Privacy Policy - Bloomberg Second Measure

Last updated: April 7, 2021

Bloomberg Second Measure LLC, Bloomberg L.P., Bloomberg Finance L.P., and their affiliates (together, “Bloomberg”) respect the privacy rights of our users and are strongly committed to protecting your privacy. This Privacy Policy applies to personal information collected through this Bloomberg Second Measure web site and the Bloomberg Second Measure web application app.secondmeasure.com (together, “this Site”). This Privacy Policy does not apply to any other web sites, products, or services or to information collected in any other way (whether offline or online), by Bloomberg, unless otherwise expressly indicated by Bloomberg.

Personal Information We Collect

Bloomberg or its designated service providers collect personal information through this Site, such as during login, when you request a password change, when you request certain services or products including a demonstration, or submit information to subscribe to our newsletter, which may include your name, phone number, address, email address, contact information, and password. If you do not provide certain personal information, not all functionality on this Site will be available.

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

Use of Cookies and Other Electronic Technologies

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

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

Bloomberg, its designated service providers, or third-party advertisers or their advertising servers may also place or recognized unique cookies on your computer or use other electronic technologies in order to help display advertisements that you see on this Site or on other websites. Information about your visits, to, and activity on, this Site and other websites, an IP address, the number of times you have viewed an advertisement, your interests and preferences and other such usage information is used, alone or in combination with other information, to create aggregate groups of users and to display advertisements that may be of particular interest to you or a group of users with similar interests. We may use Web beacons, provided by third-party advertising companies, to help manage and optimize our online advertising and product performance. Web beacons enable us to recognize a browser’s cookie when a browser visits this Site, and to learn which banner ads bring users to this Site. The use and collection of your information by third-party service providers, and third-party advertisers and their advertising servers is not covered by this Privacy Policy. To “opt out” of advertising cookies placed by participating companies in the Self-Regulatory Program for Online Behavioral Advertising, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here for browsers and click here for mobile devices. To “opt out” of advertising cookies placed by the Network Advertising Initiative’s (“NAI”) online behavioral advertising member networks, and thereby limit the tracking of your online activity and the targeted advertising you receive, please click here for browsers and click here for mobile devices. To learn how to manage privacy and storage settings for Flash cookies click here.

How We Use and Disclose Your Personal Information

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

to provide our products and services
to communicate with you
to help Bloomberg improve our products and services and develop new products and services
to provide support for our products and services, and for Bloomberg internal quality control purposes
to provide you with offers and promotions about services and products of Bloomberg or of other parties that may be of interest to you
to enhance your experience with this Site, including to save your preferences and login information
to analyze web site usage and analyze use of the Site
to protect the interests, rights, safety, or property of Bloomberg or others and to monitor compliance with and enforce the terms of any agreement with Bloomberg
to operate our services, products and systems properly.

You may instruct Bloomberg at any time not to use your personal information collected in connection with the product you requested to provide you with offers and promotions by contacting privacy@bloomberg.com and indicating Bloomberg Second Measure in the Subject line of your inquiry. Please note that if you exercise choice in this manner, you will continue to receive communications concerning your account and products and services you requested, and in response to any requests for information by you. Please also note that these processes may take some time to complete, consistent with applicable law.

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

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

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

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

Job Openings

Bloomberg, and designated service providers, may collect personal information directly from you in connection with job openings on this Site, such as when you submit a job application, including without limitation your resume or CV, or from others authorized to provide the information. Such personal information may include your name, email address, postal address, other contact information, social media handle or profile information, demographic information, or professional, employment-related, or education information. If you do not provide certain personal information, we may not be able to fully consider your application. Bloomberg and designated third parties may collect, process, use, store, and disclose this personal information for carefully considered business purposes which include some or all of the following:

to consider your suitability for employment;
to communicate with you;
for general statistical analysis and reporting purposes, including surveys and Bloomberg internal quality control purposes;
to enhance your experience with this Web site, including to save your preferences, login and profile information;
to analyze web site usage and analyze use of the Web site;
for legal or regulatory requests, process, or obligations;
to protect the interests, rights, safety, or property of Bloomberg or others; and
to operate our services, products, and systems properly.

If you are offered a position of employment at Bloomberg, certain personal information submitted in your application may be made available in an internal employee directory or other tool, for business-related purposes.

If we do not employ you at this time, we may retain and use the information that we obtain as part of your application process so as to be able to consider your application later if a suitable position becomes available, for general statistical analysis and reporting purposes, for legal or regulatory purposes, for the other purposes set out in this notice, and, if appropriate, to refer back to this application if you apply again.

Accuracy, Security and Retention of Your Personal Information

Any of your personal information collected by Bloomberg through this Site is kept on secure servers. Bloomberg uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures to protect your personal information on such servers. To help us protect your privacy, you should maintain the secrecy of your username and password you set up in connection with your participation in this Site’s service, if any. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements.

