Fitch Privacy Policy

Highlights

Last Updated: October 3, 2023

When you use or interact with a website, mobile application or other digital service (each a “Digital Service”) operated or owned by the Fitch Group, Inc. or its affiliates or subsidiaries, listed here (“we”, “us”, “our” or “Fitch”), we and third parties obtain personal and other information about you. In this Highlights section, we provide an overview of our privacy practices related to the Digital Services. Please review our full Privacy Policy below for a detailed explanation of our practices.

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 Fitch Ratings PRO, BMI, and the CreditSights platforms and may be subject to additional terms.

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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.

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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.

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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.

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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.

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Additional Information

• 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.

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Contact Us

If you have questions about our Privacy Policy you can contact us by email at privacy@thefitchgroup.com.

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FITCH PRIVACY POLICY

Last Updated: February 21, 2023

Introduction

1. INTRODUCTION

2. WHAT INFORMATION WE OBTAIN

3. HOW WE USE INFORMATION WE OBTAIN

4. HOW WE SHARE INFORMATION

5. YOUR CHOICES INCLUDING OPT-OUTS

6. HOW WE PROTECT AND STORE YOUR INFORMATION

7. INTERNATIONAL DATA TRANSFER

8. CHILDREN’S PRIVACY RIGHTS

9. THIRD-PARTY WEBSITES, MOBILE APPS OR OTHER SERVICES

10. DISPUTE RESOLUTION

11. COMPLAINTS

12. CHANGES TO THIS PRIVACY POLICY

13. CONTACT US

Related Policies:

Fitch Group, Inc. Terms of Use (“Terms of Use”) at https://www.fitch.group/terms-of-use

Fitch Group, Inc. Cookie Policy (“Cookie Policy”) at https://www.fitch.group/cookie-policy

1. INTRODUCTION

This Privacy Policy applies to the website, mobile application or other digital service (each a “Digital Service”) linking to this Privacy Policy and owned or operated by Fitch Group, Inc. or its affiliates or subsidiaries, listed here (“we”, “us”, “our” or “Fitch”).

This Privacy Policy describes how Fitch collects and processes personal information about you, how we use and protect this information, and your rights.

This Privacy Policy describes the privacy practices of Fitch only and does not cover the practices of other companies. The Digital Services, including the articles, reports, solutions 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 Fitch Ratings PRO, BMI, and the CreditSights platforms 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 personal 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 that (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 collect 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

You may provide information about other people, such as the name and email of a contact with whom you want to share our reports, or the name, job title and contact information of a member of staff for whom you are purchasing a training. Do not give us information about others unless you are authorized or have their permission to do so and have brought this Privacy Policy to their attention. We will use their information for the purposes described in this Privacy Policy.

C. Information automatically collected

The Digital Services automatically log certain information about visits to the Digital Services, such as the number and frequency of visitors, technical information about browsers and devices used to access the Digital Services, and information about crashes or other technical issues. In addition, in accordance with your expressed preferences, we and third parties automatically collect certain information through cookies and similar tools (referred collectively as “Cookies and Similar Technologies”) about your activities over time across the Digital Services as well as across third-party sites, apps or other media. Some Cookies and Similar Technologies assign or collect unique cookie IDs or other identifiers associated with your browser or device. Cookies and Similar Technologies may collect information while you are using the Digital Services or while they are running in the background of your device. More information about the Cookies and Similar Technologies used on the Digital Services, including how to manage your preferences, is set out in the Cookie Policy.

The information automatically collected includes the following:

• Information about your computer, device, browser and operating system (e.g., type, model, and/or version).

• Internet protocol (IP) address, which is used to derive your general geographic area (e.g., city and country).

• Device identifiers.

• 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.

For more information about the use of automated means in the context of interest-based advertising and how you can limit tracking, see the Cookie Policy.

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 for the following business purposes:

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, 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, 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.

  • In line with your expressed preferences we, our service providers and third parties use automated means including Cookies and Similar Technologies on the Digital Services and on third-party sites, apps or other media to (a) collect information for interest-based advertising purposes or (b) serve you interest-based ads. When you agree to the use of Cookies and Similar Technologies on the Digital Services, unique identifiers may be associated with your browser or device to support interest-based advertising.

  • 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.

  • There are steps you can take to limit the collection of your information by Cookies and Similar Technologies and the use of your information for interest-based advertising purposes. These steps vary for the web and mobile app environments and are browser and device specific. To learn more about these choices, see the Cookie Policy.

D. To protect our rights or the rights of others. This protection includes:

• Detecting, preventing and responding to fraud or potentially illegal activities, misuse of the Digital Services, intellectual property infringement or other violations of law, this Privacy Policy, our Terms of Use or other Fitch policies.

• 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.

• We will obtain your consent to collect and use certain types of personal information when we are required to do so by law (for example, in relation to sharing of your information with third parties for their own marketing activities). If we ask for your consent to process your personal information, you can withdraw your consent at any time by contacting us using the details at the end of this Privacy Policy.

Information on our use of cookies and similar technologies

Our Digital Services use Cookies and Similar Technologies to provide our Services, to understand how our Services are used, and for advertising purposes, as explained in this Privacy Policy. You can read more about the types of Cookies and Similar Technologies we use, why we use them and how you can exercise your choices in our Cookie Policy.

