Regulatory DataCorp, Inc., a Moody’s Corporation company of 211 S. Gulph Road #125, King of Prussia, PA 19406, USA, (“RDC”, “we”, “us”, or “our”) respects your privacy. This privacy notice explains in detail how we process Personal Data collected from publicly available and third-party sources which we incorporate into our database product, which we call Global Risk Information Database “GRID”).
 

“Personal Data” means information which identifies, or can be used to identify, living individuals.
 

• Purposes of Processing
• Personal Data Collected
• Sources of Personal Data
• Uses & Disclosures of Personal Data
• Retention of Personal Data
• Your Rights & Choices
• Supplementary Information for the European Union, Switzerland and the UK
• Contact & Queries
• Updates to this Privacy Notice

RDC’s main activity is providing regulatory screening services through GRID to financial institutions and other entities with regulatory compliance requirements (“Subscribers”). Subscribers use GRID in relation to their customers or those with whom they are looking to do business, some of which are companies or other legal entities, and some are individuals or sole traders. Subscribers use GRID as part of their compliance with their legal and regulatory obligations to help prevent and detect money laundering, terrorism, and other criminal activity, including know-your-client (“KYC”) obligations, sanctions screening, anti-money laundering (“AML”) and anti-corruption and bribery (“ABC”) obligations. We collect the Personal Data contained in GRID from public records, publicly available sources, and third parties. Subscribers are responsible for ensuring that their use of GRID through the results they receive from us complies with applicable laws and regulations.

We receive name, address, and date of birth of individuals from Subscribers for us to query against GRID to search for matches.
 

GRID contains the following Personal Data:

• Name and title
  
• Address
• Date of birth
• Nationality
• Information relating to:
  
  
  • jobs and companies,
  • political affiliations and political exposure,
  • religious belief affiliations,
  • sanctions, and
  • unlawful activities, including terrorism and other criminal activities.
     

We do not routinely obtain email addresses for individuals, and we rely on Subscribers (who do hold contact details) to notify those individuals that they will run checks on them using GRID if required under applicable law. Given the nature of our services that are used to identify banned and suspect entities and for fraud protection and meeting regulatory requirements relating to unlawful acts and dishonesty, there may be circumstances where providing the information to the individual would make impossible or seriously impair the achievement of the objectives of the processing.

RDC sources the Personal Data in GRID from public records, reputable publicly available sources, and third parties, including:
 

• reputable media sources: media sources published by established media organizations, national and regional titles offering accurate and high-quality reporting, industry and specialty publications,
• government publications and websites for government press releases around regulatory, enforcement, or justice department information, including sanctions lists, litigation releases, and law enforcement lists, such as Interpol Most Wanted, SEC Litigation Releases,
• insolvency lists.

Subscribers use GRID to assist them with their legal, regulatory and compliance obligations in relation to AML, KYC, ABC, fraud, organized crime, sanctions, embargoes, and associated regulatory and reputational risks. RDC processes the Personal Data for the purposes of providing the GRID services to its Subscribers, including analyzing and modelling the Personal Data to improve its accuracy and develop and improve our services. 
 

The Personal Data in GRID is limited to those necessary for these purposes. For example, without name and contact details, Subscribers would be unable to look up individuals; without year or date of birth, it would be easy to mix up individuals with the same or similar names leading to cases of mistaken identity; similarly, without nationality, it would be easy to mix up individuals with the same or similar name leading to cases of mistaken identity.
 

Subscribers are responsible for how they use the screening results they receive from us through GRID and ensuring that their use complies with applicable laws and regulations. Subscribers are responsible for how they use the results of a check performed using GRID, for example, whether to do business with a customer. RDC does not make decisions for Subscribers about individuals based on the information in GRID.
 