Rights with Respect to Your Personal Information

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

Transfer of Your Personal Information to Other Countries

Some of the uses and disclosures mentioned in this privacy policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country. By using our products and services, you consent to such transfers and processing, including to and in the United States. Bloomberg’s Intra-Group Personal Data Protection Statement below provides additional information about the transfer of personal information from the EU, EEA, and Switzerland (collectively, “EU”), or the United Kingdom, in accordance with the EU General Data Protection Regulation (“GDPR”) and UK GDPR.

Links to Third-Party Web Sites

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

Questions Regarding This Privacy Policy

If you have questions regarding this privacy policy, please contact us at privacy@bloomberg.com and include Bloomberg Second Measure in the Subject line of your inquiry. If you have complaints about Bloomberg’s processing of your personal information, you may have the right to contact the applicable supervisory authority.

Modifications to This Privacy Policy

Bloomberg reserves the right to change this privacy policy at any time by posting revisions on this web page.

Such changes will be effective upon posting.

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Law Enforcement Data Request Statement

Bloomberg will not disclose client data (which may include personal information, together “client data”) in response to requests from law enforcement, governmental, or regulatory agencies except where required to do so by law (for example, in response to valid and properly-served legal process such as a subpoena or search warrant). Bloomberg analyzes all such requests to the extent necessary and appropriate prior to responding to ensure they are valid and that Bloomberg is legally obligated to comply with them. Bloomberg’s policy is to challenge requests, including in court, in the event that Bloomberg concludes the request exceeds the relevant agency’s authority or is otherwise unlawful. Bloomberg will attempt to notify its client prior to disclosing client data and provide its client with the opportunity to challenge the legality of the request, unless: (1) prohibited by applicable law from doing so, or (2) there are clear indications of unlawful conduct in connection with the client’s use of Bloomberg services. Notwithstanding any of the foregoing, Bloomberg reserves the right to respond to urgent law enforcement requests if Bloomberg believes in good faith that an emergency involving imminent danger of death or serious physical injury justifies such disclosure.

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Intra-Group Personal Data Protection Statement

Revised December 31, 2020

Bloomberg Finance L.P., its operating agent Bloomberg L.P., and affiliates (“Bloomberg”) are committed to compliance with their data protection obligations throughout the world. This Intra-Group Personal Data Protection Statement (“Statement”) sets out the privacy principles Bloomberg follows with respect to personal information that it transfers from the European Union, European Economic Area, and Switzerland (collectively, “EU”) or the United Kingdom (“UK”), in accordance with the EU General Data Protection Regulation (“GDPR”) and UK GDPR.

Bloomberg has implemented robust processes and protections to meet the requirements of transferring personal information to third countries in accordance with applicable data protection laws. Accordingly, the relevant Bloomberg group companies have entered into Intra-Group Personal Data Protection Agreements (“IGAs”) to ensure that personal information transferred from the EU or UK is subject to appropriate safeguards, and to clearly identify the Bloomberg group companies responsible for transfers of personal information from the EU or UK.

The IGAs incorporate unchanged EU Commission Standard Contractual Clauses (“SCCs”), which include specific obligations and rights around transfers of personal information, and ensure that any personal information leaving the EU and/or UK will be transferred by Bloomberg in compliance with applicable EU and UK data protection laws. The IGAs include the operational procedures and security measures we use to maintain the accuracy and integrity of personal information and protect personal information.

Governance

We regularly review and update our governance framework, including roles and responsibilities of personnel, and maintain a working group to oversee data protection regulation compliance and document results and decisions as they relate to personal information management.

Accountability and Recordkeeping

We map the personal data life cycle and maintain a personal data map inventory, including documenting personal data flows within Bloomberg’s systems and any disclosures to third-party systems.

Security

We invest in and maintain organisational, technical, and physical safeguards intended to ensure the protection of personal information. We engage in ongoing monitoring and testing of the efficacy of these safeguards. Our data centers are dedicated solely to our products, services, and operations, and have secure and monitored access controls.

Privacy By Design

We integrate personal data mapping and accountability into our product design processes, and build personal data security into our development and product life cycles.

Administrative controls

We regularly review and update our policies, procedures, and controls to address our data protection obligations. We conduct data protection executive education and tailored training programs for data protection compliance.

The Bloomberg group companies involved in personal information transfer and management are identified in the IGAs as Data Exporter(s) or Data Importer(s). Bloomberg is an independent Data Controller unless otherwise specified. With respect to specific products and services where Bloomberg acts as a Data Processor to our customers, we make available to our customers additional data processing terms, including unchanged EU-Commission approved Controller-to-Processor SCCs. Products where Bloomberg acts as data processor include Bloomberg Vault and Bloomberg Regulatory Reporting Services.

Contact information

Questions or comments regarding this Statement should be submitted to Bloomberg’s privacy team at the following address:

General Counsel
731 Lexington Avenue
New York, NY 10022
United States

Or by emailing privacy@bloomberg.com.

This Statement may be amended from time to time, consistent with the requirements of applicable law, and will be effective immediately.