Terms of Use

These Terms of Use were last updated on May 18, 2018.

These Terms of Use (“Terms of Use”) apply to CUSIP Global Services (managed on behalf of the American Bankers Association (“ABA”) by S&P Global Market Intelligence LLC (“SPGMI”)), which you have a contract with or which provide services to you, (collectively or individually, as applicable, referred to as "CGS”, “ABA”, “SPGMI”, “Company”, "we", "our", "us").

By accessing and using any of CGS’s websites including any connected mobile application or version thereof (each a "Site"), you agree to be legally bound by these Terms of Use and you represent that you have the legal capacity to be bound by these Terms of Use. The terms "you" and "User" refer to anyone who accesses a Site.

These Terms of Use contain terms, conditions, covenants and provisions upon which you may access and use a Site and all content, including, without limitation, text, ratings, opinions, photographs, video, audio, graphics, tools, analytics, functionality, products and information (collectively, the “Content”) displayed and/or otherwise contained on a Site. If at any time you do not agree with the Terms of Use, you will stop accessing and/or using the Site(s) and the Content. Each Site and the Content contained therein is the exclusive property of CGS or its suppliers.

CGS, pursuant to an agreement with the ABA, has the right to license all proprietary rights to the CUSIP database (“CUSIP Database”), which contains CUSIP standard identifiers, CUSIP standard descriptions, CGS ISINs, CGS CINS and other information about financial instruments ("Data"). Notwithstanding anything in the Terms of Use to the contrary, your rights to use certain material available on or through each Site may be subject to separate written license agreement(s) with CGS or SPGMI (“Other Agreements”). In the event you have an Other Agreement to access all or any portion of a Site, including any separately entitled sections of a Site, then the Other Agreement, rather than these Terms of Use, will govern your use of such Site. In the event of a conflict between your Other Agreement and these Terms of Use, the terms and conditions in the Other Agreement shall prevail.

Any attempt by you to modify these Terms of Use is expressly rejected by CGS and shall have no force or effect regarding your use of a Site. CGS may change these Terms of Use at any time without notice. Changes will be posted on each Site under "Terms of Use". Your access and use of a Site after any changes have been posted will constitute your agreement to the modified Terms of Use and any changes. Therefore, you should read these Terms of Use from time to time to be aware of any such changes.

1. USE OF THE SITE(S)

CGS grants you a personal, revocable, non-exclusive, non-transferable, limited license to access and use the Site(s) and the Content conditioned upon your compliance with these Terms of Use. The Site(s) and the Content contained therein may be used solely for viewing, ad hoc noncommercial use.

You may not license, sublicense, transfer, sell, resell, publish, reproduce and/or otherwise redistribute a Site, including the Content or any component thereof in any manner (including, but not limited to, via or as part of any Internet site). You may not a) use the Content or any portion of the Site as part of any intranet or other internal network; b) create archival or derivative works based on the Content or any portion thereof; or c) modify, reverse-engineer, disassemble, decompile or store any Content or any portion of the Site. You may not use a Site or any Content contained therein, in whole or in part in any manner that either competes or is intended to compete with CGS or its affiliates, including without limitation, any distribution of any Content or a derivative work based thereon. You may not use a Site for any illegal purpose or in any manner inconsistent with these Terms of Use. CGS may discontinue or change a Site and any the Content contained therein, or their availability to you, at any time without notice. CGS is not under any obligation to update any Content following publication on a Site. The terms of these Terms of Use will survive any such discontinuation.

2. INTELLECTUAL PROPERTY RIGHTS AND UNLAWFUL USE

All proprietary rights (including, but not limited to, copyrights, trade secrets, database rights, trademark rights, rights to trade names, service marks and other product and service names and logos) contained within a Site and any and all Content, including, but not limited to, all information, data, ratings and ratings symbology, software, products and documentation contained or included therein, are and shall remain the sole and exclusive property of CGS and its suppliers. Each Site and any and all Content contained herein is protected by copyright in addition to other intellectual property laws. Any of the trademarks, service marks or logos (collectively, the "Marks") displayed on a Site may be registered or unregistered marks of CGS or others. Nothing contained on a Site shall be construed as granting any license or right to use any of the Marks displayed on the Site absent the express written permission of CGS or a third party owner of such Marks. You agree to honor all reasonable requests by CGS or its suppliers to protect and preserve their respective proprietary interests in each Site and any and all Content contained therein. Each Site and the Content are compiled, prepared, revised, selected and arranged by CGS and its suppliers through the application of methods and standards of judgment developed and applied through the expenditure of substantial time, effort and money, and each Site and any and all Content constitute valuable intellectual property of CGS and its suppliers. Copying of, use of, access to or distribution of a Site or any Content contained therein in breach of these Terms of Use may cause CGS and/or its suppliers irreparable injury that cannot be adequately compensated for by means of monetary damages. Any breach hereof by you may be enforced by CGS or its suppliers by means of equitable relief (including, but not limited to, injunctive relief) in addition to any other available rights and remedies. Any actual or attempted illegal or unauthorized uses of a Site, the Marks or any Content are strictly prohibited and may result in criminal and/or civil prosecution.

Export Restrictions. CGS does not in any manner warrant or represent that the materials on a Site, including any Content contained therein, are appropriate or available for use in any CUSIP® is a registered trademark of the American Bankers Association. CUSIP Global Services is managed on behalf of the American Bankers Association by S&P Global Market Intelligence LLC. particular location. If you choose to access a Site including any Content therein, you do so on your own initiative and you are responsible for compliance with all applicable laws.

Committee on Uniform Security Identification Procedures of the American Bankers Association (“CUSIP”). You agree and acknowledge that the CUSIP database and the information contained therein is and shall remain valuable intellectual property owned by, or licensed to, CGS and the ABA, and that no proprietary rights are being transferred to you in such materials or in any of the information contained therein. You agree that misappropriation or misuse of such materials will cause serious damage to CGS and ABA and that in such event money damages may not constitute sufficient compensation to CGS and ABA; consequently, you agree that in the event of any misappropriation or misuse, CGS and ABA shall have the right to obtain injunctive relief in addition to any other legal or financial remedies to which CGS and ABA may be entitled. You agree that you shall not publish or distribute in any medium the CUSIP database or any information contained therein or summaries or subsets thereof to any person or entity. Your only use of the CUSIP numbers and descriptions shall be in connection with the internal trading and settlement of security transactions. You further agree that the use of CUSIP numbers and descriptions is not intended to create or maintain, and does not serve the purpose of the creation or maintenance of, a master file or database of CUSIP descriptions or numbers for yourself or any third-party recipient of such materials and is not intended to create and does not serve in any way as a substitute for any products and services distributed by CGS. All use by you of the CUSIP database and the information contained therein is expressly subject to the disclaimers and limitations set forth herein. In the event you have a direct agreement with CGS, such agreement shall control your use of the CUSIP database and/or any information contained therein.

NOTE: For your protection, CGS reserves the right to view, monitor, and record activity on the Site in accordance with CGS's Privacy Policy and Cookie Notice, to the fullest extent permitted by applicable law. CGS hereby reserves the right to discontinue access to a Site either with or without notice if CGS has a reasonable basis to believe that a User is accessing or using any Content in violation of these Terms of Use, in addition to any other available rights and remedies.

3. ANTI-HACKING PROVISIONS

You expressly agree not to:

  • use or attempt to use any "deep-link," "scraper," "robot," "bot," "spider," "datamining," "computer code" or any other automated device, program, tool, algorithm, process, or methodology or manual process having similar processes or functionality, to access, acquire, copy, or monitor any portion of a Site, any Content found on or accessed through a Site, or any User Content without the prior express written consent of CGS;
  • obtain or attempt to obtain through any means any Content on a Site that has not been intentionally made publicly available, either by their public display on a Site or through their accessibility by a visible link on a Site;
  • violate any measure employed to limit or prevent access to a Site or the Content;
  • violate the security of a Site or attempt to gain unauthorized access to a Site, the Content, or data, materials, information, computer systems or networks connected to any CGS server, through hacking, password mining or any other means;
  • interfere or attempt to interfere with the proper working of a Site or any activities conducted on or through a Site, including accessing any Content prior to the time that it is intended to be available to the public on a Site;
  • take or attempt any action that, in the sole discretion of CGS imposes or may impose an unreasonable or disproportionately large load or burden on a Site or the CGS infrastructure;
  • misuse a Site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful.

