We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising, and honoring the marketing preferences you provide is important to us.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You may receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you registered for a trial or CFRA event and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the CFRA group of companies for marketing purposes.
You can ask us to stop sending you marketing messages at any time by contacting us at any time. Where we send marketing emails, we provide unsubscribe options within the email for you to provide us notice of your preference not to receive marketing messages. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of using our products/services or other related transactions.
Cookies & Internet Protocol Logs
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so or obtain your consent.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data. We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:
- CFRA’s wholly owned subsidiaries, who may be acting as joint controllers or processors and may provide various services and undertakings in furtherance of CFRA’s business. Said subsidiaries consist of CFRA UK Limited, CFRA MY Sdn Bhd (formerly known as Standard &Poor’s Malaysia Sdn Bhd), and CFRA HK Limited (Hong Kong).
- The person who provides your access to our products and services (e.g. your employer or our subscriber).
- Service providers who help us provide our products and services, such as IT and system administration service providers.
- Professional advisers including lawyers, bankers, auditors and insurers who provide such professional services to CFRA.
- Third parties where we have a duty or are permitted to disclose your personal information bylaw (e.g., government agencies, law enforcement, courts and other public authorities).
- Third parties where reasonably required to protect our rights, users, systems and products and services (e.g., attorneys and information security professionals).
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or ourassets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.
- In accordance with the consent you provide to us.
We direct third parties to respect the security of your personal data and to treat it in accordance with the law and to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers. We may share your personal data within the CFRA group of companies and this may involve storing, processing and transferring your data outside your home country, including in countries that may not offer the same level of protection as your home country. Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data internationally, we have implemented policies designed to ensure appropriate technical and administrative measures are in place to protect your personal data in accordance with applicable laws.
7. Data security. We have put in place appropriate security measures designed to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents,contractors and other third parties who have a business need to know. They will only process yourpersonal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with suspected personal data breaches and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention. We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In many cases, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) after they cease being customers, which may include as reasonably necessary for tax purposes, demonstrating compliance with contracts, during limitation periods within which claims might be made, and any retention periods prescribed by law or recommended by regulators, professional bodies or associations. In some circumstances you can ask us to delete your data: see Request erasure below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights.
Under certain circumstances, you have rights under data protection laws in relation to your personal data which are listed below and defined in the Glossary herein.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us using the contact information provided herein. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests and we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you our services/products and a secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or your employer are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Internal Third Parties
CFRA’s wholly owned subsidiaries, who may be acting as joint controllers or processors and mayprovide various services and undertakings in furtherance of CFRA’s business. Said subsidiaries consist of CFRA UK Limited, CFRA MY Sdn Bhd (formerly known as Standard & Poor’s Malaysia Sdn Bhd), and CFRA HK Limited (Hong Kong).
External Third Parties
- Service providers (who may be acting as processors and/or may be based in countries otherthan your own) who provide business, IT and system administration services.
- Professional advisers (who may be acting as processors or joint controllers) including lawyers, bankers, auditors and insurers who provide professional services such as consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities (who may be acting as processors or joint controllers and/or based in the UK or countries other than your own) who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override certain of your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Last Updated: November 6, 2018