Privacy Statement

This Statement covers the content that forms part of our Services (excluding LSEG World-Check content or information). The Privacy Statement covering LSEG World-Check is available here.

Children’s Privacy. Our Services are not generally aimed at children. We do not intentionally collect personal information from or about individuals under the age of thirteen (13); however, in the event that we learn or discover that we have collected personal information inconsistent with this statement, we will ensure that the processing of such personal information is for a lawful and legitimate purpose and we will make reasonable efforts to delete and remove such personal information following the expiration or termination of the lawful and legitimate purpose.

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 may 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.

This Statement does not apply when we are acting in the role or capacity of a processor or service provider (or any other similar role or capacity) of personal information on behalf of a third-party. In such case, we are processing personal information at the direction and instruction of the third-party and the third-party’s privacy statement(s) will govern and control.

For some Services we make decisions on how personal information is used in the context of a Service (The appropriate entity within LSEG is a controller of personal information in this case), and for other Services we will only use personal information as instructed by our customers (The appropriate entity within LSEG is a processor of personal information in this case). Below you can find more information on the cases in which LSEG is a controller of personal information and information on how to contact us. 

LSEG is a controller of personal information in respect of Services provided unless stated otherwise. To learn more about our Services please visit this page.  If you wish to contact the LSEG entity that is controller for the Service relevant to you, please contact LSEG, Privacy Office, 10 Paternoster Square, London EC4M 7LS, England, United Kingdom or, in the European Economic Area, please contact LSEG, Data Protection Officer, Messeturm Friedrich Ebert Anlage 49, Frankfurt 60327 or we welcome you to contact us.

We obtain personal information from you:

• through your interactions with us and our Services, such as, when you purchase or use our Services, when you supply or provide services to us, sign-up to use a Service, request information or to receive marketing or other communications from us (e.g. marketing emails, alerts, newsletters, etc.), register for or attend an event, apply for or carry out a regulated role or position identified in our market rules for one of the companies listed on our markets or their relevant advisors, or call us for support (please note that we may record or monitor our telephone calls for compliance and quality assurance purposes)
• through your system/device and use of our Services. Our servers, logs and other technologies may automatically collect certain information from or about you and your systems and devices (e.g. IP address, UserID, etc.) and usage information to help us administer, protect (i.e., to detect and prevent fraud and security threats), and improve our Services, analyse usage and improve users’ experience
• through cookies and similar technologies included on our Services.  Please refer to our Cookie Statement for more information about how we use cookies in our Services and how you can control their use. Information related to Interest-Based and Mobile Advertising can be found here.
• through your engagement with us as an independent contractor/consultant

We may also collect personal information about you from third parties such as:

• the party or person(s) arranging for you to access our Services (e.g. your employer, subscriber, an organisation, group, or association to which you belong or are associated with) in order to set up a user account or otherwise to access and/or use our Services
• partners and service providers who work with us in relation to our Services
• companies that provide content or information to be used in our Services
• public domain sources (e.g. sources available to the public and typically over the internet (e.g. websites available to the general public), available in or through widely distributed media, and from government databases, records, and system (e.g. U.S. Securities and Exchange Commission, U.K. Companies House, sanctions lists, etc.)

To the extent that any personal information is provided to us by a third-party, other than the data subject, such third parties are also responsible for their own compliance with applicable data protection and privacy laws.

Depending upon the Services you use or your interactions with us, on the relevant Service(s), the personal information we collect may include:

• Name and contact data, such as first and last name, email address, postal address, phone number, and other similar contact data
• Employer and Professional Level data, such as the names of your current and/or former employers, job title(s), business contact information, industry, certifications, etc.
• Educational data, such as your education history
• Account credentials, such as passwords and other security information for authentication and access
• User content, such as communications and files provided by you in relation to your use of the Services
• Payment information, such as payment card number (credit or debit card), and the security code associated with your payment instrument, if you make a payment
• Device information, such as information about your device, such as IP address, location, device identification numbers, or provider
• Usage information and browsing history, such as, information about how you navigate within our Services, your browsing history and which elements of our Services you use the most
• Location data, for Services with location-enhanced features. If we need your consent to collect geo-location data, we will collect this separately
• Demographic information, such as, your country, and preferred language
• CCTV, if you visit or work from our offices or attend our events
• Images and/or Photographs, if you visit or work from our offices or attend an event that we sponsor or organise
• Identification documentation, such as copies of passports, drivers’ licenses, other government issued identification documents, etc., if you submit a data subject rights request, attend an in-person event, etc.
• Special categories of data or sensitive personal information, such as information on health/disabilities or religion, as it relates to your use of or access to our Services or events (e.g. health/disability information relating to your access to and use of our offices or attending our events, religious information as it relates to dietary requirements for attending an event or meeting, etc.) 
• Identifiers, such as unique identification numbers, cookie identifiers, account numbers, social security numbers, national identifiers, etc.
• In addition to the above personal information, which may be sourced from public sources, additional personal information may be sourced from public sources, such as personal information (1) originally available to the public and typically over the internet; (2) that LSEG has a reasonable basis to believe is lawfully made available to the general public by or from: (i) the data subject (or consumer or individual to whom the personal information relates), (ii) widely distributed media, or (iii) from a person to whom the data subject has disclosed the personal information (provided that LSEG does not have knowledge that the data subject has restricted the information to a specific audience); or (3) lawfully made available from records, databases, and/or systems of government agencies, departments, divisions or other operating units, in electronic, paper or any other format. Examples include personal information found on: (i) sanction or watch lists; (ii) law enforcement, court, regulatory, registry or other governmental websites and databases; (iii) political websites and publications such as parliamentary, local government or individual politician websites; (iv) reputable news media and publications; and (v) information sources made public by an individual themselves, for example on their website, blog or any social media application. The public source data may also include or reveal, directly or indirectly, information about age/date of birth, race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, health data, sex life, sexual orientation, criminal offense data or family circumstances (e.g. marital status, dependents, etc.).