4. DISCLAIMER AND LIMITATIONS OF LIABILITY

THE DETERMINATION OF WHETHER A SECURITY OR OTHER FINANCIAL INSTRUMENT IS ELIGIBLE FOR A CUSIP IDENTIFIER, AND WHETHER THE REQUESTER HAS SUPPLIED THE APPROPRIATE DOCUMENTATION, SHALL BE MADE BY CGS IN ITS DISCRETION AND ANY SUCH DETERMINATION SHALL BE FINAL. CGS SHALL HAVE NO LIABILITY IN CONNECTION WITH A DETERMINATION THAT A SECURITY OR OTHER FINANCIAL INSTRUMENT IS NOT ELIGIBLE FOR A CUSIP IDENTIFIER. CUSIP NUMBERS AND STANDARD DESCRIPTIONS ARE THE VALUABLE INTELLECTUAL PROPERTY OF THE ABA. THE ASSIGNMENT OF A CUSIP NUMBER TO A PARTICULAR SECURITY BY CGS IS NOT INTENDED TO BE AND SHOULD NOT BE CONSTRUED AS AN ENDORSEMENT OF SUCH SECURITY, A RECOMMENDATION TO PURCHASE, SELL OR HOLD SUCH SECURITY OR AN OPINION AS THE LEGAL VALIDITY OF SUCH SECURITY. BECAUSE OF THE POSSIBILITY OF HUMAN OR MECHANICAL ERROR BY ISSUERS, CGS, THIRD PARTY SOURCES AND OTHERS, NEITHER CGS NOR THE ABA GUARANTEES THE ACCURACY, ADEQUATENESS OR COMPLETENESS OF ANY CUSIP DATA, AND SHALL NOT BE LIABLE OR RESPONSIBLE FOR ANY ERRORS OR OMISSIONS OR FOR THE RESULTS OBTAINED FROM THE USE OF ANY CUSIP DATA.

CGS, ABA, AND SPGMI DO NOT EXCLUDE OR LIMIT IN ANY WAY OUR LIABILITY TO YOU WHERE IT WOULD BE UNLAWFUL TO DO SO. THIS INCLUDES LIABILITY FOR DEATH OR PERSONAL INJURY CAUSED BY OUR NEGLIGENCE OR THE NEGLIGENCE OF OUR EMPLOYEES, AGENTS OR SUBCONTRACTORS AND FOR FRAUD OR FRAUDULENT MISREPRESENTATION. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, CGS, ABA, OR SPGMI AND ITS SUPPLIERS DISCLAIM ANY AND ALL WARRANTIES AND REPRESENTATIONS, EXPRESS OR IMPLIED, INCLUDING ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE AS TO A SITE OR ANY CONTENT, INCLUDING INFORMATION, DATA, SOFTWARE OR PRODUCTS CONTAINED THEREIN, OR THE RESULTS OBTAINED BY THEIR USE OR AS TO THE PERFORMANCE THEREOF.

A REFERENCE TO A PARTICULAR INVESTMENT OR SECURITY, A CREDIT RATING OR ANY OBSERVATION CONCERNING AN INVESTMENT OR SECURITY PROVIDED ON A SITE IS NOT A RECOMMENDATION TO BUY, SELL OR HOLD SUCH INVESTMENT OR SECURITY OR MAKE ANY OTHER INVESTMENT DECISIONS AND DOES NOT ADDRESS THE SUITABILITY OF ANY INVESTMENT OR SECURITY. CONTENT SHOULD NOT BE RELIED ON AND IS NOT A SUBSTITUTE FOR THE SKILL, JUDGMENT AND YOUR EXPERIENCE OR THE EXPERIENCE OF YOUR ADVISORS AND/OR CLIENTS IN MAKING INVESTMENT AND OTHER BUSINESS DECISIONS. CGS, ABA, OR SPGMI DO NOT ACT NOR SHALL BE DEEMED TO BE ACTING AS A FIDUCIARY IN PROVIDING A SITE OR ANY CONTENT.

NEITHER CGS, ABA, SPGMI NOR ANY OF ITS SUPPLIERS GUARANTEE THE ADEQUACY, ACCURACY, TIMELINESS OR COMPLETENESS OF A SITE, ANY CONTENT OR ANY COMPONENT THEREOF OR ANY COMMUNICATIONS, INCLUDING BUT NOT LIMITED TO ORAL OR WRITTEN COMMUNICATIONS (INCLUDING ELECTRONIC COMMUNICATIONS) OR OUTPUT WITH RESPECT THERETO OR THAT A SITE OR ANY CONTENT WILL BE FREE OF VIRUSES, WORMS OR “TROJAN HORSES”. NEITHER CGS, ABA, SPGMI, NOR ANY OF ITS SUPPLIERS SHALL BE SUBJECT TO ANY DAMAGES OR LIABILITY FOR ANY ERRORS, OMISSIONS OR DELAYS IN A SITE, INCLUDING CONTENT. EACH SITE, CONTENT CONTAINED THEREIN AND ANY AND ALL COMPONENTS THEREOF, IS PROVIDED ON AN “AS-IS” BASIS AND YOUR USE OF A SITE AND ANY CONTENT IS AT YOUR OWN RISK.

NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THESE TERMS OF USE, IN NO EVENT WHATSOEVER SHALL CGS, ABA, SPGMI OR ANY OF ITS SUPPLIERS BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, TRADING LOSSES OR LOST TIME OR GOOD WILL, EVEN IF THEY HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, WHETHER IN CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE. NEITHER CGS, ABA, SPGMI NOR ANY OF ITS SUPPLIERS SHALL BE LIABLE FOR ANY CLAIMS AGAINST YOU BY THIRD PARTIES.

IN THE EVENT THAT LIABILITY IS NEVERTHELESS IMPOSED ON CGS, ABA, SPGMI OR ITS SUPPLIERS, IN NO EVENT SHALL THE MAXIMUM CUMULATIVE LIABILITY OF CGS, ABA, SPGMI AND ITS SUPPLIERS IN CONNECTION WITH A SITE, ANY CONTENT AND/OR THESE TERMS OF USE, REGARDLESS OF THE FORM(S) OF ACTION, WHETHER IN CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE, EXCEED ONE HUNDRED DOLLARS (US$100). NO ACTION, REGARDLESS OF FORM, ARISING FROM OR PERTAINING TO YOUR USE OF A SITE OR THE CONTENT MAY BE BROUGHT BY YOU MORE THAN ONE (1) YEAR AFTER SUCH ACTION HAS ACCRUED.

You are entirely liable for activities conducted by you or anyone else in connection with your browsing and access to and use of a Site. If you are dissatisfied with a Site or with these Terms of Use, your sole and exclusive remedy is to stop using such Site.

5. LINKS TO OTHER WEB SITES FROM THIS SITE

You may, through hypertext or other computer links, gain access to web sites operated by persons other than CGS. Such hyperlinks are provided for your reference and convenience only and are the exclusive responsibility of the owners of each such web site. You agree that CGS is not responsible for the content or operation of such web sites, and that CGS shall have no liability to you or any other person or entity for the use of third party web sites. Except as described below, a hyperlink from a Site to another web site does not imply or mean that CGS endorses the content on such web site or the operator or operations of such web site. You are solely responsible for determining the extent to which you may use any content at any other web sites to which you link from a Site.

As you browse through a Site you may access other web sites that are subject to different terms of use. When you use those other web sites, you may be legally bound by the specific terms of use posted on such web sites. If there is a conflict between these Terms of Use and other terms of use of such web sites, the terms of use of such web sites will govern with respect to your use of such web sites.

6. USER CONTENT

The User grants to CGS a perpetual, nonexclusive, irrevocable, fully paid, royalty-free, sublicenseable and transferable (in whole or in part) worldwide right and license in any and all media, now known or later developed, to use, publish, reproduce, display, modify, transmit digitally, create derivative works based upon and otherwise exploit all material posted to or received through a Site by, from or on behalf of the User or anyone else using the User’s account (other than third party material transmitted through private electronic mail) (“User Content”) (including, without limitation, any names, voices, likenesses, performances and actions contained therein) for any purpose whatsoever (including, without limitation, advertising, commercial, promotional and publicity purposes) in CGS’s discretion without notice, approval, attribution or consideration to you or to any other person or entity. You represent and warrant that you have all rights necessary to grant the foregoing license, that neither the permission nor consent of any other person or entity is required to enable CGS to legally use the User Content in accordance with this license; that all User Content provided to a Site by you or anyone else using your account complies with all applicable laws, rules and regulations; and that CGS’s use of the User Content in accordance with this license will not violate or infringe upon the rights of any person or entity.