We do not sell or otherwise disclose Personal Data we collect about you, except as described below or otherwise disclosed to you by us or our Subscribers (or the vendor or business partner that you represent) at the time the data is collected:
 

• Affiliates. We share the Personal Data we collect or receive with our affiliates and other offices, as reasonably necessary to operate our business and to perform services for our Subscribers, and for data analysis purposes and to improve and develop products and services.
• Business Partners. We may share the Personal Data we collect or receive with our business partners as reasonably necessary to operate our business and to perform services for our Subscribers or for our business partners (namely channel partners who resell RDC’s services) or their customers.
• Service Providers. We may share Personal Data with our service providers who perform services on our behalf and in relation to the purposes described in this Privacy Policy. For example, we may use third parties to help us analyze data as part of the services, manage our services, and build out GRID. We contractually require these Service Providers to only process Personal Data in accordance with our instructions and as necessary to perform services on our behalf or comply with legal requirements.
• Compliance with Law. We may disclose Personal Data to third parties to comply with the law, respond to valid legal process, establish, assert or defend our legal rights, or prevent fraud or abuse of RDC. In particular, we may disclose your Personal Data in response to lawful requests by public authorities, such as to meet national security or law enforcement requirements.
• Business Transfers. If we are involved in a reorganization, merger, acquisition or sale of any or all of our company, business or assets, Personal Data may be transferred as part of that deal or disclosed in connection with due diligence. We will put in place contractual provisions designed to ensure that any other parties commit to keep your Personal Data confidential and to only use it for the purpose of the relevant transaction and for purposes that are consistent with those outlined in this privacy policy.

Personal Data obtained from our Subscribers and business partners is maintained for the length of the associated agreement and the required time after the termination to meet any contractual audit or regulatory obligations or to otherwise comply with applicable law.
 

Personal Data collected from public sources in GRID is stored for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure, and the applicable legal, regulatory, tax, accounting or other requirements.

If you are listed as an individual in GRID you may have rights under applicable data privacy laws. Where applicable, to access your Personal Data contained in GRID and exercise your rights of correction, objection, restriction, erasure, or digital testament, please email us at privacy@moodys.com. If you are a California resident, please see the Additional Information for California Section of our main privacy policy for information on your specific rights regarding your Personal Data. 
 

You may also have the right to complain to your local data protection authority if you have concerns about how we process your Personal Data. However, we hope we can solve any queries or concerns you may have, so please contact us directly in the first instance.

The relevant legal bases for the use of your Personal Data are:

• We or a third party (for example, business partner or Subscriber) have a legitimate interest in using your Personal Data. Our Subscribers have a legitimate interest in the processing of your Personal Data for managing their financial risks, protecting against fraud, knowing who they are doing business with, and meeting compliance and regulatory obligations.
• In relation to political, religious or criminal offence data, this will generally be processed either:
  
  
  • Where the Personal Data has manifestly been made public (for example, where it is a matter of public record that an individual belongs to a certain political party or religious organisation); or
  • In order to provide our services in circumstances where the processing is necessary for the purposes of complying with, or assisting our Subscribers to comply with, a regulatory requirement (including under AML, KYC, ABC and sanctions regulations or under industry good practice principles and regulatory guidance applying to Subscribers), which involves taking steps to establish whether the individual has committed an unlawful act, been involved in dishonesty, malpractice or other seriously improper conduct; or where the individual has manifestly made such data public.
     

RDC has put in place measures to protect Personal Data which is transferred from Switzerland, the UK and the European Economic Area. To transfer Personal Data outside of the EEA RDC has put in place EU standard contractual clauses to ensure that an equivalent level of data protection applies. To request a copy of these clauses, please contact us as specified in the “Contact & Queries” section below. We may also transfer Personal Data to countries for which the EU Commission has issued an adequacy decision where applicable.
 

We take commercially reasonable steps to ensure that Personal Data is reliable, accurate, complete, and current for its intended purpose, primarily by accessing Public Records and Publicly Available Data from reputable sources only.

If you have any questions or comments regarding RDC’s privacy practices you can do this via email at privacy@moodys.com or write to us at:
 

Legal Department
Moody’s Corporation
7 World Trade Center at 250 Greenwich Street
New York, NY 10007
+1-212-553-1653 or 1-866-995-9659
privacy@moodys.com

The most current version of this Privacy Notice will always be available here. You can check the “Last Updated” date posted at the top to see when this Privacy Notice was last updated.