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Effective: January 01, 2020

California consumer privacy notice

This California Consumer Privacy Notice (this “Notice”) supplements the Refinitiv Privacy Statement and applies solely to California consumers. This Notice applies to personal information that forms the content for Refinitiv’s products and services, to contractors, to Refinitiv’s marketing activities and to users of Refinitiv’s products and services. This Notice does not apply to Refinitiv World-Check products and any World-Check content incorporated into any of Refinitiv’s products and services.

This Notice uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

Section 1: Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers. In addition, Refinitiv may collect limited government identifiers (e.g., social security numbers, driver’s license numbers, and/or passports) in connection with certain engagements or relationships (e.g., Refinitiv’s engagement of or with contractors).
  • Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education information, credit card number, debit card number or other financial information and medical information.
  • Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ancestry, genetic information, disability, medical condition, citizenship status, and military and veteran status.
  • Commercial Information: commercial information, including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements.
  • Geolocation Data
  • Sensory Information: audio, electronic, visual, and similar information.
  • Employment Information: professional or employment-related information.
  • Education Information: education information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).

We may use the categories of personal information listed above for the purposes described in our Privacy Statement. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described below.

Purposes Categories of Personal Information 
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction

• Identifiers

• Online Activity

• Geolocation Data

• Sensory Information

Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity;

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Debugging to identify and repair errors that impair existing intended functionality

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Undertaking internal research for technological development and demonstration

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us

 

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Section 2: Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this Notice. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, (c) the categories of personal information we may have sold, and (d) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information

We may have obtained personal information about you from various sources, as described below.

Categories of Sources of Data Collection Categories of Personal Information
Directly from you, such as when you request information or provide us with your contact information

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Sensory Information

• Education Information

• Employment Information

From your devices, such as visit our websites or mobile apps

• Identifiers

• Online Activity

• Geolocation Data

• Sensory Information

Vendors who provide services on our behalf 

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Social networks

• Identifiers

• Additional Data Subject to Cal. Civ. Code §1798.80

• Protected Classifications

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Online advertising companies

• Identifiers

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

Government entities

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Sensory Information

• Education Information

• Employment Information

Publicly-available sources

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Sensory Information

• Education Information

• Employment Information

Consumer data resellers 

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Sensory Information

• Education Information

• Employment Information

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

Categories of Third Parties Categories of Personal Information
Refinitiv group companies

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Vendors who provide services on our behalf

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Professional services organizations, such as auditors and law firms

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Business partners, such as entities with whom we deliver co-branded services, provide content, or host events, conferences and seminars

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Advertising networks

• Identifiers

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

Internet service providers

• Identifiers

• Online Activity

• Geolocation Data

Data analytics providers

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Government entities

• Identifiers

• Additional Data Subject to Cal. Civ. Code § 1798.80

• Protected Classifications

• Commercial Information

• Online Activity

• Geolocation Data

• Sensory Information

• Education Information

• Employment Information

Operating systems and platforms

• Identifiers

• Online Activity

• Geolocation Data

Social networks 

• Identifiers

• Online Activity

c. Sale of Personal Information

We may allow certain third parties (such as certain advertising partners) to collect your personal information via automated technologies on our services in exchange for non-monetary consideration (such as an enhanced ability to serve you content and advertisements that may be of interest to you). You have the right to opt-out of the disclosure of your information, as detailed below.

During the 12-month period prior to the effective date of this Notice, we may have sold the following categories of personal information:

  • Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers
  • Geolocation data
  • Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements

We do not sell the personal information of minors under 16 years of age without affirmative authorization if we have actual knowledge of the individual’s age.

d. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose the categories of personal information listed in Section 1 of this Notice.

California Consumer Privacy Rights

You have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. 

Deletion: You may have the right to request that we delete certain personal information we have collected from you.

Opt-Out of Sale: You may have the right to opt-out of the sale of your personal information. Refinitiv may allow certain third parties to collect your personal information via tracking and advertising cookies, which may be considered a sale of your information under California law. To opt-out of these cookies, visit Refinitiv’s cookie preference center and follow the instructions. After opting-out of such cookies, if you clear the cookies on your browser that are associated with a Refinitiv website, this will remove your opt-out preferences and you will need to opt-out again from relevant cookies.      

Shine the Light Request: You also may have the right to request that we provide you with (1) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (2) the identity of those third parties.

How to Submit a Request : 

Submit an access, deletion, or data portability request online, or call us toll-free at (866) 463-4531.

To submit a Shine the Light request, email us at privacy.enquiries@refinitiv.com

Opt-out of the sale of your personal information online, or call us toll free at (866) 463-4531.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  We may require you to provide any or all of the following information:

  • First and last names;
  • Email address;
  • Telephone number;
  • Full residential address;
  • A copy of certain identification documents; and/or
  • Information about your interaction or relationship with Refinitiv and/or your usage of Refinitiv’s products and services.

In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. We will require you to execute the above-referenced declaration and submit it back to us.  If, in our sole determination in accordance with the CCPA, we are unable to verify your identity, Refinitiv may deny the request in whole or in part.

If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf, (1) we may require you to provide the authorized agent written permission to do so and we may require the authorized agent to submit identification information for verification purposes, and (2) for access and deletion requests, we may require you to verify your own identity directly with us (as described above). If the authorized agent provides a duly-executed power of attorney pursuant to California Probate Code sections 4000 to 4465, you will not be required to verify your own identity with us. If, in our sole determination in accordance with the CCPA, the agent does not submit proof that they have been authorized by you to act on your behalf, we may deny the request in whole or in part. For an authorized agent to submit a CCPA rights request on behalf of a California resident online, or call us toll free at (866) 463-4531.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.  This Notice is available in alternative formats upon request.  Please contact privacy.enquiries@refinitiv.com or call us toll free at (866) 463-4531 to request this Notice in an alternative format.