Users entering material into a Site are responsible for the content of that material. CGS does not have any responsibility for User Content, including the content of any messages or information posted by Users or others, or for the content of information accessible via direct or indirect hyperlinks from a Site. However, CGS retains the right, to review, edit or delete User Content that CGS deems to be illegal, offensive or otherwise inappropriate.

You may not input or distribute any material through the Site that is promotional in nature, including solicitations for funds or business, without the prior written authorization of CGS.

7. PRIVACY POLICY AND COOKIE NOTICE

Please see the CGS Privacy Policy and Cookie Notice for information on CGS’s data collection and use practices with respect to a Site.

As part of access to portions of a Site, you may be required to provide certain information, such as, your name and email address. In addition, you may be required to select a username and password. You represent and warrant that any information you provide to CGS in connection with a Site shall be accurate and complete. You further agree to keep any passwords/user IDs in connection with a Site in strict confidence and promptly advise CGS of any actual or threatened unauthorized disclosure or misuse of a Site or any passwords/user IDs with respect to a Site that come to your attention. You shall cooperate with CGS in enforcing the restrictions and limitations set forth herein.

8. COUNTRY CONDITIONS

The terms and conditions set forth in this section (the “Country Conditions”) are the result of various regulatory and/or legal requirements relating to usage of a Site including its Content. Your use of a Site in the specified jurisdictions is subject to these Country Conditions

Australia. To the extent that S&P’s Global Ratings credit ratings (the “Ratings”) are included as part of any Content, Standard & Poor’s (Australia) Pty Limited (ABN 62 007 324 852), being the holder of Australian Financial Services License No. 337565 issued pursuant to the Corporations Act 2001 (Cth) (“SPA”), whose registered office is located at Level 45, 120 Collins Street, Melbourne Vic 3000 Australia, shall provide such portion of such Content to you and S&P shall license you the right to use the intellectual property in such portion of such Content and, as owner of such intellectual property, shall receive any fees with respect thereto. SPA expressly agrees to be bound by the terms and conditions of this Terms of Use to the extent it applies to the provision of the Ratings. You accept and acknowledge that SPA’s provision of the Ratings as part of a Site to you is based on, and conditional on, the veracity and accuracy of your representation that you are a “Wholesale Client” (as such is defined in Chapter 7 of the Corporations Act of 2001 (Australia)). In addition, you acknowledge that Ratings and/or related research licensed to you pursuant to these Terms of Use or your Other Agreement, as applicable, are not intended for, and should not be distributed to, any person other than a Wholesale Client (to the extent such distribution is permitted by your Other Agreements). In furtherance of the foregoing, you undertake that (a) you will not pass on any Rating and/or related research to a party who is not a Wholesale Client and (b) that you will obtain the same undertaking from your own Wholesale Clients (to the extent such distribution is permitted by your Other Agreements). S&P Global represents that it is authorized to bind SPA to the terms and conditions set forth in these Terms of Use to the extent such terms and conditions pertain to the provision of Ratings.

All countries located in Europe, the Middle East or Africa (“EMEA”). In the event your use of the Ratings is in any country located in EMEA, you further acknowledge and agree to the following: the Ratings shall not in any circumstances be used by you where, as part of an effort CUSIP® is a registered trademark of the American Bankers Association. CUSIP Global Services is managed on behalf of the American Bankers Association by S&P Global Market Intelligence LLC. to sell securities to Retail Investors (as defined below), you use the Ratings: (a) to create a type of recommendation, (b) to create your own interpretation of the Ratings or (c) in some other form of “risk classification”. For the purposes of this Terms of Use, “Retail Investor” shall mean an individual investor who buys and sells securities or other financial products for his/her personal account, and not for another company, individual or organization.

9. ADDITIONAL LEGAL TERMS

These Terms of Use constitute the entire agreement between the parties relating to each Site and supersedes any and all other agreements, oral or in writing, with respect to such Site. The failure of CGS to insist upon strict compliance with any term of these Terms of Use shall not be construed as a waiver with regard to any subsequent failure to comply with such term or provision. To the fullest extent permitted by law, you shall indemnify, hold harmless and defend CGS, ABA, SPGMI and its suppliers from and against any and all costs, claims, damages or liabilities (including reasonable attorneys’ fees and court costs) arising out of any breach by you of Section 3 (Anti-hacking Provisions). These Terms of Use are personal to you, and you may not assign your rights or obligations to anyone. If any term or condition hereof is found by a court, administrative agency or jurisdiction to be invalid or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal and enforceable. If such modification is not possible, the relevant term shall be deemed deleted and the remaining terms and conditions hereof shall remain in full force and effect and shall be enforceable to the maximum extent permitted by law. These Terms of Use, your rights and obligations, and all actions contemplated by these Terms of Use shall be governed by the laws of the United States of America and New York State. The parties agree that the State and Federal courts of New York shall be the exclusive forums for any dispute arising out of these Terms of Use and the parties hereby consent to the personal jurisdiction of such courts. Any claim must be brought in the claimant’s individual capacity, and not as a plaintiff or class member in any purported class, collective, representative, multiple plaintiffs, or similar proceeding (“Class Action”). The parties expressly waive any ability to maintain any Class Action in any forum.

10. HOW TO CONTACT US

If you have any questions or concerns about these Terms of Use, please contact us at: privacy_official@CUSIP.com and/or S&P Global Inc.’s Chief Privacy Officer and Data Protection Officer at privacy@spglobal.com or by mail to: Chief Privacy Officer, S&P Global Inc., 55 Water Street, New York, NY 10041

CUSIP® is a registered trademark of the American Bankers Association.
CUSIP Global Services is managed on behalf of the American Bankers Association by S&P Global Market Intelligence LLC.

Privacy and Cookie Notice

CUSIP Global Services (“CGS”) (managed on behalf of the American Bankers Association (“ABA”) by S&P Global Market Intelligence LLC (“SPGMI”)), which you have a contract with or which provide services to you, (collectively or individually, as applicable, referred to as "CGS”, “ABA”, “SPGMI”, “Company”, "we", "our", "us") respect your right to privacy. This Customer Privacy Policy explains how we collect, share and use personal information about you, and how you can exercise your privacy rights. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Customer Privacy Policy.

What personal information does CGS collect and why?

The personal information that we may collect about you broadly falls into the following categories:

1. Information that you provide voluntarily

We ask you to provide certain information voluntarily, such as your contact details, user credentials, and employment information.

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For instance, this can be by way of filling in an online form when you register to use our products and services, when you register to attend an event, when you provide us with your business card information or when you request to receive information from us. The types of information we ask you to provide, and the reasons why we ask you to provide it, include:

Types of personal information Why we collect it
Billing information To maintain your account with us.
Contact details including name, telephone numbers, email address and postal address. To respond to correspondence and enquiries you send us. In some cases, to gather information needed to provide products and services requested by you or your employer. To obtain your feedback regarding our products and services.
User credentials including name, email address and personal information you provide to us in a profile. To set up and maintain your user account. To monitor and enforce compliance with our contractual terms.
Employer and employment information such as job title, function, seniority, department, and the address/country/ city of your office. To manage your individual user account which is covered by a corporate account of one of CGS's corporate customers, for instance, the corporate account of your employer.
Your preferences and interests, for instance which newsletters you would like to be subscribed to or what markets you are interested in. To enable us to send you tailored information on our products and services across our divisions that may be of interest to you.
Social security numbers, credit card numbers, and personal financial data (such as specific salary, mortgage details, net worth or individual portfolio information). We refer to this type of personal data as "Sensitive Financial Data". In some cases, our corporate customer or you may provide Sensitive Financial Data to us for the purpose of informing our statistical analysis or for us to use in providing our products or services to you. Sensitive Financial Data will not be used for purposes other than these, rented or otherwise made available to third parties for public distribution.

