CreditSights Privacy Policy

This Privacy Notice was last changed on 04 December 2020.

CreditSights Privacy Policy

This Privacy Notice was last updated on December 4, 2020

1              Who we are

We are the CreditSights group of companies and we respect your privacy. This notice describes how we collect use and share your personal information.  It is our goal to provide our users with quality information while maintaining our users’ personal privacy while doing so.  This privacy notice sets out the way we use your information: what we collect, how we collect it, how we use it, why we use it, who we share it with and the rights to which you may be entitled.

If you have any questions or anything in this notice is unclear, please get in touch with our Data Protection Officer at the following email address: privacypolicy@creditsights.com or use the contact details in the Contact Us section at the end of this notice.

We may change portions of this privacy notice from time to time, so be sure to check it on a regular basis.  If we make changes to the Privacy Notice we will revise the “Last Updated” date at the top of this Notice.  If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how we use your personal information, we will notify you by way of a prominent posting on our websites and/or e-mail and/or postal mail within a reasonable period prior to the change becoming effective.

The CreditSights group of companies is made up of several companies, including, but not limited to: (1)

CreditSights Limited (04517022) 1st Floor, Dashwood, 69 Old Broad Street, London EC2M 1QS, (2) CreditSights Singapore, LLC, a Delaware corporation with an office at 8 Marina View, Asia Square Tower 1, Level 42 Singapore 018960, and (3) CreditSights, Inc., a Delaware corporation with its principal offices at 2 Park Avenue, 24th Floor, New York, NY 10016.  Our other entities in the group include CreditSights Analytics, LLC; CreditSights Advisory Services, LLC, and CreditSights Wealth Advisors, LLC.  All such entities are bound to keep your information in accordance with this privacy notice.

Please read the entire policy carefully.  Depending on the country or jurisdiction from which you are accessing this website, different sections of this privacy notice may be applicable to you, and you should read this privacy notice carefully.  The first portion of the policy contains policies applicable generally to all of our group companies and their respective users, and the second part of this policy contains provisions applicable in specific jurisdictions. Please note that we use your information in order to be able to deliver our services to you; therefore, if you do not give us consent to use information for certain purposes, we may not be able to deliver our services to you.

2              Your information

Data Collection and Usage

With your consent (where required under applicable law), we will collect your personal information from a variety of sources including but not limited to the following:

  • through your relationship with us, for example information provided by you when you submit information to us, when accessing our website (the “Site”), in emails and other electronic communications with us, through the use of our Mobile App (as defined below) and when using our products or services and when taking part in customer surveys, competitions and promotions;
  • through your verbal and written communications with us, members of our group and our service providers;
  • from an analysis of the way you use our website and manage your account with us;
  • from third parties such as government / statutory agencies, and your employer or organisation, if you are a user under a corporate subscription; and
  • from such other sources in respect of which you have given your consent to disclose information relating to you or where not otherwise restricted.

With your consent (where required under applicable law), we will collect your personal information and use it for certain purposes, including but not limited to the following:

  • to allow access to this website, to allow you to register / subscribe / use our products and services and for the purposes set out in more detail in this section, including personalizing your experience on the Site;
  • to share your information (after its accuracy is verified where required by applicable law) with members of our group; and
  • to enter into and perform our contract with you, for example providing you with the alerts and reports that you request.

Where you are accessing this website from Indonesia, we will provide you with the option of stating that the personal information we collect is confidential or non-confidential.

To the extent permissible under applicable law, you can withdraw your consent by contacting us using the details set out in the Contact Us section below. The details of the type of personal information that we collect and the purposes for which we will use such personal information is set out in the table below:

Your information may be shared with members of our group and with some third parties.

We collect and use your information for a variety of reasons.  We need some information to enter into and perform our contract, for example providing you with the alerts and reports that you request.  Some information is processed because you’ve given your consent to that, which can be withdrawn in your account preferences and settings or by contacting us using the details set out in the Contact Us section below. Other information we collect because we have legitimate business interests.

Mobile Devices

We have a mobile application that allows you to access our Site through an application designed to enhance your experience on a mobile device (the “Mobile App”).  This Notice applies to any personal information we may collect through the Mobile App.

