e-mail "Privacy Inquiry."
In accordance with applicable laws, you may lodge
a complaint with the data protection authority for your country or region, or
where an alleged infringement of applicable data protection law occurs.
Additional Information for California
If you are a resident of California, the
California Consumer Privacy Act ("CCPA") (Civil Code §§ 1798.100 et
seq.) provides you with specific rights regarding your Personal Data. These
- You can
request information about our collection, use and disclosure of your
Personal Data over the past twelve (12) months concerning: (i) the categories of Personal Data we collected about
you, (ii) the business or commercial purpose for collecting your Personal
Data, (iii) the categories of sources from which your Personal Data is
collected, and (iv) the categories of third parties with whom we share
your Personal Data. You can request a list disclosing the categories of
your Personal Data we have shared in connection with a business purpose.
- You can
request to receive a copy of your Personal Data in a commonly used and machine-readable
- You can
request that we delete your Personal Data, subject to certain exceptions.
To exercise the rights described above, it
may be necessary for us to verify your identity or authority to make the
request and confirm the Personal Data relates to you. Only you, or a person
registered with the California Secretary of State that you authorize to act on
your behalf, may make a verifiable consumer request related to your Personal
Data. We will not discriminate against you for exercising any of your privacy
rights under CCPA or applicable law.
During the past twelve (12) months, we
collected the categories of Personal Data described above from California
residents. We also disclosed such Personal Data to third parties for the
purposes specified above during the past twelve (12) months.
the last twelve (12) months, we sold products and services that include limited
Personal Data about residents of California who are executives, officers,
managers, investors, and individual shareholders of organizations. California
residents have the right to opt-out of the sale of their Personal Data to third
parties. To exercise this right, please contact us using the information
provided in the "Contact Information for Moody's" section above
You may exercise any of the rights
described in this section, by contacting us using the information provided in
the "Contact Information for Moody's" section above.