2. Information that we collect automatically

We may also collect certain information automatically from your device, including information regarding your use patterns of our products and services. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

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Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), "click stream" data and other technical information. We also collect information about how your device has interacted with our websites and products, including the pages and products accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our website and the users of our products and services, where they come from, and what content on our website and products and services is of interest to them. We use this information:

  • for our analytics purposes;
  • to improve the quality and relevance to users, of our websites and products and services;
  • to develop and update our websites and products and services;
  • for customer services purposes, for instance, reviewing our customers' training needs in respect of the use of our products;
  • to satisfy CGS's corporate customers' requests regarding the use of our products and services by the individual users licensed by their corporate account (please note that such information in many instances and jurisdictions will be offered to clients in an aggregated form); note that customers may be required by law to request such information from S&P;
  • to send you tailored information on our products and services that we believe may be of interest or value to you and also marketing and promotional e-mails with your consent if and when required by applicable law;
  • on rare occasions to identify unauthorized use or unauthorized distribution of our products and services related or unrelated to a security issue;
  • where relevant, to review and / or update our pricing model agreed with our corporate customers; and
  • for billing purposes, so that we or others (such as content providers) are able to bill for the services provided

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology”.

3. Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including your employer or business partner if you use CGS’s products covered by their corporate subscription), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us

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The types of information we collect from your employer (if you use CGS products under your employer's corporate subscription) consists of your contact details and employment information.

The types of information we collect from other third parties include information regarding you as a marketing prospect. For example, we collect personal information from marketing vendors, social media sources, third party conferences, and other sources to the extent permitted by applicable law. We use the information we receive from these third parties to market our products and services across our divisions to you, to supplement personal information we have for purposes such as maintaining and correcting our records, adding supplemental data fields, and similar reasons to enhance the delivery of our products and services to you.

We collect personal information as part of our content collection process for some of our products. We obtain this from a variety of sources, including public filings and websites, to display within some of our products.

In general, we will use the personal information we collect from you or from third party sources only for the purposes described in this Customer Privacy Policy or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Who does CGS share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • ABA, SPGMI and its group companies, third party service providers, product content providers, and partners;
  • Your employer;
  • Competent law enforcement bodies, regulatory, government agency, court or other third parties;
  • Potential Buyers;
  • Any other person with your consent to the disclosure.

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• Our group companies, product content providers and partners;

We provide personal information to group companies, SPGMI divisions, and business partners who process personal information for purposes in line to those described in this Customer Privacy Policy or notified to you when we collect your personal information. Content providers will process your personal data for billing purposes only. A list of our current group companies is available here and a list of our content providers and partners is available here. We do not sell your usage data to third parties for the purposes of their marketing third party products or services to you;

• Third party service providers;

We provide personal information to third party service providers who provide data processing services to us. A list of our current service providers is available here;

• Your employer;

We provide personal information to your employer, in many instances and jurisdictions in an aggregate form, for purposes such as to fulfil our contract with them, to inform them of potential group training needs, to inform them of product/service use by certain categories of user and for pricing purposes.

• Competent law enforcement bodies, regulatory, government agency, court or other third parties;

We provide personal information to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

• Potential Buyers;

We provide personal information to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Customer Privacy Policy;

• Any other person with your consent to the disclosure.

Please be aware that if you disclose personal information on website message boards or chat areas, that information may be collected and used by third parties without our knowledge and may result in unsolicited communications from third parties. Such activities are beyond the control of CGS.

Legal basis for processing personal information (EEA visitors / users only)

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

As a general rule, we will only collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you (for instance, your subscription to one of our products), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for instance, where we process personal data regarding the usage of our products and services, as described above). In some cases, we may also have a legal obligation to collect personal information from you.

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If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our products and services and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our products and services, advising you of product features or new releases, informing you of product maintenance, or undertaking marketing activities. We may have other legitimate interests and if appropriate it will be clear to you at the relevant time regarding what those legitimate interests are.

Where we send you communications regarding our products or services from our different divisions and affiliates that may be of interest to you, we do so based on your consent, if and when required by applicable law.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice

How does CGS keep my personal information secure?

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

International data transfers

We use appropriate technical and organizational measures to protect the personal Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

Learn More Below

Specifically, our servers are located in various countries which may be located outside of the jurisdiction where we collected the data, such as US, Canada, United Kingdom, Ireland, Germany, the Netherlands and Singapore. This means that when we collect your personal information we may transfer it to or process it in any of the countries in which we do business.

Our group companies, third party service providers, product content providers and partners, with whom we may share personal information as described above, are located in and transfer personal information to various jurisdictions around the world.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Customer Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

You may request our Standard Contractual Clauses by contacting privacy_official@CUSIP.com and/or privacy@spglobal.com. We have implemented appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a product or service you have requested, as set forth in our information governance procedures, or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we follow our information governance procedures and either delete or anonymize your personal information, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If you wish to receive further information about the period of time for which we will process your personal information, please contact privacy_official@CUSIP.com and/or privacy@spglobal.com.

Your data protection rights

Your rights include the right to access, correct, update or request deletion of your personal information. You also have the right to withdraw the consent you have provided to us.

Learn More Below

You have the following data protection rights:

  • to access, correct, update or request deletion of your personal information.
  • you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, by using the SPGMI and/or CGS contact details below, or by visiting the preference center by clicking here:
  • LINK to SPGMI preference center https://pages.marketintelligence.spglobal.com/SPGMI-Email-SubscriptionCenter.html
  • if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area and Switzerland are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws

Notice to persons whose personal data is contained in SPGMI products (“SPGMI Products”).

Some of SPGMI Products contain personal data about persons who are directors, officers, managers or large shareholders of companies that feature in the SPGMI Products, which data SPGMI obtains from publicly available sources.

Learn More Below

Personal data in SPGMI Products is limited to business contact details, professional details, work data, compensation details, and education data and is obtained by SPGMI from publicly available sources.

Information in SPGMI Products is for reference only, for instance, to identify the officers or shareholders of a particular organization and, therefore, is made available to SPGMI’s customers for this purpose. Customers' use of your personal information is restricted by their contract with SPGMI.

SPGMI customers are located anywhere in the world, including countries with data protection laws that may differ from or offer lower protections than the laws of your country. SPGMI requires its customers by contract to comply with any applicable data protection laws.

SPGMI may share personal data in its products with affiliated companies and with those parties who provide content to SPGMI. SPGMI will not use your personal data for any other purposes than as described above, which is within SPGMI's legitimate commercial interests to provide SPGMI products and services to its customers.

SPGMI updates its product information for accuracy on a regular basis. SPGMI removes data from its systems when such data becomes obsolete inaccurate and

SPGMI has established data governance standards for collection, use and retention of the personal information. For information about your rights under data protection law, please refer to the relevant section above.

The controller of your personal data is SPGMI. Please see details below in section "How to contact us" for our DPO details and the details of our EU local representative.

Updates to this Customer Privacy Policy

We may update this Customer Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Customer Privacy Policy, the updated version will be posted, and we will take appropriate measures to inform you, consistent with the significance of the changes we make. If and where your consent is required by applicable data protection laws, we will obtain your consent to any material Customer Privacy Policy changes.

You can see when this Customer Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Customer Privacy Policy.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us at: privacy_official@CUSIP.com and/or S&P Global Inc.’s Chief Privacy Officer and Data Protection Officer privacy@spglobal.com or by mail to: Chief Privacy Officer, S&P Global Inc., 55 Water Street, New York, NY 10041.

The Company that contracted with your employer or that you select to provide you services is the controller of your personal data. If the controller of your personal information is located outside the EEA, below are the details of the EU representative of non-EEA controller:

For CGS/SPGMI:

S&P Global UK Limited

20 Canada Square

Canary Wharf

London

E14 5LH

MIPrivacyOfficer@spglobal.com

Terms of Use

These Terms of Use were last updated on May 18, 2018.

These Terms of Use (“Terms of Use”) apply to CUSIP Global Services (managed on behalf of the American Bankers Association (“ABA”) by S&P Global Market Intelligence LLC (“SPGMI”)), which you have a contract with or which provide services to you, (collectively or individually, as applicable, referred to as "CGS”, “ABA”, “SPGMI”, “Company”, "we", "our", "us").

By accessing and using any of CGS’s websites including any connected mobile application or version thereof (each a "Site"), you agree to be legally bound by these Terms of Use and you represent that you have the legal capacity to be bound by these Terms of Use. The terms "you" and "User" refer to anyone who accesses a Site.

