Privacy Policy

[Bloomberg PolarLake: Last updated: May 22, 2017]

 

Bloomberg L.P. and its affiliates, including Bloomberg PolarLake Limited and its subsidiaries (“Bloomberg PolarLake”) (together, “Bloomberg”) respect the privacy rights of our users and are strongly committed to protecting your privacy online. This privacy policy applies to information collected through this web site (“this Site”).  This Privacy Policy does not apply to any other web sites, products, or services or to information collected in any other way (whether offline or online), by Bloomberg.

 

Information We Collect

Bloomberg or a designated service provider collects information through this Site, such as during registration, when you request certain services or products, submit information to enter a sweepstakes, contest, or other promotion, or complete a survey or poll. This information includes personal information such as name, phone number, and e-mail address.

 

Do not provide information about others unless you are authorized to do so and consent to have all information used, disclosed, and transferred in accordance with this Privacy Policy. By submitting the information about others, you represent and warrant that you are authorized to do so and that you have received authorization from the person about whom you are providing the information and that person has consented to have all information used, disclosed, and transferred in accordance with this Privacy Policy.

 

Bloomberg or a designated service provider may use “cookies,” web server logs, web beacons, or other electronic tools to collect information about you, such as your IP address, browser type, language, operating system, computer platform, and the state or country from which you accessed this Site. The Bloomberg Group or a designated service provider may also use cookies, web server logs, web beacons, or other electronic tools to collect and compile statistical and other information about your use of this Site and the services provided on this Site, such as the web pages visited, the date and the time of your visit, the web sites you visited immediately before and after visiting this Site, the number of links you click within this Site, the functions you use on this Site, the databases you view and the searches you request on this Site, the data you save on or download from this Site, etc.

 

A cookie is a small text file placed on your computer. Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers contains instructions on how to set your browser to notify you before accepting cookies or to disable cookies entirely. However, note that this Site will not function properly if you disable cookies. To opt-out of Google Analytics, please click here.

 

How We Use and Disclose Your Information

Bloomberg uses the information collected through this Site, including personal information and information about your use of this Site, to enhance your experience with this Site, save your preferences and login information, analyze web site usage, analyze use of the Site, communicate with you, enforce any terms of service or other agreement related to the Site, and provide you with services or products that you request. Bloomberg may also use the information collected through this Site to provide special offers and promotions. You may instruct Bloomberg at any time not to use your personal information collected through this Site to provide you with special offers and promotions by contacting privacy@bloomberg.com and include “Bloomberg PolarLake” in the subject line. Your choice does not apply to any other Bloomberg products and services to which you may subscribe or purchase.  You can also update your settings for receiving offers and promotions by email by clicking here. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you.  Please also note that these processes may take some time to complete, consistent with applicable law.

 

To assist us with the uses described in this privacy policy, information we or our designated service providers have collected about you through this Site, including your use of this Site, may be enhanced with other information about you that we have from other sources.

 

Accuracy and Security of Personal Information

Any of your personal information collected by Bloomberg through this Site is kept on secure servers. Bloomberg uses reasonable administrative, technical, personnel, and physical measures to protect your personal information on such servers. To help us protect your privacy, you should maintain the secrecy of your username and password you set up in connection with your participation in this Site’s service, if any.

 

Accessing and Updating Your Personal Information

To access, review, rectify, or delete personal information collected about you through this Site, please contact us at privacy@bloomberg.com and include “Bloomberg PolarLake” in the subject line. All requests must include the following information: first name, last name, and e-mail address. While Bloomberg will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.

 

Transfer of Personal Information to Other Countries

Some of the uses and disclosures mentioned in this privacy policy may involve the transfer and processing of your personal information to various countries around the world that may have different levels of privacy protection than your country. By submitting your personal information, you consent to such transfers and processing, including to the United States. Bloomberg’s Intra-Group Personal Data Protection Statement provides additional information about the transfer of personal information from the EU, EEA, and Switzerland to the United States and is available below.

 

Links to Third-Party Web Sites

The Bloomberg Group may provide links to third-party web sites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those web sites before providing any of your information on such sites.

 

Questions Regarding This Privacy Policy

If you have questions regarding this privacy policy, please contact us at privacy@bloomberg.com and include “Bloomberg PolarLake” in the subject line.

 

Modifications to This Privacy Policy

Bloomberg reserves the right to change this privacy policy at any time by posting revisions on this web page. Such changes will be effective upon posting.

 

 

Bloomberg L.P. and its affiliates (“Bloomberg”) are committed to compliance with their privacy obligations in the United States and throughout the world. This Intra-Group Personal Data Protection Statement (“Statement”) sets out the privacy principles Bloomberg follows with respect to personal information that it transfers from the European Union, European Economic Area, and Switzerland (collectively, “EU”) to the United States (“U.S.”).

 

The relevant Bloomberg group companies have entered into an Intra-Group Personal Data Protection Agreement (“IGA”) in order to ensure that responsibility for personal information transferred from the EU to the U.S. is clearly identified. The parties to the IGA are considered as data controllers, or data controller and data processor under applicable law.

 

As relevant Bloomberg companies are located in the U.S., the group companies involved in the processing shall be known as a Data Exporter and a Data Importer respectively, although there may be more than one company involved in the processing of personal information.

The IGA incorporates unchanged EU Commission Standard Contractual Clauses for controller to controller, and controller to processor transfers, and the relevant Data Exporter and Data Importer will abide by these EU Commission Standard Contractual Clauses where personal information is transferred to or accessed from Bloomberg group companies in the U.S.

 

Contact Information
Questions or comments regarding this Statement should be submitted to Bloomberg’s privacy director at the following address:
Assistant Chief Legal & Compliance Officer
731 Lexington Avenue
New York, NY 10022
United States
This Statement may be amended from time to time, consistent with the requirements of applicable law, and will be effective immediately.

 

 

Bloomberg will not disclose client data (which may include personal information, together “client data”) in response to requests from law enforcement, governmental, or regulatory agencies except where required to do so by law (for example, in response to valid and properly-served legal process such as a subpoena or search warrant). Bloomberg will attempt to notify its client prior to disclosing client data unless: (1) prohibited by applicable law from doing so, or (2) there are clear indications of unlawful conduct in connection with the client’s use of Bloomberg services. Notwithstanding any of the foregoing, Bloomberg reserves the right to respond to urgent law enforcement requests if Bloomberg believes in good faith that an emergency involving imminent danger of death or serious physical injury justifies such disclosure.

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