Privacy Policy

Bloomberg PolarLake: Last updated: May 10, 2018

 

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. This privacy policy applies to personal information collected through this web site (“this Site”). This Privacy Policy does not apply to any other web sites, products, or services of Bloomberg, unless otherwise expressly indicated by Bloomberg (such as by including a link to this Privacy Policy on other Bloomberg websites or on Bloomberg mobile applications).

 

Personal Information We Collect

Bloomberg, or where relevant a designated service provider, collects personal 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, which may include your name, phone number, email address, contact information, and password. If you do not provide certain personal information, not all functionality on this Site will be available.

 

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 Personal Information

Bloomberg uses this information for carefully considered business purposes which also benefit our customers and which include some or all of the following:

 

> to provide our products and services

> to communicate with you

> to help Bloomberg improve our products and services and develop new products and services

> to provide support for our products and services, and for Bloomberg internal quality control purposes

> to provide you with offers and promotions about services and products of Bloomberg or of other parties that may be of interest to you

> to enhance your experience with this Site, including to save your preferences and login information

> to analyze web site usage and analyze use of the Site

> to protect the interests, rights, safety, or property of Bloomberg or others and to monitor compliance with and enforce any agreement with Bloomberg

> to operate our services, products and systems properly.

 

You may instruct Bloomberg at any time not to use your personal information collected through this Site to provide you with offers and promotions by contacting privacy@bloomberg.com and include “Bloomberg PolarLake” in the subject line. You can also update your settings for receiving offers and promotions 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 aggregated, analyzed or enhanced with personal or other information about you that we have from other sources.

 

Bloomberg may disclose your personal information to our affiliates (including affiliated websites and other products under common ownership or control), and our service providers, including for the purposes set out in this Privacy Policy, and to the party who authorized your use of this Site, such as your employer. Bloomberg may disclose to other third parties, including other users of this Site, information about your use of this Site and on this Site or other websites, but only in an aggregated and unattributed manner. Bloomberg may also share your personal information collected in connection with the product you requested with a sponsor or other third party (“Third-Party Providers”) that provides you with offers or promotions that may be of interest to you. You may instruct Bloomberg at any time not to share your personal information collected in connection with the product you requested with such Third Party Providers by contacting privacy@bloomberg.com and including “Bloomberg PolarLake” in the Subject line. Please note that (i) this process may take some time to complete, consistent with applicable law; and (ii) even after such process is completed, your personal information may continue to be shared with our affiliates (including affiliated websites and other products under common ownership or control) and designated service providers.

 

Bloomberg may also disclose your personal information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, rule or regulation or in response to a subpoena, court order, or other legal process, subject to Bloomberg’s Law Enforcement Data Request Statement below; (b) protect the interests, rights, safety, or property of Bloomberg or others; (c) monitor compliance with and enforce any terms of service on this Site; (d) provide our services and products (including allowing a purchaser of Bloomberg to continue to serve you); (e) perform other activities related to such services and products, including billing and collection; (f) provide you with offers or promotions from Bloomberg that may be of interest to you; or (g) operate the systems that provide our services and products properly.

 

The collection, further use, and/or disclosure of your information by Third-party Providers or by other third parties is not the responsibility of Bloomberg. Rather, such collection, use, and/or disclosure is governed by the third parties’ privacy policies.

 

Accuracy, Security and Retention of Your Personal Information

Any of your personal information collected by Bloomberg through this Site is kept on secure servers. Bloomberg uses security measures appropriate to the provision of the relevant product or service, such as 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. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements.

 

Rights with respect to Your Personal Information

Depending on the jurisdiction, you may have the right to access, correct, delete or restrict use of certain personal information collected about you through this Site. Depending on the jurisdiction, you may also have the right to request that we refrain from processing personal information. Please bear in mind that if you exercise such rights this may affect our ability to provide our products and services. For inquiries about your personal information, please contact us at by clicking here. While Bloomberg will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. Please note that it may take some time to process your request, consistent with applicable law.

 

Transfer of Your 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 and in various countries that may have different levels of privacy protection than your country. By using our products and services, you consent to such transfers and processing, including to and in 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

Bloomberg 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. If you have complaints about Bloomberg’s processing of your personal information, you may have the right to contact the applicable supervisory authority.

 

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.

 

Intra-Group Personal Data Protection Statement

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 team at the following address:
General Counsel
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.

 

Law Enforcement Data Request Statement

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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