Privacy Policy

Last Updated: April 2021

Cortera respects and values your privacy. This Privacy Policy explains how we collect your Personal Data (defined below) on those web sites of Cortera that post or link directly to this Privacy Policy (collectively, the “Site”) and through offline means, how we use, disclose, and protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. Cortera may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. Please review the “Last Updated” legend at the top of this page to determine when this Privacy Policy was most recently revised.

For the purposes of this Privacy Policy, “Cortera”, “we”, “us”, and “our” means Cortera Inc. 

You do not have to provide us with any Personal Data to visit the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site.

This Privacy Policy shall also apply to any Cortera mobile application and other forms of Cortera online activity that reference this Privacy Policy. In such instances, the term “Site” shall include the applicable mobile application or other Cortera online activity whenever that term is used herein.

Types of Data Collected

We gather Personal Data and Other Data (as described below).

Collection of Personal Data

Personal data is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number (“Personal Data”). We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so.

  • Account Setup. If you create an account to take advantage of the full range of services offered on the Site, we ask for and record Personal Data such as your name, address, phone number, and email address. We use your email address to send you updates and news, and contact you at the request of other users (such as other registered users who wish to contact you about a rating you have submitted). Your contact information will not be shared with other users.
  • Logging in to Use Features. In a few areas on the Site, we also ask you to provide information that will enable us to verify whether you are entitled to access and use certain information, materials and services available from the Site. It is completely optional for you to participate. However, failure to participate may mean that you cannot access and use certain information, materials and services. These include areas where users log on to certain areas of the Site, at which point you may be prompted to provide us with your User ID code and password as a condition to gaining access to certain information, materials or services.
  • Submissions. We store and may publicly display your submissions in order to provide the services that we offer. When we display your submissions, we do so together with the user identification code (the “User ID”) you have established. If we display your submission, we may also contact you at the request of other users who wish to discuss your submission with you. We will not reveal your contact information to other users. The term “submissions” refers to the information that you submit or post to the Site for public display, such as business ratings and reviews.
  • Requests to Contact Other Users. If you request that Cortera contact another registered user on your behalf to discuss a submission, we will share your email address with such other registered user. The decision of whether another registered user wishes to respond to you rests solely with that user.
  • Feedback. If you contact us to provide feedback, update a business listing, dispute a payment rating, or ask a question, we will record any Personal Data and other content that you provide in your communication so that we can effectively respond to your communication.
  • We may use third-party payment services (each, a “Payment Service”) to collect payments made through the Site. If you wish to make a payment through the Site, you may be directed to a webpage that is hosted by a Payment Service (or a Payment Service’s service providers) and not by Cortera. Any Personal Data that you provide through a Payment Service page will be collected by the Payment Service and not by Cortera, and will be subject to Payment Service’s privacy policy, rather than this Privacy Policy. Cortera has no control over, and is not responsible for, a Payment Service’s use of information collected through a Payment Service page.
  • Cortera collects information through various other means, including searches online, participation at conferences and events, individual introductions, from employers that enroll their employees in our services, and from selected third-party business partners. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services.
  • We collect name and professional contacts details of employees of our service providers, either directly from those third-party employees or from their employers.
  • Information Displayed in Cortera Business Profiles. Cortera collects information about businesses to produce the business profiles displayed through the Site. Cortera primarily collects this business information offline. This business information may include the names and contact information for business owners or executives, such as postal addresses, email addresses, or phone numbers (“Public Information”). Some of this Public Information comes from federal, state, or local government public records.

Use of Personal Data Collected

We use Personal Data for legitimate business purposes, including the following:

  • Fulfillment of Requests.  Cortera may use Personal Data about you to deliver products and services to you, and to provide you with information about products and services you’ve ordered.  We will engage in these activities to manage our contractual relationship with you and to fulfil our contractual obligations. 
  • We may distribute your submissions to third parties, as permitted pursuant to our Terms. When we distribute your submissions to third parties, we typically include your User ID, but we generally do not include your Personal Data unless you include your Personal Data in your submissions. However, there may be exceptions where your name and email address domain is shared with other members of the Site when you elect to participate in discussions with other members (an email address domain refers to the email service that you use; e.g., Gmail, Yahoo, etc.) For example, within the Cortera Circles offering, if you create or reply to a discussion thread, your first and last name will be displayed along with your submission to the members of your Cortera Circle. Another example is, if you apply to join a Cortera Circle, your name and email address domain will be displayed to the manager of that Cortera Circle so that the manager can evaluate your application to join the Cortera Circle.
  • If you request that Cortera contact another registered user on your behalf to discuss a submission, we will share your email address with such other registered user so that such other use can reply directly to you.
  • If we display your submission, we may contact you at the request of other registered users who wish to discuss your submission with you. The decision of whether you wish to respond to another user will lie solely with you. Should you elect to respond to another user, your response will be transmitted outside of this Site; accordingly, this Privacy Notice will not apply to your response. If you respond to another user, that user may be able to identify you and you hereby agree to assume all risks associated therewith.
  • Marketing Communications.  From time to time, in compliance with applicable laws, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you.  If your employer is a Cortera customer, we may also inform you of such products, programs, services and promotions using Personal Data about you that your employer provided to Cortera.  We may also use Personal Data of media contacts for press release distribution or sharing other newsworthy developments related to our business activities. If you would prefer that we not send electronic marketing messages to you, please see the “Your Choices” section below. 
  • Other Business Purposes.  We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the efficiency of our services), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site, completing business transactions (for example, to confirm content requested is received by customers), development and delivery of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of the Site are of most interest to users), product development, conducting surveys and market research, and administering individual accounts. We use name and professional contacts details of employees of our service providers to as part of executing and managing our contracts with them and paying their invoices.   
  • Administrative Communications.  Cortera reserves the right to use Personal Data to send to you important information regarding the Site, products, services, your account status, the User Agreement, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of the Site, products and/or services. Because this information may be important to your use of the Site, products and/or services, you may not opt-out of receiving such communications.  We will engage in this activity to manage our contractual relationship with you and/or to comply with a legal obligation.
  • Compliance with law and regulation. We may use Personal Data as necessary to comply with applicable legal and regulatory requirements such as sales tax collection, audits, etc.
  • Enforcement. We may use the information we collect in connection with your use of the Site (including your Personal Data) in order to investigate, enforce, and apply our Terms.
  • Where required by applicable law, we will only use Personal Data with your consent.

