Effective 1 October, 2018
Your privacy and trust are important to us. This Statement explains how the Refinitiv group of companies (“Refinitiv,” “we”, “us” or “our”) collect, handle, store and protect personal information about you in the context of our services. It also provides information about your rights and about how you can contact us if you have questions about how we handle your information.
This Statement applies to individuals who use any website, application, including mobile application (“app”), product, software or service of ours that hyperlinks to this Statement (we call these our “Services”).
It does not generally apply to individuals whose personal information forms part of the content included within our products, although you can find further information on that topic here.
Refinitiv provides information solutions for professionals and our Services are generally not aimed at children.
Depending on the Service, we may provide additional or different privacy statements or notices for specific interactions you have with us or to highlight how we use your personal information for specific Services. Where we do this, it will be clear which statements apply to which interactions and Services. For example, if you use one of our mobile apps, we provide you a separate notice in relation to a particular data type collected through that app.
Within our Services, there may be links to third-party websites or applications. We are not responsible for the content or privacy compliance of third party websites or applications. You should check those websites or applications for their privacy statements and terms that apply to them.
Children’s Privacy. Our Services are not generally aimed at children. In the limited circumstances where we may collect and use personal information about children, for example to develop an educational resource, we will comply with industry guidelines and applicable laws.
Refinitiv is a global company that is made up of numerous legal entities.
For some Services we make decisions on how personal information is used in the context of a Service (Refinitiv is a controller of personal information in this case), and for other Services we will only use personal information as instructed by our customers (Refinitiv is a processor of personal information in this case). Below you can find more information on the cases in which Refinitiv is a controller of personal information and information on how to contact us.
To learn more about the products in which we are a controller of personal information, please visit this page. In the European Economic Area, if you wish to contact the Refinitiv entity that is controller for the Service relevant to you, please contact Refinitiv, c/o Reuters Limited, Privacy Office, 30 South Colonnade-Canary Wharf, London E14 5EP, United Kingdom or we welcome you to contact us for more information.
We collect personal information about you from your interactions with us and from certain third parties and other sources (such as your employer or the subscriber providing access to our Services or from publicly available sources where permissible).
We obtain personal information from you:
We also collect personal information about you from third parties such as:
The type of personal information we collect depends on how you are interacting with us and which Services you are purchasing or using.
In many cases, you can choose whether or not to provide us with personal information, but if you choose not to, you may not get full functionality from the Services.
The personal information we collect consists of the following:
This section includes details of the purposes for which we use personal information and also the different legal grounds upon which we process that personal information. We use personal information to provide and improve Services and for other purposes that are in our legitimate interests, as well as for compliance purposes. Further information is set out below.
Some laws require us to explain our lawful reason for processing your personal information. We process personal information about you on the basis that it is:
You are welcome to contact us for further information on the legal grounds that we rely on in relation to any specific processing of your personal information.
We use personal information for a number of legitimate interests, including to provide and improve Services, administer our relationship with you and our business, for marketing and in order to exercise our rights and responsibilities. More detailed information about these legitimate interests is set out below.
Where we rely on legitimate interests as a lawful ground for processing your personal information, we balance those interests against your interests, fundamental rights and freedoms. For more information on how this balancing exercise has been carried out, please contact our Privacy Team.
We deliver marketing and event communications to you across various platforms such as email, telephone, text messaging, direct mail and online. Where required by law, we will ask you to explicitly opt in to receive marketing from us. If we send you a marketing communication it will include instructions on how to opt out of receiving these communications in the future.
Honoring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising.
Where we send marketing emails, we provide unsubscribe options for your use within our emails. To update your email marketing preferences, please visit the applicable email preference center, a link to which will normally be included in emails you receive from us. In addition, you can also use the “Contact Us” feature of a particular Service, discuss with your Refinitiv contact or contact our Privacy Team.
Even if you opt out of receiving marketing communications by email, we may still send you service communications or important transactional information related to your accounts and subscriptions (for purposes such as providing customer support).
Interest-based advertising (IBA) allows us to deliver targeted advertising to users of our Services. IBA works by showing you advertisements, or sending you marketing emails, that are based on the type of content you access or read. For example, as you browse our Services, one of the cookies placed on your device will be an advertising cookie so we can better understand what sort of pages or content you are interested in. The information collected about your device enables us to group you with other devices that have shown similar interests. We can then display advertising to categories of users that is based on common interests. For more information about IBA, please click here.