4. HOW WE SHARE INFORMATION

Fitch shares the information we obtain with:

A. Affiliates and Subsidiaries. We share your information within the Fitch family of companies. For example, we may share your browsing and subscription history on our website with other Fitch companies for marketing purposes and internal reporting. A list of Fitch companies with which your information may be shared is available here.

B. Corporate Subscribers. With respect to corporate subscriptions or memberships, we share your information with the organization that purchased the subscription or membership.

C. Training/Certification Issuers. Where applicable to products or services obtained through the Digital Services, we share your information with professional teaching, education, and/or examining bodies.

D. Service Providers. In connection with the operation of the Digital Services and provision of Materials, we engage various third parties to provide services or handle transactions on our behalf. These service providers use the information we provide to them as necessary or appropriate for the performance of their services.

E. Advertising- and Marketing-Related Service Providers. We may provide your information to entities that create, deliver and assess our advertising or marketing campaigns.

F. Business Partners. We may share your information with business partners, such as when we administer a conference or a course, provide a webinar in conjunction with an industry partner or when we issue a joint publication.

G. Social Media Platforms. If you interact with social media widgets on the Digital Services, or share the Materials using social media share buttons, Social Media Platforms may collect information. Fitch does not control this sharing and is not responsible for the privacy practices of the Social Media Platforms with which you engage.

H. Other Parties When Required by Law or As Necessary to Protect Our Rights. We share your information as and when we believe it necessary or appropriate to protect, enforce, or defend our legal rights, the privacy or safety of our employees, users of the Digital Services or other individuals and entities, or to comply with or enforce applicable law or legal process, including responding to court orders, warrants, regulatory investigations, subpoenas and other requests from public and government authorities.

I. Corporate Transactions. We reserve the right to transfer any of the information we have about you to proceed with the consideration, negotiation, or completion of a sale or transfer of all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition or other disposition, or in connection with a bankruptcy reorganization, dissolution, or liquidation.

J. With Your Consent or Otherwise at Your Direction. In addition, we share your information with third parties when you consent to or request such sharing.

Because we operate as part of a global business, the recipients referred to above will sometimes be located outside the jurisdiction in which you are located (or in which we provide the Digital Services). See the section on “International Data Transfer” below for more information.

YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

In certain circumstances, you may have the following rights in relation to the processing of your personal information:

• Right to Access: To request a copy of the personal information we process in relation to you and to be informed about how we use and share your personal information.

• Right to Object: To object to the processing of your personal information if (i) we are processing your personal information on the grounds of legitimate interests or for the performance of a task in the public interest (including profiling); or (ii) if we are processing your personal information for direct marketing purposes.

• Right to Rectification: To request that we update the personal information we process in relation to you, or to correct personal information that you think is incorrect or incomplete.

• Right to Erasure: To ask that we delete personal information that we process in relation to you where we do not have a legal or regulatory obligation or other valid reason to continue to process it.

• Right to Restriction: To request that we restrict the way in which we process your personal information, for example, if you dispute the accuracy of your personal information or have raised an objection which is under consideration.

• Right to Portability: To request a copy of your personal information that you have provided to us in a commonly used electronic format such as through the completion of an application form.

• Right to Automated Decision Making: To request manual intervention if you are subject to automated decisions where the decision results in a legal or similar effect to you.

Such requests are subject to applicable law. If you would like to discuss or exercise such rights, please contact us using the details provided in the “Contact Us” section below. We will contact you if we need additional information from you in order to honor your requests. For example, we may need to request specific information from you to help us confirm your identity and ensure your right to access the personal information requested, or to exercise any of your other rights. This is to ensure that personal information is not disclosed to any person who does not have authority to receive it. You can also use the manage my preferences button on websites and request access, deletion, or to be unsubscribed.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

California residents should read our Addendum for California Residents for additional information.

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 privacy@thefitchgroup.com.

6. 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, for 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.

7. 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.

8. 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.

9. 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.

10. DISPUTE RESOLUTION

Any dispute concerning the Digital Services (including our use of your personal information) will be resolved per the dispute resolution provision in the Terms of Use, which govern your use of the Digital Services. Please take a few minutes to read the Terms of Use before using the Digital Services.

11. COMPLAINTS

If you have any concerns or complaints about the way your personal information is processed, please contact the office of the Fitch Group Data Privacy Manager at privacy@thefitchgroup.com. You may also have a right to complain to a data protection or other competent authority with jurisdiction over privacy and data protection law in the country you live or work, or in the country where you believe an issue in relation to the processing of your personal information has arisen.

12. CHANGES TO THIS PRIVACY POLICY

We will update this Privacy Policy from time to time to reflect changes in our privacy practices or applicable laws. In accordance with applicable law, we may make such changes without prior notice. We will publish the updated version on the relevant Digital Services and indicate at the top of the Privacy Policy when it was most recently updated. Your use of the Digital Services will be governed by the then-current version of the Privacy Policy. Where changes to this Privacy Policy have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you and where required by applicable law, we will give you advanced notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).