Some laws require us to explain our lawful reason for processing your personal information. Personal information may be processed under more than one lawful reason/basis. We process personal information about you on the basis that it is:

• necessary for the performance of a contract: where we have a contract with you, we will process your personal information in order to fulfil that contract (i.e., to provide you with Services)
• in our or a third-party’s legitimate interests: details of those legitimate interests are set out in more detail below (e.g. provision of Services that we are contractually obliged by a third-party, such as your employer or our subscriber, to deliver to you)
• substantial public interest on the basis of applicable law (e.g. to help prevent and detect unlawful acts (e.g. money laundering, terrorism, fraud and/or other criminal activity (including, without limitation, modern slavery)))
• where you give us your consent (e.g. signing up to receive marketing and promotional communications from or about LSEG, competitions administered by or on behalf of us): we only ask for your consent in relation to specific uses of personal information where we need to and, if we need it, we will collect it separately and make it clear that we are asking for consent
• for compliance with a legal obligation (e.g. to respond to a court order or a regulator; comply with statutory and regulatory requirements within the jurisdictions within which we operate (including those relating to bribery and corruption, money laundering and sanctions; sharing personal information with external organisations (e.g. police, tax authorities, or other public authorities or government enforcement agencies))

In the limited circumstances where we process sensitive personal information, we normally do so where:

• necessary in relation to employee obligations
• personal information is within the public domain
• necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity
• processing is necessary for reasons of substantial public interest, on the basis of applicable law

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:

• to set up and administer your account and your use of our Services (including for access credentialing purposes, provide technical and customer support and training, verify your identity and perform authentication activities, facilitate and process transactions, provide suggestions and recommendations related to our Services, service our customers’ needs (including delivering the Services) and send important account, subscription and Service information)
• to administer our relationship with you, our business and our third-party providers (e.g. to send invoices)
• to understand the patterns, preferences and interests of our customers to improve and enhance our Services
• to handle enquiries and complaints
• to contact you for participation in, and to conduct, and manage, events, webinars, seminars, meetings, and/or other related gatherings or similar activities
• to run or operate competitions, prize draws, promotions, or sweepstakes that you participate in
• to undertake screening, investigation and enforcement activity in respect of companies listed on our markets, their officers and their relevant advisors
• to deliver and suggest tailored content such as news, research, reports and business information. We analyse the way you use our Services to make suggestions to you for features or Services that we believe you will also be interested in, and so that we can make our Services more user-friendly
•  to personalise your experience with our Services. We may retain your browsing and usage information to make your searches within our Services more relevant and use those insights to target advertising to you online on our websites and apps. Your choices in relation to marketing are explained here. We may sometimes share your personal information across our Services so that we can make all of the Services we deliver to you more intuitive (e.g. rather than requiring you to enter the same data many times)
• to contact you in relation to, and to conduct, surveys, polls or other research activities and to analyse the data collected for market research purposes, including, without limitation, related to creating and improving our Services
• to display information you choose to post, share, upload or make available in chat rooms, messaging services, and community and event forums (including in community and event profiles) and for related collaboration, peer connection, games and information exchange
• to provide any third-party, who has made our Services available to you (e.g. your employer or our subscriber), insights about use of the Services
• for internal research and development purposes and to improve, test and enhance the features and functions of our Services
• to provide you with marketing as permitted by law
• to meet our internal and external audit requirements, including our information security obligations (and if your employer or our subscriber provides for your access to our Services, to meet their internal and external audit requirements)
• for regulatory reporting, oversight and co-operation
• to enforce our terms and conditions
• to protect our rights, privacy, safety, networks, systems and property, or those of other persons including, without limitation, verifying identity at our premises (e.g. collecting a personal identification document and related information) and monitoring our premises for safety and security (e.g. CCTV) purposes
• for the (i) onboarding of, and management of relationships with, clients/customers, vendors/service providers, business partners, professional advisors and/or any other counterparties; (ii) negotiation and finalisation of, and/or participation in, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) or any similar transaction(s); and (iii) appointment and periodic review of any individuals in ownership, shareholder, member, manager, director, officer and/or any other executive-level positions, roles, or capacities for or with companies within the LSEG group of companies and in connection with the matters covered in (i) – (iii) immediately above, to carry out any background and screening checks (including screening checks performed using our World-Check product). For the Privacy Statement for LSEG World-Check, please click here
• for the prevention, detection or investigation of a crime or other breach of law or requirement, loss prevention or fraud
• to build, update, supplement and manage content databases made available to our customers in connection with our Services
• to comply with requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, including where they are outside your country of residence
• in order to exercise our rights, and to defend ourselves from claims and to comply with laws and regulations that apply to us or third parties with whom we work