These Terms of Use contain terms, conditions, covenants and provisions upon which you may access and use a Site and all content, including, without limitation, text, ratings, opinions, photographs, video, audio, graphics, tools, analytics, functionality, products and information (collectively, the “Content”) displayed and/or otherwise contained on a Site. If at any time you do not agree with the Terms of Use, you will stop accessing and/or using the Site(s) and the Content. Each Site and the Content contained therein is the exclusive property of CGS or its suppliers.

CGS, pursuant to an agreement with the ABA, has the right to license all proprietary rights to the CUSIP database (“CUSIP Database”), which contains CUSIP standard identifiers, CUSIP standard descriptions, CGS ISINs, CGS CINS and other information about financial instruments ("Data"). Notwithstanding anything in the Terms of Use to the contrary, your rights to use certain material available on or through each Site may be subject to separate written license agreement(s) with CGS or SPGMI (“Other Agreements”). In the event you have an Other Agreement to access all or any portion of a Site, including any separately entitled sections of a Site, then the Other Agreement, rather than these Terms of Use, will govern your use of such Site. In the event of a conflict between your Other Agreement and these Terms of Use, the terms and conditions in the Other Agreement shall prevail.

Any attempt by you to modify these Terms of Use is expressly rejected by CGS and shall have no force or effect regarding your use of a Site. CGS may change these Terms of Use at any time without notice. Changes will be posted on each Site under "Terms of Use". Your access and use of a Site after any changes have been posted will constitute your agreement to the modified Terms of Use and any changes. Therefore, you should read these Terms of Use from time to time to be aware of any such changes.

1. USE OF THE SITE(S)

CGS grants you a personal, revocable, non-exclusive, non-transferable, limited license to access and use the Site(s) and the Content conditioned upon your compliance with these Terms of Use. The Site(s) and the Content contained therein may be used solely for viewing, ad hoc noncommercial use.

You may not license, sublicense, transfer, sell, resell, publish, reproduce and/or otherwise redistribute a Site, including the Content or any component thereof in any manner (including, but not limited to, via or as part of any Internet site). You may not a) use the Content or any portion of the Site as part of any intranet or other internal network; b) create archival or derivative works based on the Content or any portion thereof; or c) modify, reverse-engineer, disassemble, decompile or store any Content or any portion of the Site. You may not use a Site or any Content contained therein, in whole or in part in any manner that either competes or is intended to compete with CGS or its affiliates, including without limitation, any distribution of any Content or a derivative work based thereon. You may not use a Site for any illegal purpose or in any manner inconsistent with these Terms of Use. CGS may discontinue or change a Site and any the Content contained therein, or their availability to you, at any time without notice. CGS is not under any obligation to update any Content following publication on a Site. The terms of these Terms of Use will survive any such discontinuation.

2. INTELLECTUAL PROPERTY RIGHTS AND UNLAWFUL USE

All proprietary rights (including, but not limited to, copyrights, trade secrets, database rights, trademark rights, rights to trade names, service marks and other product and service names and logos) contained within a Site and any and all Content, including, but not limited to, all information, data, ratings and ratings symbology, software, products and documentation contained or included therein, are and shall remain the sole and exclusive property of CGS and its suppliers. Each Site and any and all Content contained herein is protected by copyright in addition to other intellectual property laws. Any of the trademarks, service marks or logos (collectively, the "Marks") displayed on a Site may be registered or unregistered marks of CGS or others. Nothing contained on a Site shall be construed as granting any license or right to use any of the Marks displayed on the Site absent the express written permission of CGS or a third party owner of such Marks. You agree to honor all reasonable requests by CGS or its suppliers to protect and preserve their respective proprietary interests in each Site and any and all Content contained therein. Each Site and the Content are compiled, prepared, revised, selected and arranged by CGS and its suppliers through the application of methods and standards of judgment developed and applied through the expenditure of substantial time, effort and money, and each Site and any and all Content constitute valuable intellectual property of CGS and its suppliers. Copying of, use of, access to or distribution of a Site or any Content contained therein in breach of these Terms of Use may cause CGS and/or its suppliers irreparable injury that cannot be adequately compensated for by means of monetary damages. Any breach hereof by you may be enforced by CGS or its suppliers by means of equitable relief (including, but not limited to, injunctive relief) in addition to any other available rights and remedies. Any actual or attempted illegal or unauthorized uses of a Site, the Marks or any Content are strictly prohibited and may result in criminal and/or civil prosecution.

Export Restrictions. CGS does not in any manner warrant or represent that the materials on a Site, including any Content contained therein, are appropriate or available for use in any CUSIP® is a registered trademark of the American Bankers Association. CUSIP Global Services is managed on behalf of the American Bankers Association by S&P Global Market Intelligence LLC. particular location. If you choose to access a Site including any Content therein, you do so on your own initiative and you are responsible for compliance with all applicable laws.

Committee on Uniform Security Identification Procedures of the American Bankers Association (“CUSIP”). You agree and acknowledge that the CUSIP database and the information contained therein is and shall remain valuable intellectual property owned by, or licensed to, CGS and the ABA, and that no proprietary rights are being transferred to you in such materials or in any of the information contained therein. You agree that misappropriation or misuse of such materials will cause serious damage to CGS and ABA and that in such event money damages may not constitute sufficient compensation to CGS and ABA; consequently, you agree that in the event of any misappropriation or misuse, CGS and ABA shall have the right to obtain injunctive relief in addition to any other legal or financial remedies to which CGS and ABA may be entitled. You agree that you shall not publish or distribute in any medium the CUSIP database or any information contained therein or summaries or subsets thereof to any person or entity. Your only use of the CUSIP numbers and descriptions shall be in connection with the internal trading and settlement of security transactions. You further agree that the use of CUSIP numbers and descriptions is not intended to create or maintain, and does not serve the purpose of the creation or maintenance of, a master file or database of CUSIP descriptions or numbers for yourself or any third-party recipient of such materials and is not intended to create and does not serve in any way as a substitute for any products and services distributed by CGS. All use by you of the CUSIP database and the information contained therein is expressly subject to the disclaimers and limitations set forth herein. In the event you have a direct agreement with CGS, such agreement shall control your use of the CUSIP database and/or any information contained therein.

NOTE: For your protection, CGS reserves the right to view, monitor, and record activity on the Site in accordance with CGS's Privacy Policy and Cookie Notice, to the fullest extent permitted by applicable law. CGS hereby reserves the right to discontinue access to a Site either with or without notice if CGS has a reasonable basis to believe that a User is accessing or using any Content in violation of these Terms of Use, in addition to any other available rights and remedies.

3. ANTI-HACKING PROVISIONS

You expressly agree not to:

  • use or attempt to use any "deep-link," "scraper," "robot," "bot," "spider," "datamining," "computer code" or any other automated device, program, tool, algorithm, process, or methodology or manual process having similar processes or functionality, to access, acquire, copy, or monitor any portion of a Site, any Content found on or accessed through a Site, or any User Content without the prior express written consent of CGS;
  • obtain or attempt to obtain through any means any Content on a Site that has not been intentionally made publicly available, either by their public display on a Site or through their accessibility by a visible link on a Site;
  • violate any measure employed to limit or prevent access to a Site or the Content;
  • violate the security of a Site or attempt to gain unauthorized access to a Site, the Content, or data, materials, information, computer systems or networks connected to any CGS server, through hacking, password mining or any other means;
  • interfere or attempt to interfere with the proper working of a Site or any activities conducted on or through a Site, including accessing any Content prior to the time that it is intended to be available to the public on a Site;
  • take or attempt any action that, in the sole discretion of CGS imposes or may impose an unreasonable or disproportionately large load or burden on a Site or the CGS infrastructure;
  • misuse a Site by knowingly introducing viruses, trojans, worms, logic bombs or other material that is malicious or technologically harmful.

