Product Specific – Additional Provisions

This Product-Specific Addendum provides specific supplemental information for certain products and services and supplements the Policy. In case of any inconsistencies between this Product-Specific Addendum and the rest of this Policy, this Product-Specific Addendum prevails.

451 Alliance Additional Privacy Terms

If you are a 451 Alliance member or apply for membership, we collect your personal data in the course of receiving your application for membership, administering your 451 Alliance Membership, making surveys and survey results available to you, and providing discounts and other opportunities through our partners.

Types of personal information	Why we collect it
Contact details such as name, telephone numbers (which may include cell/mobile numbers), email address and postal address and details of any correspondence between us.	To respond to your communications and inquiries.   To provide membership updates, support, information and alerts.   To contact you for information verification purposes.   To obtain your feedback regarding your Membership.   To deliver Member benefits to you.   To identify duplicate records in our member database.   To deliver invitations and reminders to participate in research, which sustains your free membership.
User credentials including name, email address, and password.	To set up and maintain your Member account.   To enable you to access the Members-only content on our platforms for your own purposes.   To enable you to log in to your account and update your information, delete it, or end your membership.   To identify duplicate records in our member database.
Employer and employment information such as job title, company affiliation, function, seniority, department and location of your office.	To maintain accurate firmographic data for research purposes.   To tailor research invitations to members based on qualification or relevance. To identify duplicate records in our member database.
Any personal demographic information you provide to us, such as details of your education, professional certifications, qualifications, birth year, and your gender.	To maintain accurate demographic data for research purposes.   To identify duplicate records in our member database.
Views, opinions and feedback that you choose to share with us via your comments, ratings, interviews, posts via our Site, and survey responses.	To better understand member satisfaction and optimize the member experience.   To collect accurate, first-hand data to aggregate and anonymize for analysis to determine larger trends.
Non-sensitive demographic data or firmographic data about you or your employer that is publicly available on the internet or on social media.   Non-confidential firmographic data or contact information may be provided by third parties.	To maintain accurate demographic and firmographic data for research purposes.   To identify duplicate records in our member database.
Indication of social media platform use and links to your publicly available social media profiles.	To maintain accurate demographic and firmographic data for research purposes.   To identify duplicate records in our member database.   To identify alternative means to perform member outreach if all other direct contact is unsuccessful.

For purposes of these 451 Alliance Additional Privacy Terms, the data controller of the personal information that we collect from you is: 451 Alliance, Attn: Privacy, 55 Water Street, New York, NY 10041. This means that we determine how and why the information we collect from or about you is used. If you have questions, please refer to the “How to contact us” section of this policy or contact our Data Protection Officer at Privacy@spglobal.com or 451 Alliance, c/o S&P Global, Inc., 55 Water Street, New York, NY 10041.

 

S&P Global keeps certain activities of its business units separate from each other in order to preserve the independence and objectivity of each of these activities. As a result, your participation and personal information collected when you apply for 451 Alliance membership or otherwise use www.451Alliance.com will never be shared with the S&P Global Ratings division. S&P Global has established policies and procedures to maintain the confidentiality of non-public information received in connection with this program. S&P Global does not share 451 Alliance membership Personal Information with third parties for their direct marketing purposes.

 

Entity Insights and Public KYC Privacy Addendum

This Addendum is intended to provide Beneficial Owners, Key Controllers, Directors, and Related Parties (together, “Associated Individuals”) information about how S&P Global processes personal information when providing Entity Insights services (“Entity Insights”) and KYC services (“KYC”) from publicly available sources as described below, respectively to our clients.

For the purpose of this Addendum:

“Beneficial Owner” means an individual identified within the ownership structure of an entity S&P Global is performing Entity Insights or KYC services on.

“Key Controller” “Director” or “Related Party” means an individual identified by S&P Global in the performance of Entity Insights or KYC services as appointed or elected to exercise direct control over an entity, by participating in the governance, strategic direction, or senior executive activities.

“Publicly available sources” means personal information (1) originally available to the public and typically over the internet; or (2) 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.

Who are we?

S&P Global is the Data Controller of your personal information. A “Data Controller” is the main decision maker in respect of data processing - this means we exercise overall control over the purposes and means when processing personal information.

Why we process personal information

S&P Global collects, processes, and shares personal information as part of providing our Entity Insights and KYC services to our clients, who use this information to verify the identity of persons and entities who may become their customers, vendors or counterparties and to meet their Anti-money laundering (“AML”) and counter terrorist financing (“CTF”) due diligence obligations and for other internal business purposes, including banking, onboarding, and other regulatory purposes.