Direct Marketing

With your consent (where required under applicable law), we may collect, use and disclose certain of your personal information (such as your name, telephone number and email address) that you give us to provide you with updates; newsletters; alerts or other communications that we think may interest you, and that are part of or are related to our services and in accordance with your account preferences. With your consent (where required under applicable law), we may share personal information with third parties to help us with our marketing and promotional projects, or sending marketing communications. Such communications we may make may take place via various transmission media, such as email, SMS, and phone calls.  Further details on information we share with third parties can be found at the section Information we share below.

If you no longer wish to receive promotional and marketing emails, text messages, post and other forms of communications from us or our promotional partners in relation to which you might receive in accordance with this section, you may notify us by using one of the following ways:

  • Log into your account and update your profile.
  • Click “unsubscribe” at the bottom of an email we sent you.
  • Contact us using the details set out in the Contact Ussection.

You may, in accordance with applicable law, choose not to receive marketing communications from us at any time, free of charge, by using one of the channels described above. If you do inform us that you no longer wish to receive promotional and marketing messages, we can still contact you regarding our business relationship with you, such as account status and activity updates, or respond to your inquiries or complaints, and similar communications.

Legal requirements

We need to collect certain types of information for compliance with legal requirements relating to our anti-fraud/anti-money laundering/know your customer obligations. If this information is not provided, we cannot agree to provide a product or service for you.

Your personal information may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claims. We will not delete personal information if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

We may also collect and use your personal information as permitted by applicable laws and regulations.

How long we keep your information

We will keep your information for as long as it is reasonably necessary. It will depend on factors such as whether you or your organization have an account with us or have interacted with recent communications. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.

–      The criteria we may use to determine the retention period for certain categories of data includes:

–      the length of time that you are a subscriber;

–      whether there are contractual or legal obligations that exist that require us to retain the data for a certain period of time;

–      whether there is any ongoing legal or financial claim that you have made with us, or that is otherwise related to your relationship with us;

–      whether any applicable law, statute, or regulation allows for a specific retention period;

–      what the expectation for retention was at the time the data was provided to us.

Information we share

With your consent (where required under applicable law), there are certain circumstances where we may transfer your personal information to certain third parties, including but not limited to employees, contractors, service providers and to other relevant third parties (whether within or outside of your home jurisdiction), as specified below:

–      We may share information about you with other members of our group of companies (listed above) so we can provide the best service across our group. They are bound to keep your information in accordance with this privacy notice.

–      With your consent (where required under applicable law), we may also share information (after its accuracy is verified if required under any applicable law) with, and receive information from, your organisation about your use of our products and services, if you are a user under a corporate subscription. Please refer to your organization’s privacy notice for information about how they will use your data.

–      With your consent (where required under applicable law), we may also share your information (after its accuracy is verified if any applicable law requires) with certain contractors or service providers. They may process your personal information for us, for example, if we use a marketing agency. Other recipients/service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers.

Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the performance of their function.

–      We may also share your information with certain third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or services to you.

–      With your consent (where required under applicable law), your personal information may also be shared with or transferred to other third-party organizations in the following scenarios:

  •   If we’re discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers under suitable terms as to confidentiality;
  •   If we are reorganized or sold, information may be transferred to a buyer who can continue to provide services to you;
  •   If we’re required to by law, or under any regulatory code or practice we follow, or if we are asked by any public or regulatory authority – for example the police;
  •   If we are defending a legal claim your information may be transferred as required in connection with defending such claim.

Finally, your personal information may be shared if it is made irretrievably anonymous and aggregated, as in such circumstances the information will cease to be personal information.

We may, in accordance with the Direct Marketing section above, share your information with business and promotional partners (where you have provided your consent to such information sharing) in order to send you information about products and services you may like. If you decide you no longer want to receive such promotional and marketing messages, please see the Direct Marketing section above to find out how you can opt-out or withdraw your consent for the receipt of such messages. With your consent (where required under applicable law), we may also share your information with certain third parties that are relevant to the provision of our service . We will do this either with your consent or because we need them to see your information to provide products or services to you.