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 the Privacy Office.

Honouring your marketing preferences is important to us. You have the right to opt out of receiving direct marketing and targeted online advertising.

We use tools and technologies to deliver or display targeted marketing and advertising content on or through our Services, which may involve the use of cookies and related technologies, the tracking of IP addresses and/or assigning and tracking unique identification numbers.

We also may engage in marketing and advertising activities through chat or messenger functionality available through our Services.

We use email tracking technology including, without limitation, dynamic links and image files, when we send you marketing communications to review your engagement and the effectiveness and relevance of the communications.

We use tools and technologies to distinguish known and unknown users of our Services and to record, review, track and analyse engagement and use of our Services (e.g. recording or tracking hovers, clicks, key word searches, personal information entered into forms, etc.).

We may also engage in marketing activities on third-party platforms, including, without limitation, social media platforms; however, such activities are subject to the privacy statements and terms and conditions applicable to such third-party platforms.

How to opt out of marketing 

Where we engage in direct marketing activities, including, without limitation, direct marketing via email, post, and telephone/mobile phone, we provide individuals the ability to opt-out or unsubscribe from such marketing activities. You can use the “Contact Us” feature of a particular Service, you can use the specific opt-out or unsubscribe mechanisms made available to you in connection with a specific type of marketing communication, you can discuss with your LSEG contact, or by contacting the Privacy Office. As an example, for email marketing activities, we provide several opt-out or unsubscribe options including, without limitation, via the opt-out/unsubscribe options in emails, through our email marketing preference centre, or through contacting the Privacy Office. 

Even if you opt out of receiving marketing communications, we may still send you service communications or important transactional information related to your accounts, subscriptions and applicable products (for purposes such as providing customer support).

Interest-based advertising

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, you can visit the Internet Advertising Bureau here. 

Opting out of IBA

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 customised to you. You can exercise your online advertising choices here 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. You may also go to the Digital Advertising Alliance ("DAA") Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. If you delete cookies, use a different device, or change web browsers, you may need to opt out again.

Advertising on mobile devices

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 your information for the purposes set out in this Statement, with the following categories of recipients:

• LSEG group of companies to be used as described in this Statement
• the person providing your access to our Services (e.g. your employer or our subscriber)
• business partners with whom we deliver co-branded Services; business partners with whom we engage in product or service co-selling activities; business partners with whom we provide content, or to host events, conferences and seminars
• third parties that help us deliver Services or act on our behalf (e.g. vendors, service providers, subcontractors, processors)
• our customers who are purchasing or using our Services or the service providers or vendors of our customers for the purpose of facilitating our customers’ use of our Services
• third parties where we have a duty to or are permitted to disclose your personal information by law (e.g. government agencies, law enforcement, courts and other public authorities)
• third parties in order to participate in, or be the subject of, any sale, merger, acquisition, restructure, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings) or other similar transaction(s), in which case we may disclose your personal data to prospective buyers, sellers, advisers or partners and your data may be a transferred asset in a business sale
• third parties where reasonably required to protect our rights, users, systems and Services (e.g. legal counsel and information security professionals)
• any person you have asked us to share information with (e.g. if you upload information into a public forum it is shared publicly)

LSEG 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 LSEG 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 data protection regulators/supervisory authorities, including, without limitation, the UK and the European Commission. 

The areas in which these recipients are located will vary from time to time, but include the United States, Europe, Canada, Australia, Asia (including India, Sri Lanka and Malaysia), and all other countries where LSEG has a business presence.

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 the Privacy Office.

We have in place a global cyber information security team, led by our Chief Information Security Officer, which is responsible for implementing secure data handling practices at LSEG.

