LAST UPDATED: May 25, 2012
Moody's Corporation and its US subsidiaries adhere to EU/U.S. Safe Harbor principles with respect to covered data transferred from the European Union to the U.S. More information about the Safe Harbor program can be found at http://www.export.gov/safeharbor.
You do not have 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").
• Moody’s requests Personal Data from you when you register on the Site. The registration process requests that you provide your name, business email address, business address, business phone number, and company affiliation, and agree to the User Agreement presented at the time of registration.
• Moody’s may collect Personal Data voluntarily provided by you, including in emails to the Site, online forms, order and registration forms, surveys, promotion participation, and through offline means.
• On some of Moody’s Sites, including www.moodys.com and www.moodysanalytics.com, you are able to maintain "portfolios", listing financial instruments in which you have a special interest. Providing this information is always at your option. If you provide such information, you will be required to select a username and a password. 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 it to any other person.
• Moody’s collects offline information through various means, including participation at conferences, individual introductions, and from employers that enroll their employees in our services. From time to time, we may alsoacquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services. If we acquire such a list for promotional purposes, we seek to obtain appropriate representations from the other party that the listed individuals have opted in to receiving promotional messages from any acquirer of such list.
Use of Personal Data Collected
We may use Personal Data for the following purposes:
• Fulfillment of Requests. Moody’s may use Personal Data about you to deliver products and services, and provide you with information about products and services you’ve ordered.
• Other Communications. From time to time, 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. 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"). We typically ask you for 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 treatment of Personal Data about you conflict with this Policy, the terms and conditions of such rules shall control.
• Internal Business Purposes. We may also use Personal Data about you for our internal business purposes, such as data analysis, editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site or our other web sites, completing business transactions, development of marketing and promotion plans and materials, statistical analysis of user behavior, product development, administering individual accounts, and meeting government 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. Additionally, 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.
• IP Addresses. When you visit and interact with the Site, we and our third-party service providers may collect IP Addresses. Your Internet Protocol (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 and to improve the Site. Where required by applicable law, IP Addresses will be treated as Personal Data.
Disclosure of Personal Data Collected
We may disclose Personal Data for the following purposes:
• 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 of an administrative nature.
• Affiliate Communications. Moody’s may transfer Personal Data among our affiliates (the details of which can be found on the www.moodys.comweb site) 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 this Policy. 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. By selecting an application or providing your information on these co-branded pages, or by signing up to receive information about or download a Jointly Offered Item, you also consent to our providing Personal Data about you to those third parties. 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.
• 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 transfer any and all Personal Data that we collect to an affiliated entity or a third party 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 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; (b) to comply with legal process; (c) to respond to requests from government or public authorities; (d) to enforce our Terms of Service; (e) to protect our operations or 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.
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 email@example.com.
• 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 firstname.lastname@example.org.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you exercise the second option as described above, we will not be able to remove your Personal Data from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Data (i.e., to which we have already provided your Personal Data as of the date that we implement your request). 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.
If we intend to use your Personal Data for a purpose that is incompatible with the purposes detailed in this Policy, or if we intend to disclose it to a type of third party not previously identified, we will notify you and offer you the opportunity to opt-out of such uses and/or disclosures.
You may also indicate your choices regarding marketing-related emails by changing your preferences on your Site profile at any time, or contacting us via postal mail or telephone using the “Contact Information for Moody’s” below.
How you can access, change or suppress your Personal Data
If you would like to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, you make a request by contacting us using the information provided in the “Contact Information for Moody’s” below. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.
Moody's has established reasonable organizational and technical measures to protect Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction. Please note that while Moody’s has endeavored to create a secure and reliable Site for users, no site is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by contacting us using the information provided below in "Contact Information for Moody’s" (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
Moody’s will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Policy, or authorized by 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.
We will retain Personal Data about you for the period reasonably necessary to fulfill the purposes outlined in this Policy and consistent with retention periods required or permitted by law.
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, and by using this Site or sharing Personal Data with us, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than in your country.
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
we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, 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
If you choose to contact Moody’s via e-mail about this Policy, please mark the subject heading of your e-mail “Privacy Enquiry.”