Collection and Use of Other Data

We and our service providers may also collect and use the following types of data, referred to in this Privacy Policy as “Other Data”:

  • Monitoring Data. Cortera and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of the Site (“Monitoring Data”). We use Monitoring Data to help us understand who uses the Site and to improve and market it, as well as our other web sites and services.

Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose. 

  • Aggregated Data. We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code.  Such aggregate information may also be used for any purpose.
  • Cookies.  To enhance the Internet experience on the Site, Cortera and our service providers may use ‘cookies’ on the Site.  Cookies are data that a web server transfers to an individual’s computer for recordkeeping and other purposes.  We use cookies and other technologies to facilitate users’ ongoing access to and use of our Site.  If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site, to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about disabling cookies can be found on your Internet browser provider’s web site.  

The Site may have a Cookie Policy that applies to its use of cookies and other similar tracking technologies.  If it does, then the Cookie Policy will apply in addition to this Privacy Policy.

  • Tools.
    • We and our service providers may also use various common Internet tools such as ‘pixel tags,’ ‘action tags,’ ‘web beacons,’ ‘.gif tags,’ ‘JavaScript’ or similar technologies (together, “Tools”) in connection with Site pages and email messages in certain formats to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver services, and to help determine the effectiveness of promotional or advertising campaigns.  When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened.
  • Cortera uses cookies and Tools to understand how the Site is used and to customize and enhance the Internet experience of individual users. When you revisit the Site, Cortera may recognize you by a Tool and customize your experience. For example, once you have completed the registration process, a cookie and/or Tool will be used to avoid having you register again. We believe cookies and Tools add value to the user experience. 
  • We may use Google Analytics, which uses cookies and other similar technologies, to collect and analyze information about Site use and to report on activities and trends. The service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to https://policies.google.com/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
  • We do not respond to browser do-not-track signals at this time.
  • We may use third-party services to verify that you are a human user. Any information collected as part of such verification is subject to the privacy policy of the third-party service provider.
  • IP Addresses. When you visit and interact with the Site, we and our third-party service providers may collect Internet Protocol (IP) addresses.  Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP).  This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited.  We use IP addresses to understand how the Site is used by our users, to improve the Site and to enhance user experience of the Site.  We may also derive your approximate location from your IP address.

If we are required to treat Other Data as Personal Data under applicable law, then we may use and disclose it for the purposes described above, as well as for the purposes for which we use and disclose Personal Data as detailed in this Privacy Policy.

Our Advertising

We may use third-party advertising companies to serve advertisements regarding products and services that may be of interest to you when you access and use the Site, our apps and other websites or online services, based on information relating to your access to and use of the Site and other websites or online services on any of your devices, as well as on information received from third parties.  To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags).  They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop.  If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/.  You may download the AppChoices app at www.aboutads.info/appchoices to opt out of this practice in mobile apps. 

Disclosure of Personal Data Collected

We may disclose Personal Data for the following purposes:

  • Third-Party Service Providers.  We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, data analysis, order fulfillment, payment processing, and other services. 
  • Affiliate Communications. In compliance with applicable laws, Cortera may transfer Personal Data among our affiliates (a list of which is available at www.moodys.com/Affiliates_of_Moodys) to allow our affiliates to contact you regarding products, programs, services and promotions that they believe may be of interest to you, and such affiliates may otherwise use your Personal Data in accordance with the privacy policy applicable to them as specified in the referenced above in this bullet.  If you would prefer not to receive marketing communications from Cortera or our affiliates, please see the “Your Choices” section below. Cortera Corporation will be the party responsible for jointly used Personal Data.
  • Strategic Partners and Co-Branded Sites.  From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with Cortera to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”).  These special relationships may include co-branded web sites (“co-branded pages”). Any information, including Personal Data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners.  You should check these third parties’ web sites for information regarding their privacy practices.  PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.  If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.
  • Third-Party Data Providers.  If you subscribe to a Cortera product or service that contains third-party data, we may be required to provide your Personal Data to the third party as part of our reporting obligations. We will only do so if a third-party data provider conditions your receipt of their data on knowing your identity. 
  • Conferences and Events.  When you attend a conference or event organized by Cortera, your name and contact information may be shared with other attendees and co-hosts of the conference or event.
  • Promotions.  We may share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to those Promotions. 
  • Assignment.  We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
  • Law Enforcement; Emergencies; Compliance.  We may use and disclose Personal Data about you to others as we believe to be appropriate: (a) in compliance with laws, rules, or regulations in any country in which Cortera operates, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from government or public authorities, including government and public authorities outside your country of residence; (d) to enforce our Terms of Use; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety or property of Cortera, its affiliated entities, you, or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.

