Please read through carefully to understand our practices regarding personal information and how we use and treat it.
INFORMATION WE COLLECT
We may collect and process information that identifies you or can be used to identify or contact you, (e.g., your name, e-mail address, business address, phone number or other identifiers ("Personal Data"). We request Personal Data from you when you register on any of our Properties. In addition to information collected during registration, we may collect Personal Data that you voluntarily provide, for example, in e-mails to our Properties, online order and registration forms and surveys.
You do not have to provide us with any Personal Data to visit our Properties. If you choose to withhold requested information, however, you may not be able to use all of the features of our Properties.
In addition to Personal Data, we may collect and/or track information that by itself cannot be used to identify or contact you, (e.g., demographic information (like age, profession or gender), domain names, certain IP addresses, computer type, browser types, and other anonymous statistical data involving the use of our Properties ("Nonpersonal Data").
We use Nonpersonal Data to help us understand who uses our Properties and to improve and market our Properties.
In addition to the non Nonpersonal Data highlighted above, we may collect certain information about your computer, including, where available, your IP address or other unique identifiers from your device. This information is collected for system administration (for example to enable identification and log-on for certain services), but also to understand more generally about the way users interact with our services. In certain cases, these IP addresses may amount to Personal Data or, when used in combination with other data which we hold, may enable us to identify you. This statistical information is not shared other than with our Affiliates in order to inform internal planning purposes. Once aggregated, this becomes generic Nonpersonal Data about our users' browsing actions and patterns, and does not identify any individual.
Cookies and other Tracking Tools
When you visit a Property, we may recognize you by a Tracking Tool and customize your use of that particular Property accordingly (e.g., once you have registered, a cookie will be used to avoid asking you to register again). The information obtained from using these technologies is not sold or otherwise made available to third parties except in accordance with this policy.
The cookies we use are referred to as session or persistent cookies, depending on how long they are used:
Session cookies only last for your online session and disappear from your computer or device when you close your browser.
Persistent cookies stay on your computer or device after the browser has been closed and last for the period of time specified in the cookie. These persistent cookies are activated each time you visit the Property where the cookie was generated.
When you use our Properties and services, the following 3 categories of cookies may be set on your device:
A. 'Strictly necessary' cookies
These cookies are essential in helping you to move around our Web sites and use their features, such as accessing secure areas of our Properties. Without these cookies, some services cannot be provided. These cookies do not gather information about you that could be used for marketing or remembering where you've been on the internet.
Some examples of these strictly necessary cookies include:
|Cookie Name||Purpose of the cookie|
|JSESSIONID||Session Information: the cookie identifies a user and allows for browsing sessions at a Property to be maintained.|
|BIGipServerfitchratings||Session Information: this cookie is used with our network load balancer in directing requests to the specific web server where an allocated user session is stored.|
|CFID||Session Information: used by our Coldfusion server to identify a user's session. This cookie is placed on your device by us and not by a third party.|
|CFTOKEN||Session Information: Used by our Coldfusion server to manage a user's session. This cookie is placed on your device by us and not by a third party.|
|VISITORID||Segmentation: identifies a unique user instance.|
B. Functional cookies
These functional cookies allow Web sites and applications to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal or secure features or to ensure the technology on our Properties is performing effectively. The information these cookies collect is usually anonymous which means we cannot identify you personally but sometimes they are used to cross-reference other information we hold so that we can provide you access to the services that you subscribe to or to tailor our online services specifically to you. They do not gather any information about you that could be used for selling advertising or remembering where you've been on the Internet outside of the Properties.
Some examples of these functional cookies include:
|Cookie Name||Purpose of the cookie|
|AUS_USERTYPE||Functional Service: identifies Australian retail investors users for local regulatory purposes.|
|USERID_NBR||Functional Service: assigns a unique internal ID to each user in our database. It includes no Personal Data.|
|AUTO_LOGIN_ID||Functional Service: a unique ID to identify a user which permits the user to automatically log on. This number is random and non-sequential.|
|GEOIP_COUNTRY_CODE||Functional Service: identifies the domicile of the user for regulatory/personalization purposes.|
|clientLastHTimes||Functional Service: an Akamai cookie that measures video playback quality via a beacon). This Tracking Tool is placed on your device by Akamai and not by a us.Further information on what Akamai tools do and how certain tools can be disabled can be found at: http://www.akamai.com/html/policies/privacy_statement.html|
|clientLastPTimes||Functional Service: an Akamai cookie that measures video playback quality via a beacon. Tracking Tool is placed on your device by Akamai and not by a us. Further information on what Akamai tools do and how certain tools can be disabled can be found at: http://www.akamai.com/html/policies/privacy_statement.html|
|ROIA_C||Segmentation: a Brightcove cookie to identify a unique user. This cookie is placed on your device by Brightcove and not by us. Further information on what Brightcove cookies do and how they can be disabled can be found at: http://support.brightcove.com/en/video-cloud/docs/video-cloud-player-cookies|
|BC_BANDWIDTH||Session Information: a Brightcove cookie to gauge bandwidth performance. This cookie is placed on your device by Brightcove and not by us . Further information on what this cookie does and how it can be disabled can be found at: http://support.brightcove.com/en/video-cloud/docs/video-cloud-player-cookies|
C. Analytics cookies
In order to keep our Properties and services relevant, easy to use and up-to-date, we use web analytics services provided by our trust third party technology partners to help us understand how people use them. For example, we can see which parts of the Properties and services are most popular, identify when errors occur, and test different versions of a page or feature to see which one works best.
