Version 2.1 - June 28, 2019
Last Updated: June 28, 2019
The Digital Services, including the articles, reports, solutions, training and other products and services made available through the Digital Services (collectively, the “Materials”), are made available for informational and research purposes and are intended for users acting in a professional capacity. Please note that access to certain Digital Services may require a subscription, such as to the Fitch Connect premium service, and may be subject to additional terms.
What Information We Obtain
Information you provide or that we collect directly from you when you use the Digital Services, including when you create an account, complete a form or subscribe to a mailing list. This may include your contact or demographic information.
Certain Digital Services or Materials may require a payment for access. We use payment information for the limited purposes of processing your transaction, providing you with the requested service or information and to protect our rights or the rights of others.
Information you provide us about others, such as the name and email of a contact with whom you want to share the Materials or the name, job title and contact information of a member of staff for whom you are purchasing a training.
Information collected by automated means such as cookies or similar tools. This may include information about your device and browser, including IP address or mobile device advertising identifiers, as well as information about how you and others use, interact with or respond to the Digital Services. This collection may take place while you are using a Digital Service or while the Digital Service is running in the background of your device.
Information we obtain from other sources, such as event organizers, data suppliers, business partners and social media platforms.
How We Use Information We Obtain
To process your requests and provide you with the Digital Services, including to customize and improve the Digital Services or Materials and provide recommendations.
To learn about users of the Digital Services and Materials and analyze how you and others interact with and respond to the Digital Services.
To communicate with you, including to send you marketing and promotional communications.
For our advertising and marketing purposes.
To protect our rights and the rights of others.
How We Share Information
Within the Fitch family of companies.
With service providers that perform services or handle transactions on our behalf.
With respect to corporate subscriptions, memberships and/or other services, with the organization that purchased the services, subscription, and/or membership.
With business partners.
Where applicable, with professional teaching, education, and/or examining bodies.
Other parties when required by law or as necessary to protect our rights, and in the context of corporate transactions.
With your consent or otherwise at your direction.
Your Choices, Including Opt-Outs
You may take steps to limit the use of your information for interest-based advertising on your browser or mobile device. See https://www.fitch.group/cookie-policy for more information.
You may unsubscribe from our marketing or promotional emails by clicking the “Unsubscribe” link in our emails, or for certain Digital Services, by logging into your account and adjusting your preferences.
We use a variety of security technologies and procedures to help protect information from unauthorized access, use or disclosure.
Fitch operates the Digital Services globally, including from the United States. Information may be processed and stored in the United States or other countries
The Digital Services are not intended for use by children under the age of 13.
Last Updated: March 29, 2019
What Information We Obtain
How We Use Information We Obtain
How We Share Information
Your Choices, Including Opt-Outs
Additional Information for California Residents and Journalists
How We Protect Your Information
Children’s Privacy Rights
Third-Party Websites, Mobile Apps or Other Services
Please note that access to certain Digital Services may require a subscription, such as to the Fitch Connect premium service, and may be subject to additional terms. Note that different types of data may be obtained depending on the Digital Service or Materials you interact with (e.g., Fitch may obtain information relating to your qualifications and credentials when you apply for a certification through a Fitch Learning Digital Service). Where the practices for a certain Digital Service differ from the general practices, this is called out specifically.
2. WHAT INFORMATION WE OBTAIN
When you use a Digital Service, we obtain various types of information related to you and your use of the Digital Service or Materials. This data includes information that directly identifies you such as your name, job title, or contact information as well as information such as online identifiers or cookie-level data that may indirectly identify you. The information we obtain generally consists of information (1) you provide us about yourself or that we directly collect from you, (2) you provide us about others, (3) automatically collected about your interactions with the Digital Services or Materials, and (4) we get from other sources as described further below.
A. Information we obtain directly from you
Fitch asks you to provide information about yourself when you use the Digital Services, including when you create an account, complete a form or subscribe to a mailing list. You may not be able to use certain features if you choose not to submit the requested information.
The information you provide us or that we directly obtain from you includes details such as:
Contact information (e.g., your name, email address, job title, company name).
Demographic and interests information (e.g., region, industry sector, preferred language, topics of interest).
