IPREO

PRODUCTS PRIVACY POLICY

 

This website (this “Site”), including any associated desktop application downloaded to your computer (an “Application”) is brought to you by the Ipreo LLC and Ipreo group companies, which include Ipreo Limited and Ipreo Data Inc., (“Ipreo,” “we” or “us”).

Ipreo offers access to an array of products and services, including but not limited to, Ipreo’s various commercial databases, as well as, various capital markets‑related software and services. The services, products, data and information provided by Ipreo on this Site and/or through other websites and channels, together with any Applications and any other associated software applications and functionality are collectively referred to in this Privacy Policy as “the Products.” Use of the Products in connection with this Site is governed by our Terms of Use and any applicable license or other service agreement(s) (“Customer Agreement”) between Ipreo and its customers (“Customers”).

This privacy policy (the “Privacy Policy”) describes how Ipreo treats information you, other authorized users, or our Customers may provide to us, or which we otherwise collect, which can directly or indirectly identify you (“Personal Information”), how we may use your Personal Information, how we protect the security of your Personal Information and how you may change or request that we amend your Personal Information on our systems. To the extent Personal Information is governed and protected by European Union (“EU”) and/or UK data protection laws (such Personal Information is hereinafter referred to as “EU Personal Information”) we will ensure that we comply with all relevant EU and/or UK data protection laws when processing EU Personal Information.

The Personal Information that we intend to process includes your name, business phone number, business postal address, business email address, your IP address, your password and your username, and where appropriate, your activity and transactions on the Site.

Ipreo respects the privacy of its Product users and Site visitors and strives to protect the security of the Personal Information it processes.

Click the link below for Ipreo’s policy on each topic:

1.      How and When We Collect and Use Personal Information

2.      Our Purposes for Processing

3.      Our Use of Cookies

4.      Ipreo as a Data Processor

5.      How we Share your Personal Information

6.      How we Protect the Security of your Personal Information

7.      Children’s Privacy

8.      Your Rights Regarding your Personal Information

9.      Other Websites

10.  Changes to this Privacy Policy

11.  How to Contact us


1.     How and When We Collect and Use Personal Information

We may collect the following Personal Information:

(a)   Information you, another Authorized User or our Customer gives us. We collect your Personal Information you provide when you sign up to use this Site and/or the Product(s).  We will also process your Personal Information when it is provided to us by another authorized user or a Customer in connection with the use of the Products. In some situations, we may also record your username and/or password which you provide to sign-in to the Products.

 

We may use this Personal Information to respond to specific requests for information about the Products and other inquiries. We only use the Personal Information provided by you or our Customer when signing up to use a Product for purposes related to the provision of the Product(s) to you and our Customer.

(b)   Information we get from your use of this Site. When you access this Site, our systems automatically record information such as your Internet Protocol (“IP”) address, mobile device identifier, browser type and characteristics, and whether and how frequently you use this Site and the Products and services available through this Site.

 

We process this Personal Information to understand users’ preferences, to better serve users, and to improve this Site and the Products.

(c)   Information you or other Authorized Users and Customers Upload to the Products: The Products may permit the uploading, posting, storage and viewing of Personal Information or other content submitted by you or another authorized user of the Products under an applicable Customer Agreement (“User-Submitted Content ”). User-Submitted Content is provided by the Customer and/or authorized users and, except as otherwise provided in this paragraph and paragraph 1(d) “Aggregated Data” below, will be processed by Ipreo as a data processor in accordance with the Customer’s instructions. The Customer will be responsible for all processing of User-Submitted Content, including complying with the applicable Terms of Use, Customer Agreement and all applicable privacy, data security, and other laws and regulations. Except as otherwise provided in this paragraph and paragraph 1(d) “Aggregated Data” below, Ipreo is not a data controller in respect of User-Submitted Content (See 4 “Ipreo as a Data Processor” below).

 

We process User-Submitted Content primarily for the provision of the Products. We also use this Personal Information to address a system, security, or support issue, or a suspected violation of our Terms of Use or Customer Agreement, and to create aggregate information (see 1(d) “Aggregate Data” below)

(d)   Aggregated Data. We may collect information regarding use of this Site or the Products, or about a category of users of this Site, and combine that information with other information pertaining to use of this Site and the Products by you and other users. In addition, we may create “Aggregated Data” using the User-Submitted Content, and may use such Aggregated Data in connection with our provision of the Products and for other Ipreo business purposes and to create new products. “Aggregated Data” means data resulting from the aggregation, calculation, analysis or compilation of User-Submitted Content and/or data from other sources, including other clients or customers of Ipreo; provided that (i) such resulting data does not identify you or any other individual or Customer as the source of any such data, and (ii) the identities of Customer and Customer’s clients are not disclosed by or discernable from the resulting data without an extraordinary amount of time or effort. No such Aggregated Data will include your Personal Information.