What personal information we process

S&P Global collects personal information when providing Entity Insights and KYC services to our clients, including:

• Identifying information (e.g. name (first and last name), gender, date of birth, nationality)
• Professional or residential address
• Professional role/title
• Government identification information and personal identification numbers (e.g. passport details, driving license details, social security numbers)
• Publicly available data on sanctions, regulatory enforcement, or adverse media covering criminal data

Associated Individual information –

• Type of association
• Level of association
• Percentage of association

How we ensure our processing of personal information is lawful

S&P Global and the third parties we serve have a legitimate interest in processing the personal information provided through Entity Insights and KYC services. S&P Global clients have a legitimate interest in gaining access to high-quality and easily manageable data of the type we process in order to optimize their AML and CTF compliance requirements and protect the public from financial crime, fraud and serious misconduct S&P Global has a legitimate interest to reduce the societal cost of money laundering through the provision of cost-effective Entity Insights and KYC solutions. We aim to reduce the AML and CTF risks faced by our clients by providing effective products that assist our customers in establishing and maintaining systems and controls for countering the money laundering and terrorist financing efforts of criminals.

S&P Global has thoroughly assessed our legitimate interest, considered the potential impact on you (positive or negative) and your rights under data privacy laws, and will not use your personal information for activities where the impact on you overrides the legitimate interests we have in processing your personal information.

Where we process special or adverse criminal information, we will do so for reasons of substantial public interest, pursuant to applicable law.

Who do we share personal information with?

In addition to the description in the When does S&P Global Disclose my Personal Information? Section of this Policy, S&P Global discloses personal information to unaffiliated third-party clients who utilize Entity Insights or KYC services. These third-party clients are also data controllers when they process personal information. S&P Global enters into processing agreements with these third-party clients to ensure they only process personal information in accordance with the commitments we’ve set out in this Addendum.

Where do we source personal information from?

We compile a range of personal and non-personal ‘business’ information from various public sources, including websites, news sources, regulatory filings and official government watchlists, open government databases, exchanges, and public registries.

Kensho Additional Privacy Terms

These Kensho Additional Privacy Terms are intended to provide you with additional specific information about how we process your personal information when you use the Kensho Service. 

User-Provided Content: If you choose to provide us with or share content created by you (or created by a third party, and for which you have permission to post) (“User-Provided Content”), we may collect the information you post. We may use User-Provided Content that you post as described in the Kensho Website Terms of Use or Kensho Terms of Service as applicable. We may also retain User-Provided Content as necessary to resolve disputes, provide customer support and troubleshoot problems as permitted by law. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on a Service, we may collect such information into a file specific to you.

Sharing and Chat. Some Service features may allow you to share information available on the Service with others who may or may not be Service members. These features may require you to provide email addresses of your intended recipients. We will use these email addresses to email the requested information to the recipients you have chosen, and we may identify you in such emails as a Service user who requested that the information be shared with the recipient. Some of our Services include a chat or communication protocol to allow you to communicate with us or other users in real time. We may use the information you provide, including personal information, to provide you with a response to any inquiries, questions, or similar, as well as provide you with links and information to Services you request or inquire about.

 

Commodity Insights LIVE Privacy Statement

 

What is this Commodity Insights LIVE Privacy Statement about?

This Privacy Statement is intended to provide you with additional specific information about how we process your personal information when you use Commodity Insights LIVE. 

Please note that this Privacy Statement is intended to be additional to the rest of the S&P Global Privacy Policy, and should be read alongside the S&P Global Privacy Policy. With respect to Commodity Insights LIVE only, if there is any inconsistency between this Privacy Statement and the S&P Global Privacy Policy, then this Privacy Statement prevails.

What personal information does S&P Global collect during your use of Commodity Insights LIVE and why?

The personal data that we collect from or about you in the context of the Commodity Insights LIVE platform falls into the following categories:

