(as
of May 5, 2008)
This Privacy Policy and the Terms of Use (or, if you
register with this Site, the user agreement you enter into as part of that registration
process) together govern your use of this website (the “Site”). BY USING THE SITE, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY
AND OF US PROCESSING YOUR PERSONAL DATA IN ACCORDANCE WITH THE TERMS OF THIS
PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE
THE SITE. YOUR CONTINUED USE OF THE SITE FOLLOWING THE POSTING OF CHANGES TO
THIS PRIVACY POLICY WILL MEAN THAT YOU ACCEPT THOSE CHANGES.
This Privacy Policy explains how we collect your
personal data on the Site, how we protect such data, and the choices you have
concerning our use of such data. Please
read this Privacy Policy carefully. For the purposes of this Privacy Policy,
"we", "us", and "our" means Moody’s Investors
Service, Inc. and its affiliates. A
complete list of Moody’s group affiliates can be found on the www.moodys.com website. Our representatives
in France, Germany, Italy and Spain are Moody’s France SAS, Moody’s Deutschland
GmbH, Moody’s Italia, S.r.l. and Moody’s España S.A. respectively (contact
information for Moody’s Investors Service, Inc. and for each representative can
be found at the www.moodys.com website).
This Privacy Policy represents our current (as of May
5, 2008) data collection and usage practices. (In connection with registering with the U.S. Department of
Commerce's Safe Harbor program, we have added summaries of our Personal Data
practices with respect to data integrity and enforcement, and we expressly
state Moody's adherence to US Safe Harbor principles. Moody’s
adheres to the U.S. safe harbor privacy principles of notice, choice, onward
transfer, security, data integrity, access and enforcement.) Moody's
will from time to time review and revise these practices. We will post any
changes to this Privacy Policy here. Please refer back to this Privacy Policy
on a regular basis.
This Privacy Policy applies only to information
collected by the Site. We are not responsible for the privacy of any
information you reveal or post in any public forum (e.g., message board or chat
room), or for the privacy practices of websites that are operated or owned by
third parties.
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. In addition to information collected during
registration, Moody’s may collect Personal Data knowingly provided by you in
emails to the Site, online forms, order and registration forms, surveys, and
contest entries. In addition, on some of Moody’s web sites, including
www.moodys.com and www.mkmv.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 any site visitor who knows your username and password. For this
reason, please safeguard your username and password carefully and do not
disclose it to any other person.
In all of these cases, we will collect Personal Data
from you only if you voluntarily submit such information to us. Unless you give
us permission to do so, we will not sell, share, license, trade or rent your
Personal Data other than as specified in this Privacy Policy.
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.
If you would like to register on the Site on an
anonymous basis, meaning that any Personal Data you provide will not be
associated with your user account or Monitoring Data (except to the extent
necessary to inform you about and/or enforce the terms of the User Agreement
and this Privacy Policy), please paste the following URL into your browser
which will enable you to do so:
Collection of Monitoring Data and Use of Tracking Tools
In addition to Personal Data, Moody’s may collect
and/or track information that by itself cannot be used to identify or contact
you, e.g., demographic information, domain names, computer type, browser types,
screen resolution, and other anonymous 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 and Moody’s other web
sites. Whenever we use Monitoring Data to create a user profile, we do so under
a username.
To enhance the Internet experience on the Site,
Moody's may use various Internet technologies such as 'cookies,' ‘action tags,’
‘web bugs,’ ‘.gif tags,’ and 'JavaScript' (together, "Tracking
Tools"). Tracking Tools are files or tools that are placed on your
computer in order to identify your Web browser and the activities of your
computer on the Site. Moody’s uses these technologies to customize and enhance
the Internet experience of individual users. When you revisit the Site, Moody’s
may recognize you by a Tracking Tool and customize your experience accordingly.
For example, once you have completed the registration process, a cookie will be
used to avoid having you register again. You may decline Internet cookies, if
any, by using the appropriate feature of your Web browser software, if
available. If cookies are disabled, however, all features of the Site may not
operate as intended. Information about the procedure you are required to follow
in order to disable cookies can be found on your Internet browser provider’s
website.
We believe Tracking Tool technologies add value to
the user experience, and the information resulting from these technologies is
not sold or otherwise made available to third parties by Moody’s.