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. While we use reasonable means to protect your security as described above, data transmission over the internet cannot always be guaranteed to be one hundred percent (100%) secure. We cannot and do not warrant the security of any personal information you transmit, and all such transmissions are done at your own risk.

LSEG has a Records and Information Governance team that works in conjunction with the Privacy Office to implement policies and rules relating to the retention of personal information. We have a records retention process 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:

• the length of time necessary to fulfil the purposes we collected it for
• when you or your employer (or other subscriber providing for your access to our Services) cease to use our Services
• the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations
• any limitation periods within which claims might be made
• any retention periods prescribed by law or recommended by regulators, professional bodies or associations
• the existence of any relevant proceedings

We will honour your rights under applicable data protection laws. You have the following rights under UK and European laws, and may have similar rights under the laws of other countries.

• Right of subject access: The right to make a written request for details of your personal information and a copy of that personal information
• Right to rectification: The right to have inaccurate information about you corrected or removed
• Right to erasure (“right to be forgotten”): The right to have certain personal information about you erased
• Right to restriction of processing: The right to request that your personal information is only used for restricted purposes where:
  • the accuracy of personal information is contested;
  • the processing is unlawful, but you object to the erasure of the personal information; or
  • we no longer require the personal information, but it is still required for the establishment, exercise, or defence of a legal claim.
• Right to opt out of marketing: The right to request that you not receive marketing communications from us, which can be for a specific type of marketing communication or for all marketing communications
• Right to object: The right to object to processing of your personal information in cases where our processing is based on the performance of a task carried out in the public interest or we have let you know the processing is necessary for our or a third-party’s legitimate interests
• Right to data portability: The right to ask for the personal information you have made available to us to be transferred to you or a third-party in machine-readable format
• Right to withdraw consent: The right to withdraw any consent you have previously given us to handle your personal information. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information prior to the withdrawal of your consent

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 visit this site.

South Africa – Access to Information

LSEG have established processes and procedures to allow appropriate data subjects to exercise their rights under South Africa’s Protection of Personal Information Act. If you wish to exercise your rights, please visit here. For more information on our processes and procedures, and your rights, you can visit our Promotion of Access to Information Manual.

Brazil privacy rights

For information and disclosures applicable to data subjects covered under the Lei Geral de Proteção de Dados, please visit here.

California privacy rights

The California Consumer Privacy Notice supplements this Statement and applies solely to California consumers.

1. LSEG World-Check: This Statement does not cover or address the information contained in, and the data processing activities associated with, our World-Check product. To access the Privacy Statement for LSEG World-Check please click here.
2. LSEG Enhanced Due Diligence (“EDD”): EDD is a detailed integrity and advanced background checks service that provides information to assist organisations identify and protect against any regulatory and/or reputational risks that might arise in connection with entering into relationships and/or transactions with individuals and/or entities. The information processed in connection with EDD may involve both personal information provided to us by a customer who is engaging us to conduct a search or check through EDD (e.g. passport information, resumes/CVs, etc.) and information sourced by us from various public data sources. LSEG’s processing of information provided or supplied to us by a customer is done so with LSEG in the role or capacity of a processor (or other similar term) and therefore such processing activities are not subject to this Statement. LSEG’s processing of information sourced through public sources is done so with LSEG in the role or capacity of a controller (or other similar term) and such processing activities are subject to this Statement. EDD is to be used for internal compliance purposes in connection with a customer’s legal or regulatory obligations connected to preventing or detecting unlawful acts and malpractice (such as money laundering, terrorism, fraud and modern slavery).
   

For more information about how your bank, counterparty or finance or risk professional handles your personal information, please contact them directly.

Data Content Products

In connection with our Services, LSEG builds, supplements and manages various content databases, which include personal information of or about certain data subjects (e.g. officers and directors; ownership and shareholders; investment professionals; research analysts). The information contained in these databases are collected from various sources, including, without limitation, from public sources (e.g. corporate websites), approved financial publications, from data subjects, from government records or databases (e.g. U.S. Securities and Exchange Commission, Companies House in the U.K.), and from third parties (e.g. business partners, colleagues of the data subject). We build and manage these content databases to provide a directory service to users of the content and the users of the content are solely responsible for ensuring that they process the content in accordance with applicable data protection, privacy and marketing laws.

The personal information available in the content databases may be used for several purposes including, without limitation, conducting research and performing due diligence activities, engaging in contact mapping, verifying existing contact information, and facilitating discussions or communications regarding business opportunities.

The sources from which the personal information may be received or collected are responsible for their own compliance with applicable data protection/privacy laws and for ensuring the accuracy and completeness of the personal information maintained by such third parties or persons.

If you have any enquiries or wish to exercise your rights under data protection and privacy laws or would like to make further inquiries about how personal information is used within a specific Service, please contact the Privacy Office.

Cookies

Please also refer to our Cookie Statement for details on how we collect, use, or disclose information in respect of cookies.