 

2.  Grounds for Processing Personal Information

The Personal Information that we may need to process includes your name, business phone number, business postal address, business email address, your IP address, your password and your username, and where appropriate, your activity and transactions on the Site. We need such Personal Information primarily to allow us to perform the contracts with our Customers and enable you to use the Products, to enable us to comply with legal obligations, for the purpose of addressing a system, security or support issue, or a suspected violation of the Terms of Use, the Customer Agreement or the law and, in many cases we may use your Personal Information to pursue legitimate interests of our own and those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your Personal Information for our legitimate interests include some or all of the following:

(a)   To provide the Products, to enhance, modify, personalize or otherwise improve and support the Products and this Site and to conduct communications for the benefit of our Customers and users of the Products.

(b)   To update and maintain the accuracy of Personal Information.

(c)   To enhance network and information security, including preventing unauthorised access to our computer and electronic communications systems and preventing malicious software distribution.

(d)   To conduct data analytics studies to review and better understand how users interact with the Products.

 

Whenever we process Personal Information for these purposes we ensure that we keep your Personal Information rights in high regard and to take account of these rights You have the right to object to this processing if you wish, and if you do wish to do so please click here. Please bear in mind that if you do object and we cannot demonstrate compelling legitimate grounds to continue processing your Personal Information, we will stop processing your Personal Information which may affect our ability to provide you with certain services and carry out tasks to your benefit. It may also affect your ability to use the Products. Please also see your rights regarding your Personal Information in 8, “Your rights Regarding your Personal Information” below.

3. Our Use of Cookies

We use cookies, which are small data files that this Site may transfer to your browser. You can find more information about cookies at websites such as www.allaboutcookies.org and www.youronlinechoices.eu. For more information on what cookies Ipreo use and why, please see our Cookie Policy below

4. Ipreo as a Data Processor

We may process certain Personal Information when acting as a Customer’s service provider. This includes Personal Information included in User-Submitted Content, as well as other information provided by users and stored in the Products. We may also obtain your Personal Information from a Customer or authorized users who add you as a participant or invitee in connection with a Product. Since the Products and this Site are intended for business purposes only, you should only enter business contact information. Ipreo does not own or control such Personal Information, except as provided in paragraphs 1(c) and 1(d) above, and we handle such Personal Information only as a processor. Our Customers are responsible for making sure that privacy rights are respected, including ensuring appropriate disclosures about third party data collection and use. To the extent that we are acting as a Customer’s data processor, we will process Personal Information in accordance with the terms of our Customer Agreement with the Customer and the Customer’s lawful instructions.  If you have any questions or concerns about the processing of any of such Personal Information, please contact the relevant Customer who invited you to use the Product.

5. How we Share your Personal Information

(a)   Among Ipreo Group Companies: We may share Personal Information among the Ipreo companies including those described above for purposes of providing the Products and in support of this Site.

(b)   With Third Party Service Providers: We may provide your Personal Information to our third party service providers so that they may assist us in connection with operating this Site and providing the Products; for example, our data centers, support services providers, developers and other similar or related services. We typically enter into written contracts with our third party service providers, require them to use Personal Information only for that purpose and require assurances that they will appropriately protect Personal Information entrusted to them.

(c)   For Law Enforcement and Legal Purposes: We may disclose your Personal Information as we deem necessary or appropriate: (i) under applicable law, (ii) to comply with legal process; (iii) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (iv) to enforce our Terms of Use and Customer Agreements; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety or property, and/or those of our affiliates, you or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

(d)   Transfers outside the European Economic Area (“EEA”): The sharing of your EU Personal Information as described above may involve the transfer of your EU Personal Information outside the EEA, including to and in the United States. Whenever we transfer any EU Personal Information outside the EEA we will have or put in place an adequate level of protection to ensure that any such transfers comply with applicable EU and/or UK data protection laws, including with respect to transfers among Ipreo affiliates, the standard data protection clauses adopted by the EU Commission. If you require further information about this protective measure, you can request it from the Data Protection Officer by clicking here.

(e)   Access among Users Within the Same Business Account: For many Customers, Ipreo has incorporated functionality in this Site and the Products that shares information among the Customer’s authorized users. Depending on the specific functionality that has been implemented, and the permissions granted to the user by the Customer, User-Submitted Content added into this Site by you or another authorized user may be shared with other authorized users. A Customer may also specify a designated user with special rights to access all User- Submitted Content within the Customer’s applicable account, including all information submitted by you as well as your Personal Information and that of other users under the same Customer account. If you have any questions about such access, you should speak with your Customer account administrator.

6. How we Protect the Security of your Personal Information

We are committed to maintaining the security of Personal Information. We employ reasonable organizational, technical and administrative measures to secure and protect Personal Information collected as described in this Privacy Policy from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. We permit persons working for us to access and use the Personal Information you provide only to serve legitimate business and service needs consistent with this Privacy Policy. We also require our third party service providers to implement appropriate security measures. Please remember, though, that no method of electronic transmission or storage is 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us (see 11, “How to Contact Us” below). We retain Personal Information for as long as we reasonably require it for legal, business or contractual purposes. In determining data retention periods, we take into consideration local laws, contractual obligations, technology constraints and the expectations and requirements of our Customers. When we no longer need Personal Information, we securely delete or destroy it.

