Date: May 17, 2018
Personal Information We Collect
Bloomberg or, where relevant a designated service provider, collects personal information through this Site, such as during registration, when you request certain services or products, or submit information to complete a survey or poll, which may include your name, phone number, address, email address, contact information, and password. If you do not provide certain personal information, not all functionality on this Site will be available.
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How We Use and Disclose Your Personal Information
Bloomberg 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 Bloomberg improve our products and services and develop new products and services
- to provide support for our products and services, and for Bloomberg internal quality control purposes
- to provide you with offers and promotions about services and products of Bloomberg or of other parties that may be of interest to you
- to enhance your experience with this Site, including to save your preferences and login information
- to analyze web site usage and analyze use of the Site
- to protect the interests, rights, safety, or property of Bloomberg or others and to monitor compliance with and enforce the terms of any agreement with Bloomberg
- to operate our services, products and systems properly.
You may instruct Bloomberg at any time not to use your personal information collected in connection with the product you requested to provide you with offers and promotions by contacting firstname.lastname@example.org and indicating OpenFIGI in the Subject line of your inquiry. You can also update your settings for receiving offers and promotions by clicking here(http://www.bloomberg.com/email-settings). 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 by you. Please also note that these processes may take some time to complete, consistent with applicable law.
Bloomberg may also disclose your personal 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 Bloomberg or others; (c) monitor compliance with and enforce any terms of service on this Site; (d) provide our services and products (including allowing a purchaser of Bloomberg 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 Bloomberg; or (g) operate the systems that provide our services and products properly.
The collection, further use, and/or disclosure of your information by Third-party Providers or by other third parties are not the responsibility of Bloomberg. Rather, such collection, use, and/or disclosure are governed by the third parties’ privacy policies.
Accuracy, Security and Retention of Your Personal Information
Any of your personal information collected by Bloomberg through this Site is kept on secure servers. Bloomberg 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 your username and password you set up in connection with your participation in this Site’s service, if any. 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.
If applicable, certain databases available to registered users of this Site 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 this Site. 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(http://www.bloomberg.com/datainquiry). While Bloomberg 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 law.
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 this Site, please contact us at email@example.com and include OpenFIGI in the Subject line of your inquiry.
Transfer of Your Personal Information to Other Countries
Links to Third-Party Web Sites
Bloomberg 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.
Such changes will be effective upon posting.
Law Enforcement Data Request Statement
Bloomberg will not disclose client data (which may include personal information, together "client data") in response to requests from law enforcement, governmental, or regulatory agencies except 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 reviews the legality of all such requests prior to responding to ensure they are valid and that Bloomberg is legally obligated to comply. Bloomberg challenges requests, including, where necessary, through court challenges and exercise of available appellate rights, if, after careful assessment, Bloomberg concludes that the request exceeds the relevant agency's authority or is otherwise unlawful. When challenging requests, Bloomberg seeks interim measures with a view to suspending the effects of the request until competent judicial authority has ruled on its merits.
Bloomberg will notify its client about any legally binding request prior to disclosing client data in response to that request, and will notify its client if Bloomberg becomes aware of any direct access by public authorities to client data, unless: (1) Bloomberg is 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.
If Bloomberg responds to a request for disclosure, Bloomberg will attempt to provide the minimum amount of information permissible, based on a reasonable interpretation of the request. 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.
Intra-Group Personal Data Protection Statement
December 31, 2020
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.