Use of Personal
Data Collected
Moody’s may use Personal Data it collects for
editorial and feedback purposes, marketing and promotion, statistical analysis
of users’ behavior, product development, delivering products and services, providing customer support, customizing and
improving the content and layout of the Site or its other web sites, completing
business transactions, administering individual accounts and meeting government
regulatory requirements such as sales tax collection. Monitoring Data may be
used for internal or external purposes such as researching and identifying
market segments and needs. Moody’s will not disclose to third parties any of
your Personal Data, except to the extent necessary to comply with applicable
laws, rules, or regulations, with your express permission, or to preserve
Moody’s legal rights in the Site’s content. Moody’s reserves the right to
transfer such information within the group (the details of which can be found
on the www.moodys.com website), to successors to the relevant portion of any of
Moody’s businesses, or to independent contractors it engages to assist with or
perform on Moody’s behalf any of the foregoing activities. In addition, Moody’s
reserves the right to use Personal Data to contact you regarding your account
status and changes to the User Agreement, this Privacy Policy, or any other
policies, agreements or transactions relevant to your use of the Site. Moody’s
will take reasonable steps to maintain the integrity of the collected data so
that it is reliable and appropriate for the foregoing uses.
Your Choices Regarding Personal
Data Collection and Use
You may "opt-in" to having your Personal
Data used by Moody’s to send promotional correspondence to you now by checking
the appropriate box on the Registration Form, or at any time in the future by
changing your User Profile, or by contacting Moody’s via postal mail, e-mail,
or telephone at the address below.
Except as described in the paragraph above, Moody’s will not share any
Personal Data with a third party without giving you the opportunity to
"opt-in" and give or deny us permission to do so.
Upon request via postal mail, e-mail, or telephone,
Moody’s will provide to you a summary of any Personal Data retained by Moody’s
regarding you. You may modify, correct, change or update Personal Data that
Moody’s has collected via the Site. You may refuse to have your Personal Data
processed by Moody’s or you may request that your Personal Data be anonymised,
blocked (so that Moody’s continues to hold your Personal Data but temporarily
refrains from processing it) or removed from Moody’s database by contacting
Moody’s via postal mail, e-mail, or the telephone number indicated below,
provided, however, that such requests may require you to register again with
Moody’s in the event you later wish to access the Site. You may ask Moody’s to
certify that it has notified the entities to whom your Personal Data has been
transferred of any such changes to or removal of your Personal Data. You should
be aware that it may not be technologically possible to remove or verify each
and every record of information you have provided to us from our system. The
need to back-up our systems to protect information from inadvertent loss means
that a copy of your Personal Data may exist in archived systems. However,
promptly after receiving your request, all Personal Data stored in databases we
actively use and other readily searchable media will be updated, corrected, changed,
deleted or confirmed to you, as appropriate, as soon as reasonably practicable.
Links
The Site may contain links to other Internet
websites. Moody’s does not endorse, and is not responsible for, the privacy
practices or the content of these websites. You should review the applicable
privacy policies in connection with your use of such third party websites.
Security Measures
Moody's has established reasonable precautions to
protect collected Personal Data from loss, misuse, unauthorized access, disclosure,
alteration or destruction, which include contractual, administrative, physical,
and technical steps. Technical measures include use of firewall protection and
encryption technology where appropriate. Although Moody's takes reasonable
precautions to assess the reliability of such technology, it relies on the
statements of the vendors of those products and services as part of its
security evaluation. Please note that while Moody’s has endeavoured to create a
secure and reliable site for users, the confidentiality of any communication or
material transmitted to/from Moody’s the Site or e-mail cannot be guaranteed.
Data Integrity
Moody’s
will use Personal Data only in ways that are compatible with the purposes for which
it was collected or subsequently 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), but Moody’s must
depend on you to update or correct your Personal Data whenever necessary.
Export of Personal Data
By using the Site, you acknowledge and consent to the
fact that Personal Data provided by you or collected by us through your use of
the Site is stored and processed by us in the United States where data
protection laws may not afford the same level of protection as those of the
country in which you are located (this is the case for users located in the
European Economic Area (“EEA”)). You also
acknowledge and consent to the fact that we may, at our discretion, store and
process such data in other countries (including countries outside the EEA)
where data protection laws may not afford the same level of protection as those
of the country in which you are located.
Enforcement
Moody’s
periodically will review its compliance with this Privacy Policy. Moody’s will also review and respond to any
formal written complaints that we received from you. Moody’s will cooperate with the appropriate
regulatory authorities, including the European Union data protection
authorities, to resolve any complaints that cannot be resolved between us.
Contact Information for Moody’s
Questions or concerns regarding Moody's data
protection practices should be addressed to:
Legal Department
Moody’s Corporation
7 World Trade Center at 250 Greenwich Street
New York, NY 10007
Phone: +1-212-553-1653
E-mail: privacy@moodys.com
If you choose to contact Moody’s via e-mail about this policy, please mark the
subject heading of your e-mail “Privacy Enquiry”.
We shall keep a copy of this Privacy Policy and if,
at any time, you would like to see a copy of it, you should write to the
address above.
BY USING THE SITE,
YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY AND OF US PROCESSING YOUR
PERSONAL DATA IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DO
NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE THE SITE. YOUR CONTINUED
USE OF THE SITE FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY WILL
MEAN THAT YOU ACCEPT THOSE CHANGES.