If you want to opt out of receiving interest-based advertising, it does not mean that you will no longer receive advertising when you are using our Services. It just means that we will not use your personal information for IBA and that any advertising you see will not be customized to you. You can exercise your online advertising choices or by clicking the AdChoices icon in an ad and following the instructions. You may also opt out of receiving interest-based ads from many sites through the Network Advertising Initiative’s (NAI) Opt Out Tool and in the EU. If you delete cookies, use a different device, or change web browsers, you may need to opt out again.
Mobile devices have an identifier that gives companies the ability to serve targeted ads to a specific mobile device. In many cases, you can turn off mobile device ad tracking or you can reset the advertising identifier at any time within your mobile device privacy settings. Another tool you can use to control advertising on your mobile device is the AppChoices App. You may also choose to turn off location tracking on your mobile device. If you turn off ad tracking or location tracking, we will no longer use information collected from your device’s advertising identifier for the purposes of advertising. You may still see the same number of ads but they may be less relevant because they will not be based on your interests. Where we need your consent to gather information about your location we will obtain this from you.
We share personal information within the Refinitiv group, with our business partners and third party service providers, the person providing for your access to our Services (if that is not you) and in accordance with law. Our third-party service providers are not permitted to share or use personal information we make available to them for any purpose other than to provide services to us.
We share your information for the purposes set out in this Statement, with the following categories of recipients:
Refinitiv is a global organization and your personal information may be stored and processed outside of your home country, including in countries that may not offer the same level of protection for your personal information as your home country. We have measures in place to ensure that when your personal information is transferred internationally, it is subject to appropriate safeguards in accordance with data protection laws. Often, these include contractual safeguards. More information about these safeguards (including copies, where relevant) can be obtained by contacting us here.
Refinitiv has networks, databases, servers, systems, support and helpdesks around the world. We collaborate with third parties like cloud hosting services, suppliers and technology support located around the world to serve the needs of our business, workforce and customers. We take appropriate steps to ensure that personal information is processed, secured and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within Refinitiv or to third parties in areas outside of your home country, including to countries that have not been declared adequate for the purposes of data protection by the European Commission.
The areas in which these recipients are located will vary from time to time, but include the United States, Europe, Canada, Asia (including Australia and India), and other countries where Refinitiv has a presence or uses contractors.
When we transfer personal information internationally, we put in place safeguards in accordance with applicable law (including Articles 44 to 50 of the EU General Data Protection Regulation). If you would like to know more about our data transfer practices and obtain copies of any relevant safeguarding measures, please contact our Privacy Team.
Refinitiv takes the security of personal information seriously and we use appropriate technologies and procedures to protect personal information (including administrative, technical and physical safeguards) according to the risk level and the service provided.
We have in place a global Information Security and Risk Management team, led by our Chief Information Security Officer, which is responsible for implementing secure data handling practices at Refinitiv.
Our information security policies and procedures are closely aligned with widely accepted international standards and are reviewed regularly and updated as necessary to meet the sensitivity of the personal information we handle, our business needs, changes in technology and regulatory requirements. We have implemented appropriate information security controls.
We retain your information in accordance with our enterprise records retention schedule. You can find more information on the criteria used to calculate the retention periods set out below.
Refinitiv has a Records and Information Governance team that works in conjunction with our Privacy Team to implement policies and rules relating to the retention of personal information. We have an enterprise records retention schedule that is based upon a classification scheme consisting of business functions, record classes, and record types.
We calculate retention periods for your personal information in accordance with the following criteria:
You may have rights under European and other laws to have access to your personal information and to ask us to rectify, erase and restrict use of, your personal information. You may also have rights to object to your personal information being used, to ask for the transfer of personal information you have made available to us and to withdraw consent to the use of your personal information. Further information on how to exercise your rights is set out below.
We will honor your rights under applicable data protection laws. You have the following rights under European laws, and may have similar rights under the laws of other countries.
These rights are not absolute and they do not always apply in all cases.
In response to a request, we will ask you to verify your identity if we need to, and to provide information that helps us to understand your request better. If we do not comply with your request, whether in whole or in part, we will explain why.
In order to exercise your rights please this site.
A cookie is a small text file that is placed on a computer or other device and is used to identify the user or device and to collect information. Cookies are typically assigned to one of four categories, depending on their function and intended purpose: absolutely necessary cookies, performance cookies, functional cookies, and cookies for marketing purposes.
Absolutely necessary cookies: These cookies are essential to enable you to move around a website and use its features. Without these cookies, Services you have asked for, like adding items to an online shopping cart, cannot be provided.
Performance cookies: These cookies collect information about how you use our websites. Information collected includes, for example, the Internet browsers and operating systems used, the domain name of the website previously visited, the number of visits, average duration of visit, and pages viewed. These cookies only collect information in an aggregated format. Performance cookies are used to improve the user-friendliness of a website and enhance your experience.