Where your information will be held

Your personal information will be stored in either Singapore, the US or the United Kingdom. Subject to your consent (where required under applicable law), your personal information may be transferred outside the country from which you are accessing this website (“Local Territory“). When we transfer your data to our group companies we store information on servers which may be located in countries outside your Local Territory, such as the United States, Singapore or the United Kingdom. These countries may not always have data protection laws equivalent to those applicable in your Local Territory. In addition, the information we collect from you may be transferred to, and stored by, IT vendors who operate on our behalf and who are based outside your Local Territory, including “cloud-based” storage providers. In these circumstances, where required under applicable data protection law, we will take reasonable steps to ensure that they provide a standard of protection comparable to the protection under the data protection laws of your Local Territory.

In relation to the transfer out of your Local Territory, specifically for Indonesia we will coordinate with the Indonesia Ministry of Communications and Informatics or the appointed authorized official and implement the regulations on the exchange of transboundary personal information. Further, we will report to the Indonesia Ministry of Communications and Informatics or the appointed authorized official : (i) the implementation plan of your personal information transfer, at least containing the clear name, designated country, recipient subject name, implementation date, and reason/purpose of transfer; and (ii) the result of the your personal information transfer after the successful implementation of the transfer.

Where your Local Territory is in the European Economic Area (“EEA“), we may transfer your personal information out of the EEA. Some of the countries to which your personal information may be transferred that are located outside the EEA do not benefit from an adequacy decision by the EU Commission regarding protection afforded to personal information in that country. The transfer of this information is governed by a contract including standard contractual clauses (SCCs) approved by the European Commission. We will only transfer personal information out of the EEA where the appropriate safeguards set out in the European General Data Protection Regulation are in place. We are happy to provide you with copies of the regulator approved SCCs, which you can request using the details set out in the Contact Us section below.

3              Your rights

You have certain rights in relation to your personal information. The availability of these rights and the ways in which you can use them are set out below in more detail as well as in the section on Direct Marketing.

Some of these rights will only apply in certain circumstances. If you would like to exercise, or discuss, any of these rights, please contact us at privacypolicy@creditsights.com or in one of the ways provided in the Contact Us section at the end of this privacy notice.

Access: You are entitled to ask us if we are holding and/ or processing your information and, if we are, you can request access to your personal information. This enables you to receive a copy of the personal information we hold about you. In addition, if you are accessing our website from Singapore, you will also be able to obtain certain other information about it, such as how your personal information has been used in the 12 months prior to your request; if you are accessing our website from Thailand, you will be able to obtain information on the sources from which your personal information is obtained without your consent; if you are accessing our website from Indonesia, you will be able to request that your personal information not be used or displayed by a third party.

Moreover, if you are accessing our website from Thailand or the European Union, you are entitled to obtain your personal information we hold about you available in readable form or form generally usable by automatic tool or equipment. You are also entitled to request that such form be transferred to other data controller to be designated by you.

Correction: You are entitled to request that any incomplete or inaccurate personal information we hold about you is corrected or supplemented. In addition, if you are accessing our website from Thailand, we will record your such request and, if we decide not to proceed with your request, we will also record our reason for arriving at that conclusion. You have the responsibility to notify us as to changes in your personal details so that we can ensure that your personal information is up to date.

Objection/ Erasure: If you are accessing our website from Thailand, you are entitled to object any collection, use or disclosure of your personal information by us at any time according to applicable law; where we fail to comply with any applicable law, you are entitled to request us to delete, destroy, anonymize or temporarily suspend the use of your personal information. If you are accessing our website from Taiwan, you have the right to discontinue collection, processing or use, or deletion of your personal information by us, and communicate to us your objection to the use of your personal information for marketing purposes. If you are accessing our website from the European Union, you are entitled to ask us to delete or remove personal information in certain circumstances. Additionally, where we are processing your personal information based on our legitimate interests (or those of a third party), you may challenge this and you also have the right to object where we are processing your personal information for direct marketing purposes.