Payment information for purchases made through the Digital Services (e.g., payment card number, expiration date and billing information). This information is used for the limited purposes of processing your transaction, providing you with the Materials and to protect our rights or the rights of others.
Information you choose to share with us (e.g., when you submit an inquiry through an online form on a Digital Service).
Transactional and activity information (e.g., requests, searches or orders).
If you apply for a course administered by Fitch Learning, we may request further details from you. This information is used for purposes of assessing your qualification for the course and may include:
Educational background and work experience.
Date of birth.
Information provided by you in your personal statement and other information you choose to share with us in support of your application for the course.
B. Information you provide about others
C. Information automatically collected
The information automatically collected includes the following:
Information about your computer, device, browser and operating system (e.g., type, model, or version).
Internet protocol (IP) address, which is used to derive your general geographic area (e.g., city and country).
Information about your interactions with the Digital Services, including browsing activities and clickstream data that reflect the Materials you have accessed, clicked on, or viewed.
Information about how you accessed the Digital Services, including details about websites or apps visited immediately before or after accessing a Digital Service.
Demographic and interests information (e.g., region, industry sector, preferred language, topics of interest).
Information about your interactions with email messages and other communications, such as whether you opened or forwarded the email or clicked on links contained in the email.
D. Information we obtain from other sources
Fitch receives information about you from other sources which may be combined with information obtained about you as a result of your interactions with the Digital Services or Materials. For example, we obtain data from:
Organizers of industry events. We obtain information from organizers of events and conferences you attend subject to the sharing practices of the relevant event organizers.
Third-party data suppliers such as data aggregators, data resellers, public databases and business partners. These suppliers provide us with demographic information, information about your organization, and other information that helps us learn about you and other users of the Digital Services.
Your organization or other individuals at your organization if you are authorized to access a Digital Services and/or Materials via a corporate account.
Operators of third-party sites, platforms or other devices and technologies when you interact with the Materials on those channels and platforms.
Social Media Platforms and similar services (“Social Media Platforms”). We obtain information from Social Media Platforms such as LinkedIn, which may include your username, user ID, demographic information and other information, subject to the settings and privacy practices of the relevant Social Media Platform.
The categories of information that we collect about you from other sources are your personal details (for example your name and date of birth) and your contact details (such as your phone number, email address, postal address or mobile number).
3. HOW WE USE INFORMATION WE OBTAIN
Fitch uses the information we obtain:
A. To provide you with the Digital Services. This service includes:
Processing your requests regarding the Digital Services and the Materials.
Providing customer assistance or technical support.
Customizing the Digital Services and Materials, providing recommendations and enhancing the quality and your overall experience with the Digital Services, including by retaining your user preferences or optimizing the presentation of the Digital Services and Materials based on your industry or interests and for the browser or device you use to access the Digital Services.
Maintaining, operating, improving and developing the Digital Services, Materials and other Fitch products and services.
Learning about users of the Digital Services and analyzing how you and others interact with and respond to the Digital Services and Materials, including by measuring and optimizing usage, reliability and performance, conducting market research, performing analytics, and supporting our operations (e.g., for accounting, auditing, financial, legal or other purposes).
B. To communicate with you. This activity includes:
Sending you Materials you have requested or which we believe are of interest to you.
Sending you informational messages about the Digital Services (e.g., to confirm your access to the relevant Materials or notify you of changes to a Digital Service).
Delivering marketing or promotional communications.
Responding to your questions or addressing your requests.
Providing you with surveys regarding the Digital Services.
C. For advertising and marketing purposes, including interest-based advertising. This activity includes:
Developing, managing and conducting advertising and marketing campaigns, promotions and offers, including about the Digital Services, Materials and other Fitch products, services or initiatives.
Cross-device linking. If you access the Digital Services from multiple browsers or devices, we, our service providers and third parties may try to establish connections among and link the different browsers and devices you use to access the Digital Services. This helps us provide you with a seamless experience across the browsers and devices you use and serve you with the relevant Materials.