Functionality cookies: These cookies allow the website to remember choices you make (such as your username or ID, language preference, or the area or region you are in) and provide enhanced, more personal features. These cookies can also be used to remember changes you have made to text size, fonts, and other customizable parts of web pages. They may also be used to provide Services you have asked for, such as watching a video or commenting on a blog. These cookies cannot track your browsing activity on other websites.
Targeting and advertising cookies: These cookies track browsing habits and are used to deliver targeted (interest-based) advertising. They are also used to limit the number of times you see an ad and to measure the effectiveness of advertising campaigns. They remember that you have visited a website and this information is shared with other organizations, such as advertisers.
You can manage website cookies in your browser settings, and you always have the choice to change these settings by accepting, rejecting, or deleting cookies. If you choose to change your settings, you may find that certain functions and features will not work as intended on the Services. All browser settings are slightly different, so to manage cookies, you should refer to the relevant settings within your browser.
We understand that you may want to know more about cookies. Here are some useful resources that provide detailed information about types of cookies, how they are used, and how you can manage your cookie preferences: www.aboutcookies.org or www.allaboutcookies.org. Please click below for detailed information on how to disable and delete cookies in some commonly used browsers:
We use certain other tracking technologies in addition to cookies:
Some browsers transmit Do Not Track (DNT) signals to websites. Due to the lack of a common interpretation of DNT signals throughout the industry, we do not currently alter, change, or respond to DNT requests or signals from these browsers. We continue to monitor industry activity in this area and reassess our DNT practices as necessary.
Some of our Services may include social networking features, such as the Facebook® “Like” button and widgets, “Share” buttons, and interactive mini-programs. Additionally, you may choose to use your own social networking logins from, for example, Facebook or LinkedIn®, to log into some of our Services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these Services. These Services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy statements or policies applicable to the third-party services you connect to, use, or access. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on the Services.
This Statement generally relates to the personal information we collect about users in connection with the Services, where we make decisions about how that personal information is handled (Refinitiv as a controller). However, you can click on “Learn More” below for more information about how we process personal information that our customers input into our Services and for which Refinitiv does not make decisions about (Refinitiv as a processor).
Where we need to give you additional information about how your personal information is used in relation to specific Services we will provide separate or additional privacy notices.
Your professional service provider (e.g., your financial adviser) and other third parties may enter your personal information into Services we make available to, and host for them on their behalf. They may provide their own privacy notices to you. You should contact them for these notices, and you may also be able to find their privacy notices on their websites.
Many professionals and third parties rely on the use of publicly available information in order to carry out research or to satisfy their compliance obligations (e.g., to carry out anti-money-laundering checks).
To assist them, we make available information obtained from publicly available sources like public websites, open government databases or other data in the public domain (some of which is behind a paywall and some not).
Refinitiv provides Services to financial industry, compliance and risk professionals, helping them with efficiency tools and data to assess and improve risk and compliance management, analyze and access financial transactions, generate better returns and create efficient, reliable business infrastructure. Such Services will process personal information entered by our customers as well as provide publicly available information about individuals to assist customers with governance, risk and compliance activities.
For example, Refinitiv provides a Service called World-Check, which helps financial institutions, corporates, professional services firms, governments, law enforcement agencies, regulators and other World-Check customers to perform due diligence and other screening activities in accordance with their legal or regulatory obligations and risk management procedures carried out in the public interest. For this Service, Refinitiv may store personal data entered by a customer and also will make information about individuals available to such customer for use limited to compliance and other public interest purposes. World-Check has its own privacy statement, which is available here.
For more information about how your bank, counterparty or finance or risk professional handles your personal information, please contact them directly.
If you have any questions, comments, complaints or suggestions in relation to data protection or this Statement, or any other concerns about the way in which we process information about you, please contact our Privacy Team or at Privacy Office, Refinitiv, 30 South Colonnade-Canary Wharf, London E14 5EP, United Kingdom.
If you are not satisfied with the response, we encourage you to escalate your query to our Data Protection Officer or at Data Protection Officer, Refinitiv, 30 South Colonnade-Canary Wharf, London E14 5EP, United Kingdom.
Filing a Complaint. If you are not content with how Refinitiv manages your personal information, you can lodge a complaint with a privacy supervisory authority. In the European Economic Area, the relevant supervisory authority is the one in the country or territory where:
A list of National Data Protection Authorities in the European Economic Area can be found here.
This Statement may be subject to updates. Any material future changes or additions to the processing of personal information as described in this Statement affecting you will be communicated to you through an appropriate channel. For example, we may place a prominent notice on a product site or email you to let you know of an updated Statement.