Withdraw consent: In some jurisdictions, you have the right to withdraw consent to the collection, use and/or disclosure of your personal information, and/or to direct marketing communications at any time. In addition, if you are accessing our website from China, you also have the right to change the scope of your consents at any time.  Please note, however, that in certain circumstances, withdrawing your consent may not make it possible for us to deliver the services to you.

Restriction: If you are accessing our website from the European Union, you are entitled to ask us to suspend the processing of certain of your personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

You also have a right to lodge a complaint with a supervisory authority where we are based, or where an alleged infringement of Data Protection law has taken place.

 

Cookies

We use cookies that identify your browser or device. They collect and store information when you visit our Site about how you use it. We collect such information for security purposes, to facilitate navigation, to personalize/tailor your experience when on the Site, and to recognize your device when you come to the Site..

Security

We are committed to keeping your personal information safe. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.   You are responsible for keeping your account passcode, subscription numbers and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorised use or any other breach of security involving your information, you must notify us as soon as possible.  Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

Protecting Children’s Privacy

Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on the Site. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Site or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at privacypolicy@creditsights.com.  California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information; please contact privacypolicy@creditsights.com for more information.

Changes to the notice

This notice will be changed from time to time. If we change anything important about this notice (the information we collect, how we use it or why) we will highlight those changes at the top of the notice and provide a prominent link to it for a reasonable length of time following the change.

If you would like to access previous versions of this privacy notice please contact us using the details in the Contact Us section.

Contact Us

If you have any questions about this privacy notice please contact us at smcnally@creditsights.com or on +44 (0)20 7429 2099, or at 1st Floor, Dashwood, 69 Old Broad Street, London EC2M 1QS.

In Asia-Pacific please use the contact details below:

Australia: Joelyn Ong (jong@creditsights.com)

China: Joelyn Ong (jong@creditsights.com)

Hong Kong: Joelyn Ong (jong@creditsights.com)

Japan: Joelyn Ong (jong@creditsights.com)

Malaysia: Joelyn Ong (jong@creditsights.com)

New Zealand: Joelyn Ong (jong@creditsights.com)

The Philippines: Joelyn Ong (jong@creditsights.com)

Singapore: Joelyn Ong at [jong@creditsights.com ] or on [+65 6536 8621]

South Korea: Joelyn Ong (jong@creditsights.com)

Taiwan: [Joelyn Ong (jong@creditsights.com)]

Special Provisions for Users Located in Certain Jurisdictions:

If you are accessing our website from South Korea, please carefully read the important information in the statements below.   You will be asked to consent to these provisions prior to being given access to the research on the website.

  1. Collection and Use of Personal Data (Mandatory)

We collect the following personal data from you when you access our website, for the following purposes.

You will be asked to agree to the collection and use of your personal data by CreditSights Singapore LLC (“the Company”) in the manner described in the table below.

You have the right to refuse to give consent to the collection and use of your personal data by the Company in the manner described above, in which case you may not be able to use the service as set forth in the Purpose(s) of Collection/Use.

1-1,   Collection and Use of Personal Data (Optional)

We collect the following personal data from you when you access our website, for the following purposes

You will be asked to agree to the collection and use of your personal data by the Company in the manner described in the table below.

You have the right to refuse to give consent to the collection and use of your personal data by the Company in the manner described above, in which case you may not be able to use the service as set forth in the Purpose(s) of Collection/Use.

 

  1. Provision of Personal Data to a Third Party (Optional)

You will be asked to agree to the provision of personal data by the Company to a third party in the manner described below.

You have the right to refuse to give consent to the provision of your personal data by the Company to Recipients such as below, in which case you may not be able to use our services.

  1. Outsourcing of Processing of Personal Data (Optional)

We may also outsource the processing of personal data and you will be asked to agree to the outsourcing of personal data by the Company in the manner described below.

You have the right to refuse to give consent to the outsourcing of processing of your personal data by the Company to outsourced processors such as above, in which case you may not be able to use or access certain services provided by us which require the use of outsourced processors.

※ You have the right to refuse to give consent to the outsourcing of processing of your personal data by the Company to outsourced processors such as above, in which case you may not be able to use or access certain services provided by us which require the use of outsourced processors.

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