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.
Types of Data Collected
We gather 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 registration.
• 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 laws.
• On some of Moody’s Sites, including www.moodys.com, 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.
• 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.
Use of Personal Data Collected
We use Personal Data transparently and in compliance with applicable law, for legitimate business purposes, including the following:
• 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.
• 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, receipt of services from you or your employer, conducting surveys and market research, and administering individual accounts.
• 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.
Collection and Use of 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.
Unless 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.
o We do not respond to browser do-not-track signals at this time.
• IP 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.
Disclosure of Personal Data Collected
We may disclose Personal Data for the following purposes:
• 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 co-branded pages.
• 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).
If 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 emails by 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.
You 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 any time.
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.
Moody’s has established appropriate organizational and technical measures, including external third-party audits for particular products and services, 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.
We 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 Personal Data
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.
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.
If you are located in other countries, we will also ensure that we have appropriate legal grounds to perform cross-border transfers of your Personal Data. Where required in certain jurisdictions, we comply with requirements on initial processing of Personal Data with the use of databases located in the country of collection of your Personal Data.
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.
Sensitive 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
Questions 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
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.
In those countries where we are required to have appointed a data protection officer, you may contact the Data Protection Officer by sending an e-mail to firstname.lastname@example.org with the subject heading “DPO Inquiry.”
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 include:
• 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 format.
• 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.
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 below.