4. DISCLAIMER AND LIMITATIONS OF LIABILITY

THE DETERMINATION OF WHETHER A SECURITY OR OTHER FINANCIAL INSTRUMENT IS ELIGIBLE FOR A CUSIP IDENTIFIER, AND WHETHER THE REQUESTER HAS SUPPLIED THE APPROPRIATE DOCUMENTATION, SHALL BE MADE BY CGS IN ITS DISCRETION AND ANY SUCH DETERMINATION SHALL BE FINAL. CGS SHALL HAVE NO LIABILITY IN CONNECTION WITH A DETERMINATION THAT A SECURITY OR OTHER FINANCIAL INSTRUMENT IS NOT ELIGIBLE FOR A CUSIP IDENTIFIER. CUSIP NUMBERS AND STANDARD DESCRIPTIONS ARE THE VALUABLE INTELLECTUAL PROPERTY OF THE ABA. THE ASSIGNMENT OF A CUSIP NUMBER TO A PARTICULAR SECURITY BY CGS IS NOT INTENDED TO BE AND SHOULD NOT BE CONSTRUED AS AN ENDORSEMENT OF SUCH SECURITY, A RECOMMENDATION TO PURCHASE, SELL OR HOLD SUCH SECURITY OR AN OPINION AS THE LEGAL VALIDITY OF SUCH SECURITY. BECAUSE OF THE POSSIBILITY OF HUMAN OR MECHANICAL ERROR BY ISSUERS, CGS, THIRD PARTY SOURCES AND OTHERS, NEITHER CGS NOR THE ABA GUARANTEES THE ACCURACY, ADEQUATENESS OR COMPLETENESS OF ANY CUSIP DATA, AND SHALL NOT BE LIABLE OR RESPONSIBLE FOR ANY ERRORS OR OMISSIONS OR FOR THE RESULTS OBTAINED FROM THE USE OF ANY CUSIP DATA.

CGS, ABA, AND SPGMI DO NOT EXCLUDE OR LIMIT IN ANY WAY OUR LIABILITY TO YOU WHERE IT WOULD BE UNLAWFUL TO DO SO. THIS INCLUDES LIABILITY FOR DEATH OR PERSONAL INJURY CAUSED BY OUR NEGLIGENCE OR THE NEGLIGENCE OF OUR EMPLOYEES, AGENTS OR SUBCONTRACTORS AND FOR FRAUD OR FRAUDULENT MISREPRESENTATION. TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, CGS, ABA, OR SPGMI AND ITS SUPPLIERS DISCLAIM ANY AND ALL WARRANTIES AND REPRESENTATIONS, EXPRESS OR IMPLIED, INCLUDING ANY WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE OR USE AS TO A SITE OR ANY CONTENT, INCLUDING INFORMATION, DATA, SOFTWARE OR PRODUCTS CONTAINED THEREIN, OR THE RESULTS OBTAINED BY THEIR USE OR AS TO THE PERFORMANCE THEREOF.

A REFERENCE TO A PARTICULAR INVESTMENT OR SECURITY, A CREDIT RATING OR ANY OBSERVATION CONCERNING AN INVESTMENT OR SECURITY PROVIDED ON A SITE IS NOT A RECOMMENDATION TO BUY, SELL OR HOLD SUCH INVESTMENT OR SECURITY OR MAKE ANY OTHER INVESTMENT DECISIONS AND DOES NOT ADDRESS THE SUITABILITY OF ANY INVESTMENT OR SECURITY. CONTENT SHOULD NOT BE RELIED ON AND IS NOT A SUBSTITUTE FOR THE SKILL, JUDGMENT AND YOUR EXPERIENCE OR THE EXPERIENCE OF YOUR ADVISORS AND/OR CLIENTS IN MAKING INVESTMENT AND OTHER BUSINESS DECISIONS. CGS, ABA, OR SPGMI DO NOT ACT NOR SHALL BE DEEMED TO BE ACTING AS A FIDUCIARY IN PROVIDING A SITE OR ANY CONTENT.

NEITHER CGS, ABA, SPGMI NOR ANY OF ITS SUPPLIERS GUARANTEE THE ADEQUACY, ACCURACY, TIMELINESS OR COMPLETENESS OF A SITE, ANY CONTENT OR ANY COMPONENT THEREOF OR ANY COMMUNICATIONS, INCLUDING BUT NOT LIMITED TO ORAL OR WRITTEN COMMUNICATIONS (INCLUDING ELECTRONIC COMMUNICATIONS) OR OUTPUT WITH RESPECT THERETO OR THAT A SITE OR ANY CONTENT WILL BE FREE OF VIRUSES, WORMS OR “TROJAN HORSES”. NEITHER CGS, ABA, SPGMI, NOR ANY OF ITS SUPPLIERS SHALL BE SUBJECT TO ANY DAMAGES OR LIABILITY FOR ANY ERRORS, OMISSIONS OR DELAYS IN A SITE, INCLUDING CONTENT. EACH SITE, CONTENT CONTAINED THEREIN AND ANY AND ALL COMPONENTS THEREOF, IS PROVIDED ON AN “AS-IS” BASIS AND YOUR USE OF A SITE AND ANY CONTENT IS AT YOUR OWN RISK.

NOTWITHSTANDING ANYTHING TO THE CONTRARY IN THESE TERMS OF USE, IN NO EVENT WHATSOEVER SHALL CGS, ABA, SPGMI OR ANY OF ITS SUPPLIERS BE LIABLE FOR ANY DIRECT, INDIRECT, SPECIAL, INCIDENTAL, PUNITIVE OR CONSEQUENTIAL DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, TRADING LOSSES OR LOST TIME OR GOOD WILL, EVEN IF THEY HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, WHETHER IN CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE. NEITHER CGS, ABA, SPGMI NOR ANY OF ITS SUPPLIERS SHALL BE LIABLE FOR ANY CLAIMS AGAINST YOU BY THIRD PARTIES.

IN THE EVENT THAT LIABILITY IS NEVERTHELESS IMPOSED ON CGS, ABA, SPGMI OR ITS SUPPLIERS, IN NO EVENT SHALL THE MAXIMUM CUMULATIVE LIABILITY OF CGS, ABA, SPGMI AND ITS SUPPLIERS IN CONNECTION WITH A SITE, ANY CONTENT AND/OR THESE TERMS OF USE, REGARDLESS OF THE FORM(S) OF ACTION, WHETHER IN CONTRACT, TORT, STRICT LIABILITY OR OTHERWISE, EXCEED ONE HUNDRED DOLLARS (US$100). NO ACTION, REGARDLESS OF FORM, ARISING FROM OR PERTAINING TO YOUR USE OF A SITE OR THE CONTENT MAY BE BROUGHT BY YOU MORE THAN ONE (1) YEAR AFTER SUCH ACTION HAS ACCRUED.

You are entirely liable for activities conducted by you or anyone else in connection with your browsing and access to and use of a Site. If you are dissatisfied with a Site or with these Terms of Use, your sole and exclusive remedy is to stop using such Site.

5. LINKS TO OTHER WEB SITES FROM THIS SITE

You may, through hypertext or other computer links, gain access to web sites operated by persons other than CGS. Such hyperlinks are provided for your reference and convenience only and are the exclusive responsibility of the owners of each such web site. You agree that CGS is not responsible for the content or operation of such web sites, and that CGS shall have no liability to you or any other person or entity for the use of third party web sites. Except as described below, a hyperlink from a Site to another web site does not imply or mean that CGS endorses the content on such web site or the operator or operations of such web site. You are solely responsible for determining the extent to which you may use any content at any other web sites to which you link from a Site.

As you browse through a Site you may access other web sites that are subject to different terms of use. When you use those other web sites, you may be legally bound by the specific terms of use posted on such web sites. If there is a conflict between these Terms of Use and other terms of use of such web sites, the terms of use of such web sites will govern with respect to your use of such web sites.

6. USER CONTENT

The User grants to CGS a perpetual, nonexclusive, irrevocable, fully paid, royalty-free, sublicenseable and transferable (in whole or in part) worldwide right and license in any and all media, now known or later developed, to use, publish, reproduce, display, modify, transmit digitally, create derivative works based upon and otherwise exploit all material posted to or received through a Site by, from or on behalf of the User or anyone else using the User’s account (other than third party material transmitted through private electronic mail) (“User Content”) (including, without limitation, any names, voices, likenesses, performances and actions contained therein) for any purpose whatsoever (including, without limitation, advertising, commercial, promotional and publicity purposes) in CGS’s discretion without notice, approval, attribution or consideration to you or to any other person or entity. You represent and warrant that you have all rights necessary to grant the foregoing license, that neither the permission nor consent of any other person or entity is required to enable CGS to legally use the User Content in accordance with this license; that all User Content provided to a Site by you or anyone else using your account complies with all applicable laws, rules and regulations; and that CGS’s use of the User Content in accordance with this license will not violate or infringe upon the rights of any person or entity.

