Privacy Policy
LAST UPDATED: March 4, 2011
This Privacy Policy explains how we collect your personal data on Moody’s Economy.com web site and the Moody’s Economy.com network of web sites that post or link directly to this Privacy Policy, including FreeLunch.com, Dismal Scientist and Consumer Flow (collectively, the “Site”), how we protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. Moody’s may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was most recently revised.
For the purposes of this Privacy Policy, “Moody’s”, “we”, “us”, and “our” means Moody’s Analytics, Inc.
We note that Moody’s adheres to EU/U.S. Safe Harbor principles with respect to data transferred from the European Union including privacy principles of notice, choice, onward transfer, security, data integrity, access and enforcement. More information about the Safe Harbor program can be found at http://www.export.gov/safeharbor.
This Privacy Policy applies only to personal data that is (a) collected by us through the Site or (b) included within customer lists that may be acquired by us from third parties. Other than with respect to item (b) of the preceding sentence, this Privacy Policy does not apply to our offline collection of personal data.
We may make available through the Site message boards, forums, chat functionality, blogs and other publicly accessible forums to which you may be able to post information and materials. We are not responsible for the privacy of any information you reveal or post in any such public forum (e.g., message board or chat room), or for the privacy practices of web sites that are operated or owned by third parties. We urge you to exercise discretion and caution when deciding to disclose Personal Data, or any other information, on the Site. WE ARE NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL DATA THAT YOU VOLUNTARILY DISCLOSE THROUGH THE SITES.
Types of Data Collected
We gather three basic types of information: Personal Data, Monitoring Data and IP Addresses. Collection of Personal Data
Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number (“Personal Data”). Moody’s requests Personal Data from you when you register on the Site. The registration process requests that you provide your name, business email address, business address, business phone number, and company affiliation, and agree to the Terms of Use presented at the time of registration. In addition to information collected during registration, Moody’s may collect Personal Data voluntarily provided by you, including in emails to the Site, online forms, order, subscription and registration forms, surveys, and promotion participation. In addition, in connection with the Site, you may be able to maintain profiles that you may customize to contain financial information in which you have a special interest. Providing this information is always at your option. If you provide such information, you will be required to select a username and a password. To be useful, this information must be stored on the Site, and is accessible to any site visitor who knows your username and password. For this reason, please safeguard your username and password carefully and do not disclose it to any other person.
We may use third-party payment services (each, a “Payment Service”) to collect payments made through the Site. If you wish to make a payment through the Site, you may be directed to a webpage that is hosted by the Payment Service (or the Payment Service's service providers) and not by Moody’s (such page, the “Payment Service Page”). Any Personal Data that you provide through the Payment Service Page may be collected by Payment Service as well as by Moody’s; we note that any such collection and subsequent use of Personal Data by Payment Service will be subject to Payment Service’s privacy policy, while our collection and use of such Personal Data will be subject to this Privacy Policy. Moody’s has no control over, and shall not be responsible for, Payment Service's use of information collected through the Payment Service Page. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE COLLECTION AND USE OF INFORMATION BY PAYMENT SERVICE THROUGH THE PAYMENT SERVICE PAGE OR THE PRIVACY OR INFORMATION PRACTICES OF PAYMENT SERVICE.
You do not have to provide us with any Personal Data to visit the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site.
As noted above, this Privacy Policy does not address our offline collection of information, with the exception of Personal Data included on customer lists that may be acquired by us from third parties. In that regard, we note that, from time to time, we may acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services. If we acquire such a list for promotional purposes, we seek to obtain appropriate representations from the other party that the listed individuals have opted into receiving promotional messages from any acquirer of such list.
If you use the Email a Colleague feature, we will ask for a name and email address of your colleague for the purpose of sending an email message. We ask for this information for the sole purpose of sending a one-time email message. Please note that this referral service should only be used for individuals in their business or professional capacities – it should not be used for personal contacts. Before you pass onto us the email address of any individual, you should be satisfied that your colleague consents to being contacted in this way.
Collection of Monitoring Data and Use of Certain Online Tools
In addition to Personal Data, Moody’s and its service providers may collect and/or track information that by itself cannot be used to identify or contact you, e.g., demographic information, domain names, computer type, browser types, screen resolution, and other anonymous statistical data involving the use of the Site (“Monitoring Data”). We use Monitoring Data to help us understand who uses the Site and to improve and market it and Moody’s other web sites.
Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user. Additionally, we may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information is considered Monitoring Data for purposes of this Privacy Policy.
To enhance the Internet experience on the Site, Moody’s and our service providers may use ‘cookies’ on the Site. Cookies are data that a web server transfers to an individual’s computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users’ ongoing access to and use of our Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site, to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about the procedure you are required to follow in order to disable cookies can be found on your Internet browser provider’s web site. We expect our service providers to honor any decision by you to block or disable cookies in connection with the Site.