7. Children's Privacy

Minors under the age of 18 should not provide any information to us using this Site or the Products. We do not knowingly collect personal information from individuals under the age of 18.

8. Your rights Regarding your Personal Information

You may have the right to access the Information that we process about you and to request that we correct, amend, or delete it if it is inaccurate or processed in breach of applicable laws, if such right is provided by law in the applicable jurisdiction. These rights may not apply in some cases and, if you make a request, we shall inform you if that is the case. If you would like to request access to, or a correction or amendment to, your EU Personal Information or request deletion of your EU Personal Information, click here.   

9. Other Websites

This Privacy Policy applies to Personal Information collected in connection with your use of this Site and the Products. Information submitted on a third party website linked to this Site is subject to the terms of the privacy Policy applicable to such third party website, and not the terms of this Privacy Policy. Ipreo is not associated with these third party websites and does not review their privacy policies. We cannot guarantee the privacy of any information that may be obtained by third parties at these other websites. We strongly encourage you to review the privacy policies of any website you visit before supplying personal information through that website.

10. Changes to the Privacy Policy

We may revise this Privacy Policy from time to time in order to address new or revised website functionality, new or revised aspects of the Products, Internet technology, or applicable law. The handling of Personal Information is governed by the version of this Privacy Policy in effect when such information is received. Therefore, you should review it from time to time to be sure that you are aware of the most up-to-date applicable provisions. Your continued use of this Site and the Products after we have posted changes to this Privacy Policy indicates your agreement to the amended terms of this Privacy Policy.

11. How to Contact Us

Ipreo Limited and the Ipreo entities that process the Personal Information may be contacted at privacy@ipreo.com. The Ipreo group comprise entities and offices in the UK, US, APAC and South Africa.

Ipreo has a data protection officer who may be contacted by clicking here.

Your questions, comments and feedback are very important to us. For privacy-related issues or questions, please contact us at privacy@ipreo.com.

We will investigate and attempt to resolve any complaints or disputes we receive regarding the processing of your Personal Information. To the extent your Personal Information is EU Personal Information, and you are unsatisfied with the resolution of any complaint, you may contact the UK Information Commissioner’s Office for further information and assistance.

Effective Date: 5/24/18

Version: 3.0


 

IPREO COOKIES POLICY

 

We use "cookies," which are small data files that this Site may transfer to your browser.

1.                Types of cookies

Generally, the cookies we use fall into the following two categories:

(a)             "Strictly necessary cookies" which are essential for you to move around within this Site and for the operation of this Site.

(b)             "Performance cookies" which analyze how our users use this Site and monitor this Site’s performance.

Within these two categories, we currently use or may use in the future the following types of cookies:

 

(a)             Session cookies (temporary cookies that expire when you log off this Site or when your session automatically times out) to maintain your session and maintain security and verify details while you use this Site as you navigate from page to page.

(b)             Persistent cookies (cookies stored on your browser between sessions) to help uniquely recognize you or your browser and remember how you have used this Site.

In addition to cookies that send information to us, this Site may also permit use of cookies to collect information and send it to third parties for analytical purposes, to permit functionality on this Site, or to help with authentication (see below).

2.                Functionality services we use

This Site may make use of Google Maps, Google Site Search, Microsoft’s Bing Maps, or other third party services, which may place cookies on your browser and collect IP address and browser data and related information in order to facilitate functionality and to maintain and improve the quality, security and integrity of the third party services. In some instances, the third party services may make use of web beacons to help deliver cookies and compile usage information. Data collected by third parties are subject to those third parties’ own privacy policies.

3.                Analytics and marketing services we use

In addition, this Site may use analytics features such as services provided by Google Analytics, Ion Interactive, and Daddy Analytics, as well as marketing software tools such as the email tools provided by Marketo. Cookies placed on your browser by such services may collect limited information pertaining to your use of this Site, including traffic and usage data. In accordance with the applicable service terms, such services do not collect personal information. Use of data collected by analytics services (generally, in aggregate form only) is subject to the service’s own privacy policies. Note that Google offers a Google Analytics browser add-on (designed to be compatible only with certain browsers) to provide website visitors the ability to prevent their data from being collected and used by Google Analytics.

We do not collect personal information about your online activities across third party websites or online services, and thus this Site does not respond to web-browser “do-not-track” signals or other similar mechanisms. We do not permit our third party service providers to collect information from this Site for other websites other than as described in the preceding paragraph.

4.                Controlling and deleting cookies

If you want to control or delete the cookies we set, you can do this through your browser settings. The ‘help’ function within your browser should tell you how. However, restricting cookies may affect your use of this Site and prevent some services and selection tools from working.