Users entering material into a Site are responsible for the content of that material. CGS does not have any responsibility for User Content, including the content of any messages or information posted by Users or others, or for the content of information accessible via direct or indirect hyperlinks from a Site. However, CGS retains the right, to review, edit or delete User Content that CGS deems to be illegal, offensive or otherwise inappropriate.

You may not input or distribute any material through the Site that is promotional in nature, including solicitations for funds or business, without the prior written authorization of CGS.

7. PRIVACY POLICY AND COOKIE NOTICE

Please see the CGS Privacy Policy and Cookie Notice for information on CGS’s data collection and use practices with respect to a Site.

As part of access to portions of a Site, you may be required to provide certain information, such as, your name and email address. In addition, you may be required to select a username and password. You represent and warrant that any information you provide to CGS in connection with a Site shall be accurate and complete. You further agree to keep any passwords/user IDs in connection with a Site in strict confidence and promptly advise CGS of any actual or threatened unauthorized disclosure or misuse of a Site or any passwords/user IDs with respect to a Site that come to your attention. You shall cooperate with CGS in enforcing the restrictions and limitations set forth herein.

8. COUNTRY CONDITIONS

The terms and conditions set forth in this section (the “Country Conditions”) are the result of various regulatory and/or legal requirements relating to usage of a Site including its Content. Your use of a Site in the specified jurisdictions is subject to these Country Conditions

Australia. To the extent that S&P’s Global Ratings credit ratings (the “Ratings”) are included as part of any Content, Standard & Poor’s (Australia) Pty Limited (ABN 62 007 324 852), being the holder of Australian Financial Services License No. 337565 issued pursuant to the Corporations Act 2001 (Cth) (“SPA”), whose registered office is located at Level 45, 120 Collins Street, Melbourne Vic 3000 Australia, shall provide such portion of such Content to you and S&P shall license you the right to use the intellectual property in such portion of such Content and, as owner of such intellectual property, shall receive any fees with respect thereto. SPA expressly agrees to be bound by the terms and conditions of this Terms of Use to the extent it applies to the provision of the Ratings. You accept and acknowledge that SPA’s provision of the Ratings as part of a Site to you is based on, and conditional on, the veracity and accuracy of your representation that you are a “Wholesale Client” (as such is defined in Chapter 7 of the Corporations Act of 2001 (Australia)). In addition, you acknowledge that Ratings and/or related research licensed to you pursuant to these Terms of Use or your Other Agreement, as applicable, are not intended for, and should not be distributed to, any person other than a Wholesale Client (to the extent such distribution is permitted by your Other Agreements). In furtherance of the foregoing, you undertake that (a) you will not pass on any Rating and/or related research to a party who is not a Wholesale Client and (b) that you will obtain the same undertaking from your own Wholesale Clients (to the extent such distribution is permitted by your Other Agreements). S&P Global represents that it is authorized to bind SPA to the terms and conditions set forth in these Terms of Use to the extent such terms and conditions pertain to the provision of Ratings.

All countries located in Europe, the Middle East or Africa (“EMEA”). In the event your use of the Ratings is in any country located in EMEA, you further acknowledge and agree to the following: the Ratings shall not in any circumstances be used by you where, as part of an effort CUSIP® is a registered trademark of the American Bankers Association. CUSIP Global Services is managed on behalf of the American Bankers Association by S&P Global Market Intelligence LLC. to sell securities to Retail Investors (as defined below), you use the Ratings: (a) to create a type of recommendation, (b) to create your own interpretation of the Ratings or (c) in some other form of “risk classification”. For the purposes of this Terms of Use, “Retail Investor” shall mean an individual investor who buys and sells securities or other financial products for his/her personal account, and not for another company, individual or organization.

9. ADDITIONAL LEGAL TERMS

These Terms of Use constitute the entire agreement between the parties relating to each Site and supersedes any and all other agreements, oral or in writing, with respect to such Site. The failure of CGS to insist upon strict compliance with any term of these Terms of Use shall not be construed as a waiver with regard to any subsequent failure to comply with such term or provision. To the fullest extent permitted by law, you shall indemnify, hold harmless and defend CGS, ABA, SPGMI and its suppliers from and against any and all costs, claims, damages or liabilities (including reasonable attorneys’ fees and court costs) arising out of any breach by you of Section 3 (Anti-hacking Provisions). These Terms of Use are personal to you, and you may not assign your rights or obligations to anyone. If any term or condition hereof is found by a court, administrative agency or jurisdiction to be invalid or unenforceable, it shall be deemed modified to the minimum extent necessary to make it valid, legal and enforceable. If such modification is not possible, the relevant term shall be deemed deleted and the remaining terms and conditions hereof shall remain in full force and effect and shall be enforceable to the maximum extent permitted by law. These Terms of Use, your rights and obligations, and all actions contemplated by these Terms of Use shall be governed by the laws of the United States of America and New York State. The parties agree that the State and Federal courts of New York shall be the exclusive forums for any dispute arising out of these Terms of Use and the parties hereby consent to the personal jurisdiction of such courts. Any claim must be brought in the claimant’s individual capacity, and not as a plaintiff or class member in any purported class, collective, representative, multiple plaintiffs, or similar proceeding (“Class Action”). The parties expressly waive any ability to maintain any Class Action in any forum.

10. HOW TO CONTACT US

If you have any questions or concerns about these Terms of Use, please contact us at: privacy_official@CUSIP.com and/or S&P Global Inc.’s Chief Privacy Officer and Data Protection Officer at privacy@spglobal.com or by mail to: Chief Privacy Officer, S&P Global Inc., 55 Water Street, New York, NY 10041

CUSIP® is a registered trademark of the American Bankers Association.
CUSIP Global Services is managed on behalf of the American Bankers Association by S&P Global Market Intelligence LLC.

Privacy and Cookie Notice

CUSIP Global Services (“CGS”) (managed on behalf of the American Bankers Association (“ABA”) by S&P Global Market Intelligence LLC (“SPGMI”)), which you have a contract with or which provide services to you, (collectively or individually, as applicable, referred to as "CGS”, “ABA”, “SPGMI”, “Company”, "we", "our", "us") respect your right to privacy. This Customer Privacy Policy explains how we collect, share and use personal information about you, and how you can exercise your privacy rights. If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Customer Privacy Policy.

What personal information does CGS collect and why?

The personal information that we may collect about you broadly falls into the following categories:

1. Information that you provide voluntarily

We ask you to provide certain information voluntarily, such as your contact details, user credentials, and employment information.

Learn More Below

For instance, this can be by way of filling in an online form when you register to use our products and services, when you register to attend an event, when you provide us with your business card information or when you request to receive information from us. The types of information we ask you to provide, and the reasons why we ask you to provide it, include:

Types of personal information Why we collect it
Billing information To maintain your account with us.
Contact details including name, telephone numbers, email address and postal address. To respond to correspondence and enquiries you send us. In some cases, to gather information needed to provide products and services requested by you or your employer. To obtain your feedback regarding our products and services.
User credentials including name, email address and personal information you provide to us in a profile. To set up and maintain your user account. To monitor and enforce compliance with our contractual terms.
Employer and employment information such as job title, function, seniority, department, and the address/country/ city of your office. To manage your individual user account which is covered by a corporate account of one of CGS's corporate customers, for instance, the corporate account of your employer.
Your preferences and interests, for instance which newsletters you would like to be subscribed to or what markets you are interested in. To enable us to send you tailored information on our products and services across our divisions that may be of interest to you.
Social security numbers, credit card numbers, and personal financial data (such as specific salary, mortgage details, net worth or individual portfolio information). We refer to this type of personal data as "Sensitive Financial Data". In some cases, our corporate customer or you may provide Sensitive Financial Data to us for the purpose of informing our statistical analysis or for us to use in providing our products or services to you. Sensitive Financial Data will not be used for purposes other than these, rented or otherwise made available to third parties for public distribution.

2. Information that we collect automatically

We may also collect certain information automatically from your device, including information regarding your use patterns of our products and services. In some countries, including countries in the European Economic Area, this information may be considered personal information under applicable data protection laws.