We and our service providers may also use various common Internet tools such as ‘pixel tags,’ ‘action tags,’ ‘web beacons,’ ‘.gif tags,’ ‘JavaScript’ or similar technologies (together, “Tools”) in connection with Site pages and email messages in certain formats to among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Sites, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened.
Moody’s uses these technologies to understand how the Site is used and to customize and enhance the Internet experience of individual users. When you revisit the Site, Moody’s may recognize you by a Tool and customize your experience accordingly. For example, once you have completed the registration process, a cookie and/or Tool will be used to avoid having you register again. We believe cookies and Tool technologies add value to the user experience, and the information resulting from these technologies is not sold or otherwise made available by Moody’s to third parties for such third parties’ marketing purposes. We similarly expect our service providers to do the same.
Collection of IP Addresses
When you visit and interact with the Site, we and third parties with whom we have contracted to provide services to us may collect IP Addresses. Your Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Sites, along with the time(s) of your visit(s) and the page(s) that you visited. Where required by applicable law, this log information may be treated as Personal Data.
Use of Data Collected
Use of Personal Data Collected
Fulfillment of Requests. Moody’s may use Personal Data about you to fulfill the purpose for which such Personal Data was provided (e.g., to send newsletters to you, to process payments or to deliver products and services).
Other Communications. From time to time, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If you would prefer that we do not send electronic marketing messages to you, please see the “Your Choices” section below.
Promotions. We may operate sweepstakes, contests and similar promotions (collectively, “Promotions”). We typically ask you for certain Personal Data when you enter and, if applicable, win a Promotion. You should carefully review the rules, if any, of each Promotion in which you participate, as they may contain additional important information about our use of Personal Data about you. Consistent with our Safe Harbor obligations, to the extent that the terms and conditions of such rules concerning the treatment of Personal Data about you conflict with this Policy, the terms and conditions of such rules shall control.
Internal Business Purposes. We may also use Personal Data about you for our internal business purposes, such as data analysis, editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site or other web sites, completing business transactions, marketing & promotion, statistical analysis of user behavior, product development, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits and so forth.
Administrative Communications. In addition, Moody’s reserves the right to use Personal Data to send to you important information regarding the Site, your account status and changes to the Terms of Use, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of the Site. Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.
Use of Monitoring Data Collected
Monitoring Data may be used for internal or external purposes such as researching and identifying market segments and needs. Because Monitoring Data does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share Monitoring Data with affiliated entities and other third parties, for any purpose.
In some instances, we may combine Monitoring Data with Personal Data (such as combining your name with your geographic location). If we do combine Monitoring Data with Personal Data, the combined information will be treated by us as Personal Data as long as it is so combined.
Disclosure of Personal Data Collected
Third Party Service Providers. We work with content partners and third parties who provide services including but not limited to data analysis, payment processing, order fulfillment and other services of an administrative nature. We reserve the right to share Personal Data about you with such content partners and third parties for the purpose of enabling these third parties to provide such services in a manner consistent with our Safe Harbor obligations.
Affiliate Communications. Moody’s reserves the right to transfer Personal Data among our affiliates (the details of which can be found on the www.moodys.com web site) to allow our affiliates to contact you regarding products, programs, services and promotions that they believe may be of interest to you. Our representatives in France, Germany, Italy and Spain are Moody’s France SAS, Moody’s Deutschland GmbH, Moody’s Italia, S.r.l. and Moody’s España S.A. respectively (contact information for Moody’s Investors Service, Inc. and for each representative can be found at the www.moodys.com web site). If you would prefer not to receive marketing communications from Moody’s or our affiliates, please see the “Your Choices” section below.
Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with Moody’s to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded sites (“co-branded pages”). Any information, including Personal Data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners. By selecting an application or providing your information on these co-branded pages, or by signing up to receive information about or download a Jointly Offered Item, you also consent to our providing Personal Data about you to those third parties. However, please note that as third parties generally use Personal Data about you in accordance with their own privacy practices, you should check these third parties’ web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES; NOR DOES IT ADDRESS OUR PRACTICES WITH RESPECT TO ANY OF OUR SITES OTHER THAN THE SITE. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or pages that are co-branded with third parties.
Promotions. We reserve the right to share the Personal Data that you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to such Promotion. You should carefully review the rules, if any, of each Promotion in which you participate, as they may contain additional important information about a sponsor's or other third parties’ use of Personal Data about you. Consistent with our Safe Harbor obligations, to the extent that the terms and conditions of such rules concerning the treatment of Personal Data about you conflict with this Policy, the terms and conditions of such rules shall control.