Interest-based advertising (also known as targeted or personalized advertising or ads) is advertising based on your interests as inferred from your activities over time on the Digital Services and online services operated by third parties, as well as other information. Interest-based ads consist of text ads, images, animations or videos and are displayed to you based on various factors, including the context of the site or app in which they appear (e.g., sport or travel section), information you provided to the operator of the site or app (e.g., when you created an account), your activities on the site or app (e.g., pages viewed, searches performed or ads clicked), and information such as your demographic, interests and household information.
We use online and offline information we obtain about you, including your personal information, for interest-based advertising purposes. We aggregate the information we obtain to create audiences that are most likely to respond to ads based on demographic, interests or household information.
Interest-based ads may be displayed to you by third parties, such as ad networks or exchanges.
D. To protect our rights or the rights of others. This protection includes:
Performing audits, assessments and testing or troubleshooting activities.
Backing up our systems (including for disaster recovery purposes) and enhancing the overall security of the Digital Services.
Complying with and enforcing applicable legal requirements (including legal process such as court orders, warrants, regulatory investigations, or subpoenas) and/or fulfilling contractual obligations.
LEGAL BASIS FOR USING THE INFORMATION
We must have a legal basis to process your personal information. The legal basis will be one of the following:
To honor our contractual obligations to you when we use your information to provide you with the Digital Services or to provide access or a subscription to Materials. For example, when you purchase a subscription from us, it will be necessary to process your payment details and contact details to confirm and provide the subscription. Similarly, when you sign up for a mobile app, we will need to process your registration information so that we can set up your user account and provide the relevant services to you. Failure to provide the information could prevent or delay the fulfilment of the contractual obligations.
To comply with our legal obligations when we use your information to protect our rights or the rights of others and when we share your information with other parties where required by law or as necessary to protect our rights. We are required to collect certain information from you when processing your subscription payment for tax or financial reporting reasons. Similarly, local tax law will often require us to keep information about contest or promotion participants for audit and taxation purposes.
To meet our legitimate interests when we use your information to provide you with the Digital Services, to communicate with you and for advertising and marketing purposes, including interest-based advertising or when we share your information with our affiliates and subsidiaries, in the context of a corporate transaction or with our business partners, social media platforms and advertisers. Our legitimate interests include improving the Digital Services, our products and services, understanding how you interact with our Digital Services and publications, deriving knowledge to develop new products and services, and customizing the Digital Services by making them more relevant and interesting to you and others. When we process personal information to meet our legitimate interests, we put in place safeguards to help ensure that your privacy is given due regard.
5. YOUR CHOICES, INCLUDING OPT-OUTS
Direct Marketing Opt-Outs
You may opt out of receiving marketing or promotional emails from us by clicking on the “unsubscribe” or “Preference Center” links contained in such emails. Depending on the Digital Service you use, you may also be able to opt out of marketing or promotional emails by logging into your account and managing your email preferences. Please keep in mind that if you opt out of receiving marketing or promotional emails we will still send you transactional emails or other communications relating to your use of the Digital Services or Materials (e.g., to confirm your access to the relevant Materials, to inform you of changes to a Digital Service or in response to your password recovery request). You may request that we stop sending you direct mail marketing communications by notifying by email at firstname.lastname@example.org
6. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS AND JOURNALISTS
Do Not Track
Fitch does not currently take steps to respond to browsers “Do Not Track” signals as no uniform standard to respond to such signals has been developed at this time.
Fitch receives information about you from third-party media database providers. These suppliers provide us with information including your contact details, business organization and coverage beat(s) so that we can send you Fitch content that reflects your interests.
7. HOW WE PROTECT AND STORE YOUR INFORMATION
Fitch uses a variety of security technologies and procedures to help protect information from unauthorized access, use or disclosure. However, please be aware that no security measure is perfect or impenetrable. Therefore, while we make reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If you register an account on the Digital Services, you are responsible for keeping your password secure. Do not share your login credentials with others.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:
Maintain business records for analysis, understanding market trends and/or audit purposes and to improve our Digital Services.
Comply with record retention requirements under applicable laws or other relevant legal or regulatory requirements.
Defend, establish, exercise or bring any existing or potential legal claims.
Carry out fraud detection and prevention.
Deal with any complaints regarding the Digital Services, our products and services.