Types of personal information	Why we collect it	Lawful grounds for processing
Personal information including name, email address, company name, job title, city, business phone, zip/ postal code, country of residence, and markets and commodities you are interested in.	To register for a Commodity Insights LIVE account and maintain your Commodity Insights LIVE account. To provide the Commodity Insights LIVE services to you, including where you register for events. To provide Commodity Insights LIVE service updates (e.g. if we update our Terms of Use or this Privacy Statement).	For our legitimate interests in registering users, administering user accounts, ensuring compliance with our Terms of Use, and providing the Commodity Insights LIVE platform to you. In certain jurisdictions, such as the People’s Republic of China (“PRC”), we process personal information only if we have obtained your consent or if such processing is necessary for us to perform our contract with you.
First and Last Name, Company, Country of Residence and IP address	To carry out compliance/ sanction checks on you prior to you successfully registering for and accessing Commodity Insights LIVE.	To comply with our legal obligations. For our legitimate interests in ensuring that we provide the Commodity Insights LIVE program only to individuals who are not the subject of sanctions. In certain jurisdictions, such as the PRC, we process personal information only if we have obtained your consent or if such processing is necessary for us to perform the Term of Use and/or other contracts with you.
Profile information such as your preferences and interests within the Commodity Insights LIVE platform, including the markets and commodities you are interested in, your profile visibility preferences and your preferred time zone, and your connections	To enable us to tailor information on Commodity Insights LIVE to information that may interest you. To allow other users with similar interests and preferences to find you.	For our legitimate interests of promoting our services and both our and your legitimate interests in providing you only with materials that you have expressed an interest in or facilitating connection with other users who have similar interests. In certain jurisdictions, such as the PRC, we process personal information only if we have obtained your consent or if such processing is necessary for us to perform the Term of Use and/or other contracts with you.
Any other personal information that you upload to your 'My Profile' section of your Commodity Insights LIVE account.	To enable you to tailor your Commodity Insights LIVE account.	For your legitimate interests in tailoring your Commodity Insights LIVE account and sharing content about yourself with other users. In certain jurisdictions, such as the PRC, we process personal information only if we have obtained your consent or if such processing is necessary for us to perform the Term of Use and/or other contracts with you.
Name, email address, your direct marketing preferences.	If requested, to provide S&P Global Commodity Insights promotional materials.	Your consent where required by applicable law.
Issues, questions and problems you have when using Commodity Insights LIVE, how you use or want to use Commodity Insights LIVE.	To respond to your communications and inquiries, in relation to Commodity Insights LIVE and to remedy or resolve any issues.	For our legitimate interests in providing the Commodity Insights LIVE platform to you and enabling us to provide the platform services to you effectively. In certain jurisdictions, such as the PRC, we process personal information only if we have obtained your consent or if such processing is necessary for us to perform the Term of Use and/or other contracts with you.
Log- in details including name and email address	To provide the Commodity Insights LIVE services and functionalities to you, including to register you for events, to verify your identity or to provide you with access to any learning materials we make available	For our legitimate interests in providing the Commodity Insights LIVE platform to you and enabling us to provide the platform services to you effectively, including access to any learning materials we make available. In certain jurisdictions, such as the PRC, we process personal information only if we have obtained your consent or if such processing is necessary for us to perform the Term of Use and/or other contracts with you.

We also collect some data automatically from you during your use of the Commodity Insights LIVE platform. Please see the S&P Global Privacy Policy for details of when we collect information automatically from your device.

 

Who does S&P Global share your Commodity Insights LIVE personal information with?

We may share the personal information you have provided in connection with your use of the Commodity Insights LIVE platform between our S&P divisions and with our webinar and conference partners so that we can send marketing and communications relating to our business and allow you to access or register for events provided by other S&P divisions.

Your Commodity Insights LIVE profile, and the personal information that you include in it, will also be accessible to all other Commodity Insights LIVE users. Personal information that you disclose on forum discussions, or any other public area of the platform will also be accessible to other Commodity Insights LIVE users. You may also directly disclose personal information to other users when privately messaging other Commodity Insights LIVE users.

Where the Personal Information Protection Law ("PIPL") applies, we will obtain your separate consent (i) before we share your personal information with our S&P divisions (where they are separate data controllers) and our webinar and conference partners, and, (ii) in particular where our S&P divisions and our webinar and conference partners are located outside of China, before we export your personal information from the PRC (by ways of, including but without limitation, providing your personal information to the overseas recipients or granting the overseas recipient access to your personal information stored in the PRC). We will take necessary measures to ensure that your personal information will be protected by the overseas recipient at a level at least up to the standards set by PIPL. Subject to the volume and nature of the relevant data export involving your personal information, we will carry out such data export by virtue of a lawful transfer tool recognised by PIPL including standard contract, certification, and/or a security assessment.

Please see the S&P Global Privacy Policy for further details of when your data may be disclosed to certain recipients.

 

What are your Rights?

Depending on which laws apply to your personal information, you may have the right to make certain requests regarding your personal information. Please see the "What are your data protection rights?" section of the S&P Global Privacy Policy for a list of rights that may apply to you.

To the extent that PIPL applies to our processing of your personal information, you may also be entitled to the rights (i) to request for the portal for transferring your personal information to other data controllers, but we may grant such request only if the conditions set by CAC have been met, and, (ii) to request for explanation or elaboration of this Privacy Statement and any other rules on the processing of your personal information hereunder.

If you are a U.S. resident, you may have additional rights under certain U.S. state privacy laws. Please see our US Addendum to the S&P Global Privacy Policy for more information and how you may exercise such rights.