Organizational Subscribers. Where an organization subscribes to our products through the Site, we may share aggregated and detailed account usage information for that organization’s named user accounts with the main customer contract for that organization. This information aids the subscribing organization in determining the appropriate number of user accounts, allocations of products, and overall utility of those products. Thus, your use of the Site may be shared with your employer. Additionally, information associated with your profile may be shared with other users from your organization.
Assignment. We reserve the right to transfer any and all information that we collect to an affiliated entity or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
Law enforcement; emergencies; compliance. Notwithstanding any other provision of this Privacy Policy to the contrary, we reserve the right to disclose Personal Data about you to others as we believe to be appropriate (a) under applicable law; (b) to comply with legal process; (c) to respond to governmental requests; (d) to enforce our Terms of Service; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety or property of Moody’s, the affiliated entities, you or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
Your Choices Regarding Personal Data Collection and Use
You may “opt-in” to having your Personal Data used by Moody’s to send promotional correspondence to you now by checking the appropriate box on the Registration Form, or at any time in the future by changing your User Profile, or by contacting Moody’s via postal mail, e-mail, or telephone using the contact information below. If you decide later that you no longer would like to receive promotional correspondence from us, you may indicate that preference by contacting us via postal mail, e-mail or telephone using the contact information below or by un-checking the appropriate box on your Site profile at any time.
To the extent the laws of your country entitle you to review, modify, correct, change, update, block (so that Moody’s continues to hold your Personal Data but temporarily refrains from processing it), remove or anonymize Personal Data about you that Moody’s has collected, you may exercise this right by logging onto Economy.com, clicking on “My Economy” and then going to the “Edit Profile” link or by making a request via postal mail, e-mail or telephone using the contact information below. However, such requests may require you to register again in the event you later wish to access the Site. Where the laws of your country require it, you may ask Moody’s to certify that it has notified the entities to whom your Personal Data has been transferred of any such changes to or removal of your Personal Data. We may need to verify your identity before implementing your request. We will endeavor to comply with your request as soon as reasonably practicable, and in any event within thirty (30) days of reception. We may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which will not be removed. We are not responsible for removing or suppressing information from the databases of third parties with whom we have already shared Personal Data about you.
Links
The Site may contain links to other Internet web sites. These linked sites are not under Moody’s control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and Moody’s does not endorse, and is not responsible for, the privacy practices or the content of these web sites. If you provide any Personal Data through any such third-party web site, your transaction will occur on such third party's web site (not the Site) and the Personal Data you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES OR SITES THAT DO NOT POST OR LINK DIRECTLY TO THIS PRIVACY POLICY.
Security Measures
Moody's has 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 may include use of firewall protection and encryption technology where Moody’s deems such measures are appropriate. We use SSL encryption to protect financial information when you are connected to the Site.
Please note that while Moody’s has endeavored to create a secure and reliable site for users, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Site or that is stored by us. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by contacting us in accordance with the Section entitled “Contact Information for Moody’s”) below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).
Data Integrity
Moody’s will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. Moody’s will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you), but Moody’s must depend on you to update or correct your Personal Data whenever necessary.
Retention Period
We will retain Personal Data about you for the period reasonably necessary to fulfill the purposes outlined in this Policy and consistent with retention periods required by law and/or regulation.
Export of Personal Data
You acknowledge and consent to the fact that Personal Data provided by you or collected by us may be stored and processed by us in the United States which may provide a different level of data security than in your country of residence. You also acknowledge and consent to the fact that we may, at our discretion, store and process such data in other countries and we will endeavor to protect the Personal Data under our control wherever it is processed or stored.
Enforcement
Moody’s periodically will review its compliance with this Privacy Policy. Moody’s will also review and respond to any formal written complaints that we received from you. Moody’s will cooperate with the appropriate regulatory authorities, including the European Union data protection authorities, to resolve any complaints that cannot be resolved between us.
Children’s Online Privacy Protection
The safety of children is important to us. The Site is a general audience site and is not directed to children under the age of 13. Similarly, services available on or through the Site are not directed to nor intended for anyone under the age of 13. We will not knowingly accept, collect or maintain Personal Data from or about anyone under the age of 13 years. If you believe we have any information from or about anyone under age 13, please contact us at privacy@moodys.com.
Contact Information for Moody’s
Questions or concerns regarding Moody's data protection practices should be addressed to:
Legal Department
Moody’s Analytics, Inc.
7 World Trade Center at 250 Greenwich Street
New York, NY 10007
Phone: +1-212-553-1653
E-mail: privacy@moodys.com
If you choose to contact Moody’s via e-mail about this policy, please mark the subject heading of your e-mail “Privacy Enquiry.”
We shall keep a copy of this Privacy Policy and if, at any time, you would like to see a copy of it, you should write to the address above.