Some examples of these analytical cookies include:
|Cookie Name||Purpose of the cookie*|
|cmTPSet||Analytics: generated by Coremetrics for web analytics purposes.|
|90226940_login||Analytics: generated by Coremetrics for web analytics purposes.|
|90226940_reset||Analytics: generated by Coremetrics for web analytics purposes.|
|CoreID6||Analytics: generated by Coremetrics for web analytics purposes.|
|TestSess3||Analytics: generated by Coremetrics for web analytics purposes.|
|_utmc||Analytics: generated by Google Analytics for web analytics purposes.|
|_utma||Analytics: generated by Google Analytics for web analytics purposes.|
|_utmz||Analytics: generated by Google Analytics for web analytics purposes.|
|AkamaiAnalytics_VisitCookie||Analytics: generated by Akamai and used to store information about the number of browser tabs currently open.|
|AkamaiAnalytics_BrowserSessionId||Analytics: generated by Akamai and used to store the ID for a particular session|
*Tracking Tools are placed on your device by third parties trusted by us to provide certain analytics services. The Tracking Tools are then used by these trusted technology partners to support their tools and systems and additionally their services may be used by us to help us understand the general performance of our Properties.
You can reset your Web browser to refuse certain types of Tracking Tools or to indicate when a Tracking Tool is being sent. However, certain features of the services may not work if you delete or disable Tracking Tools. Additionally, you have the ability to accept or to decline cookies from our Properties and other third party Web sites by modifying the settings in your browser. You may, however, not be able to use or access all of the interactive features of the relevant Property if cookies are disabled.
Additionally, if you have a Flash player installed on your computer, your Flash player can be set to reject or delete Flash cookies. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Properties or certain areas or features of the Properties.
For further information on cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit http://www.allaboutcookies.org/.
HOW WE USE INFORMATION AND WHEN WE MAY SHARE AND DISCLOSE INFORMATION GENERALLY
We use Personal Data that we collect solely for our internal use, including for statistical analysis of users' behavior, for product development, for content improvement or to customize the content and layout of our Properties. We may, in our sole discretion, use Personal Data to contact you regarding (i) your account status and changes to the subscriber agreement, (ii) this Policy, (iii) any other policies, agreements or transactions relevant to your use of the Properties and (iv) in accordance with applicable laws, marketing to you products and services which we believe may be of interest to you.
From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours ("Third-Party Providers"). For example, we may contract with Third-Party Providers to provide certain services, such as hosting and maintenance, data storage and management and marketing and promotions. We provide our Third-Party Providers with the information necessary for them to perform these services on our behalf. Each service Provider must agree to use reasonable security procedures and practices appropriate to the nature of the information involved in order to protect your Personal Data from unauthorized access, use or disclosure.
Nonpersonal Data, including for example data gathered by Google, Coremetrics, Akamai and Brightcove cookies, may also be used for internal or external purposes such as researching and identifying market segments and needs and assessing the performance of our Properties. In some instances, for example in the case of our use of analytics services provided by trusted third party suppliers where we share certain aggregated data and information with these third parties in order for them to provide us with information about the way our Properties are used or navigated or to classify aggregated segments or types of users. In other circumstances this sharing takes place in order to technically enhance or support the services provided by our Properties (for example to speed-up download speeds or facilitate site functionality such as video playback).
OTHER DISCLOSURES OF PERSONAL DATA TO THIRD-PARTY PROVIDERS
We may share and disclose your Personal Data and Nonpersonal Data with businesses controlling, controlled by, or under common control with us.
We may also share and disclose your Personal Data and Nonpersonal Data:
- In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data and Nonpersonal Data to the prospective seller or buyer of such business or assets; and
- If Fitch Ratings, Inc. or any of its Affiliates or substantially all of its or their assets are acquired by a third party, in which case Personal Data and Nonpersonal Data held by it about its customers may be one of the transferred assets.
PROCESSING AND STORAGE OF DATA IN THE UNITED STATES
Please be aware that your Personal Data and communications may be transferred to and maintained on servers or databases located outside your state, province, or country.
If you are located outside of the United States, please be advised that the laws in the United States may not be as protective of your privacy as those in your location. By using our Properties you agree that the collection, use, transfer, and disclosure of your Personal Data and communications will be governed by the applicable laws in the United States.
Each Property may contain links to Web sites and other interactive properties of third parties. We are not responsible for the collection and use of your information by these third parties, which will be governed by their data collection policies. We do not endorse, and are not responsible for, the privacy practices or the content of these properties. Please check these policies before you submit any Personal Data to these Web sites.
We have 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. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Properties or services, we cannot and do not guarantee the security of any information you transmit on or through the Properties or services, and you do so at your own risk.
CONTACT INFORMATION FOR FITCH RATINGS
The Data Controller for this Property is Fitch Ratings, Inc.
Fitch Ratings, Inc.
33 Whitehall Street
New York, NY 10004
If you are based in the European Union, you have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your Personal Data for such purposes or if we intend to disclose your information to any Third-Party Providers for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at firstname.lastname@example.org.
ACCESS TO INFORMATION
If you are based in the European Union, your local laws give you the right to access information held about you. Your right of access can be exercised in accordance with the relevant local legislation. Any access request may be subject to a limited administration fee (up to any limit imposed by local law) to meet our costs in providing you with details of the information we hold about you.
Effective Date: January 25, 2013