If you would like to receive more information on the third parties with whom we share your Personal Data, please contact us by using the information provided in the “Contact Us” section below.

Your Choices

We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. 

  • If you no longer want to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by submitting a Privacy Request Form or by clicking the “unsubscribe” link at the bottom of our emails.
  • If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by submitting a Privacy Request Form.

We will comply with your request(s) as soon as reasonably practicable, and in accordance with applicable law.  Further, please note that requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing emails from Cortera.  Please also note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.

You may also indicate your choices regarding marketing-related emails by contacting us via postal mail or telephone using the information in the “Contact Us” section below, or if you have a Site profile/account, by changing your preferences on your Site profile/account at any time.

How you can access, change or suppress your Personal Data

If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may make a request by accessing and completing a Personal Data Request Form.   We will respond to your request consistent with applicable law.  For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.  We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.  Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion. 

Links

The Site may contain links to other Internet web sites, including social media sites and third-party hosted collaboration tools. These linked sites are not under Cortera control.  We provide links only as a convenience, and Cortera does not endorse or control, and is not responsible for, the privacy practices or the content of these linked sites.  If you provide any Personal Data through any third-party web site, or choose to communicate with us using third-party collaboration tools or other social media platforms, your transaction will occur on that third party’s web site (not the Site) and the Personal Data you provide will be collected by, and controlled by the privacy policy of, that third party.  We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.  PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES THAT DO NOT POST OR LINK DIRECTLY TO THIS PRIVACY POLICY.

Security Measures

Cortera has established reasonable organizational and technical measures to protect Personal Data within our organization from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Please note that while Cortera has endeavored to create a secure and reliable Site for users, no site is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by contacting us using the information provided below in “Contact Us” (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).

Data Integrity

Cortera will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Privacy Policy, or authorized by you.  Cortera will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you).  Cortera depends on you to update or correct your Personal Data whenever necessary.

Retention Period

We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.  The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). 

Cross Border Transfer of Personal Data

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

We ensure that we have appropriate legal grounds to perform cross-border transfers of your Personal Data.

If you are located in the European Economic Area (“EEA”):  Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available on the EU Commission’s adequacy list online at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).  For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data.  You may obtain a copy of these measures by contacting us using the information provided in the “Contact Us” section below.   

Use of this Site by Minors

This Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through this Site. 

Sensitive Personal Data Restriction

Unless we specifically request for information to comply with applicable anti-money laundering laws and other applicable laws, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, passport numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.

Contact Us

Questions or concerns regarding Cortera’s data protection practices should be addressed to:

Legal Department
Moody’s Corporation
7 World Trade Center at 250 Greenwich Street
New York, NY 10007

Or submit a Privacy Request Form to us directly.

In accordance with applicable laws, you may lodge a complaint with the data protection authority for your country or region, or where an alleged infringement of applicable data protection law occurs.

Additional Information for California

If you are a resident of California, the California Consumer Privacy Act (“CCPA”) (Civil Code §§ 1798.100 et seq.) provides you with specific rights regarding your Personal Data.  These include:

  • You can request information about our collection, use and disclosure of your Personal Data over the past twelve (12) months concerning: (i) the categories of Personal Data we collected about you, (ii) the business or commercial purpose for collecting your Personal Data, (iii) the categories of sources from which your Personal Data is collected, and (iv) the categories of third parties with whom we share your Personal Data.  You can request a list disclosing the categories of your Personal Data we have shared in connection with a business purpose.
  • You can request to receive a copy of your Personal Data in a commonly used and machine-readable format.
  • You can request that we delete your Personal Data, subject to certain exceptions. 

To exercise the rights described above, it may be necessary for us to verify your identity or authority to make the request and confirm the Personal Data relates to you. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. We will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law.

During the past twelve (12) months, we collected the categories of Personal Data described above from California residents. We also disclosed such Personal Data to third parties for the purposes specified above during the past twelve (12) months.

In the last twelve (12) months, we sold products and services that include limited Personal Data about residents of California who are executives, officers, managers, investors, and individual shareholders of organizations. California residents have the right to opt-out of the sale of their Personal Data to third parties. To exercise this right, please click here and follow the instructions on that page. A link to this webpage is also available on our homepage.

How to Contact Us 

You may exercise any of the rights described in this section by completing a Personal Data Request Form.

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