Personal Information We Collect
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How We Use and Disclose Your Personal Information
The Bloomberg Group uses this information for carefully considered business purposes which also benefit our customers and which include some or all of the following:
- to provide our products and services
- to communicate with you
- to help the Bloomberg Group improve our products and services and develop new products and services
- to provide support for our products and services, and for internal quality control purposes
- to provide you with offers and promotions about services and products of the Bloomberg Group or of other parties that may be of interest or relevant to you
- to send you push notifications from our mobile application
- to enhance your experience with the Sites, including to save your preferences and login information and provide relevant content
- to analyze website usage and analyze use of the Sites
- to protect the interests, rights, safety, or property of the Bloomberg Group or others and to monitor compliance with and enforce any agreement with the Bloomberg Group, and enforce any restrictions or limitations on the use of the services or products on the Sites
- to operate the services, products and systems of the Bloomberg Group properly.
You may instruct the Bloomberg Group at any time not to use your personal information collected through the Sites to provide you with offers or promotions by contacting email@example.com. You can also update your settings for receiving offers and promotions by clicking here. Please note that it may take some time to process your request, consistent with applicable law. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information from you.
The collection, further use and/or disclosure of your information by Third Party Providers is not the responsibility of the Bloomberg Group. Rather, such use and/or disclosure is governed by the Third- Party Providers’ privacy policies.
The Bloomberg Group may also disclose your information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, rule or regulation or in response to a subpoena, court order, or other legal process, subject to Bloomberg’s Law Enforcement Data Request Statement below; (b) protect the interests, rights, safety, or property of the Bloomberg Group or others; (c) monitor compliance with and enforce any terms of service on the Sites; (d) provide our services or products (including allowing a purchaser of the Bloomberg Group to continue to serve you); (e) perform other activities related to such services and products, including billing and collection;
(f) provide you with offers or promotions from the Bloomberg Group; and (g) operate the systems that provide the services and products of the Bloomberg Group properly.
Accuracy, Security and Retention of Your of Personal Information
Any of your personal information collected by the Bloomberg Group through the Sites is kept on secure servers. The Bloomberg Group uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures to protect your personal information on such servers. To help us protect your privacy, you should maintain the secrecy of the username and password you set up in connection with your participation in the Sites’ services. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements.
Certain databases available to registered users of the Sites may contain personal information received from third-party data suppliers. This personal information is contained in public records, publicly available information, and non-public information (collectively, “public records information”). Your use of this information is restricted to specific, legitimate purposes, and such information may not be used to violate any applicable laws, rules, or regulations.
Rights with respect to Your Personal Information
Depending on the jurisdiction, you may have the right to access, correct, delete, or restrict use of certain personal information collected about you through the Sites. Depending on the jurisdiction, you may also have the right to request that we refrain from processing personal information. Please bear in mind that if you exercise such rights this may affect our ability to provide our products and services. For inquiries about your personal information, please contact us by clicking here. While the Bloomberg Group will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. Please note that it may take some time to process your request, consistent with applicable laws.
If you wish to access, correct, delete, or restrict use of your personal information contained in public records information, you will need to contact the third-party supplier of the information directly. If you have any questions regarding public records information on the Sites, please contact us at firstname.lastname@example.org.
Transfer of Personal Information to Other Countries
Links to Third-Party Web Sites
The Bloomberg Group may provide links to third-party web sites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those web sites before providing any of your information on such sites.
Your California Privacy Rights
If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by the Bloomberg Group to its affiliates and/or third parties for their direct marketing purposes. To make such a request, please send an email with your first name, last name, mailing address, email address and telephone number to email@example.com. Please include “California Privacy Rights” in the Subject line of your email. You may also make such a request by writing to us at:
Attn: Legal Department
731 Lexington Avenue
New York, NY 10022
Last updated: August 24, 2020
Intra-Group Personal Data Protection Statement
Bloomberg Finance L.P., its operating agent Bloomberg L.P., and affiliates (“Bloomberg”) are committed to compliance with their data protection obligations throughout the world. This Intra-Group Personal Data Protection Statement (“Statement”) sets out the privacy principles Bloomberg follows with respect to personal information that it transfers from the European Union, European Economic Area, and Switzerland (collectively, “EU”) or the United Kingdom (“UK”), in accordance with the EU General Data Protection Regulation (“GDPR”) and UK GDPR.
Bloomberg has implemented robust processes and protections to meet the requirements of transferring personal information to third countries in accordance with applicable data protection laws. Accordingly, the relevant Bloomberg group companies have entered into Intra-Group Personal Data Protection Agreements (“IGAs”) to ensure that personal information transferred from the EU or UK is subject to appropriate safeguards, and to clearly identify the Bloomberg group companies responsible for transfers of personal information from the EU or UK.
The IGAs incorporate unchanged EU Commission Standard Contractual Clauses (“SCCs”), which include specific obligations and rights around transfers of personal information, and ensure that any personal information leaving the EU and/ or UK will be transferred by Bloomberg in compliance with applicable EU and UK data protection laws. The IGAs include the operational procedures and security measures we use to maintain the accuracy and integrity of personal information and protect personal information.
We regularly review and update our governance framework, including roles and responsibilities of personnel, and maintain a working group to oversee data protection regulation compliance and document results and decisions as they relate to personal information management.
- Accountability and Recordkeeping
We map the personal data life cycle and maintain a personal data map inventory, including documenting personal data flows within Bloomberg’s systems and any disclosures to third-party systems.
We invest in and maintain organisational, technical, and physical safeguards intended to ensure the protection of personal information. We engage in ongoing monitoring and testing of the efficacy of these safeguards. Our data centers are dedicated solely to our products, services, and operations, and have secure and monitored access controls.
- Privacy By Design
We integrate personal data mapping and accountability into our product design processes, and build personal data security into our development and product life cycles.
- Administrative controls
We regularly review and update our policies, procedures, and controls to address our data protection obligations. We conduct data protection executive education and tailored training programs for data protection compliance.
The Bloomberg group companies involved in personal information transfer and management are identified in the IGAs as Data Exporter(s) or Data Importer(s). Bloomberg is an independent Data Controller unless otherwise specified. With respect to specific products and services where Bloomberg acts as a Data Processor to our customers, we make available to our customers additional data processing terms, including unchanged EU-Commission approved Controller-to-Processor SCCs. Products where Bloomberg acts as data processor include Bloomberg Vault and Bloomberg Regulatory Reporting Services.
Questions or comments regarding this Statement should be submitted to Bloomberg’s privacy team at the following address:
731 Lexington Avenue
New York, NY 10022
Or by emailing firstname.lastname@example.org.
This Statement may be amended from time to time, consistent with the requirements of applicable law, and will be effective immediately.
Last updated: December 23, 2020
Law Enforcement Data Request Statement
Bloomberg will not disclose client data (which may include personal information, together “client data”) except in response to requests from law enforcement, governmental, or regulatory agencies only where required to do so by law (for example, in response to valid and properly-served legal process such as a subpoena or search warrant). Bloomberg will attempt to notify its client prior to disclosing client data unless: (1) prohibited by applicable law from doing so, or (2) there are clear indications of unlawful conduct in connection with the client’s use of Bloomberg services. Notwithstanding any of the foregoing, Bloomberg reserves the right to respond to urgent law enforcement requests if Bloomberg
believes in good faith that an emergency involving imminent danger of death or serious physical injury justifies such disclosure.