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
8. INTERNATIONAL DATA TRANSFER
Fitch operates the Digital Services globally, including in the United States. Any information we obtain about you in connection with your use of the Digital Services may be processed and stored in the United States or other countries. The laws of these countries may not provide the same level protection for your personal information as your home country.
When Fitch transfers your personal information from the European Economic Area (EEA), United Kingdom or Switzerland to a non-EEA country, we rely on one or more of the following legal mechanisms: Standard Contractual Clauses, or your consent.
For more information about the safeguards we use, please contact us via the details listed at the end of this Notice.
9. CHILDREN’S PRIVACY RIGHTS
The Digital Services are not intended for use by children, especially those under the age of 13, and we do not knowingly collect personal information from children under the age of 13.
10. THIRD-PARTY WEBSITES, MOBILE APPS OR OTHER SERVICES
We are not responsible for the privacy practices of any non-Fitch operated websites, mobile apps or other services and channels, and we encourage you to review the privacy policies or notices published by relevant third parties.
11. DISPUTE RESOLUTION
13. CONTACT US
The Fitch entity responsible for the Digital Services you are using or accessing is the controller responsible for the personal information we collect and process in relation to that Digital Service. The relevant controllers and the Digital Services they provide are listed below, along with their contact details.
|Division||Digital Service||Contact Details|
|Fitch Ratings, Inc.||email@example.com|
|Fitch Solutions, Inc.||firstname.lastname@example.org|
|Fitch Learning Ltd.||email@example.com|
|Fitch Learning Mobile|
|Fitch Learning Cognition|
|IMC: Are You Ready?|
|Business Monitor International Ltd.||firstname.lastname@example.org|
|Fitch (Hong Kong) Limitedemail@example.com|
|Fitch Australia PTY. Limitedfirstname.lastname@example.org|
|Fitch Centroamerica, S.A. (Guatemala)||email@example.com|
|Fitch Centroamerica, S.A. (Panama)||firstname.lastname@example.org|
|Fitch Chile Clasificadora de Riesgo Limitadaemail@example.com|
|Fitch Costa Rica Calificadora de Riesgo, S.A.||firstname.lastname@example.org|
|Fitch Deutschland GMBHemail@example.com|
|Fitch Holding S.A.||firstname.lastname@example.org|
|Fitch India Services Private Limitedemail@example.com|
|Fitch Italia S.P.A.||firstname.lastname@example.org|
|Fitch Mexico S.A. de C.V.||email@example.com|
|Fitch North Africa S.A. (Tunisia)||firstname.lastname@example.org|
|Fitch Polska S.A.||email@example.com|
|Fitch Ratings (Beijing) Limitedfirstname.lastname@example.org|
|Fitch Ratings (Thailand) Ltdemail@example.com|
|Fitch Ratings Brasil LTDAfirstname.lastname@example.org|
|Fitch Ratings CIS Limitedemail@example.com|
|Fitch Ratings Colombia S.A. Sociedad Calificadorda de Valoresfirstname.lastname@example.org|
|Fitch Ratings España, S.A.U.||email@example.com|
|Fitch Ratings Japan Limitedfirstname.lastname@example.org|
|Fitch Ratings Kredi Derecelendirme Hizmetleri A.S.||email@example.com|
|Fitch Ratings Lanka Limitedfirstname.lastname@example.org|
|Fitch Ratings Limitedemail@example.com|
|Fitch Ratings Singapore Pte Ltdfirstname.lastname@example.org|
|Fitch Republica Dominicana S.R.L.||email@example.com|
|Fitch Solutions Asia Pte Ltdfirstname.lastname@example.org|
|Fitch Solutions Deutschland GMBHemail@example.com|
|Fitch Solutions Limitedfirstname.lastname@example.org|
|Fitch Southern Africa (Pty) Limitedemail@example.com|
|Fitch Venezuela, Sociedad Calificadora de Riesgo, S.A.||firstname.lastname@example.org|
|FIX SCR SAemail@example.com|
|FIX SCR Uruguay Calificadora De Riesgo SAfirstname.lastname@example.org|
|Inter Arab Rating Company S.A.E.||email@example.com|
|PT Fitch Ratings Indonesiafirstname.lastname@example.org|