Moody’s Corporation and its U.S. subsidiaries adhere to the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union member countries and Switzerland to the U.S. Moody’s Corporation and its U.S. subsidiaries have certified that they adhere to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. For more information about the Safe Harbor program, and to view Moody’s Corporation and its U.S. subsidiaries’ certification, please visit http://www.export.gov/safeharbor.
In addition to our adherence to the Safe Harbor Frameworks, Moody’s affiliates globally have entered into an agreement to permit the cross-border transfer of Personal Data amongst such Moody’s affiliates.
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 receive Personal Data from social media platforms. For example, if you elect to use your social media credentials to log-in to your Site account, certain Personal Data from your social media account will be shared with us, which may include Personal Data that is part of your profile.
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, phone calls with Moody’s customer service and through other means.
On some of Moody’s Sites, including www.moodys.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 information through various other means, including participation at conferences and events, individual introductions, from employers that enroll their employees in our services and from selected third party business partners. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services.
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.
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, 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
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 Internet Protocol (IP) addresses. Your 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.
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 downloading 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.
Support Portal and Chat Tool. If you subscribe to a document in the Content section of our Support Portal, your full name or user name will appear on the page on a subscriber list that is visible to other users. If you use our Chat Tool, your full name or user name will appear to other users in your organization. If you do not want your name or user name displayed, please do not subscribe to documents in the Content section or use the Chat Tool.
Conferences and Events. When you attend a conference or event organized by Moody’s, your name and contact information may be shared with other attendees.
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).
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 firstname.lastname@example.org.
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 email@example.com.
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.
You may also indicate your choices regarding marketing-related emails by changing your preferences on your Site profile/account 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 may make a request by contacting us using the information provided in the “Contact Information for Moody’s” below. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion.
Moody’s has established reasonable organizational and technical measures to protect Personal Data within our organization from loss, misuse, or 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).
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