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Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), "click stream" data and other technical information. We also collect information about how your device has interacted with our websites and products, including the pages and products accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our website and the users of our products and services, where they come from, and what content on our website and products and services is of interest to them. We use this information:

  • for our analytics purposes;
  • to improve the quality and relevance to users, of our websites and products and services;
  • to develop and update our websites and products and services;
  • for customer services purposes, for instance, reviewing our customers' training needs in respect of the use of our products;
  • to satisfy CGS's corporate customers' requests regarding the use of our products and services by the individual users licensed by their corporate account (please note that such information in many instances and jurisdictions will be offered to clients in an aggregated form); note that customers may be required by law to request such information from S&P;
  • to send you tailored information on our products and services that we believe may be of interest or value to you and also marketing and promotional e-mails with your consent if and when required by applicable law;
  • on rare occasions to identify unauthorized use or unauthorized distribution of our products and services related or unrelated to a security issue;
  • where relevant, to review and / or update our pricing model agreed with our corporate customers; and
  • for billing purposes, so that we or others (such as content providers) are able to bill for the services provided

Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies and similar tracking technology”.

3. Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party sources (including your employer or business partner if you use CGS’s products covered by their corporate subscription), but only where we have checked that these third parties either have your consent or are otherwise legally permitted or required to disclose your personal information to us

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The types of information we collect from your employer (if you use CGS products under your employer's corporate subscription) consists of your contact details and employment information.

The types of information we collect from other third parties include information regarding you as a marketing prospect. For example, we collect personal information from marketing vendors, social media sources, third party conferences, and other sources to the extent permitted by applicable law. We use the information we receive from these third parties to market our products and services across our divisions to you, to supplement personal information we have for purposes such as maintaining and correcting our records, adding supplemental data fields, and similar reasons to enhance the delivery of our products and services to you.

We collect personal information as part of our content collection process for some of our products. We obtain this from a variety of sources, including public filings and websites, to display within some of our products.

In general, we will use the personal information we collect from you or from third party sources only for the purposes described in this Customer Privacy Policy or for purposes that we explain to you at the time we collect your personal information. However, we may also use your personal information for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

Who does CGS share my personal information with?

We may disclose your personal information to the following categories of recipients:

  • ABA, SPGMI and its group companies, third party service providers, product content providers, and partners;
  • Your employer;
  • Competent law enforcement bodies, regulatory, government agency, court or other third parties;
  • Potential Buyers;
  • Any other person with your consent to the disclosure.

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• Our group companies, product content providers and partners;

We provide personal information to group companies, SPGMI divisions, and business partners who process personal information for purposes in line to those described in this Customer Privacy Policy or notified to you when we collect your personal information. Content providers will process your personal data for billing purposes only. A list of our current group companies is available here and a list of our content providers and partners is available here. We do not sell your usage data to third parties for the purposes of their marketing third party products or services to you;

• Third party service providers;

We provide personal information to third party service providers who provide data processing services to us. A list of our current service providers is available here;

• Your employer;

We provide personal information to your employer, in many instances and jurisdictions in an aggregate form, for purposes such as to fulfil our contract with them, to inform them of potential group training needs, to inform them of product/service use by certain categories of user and for pricing purposes.

• Competent law enforcement bodies, regulatory, government agency, court or other third parties;

We provide personal information to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;

• Potential Buyers;

We provide personal information to a potential buyer (and its agents and advisers) in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Customer Privacy Policy;

• Any other person with your consent to the disclosure.

Please be aware that if you disclose personal information on website message boards or chat areas, that information may be collected and used by third parties without our knowledge and may result in unsolicited communications from third parties. Such activities are beyond the control of CGS.

Legal basis for processing personal information (EEA visitors / users only)

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

As a general rule, we will only collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you (for instance, your subscription to one of our products), or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for instance, where we process personal data regarding the usage of our products and services, as described above). In some cases, we may also have a legal obligation to collect personal information from you.

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If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).

Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to provide our products and services and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our products and services, advising you of product features or new releases, informing you of product maintenance, or undertaking marketing activities. We may have other legitimate interests and if appropriate it will be clear to you at the relevant time regarding what those legitimate interests are.

Where we send you communications regarding our products or services from our different divisions and affiliates that may be of interest to you, we do so based on your consent, if and when required by applicable law.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided below.

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you, including to serve interest-based advertising. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice

How does CGS keep my personal information secure?

We use appropriate technical and organizational measures to protect the personal information that we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information.

International data transfers

We use appropriate technical and organizational measures to protect the personal Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).

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Specifically, our servers are located in various countries which may be located outside of the jurisdiction where we collected the data, such as US, Canada, United Kingdom, Ireland, Germany, the Netherlands and Singapore. This means that when we collect your personal information we may transfer it to or process it in any of the countries in which we do business.

Our group companies, third party service providers, product content providers and partners, with whom we may share personal information as described above, are located in and transfer personal information to various jurisdictions around the world.

However, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Customer Privacy Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law.

You may request our Standard Contractual Clauses by contacting privacy_official@CUSIP.com and/or privacy@spglobal.com. We have implemented appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

Data retention

We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a product or service you have requested, as set forth in our information governance procedures, or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate business need to process your personal information, we follow our information governance procedures and either delete or anonymize your personal information, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If you wish to receive further information about the period of time for which we will process your personal information, please contact privacy_official@CUSIP.com and/or privacy@spglobal.com.

Your data protection rights

Your rights include the right to access, correct, update or request deletion of your personal information. You also have the right to withdraw the consent you have provided to us.

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You have the following data protection rights:

  • to access, correct, update or request deletion of your personal information.
  • you can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you, by using the SPGMI and/or CGS contact details below, or by visiting the preference center by clicking here:
  • LINK to SPGMI preference center https://pages.marketintelligence.spglobal.com/SPGMI-Email-SubscriptionCenter.html
  • if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area and Switzerland are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws

Notice to persons whose personal data is contained in SPGMI products (“SPGMI Products”).

Some of SPGMI Products contain personal data about persons who are directors, officers, managers or large shareholders of companies that feature in the SPGMI Products, which data SPGMI obtains from publicly available sources.

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Personal data in SPGMI Products is limited to business contact details, professional details, work data, compensation details, and education data and is obtained by SPGMI from publicly available sources.

Information in SPGMI Products is for reference only, for instance, to identify the officers or shareholders of a particular organization and, therefore, is made available to SPGMI’s customers for this purpose. Customers' use of your personal information is restricted by their contract with SPGMI.

SPGMI customers are located anywhere in the world, including countries with data protection laws that may differ from or offer lower protections than the laws of your country. SPGMI requires its customers by contract to comply with any applicable data protection laws.

SPGMI may share personal data in its products with affiliated companies and with those parties who provide content to SPGMI. SPGMI will not use your personal data for any other purposes than as described above, which is within SPGMI's legitimate commercial interests to provide SPGMI products and services to its customers.

SPGMI updates its product information for accuracy on a regular basis. SPGMI removes data from its systems when such data becomes obsolete inaccurate and

SPGMI has established data governance standards for collection, use and retention of the personal information. For information about your rights under data protection law, please refer to the relevant section above.

The controller of your personal data is SPGMI. Please see details below in section "How to contact us" for our DPO details and the details of our EU local representative.

Updates to this Customer Privacy Policy

We may update this Customer Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Customer Privacy Policy, the updated version will be posted, and we will take appropriate measures to inform you, consistent with the significance of the changes we make. If and where your consent is required by applicable data protection laws, we will obtain your consent to any material Customer Privacy Policy changes.

You can see when this Customer Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Customer Privacy Policy.

How to contact us

If you have any questions or concerns about our use of your personal information, please contact us at: privacy_official@CUSIP.com and/or S&P Global Inc.’s Chief Privacy Officer and Data Protection Officer privacy@spglobal.com or by mail to: Chief Privacy Officer, S&P Global Inc., 55 Water Street, New York, NY 10041.

The Company that contracted with your employer or that you select to provide you services is the controller of your personal data. If the controller of your personal information is located outside the EEA, below are the details of the EU representative of non-EEA controller:

For CGS/SPGMI:

S&P Global UK Limited

20 Canada Square

Canary Wharf

London

E14 5LH

MIPrivacyOfficer@spglobal.com

Privacy Preference Centre

Your Privacy

When you visit any web site, it may store or retrieve information on your browser, mostly in the form of cookies. This information might be about you, your preferences or your device and is mostly used to make the site work as you expect it to. The information does not usually directly identify you, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies. Click on the different category headings to find out more and change our default settings. However, blocking some types of cookies may impact your experience of the site and the services we are able to offer.

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