Effective Date: October 19, 2017
Dow Jones & Company, Inc., and its subsidiaries (“Dow Jones”) want you to be familiar with how we collect, use and disclose information from and about you because we respect your concerns about your privacy, and we want to maintain your trust.
This Risk & Compliance Privacy Policy describes our practices in connection with information we collect through the Risk & Compliance website, mobile site, applications (“apps”), electronic newsletter, widget or other online service operated by us from which you are accessing this Privacy Policy (the “Risk & Compliance Services”). Please note that if your subscription includes any other Dow Jones product in addition to the Risk & Compliance Services, we will treat the information we collect in connection with your use of the Risk & Compliance Services in accordance with the Dow Jones Privacy Policy, not this Privacy Policy. If there is a conflict between this Privacy Policy and your company’s Risk & Compliance Services corporate subscription agreement, the Risk & Compliance Services corporate subscription agreement will take precedence.
As described more fully below, we may share your Personal Data or Other Information with our subsidiaries, and affiliated companies (“Dow Jones Affiliates”), for the purposes described in this Privacy Policy. A list of Dow Jones subsidiaries and Affiliates is available in annual reports accessible here. By using the Risk & Compliance Services, you acknowledge you have read and accept this Privacy Policy.
The Risk & Compliance Services are general audience sites, and are not targeted to, and do not knowingly collect Personal Data from, minors under 16 years of age.
Dow Jones and our service providers collect Personal Data to offer services you have requested or that we have a legitimate interest to believe are of interest to our customers, to manage the relationships we have with our customers and partners, and to perform activities based on your consent. Dow Jones and our service providers may collect the following information from and about you:
"Personal Data" for purposes of this Privacy Policy is the information that identifies you as an individual or relates to an identifiable person.
We collect Personal Data when you submit it to us, such as when you register for or subscribe to the Risk & Compliance Services, create a profile, take a survey, visit our Risk & Compliance Services, or use an interactive feature to communicate with Dow Jones (such as chat). The Personal Data you submit may include your name, postal address, telephone number, mobile number, gender, username, and email address.
To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as Dow Jones Affiliates, business partners, and, if applicable to you, the third party provider of your subscription. The Personal Data we receive from third parties may include your name, contact information, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications.
"Other Information" is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, geolocation data obtained with your consent where required by applicable law, and aggregated information.
We collect Other Information when you submit it to us. This may include your birthday, education, occupation, and interests.
We may receive Other Information about you from third parties, including, for example, demographic data, information about your interests, and information about your activities on other websites.
Our Services use cookies and other tracking technologies to function effectively and deliver certain features. For more information about how we use cookies and tracking technologies, please refer to our Cookie Policy.
We may use the Personal Data we collect from and about you for the purposes set forth below. We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data, we treat the combined information as Personal Data.
To improve the quality of our products and services and to present products and offers tailored to you, we may also combine the Personal Data and Other Information we collect with information relating to your use of other Dow Jones products, services and websites. In addition, we may supplement the Personal Data and Other Information we collect with information from Dow Jones Affiliates or business partners.
We use the information we collect from and about you to provide our products and services and features to you, including: to process and fulfill your subscription, to create and manage your accounts, to send you information about your relationship or transactions with us, to measure and improve those services and features, to provide you with customer support, including online chats, and to respond to inquiries.
Dow Jones and Dow Jones Affiliates may periodically send promotional materials, with your permission where required, or notifications related to our products and services. To help make these materials more relevant to you, we may use and combine any of the Personal Data and Other Information we collect to assist us in sending you these materials. If you want to stop receiving these materials, please follow the instructions in the Your Rights and Choices section below. We may also use your information to respond to inquiries or requests you make to us.
Dow Jones may use your Personal Data as we believe to be necessary or appropriate in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Dow Jones, our Dow Jones Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
Dow Jones & Company, Inc. and its subsidiaries may share your Personal Data with one another, as well as with Dow Jones Affiliates for the purposes described in this Privacy Policy, including for each company’s marketing purposes if you have consented to such use. Users who visit Dow Jones Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Policy. Dow Jones is the party responsible for the management of the jointly-used Personal Data.
In addition, we may share your Personal Data with non-affiliated third parties when sharing is permitted by you or authorized by this Privacy Policy, as follows:
If your subscription is provided in whole or in part by your employer or other third party, we may share with them information about your access to and use of your subscription. When providing this information, we may reveal limited amounts of your Personal Data such as your name or email address.
We may make your Personal Data available to certain third party service providers, such as contractors, agents or sponsors, or Dow Jones Affiliates, who help us manage or provide our products and services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; and processing data or statistics. These third party service providers are required to protect Personal Data entrusted to them and not use it for any other purpose than the specific service they are providing on our behalf.
There may be instances when Dow Jones may disclose your Personal Data, including situations where we have a good faith belief that such disclosure is necessary in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Dow Jones, our Dow Jones Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activities or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or to respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
If Dow Jones sells all or part of its business or assets or is otherwise involved in a merger, reorganization, dissolution, liquidation, or transfer of all or part of its business, as part of that transaction Dow Jones may transfer your information to the party or parties and their advisors involved in the transaction.
Dow Jones uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service in accordance with the instructions below.
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.
You may opt out of direct marketing receiving electronic communications from us (including notifications, or promotions from us on behalf of third parties), or our sharing of your Personal Data with Dow Jones Affiliates for their direct marketing purposes, by changing your account settings through the appropriate link on the website account services page or following the unsubscribe instructions at the bottom of each email. You can opt out of direct marketing from Dow Jones Affiliates by using the unsubscribe links they provide or following the steps in their applicable policies.
Please note there are certain service notifications that you may not opt out of, such as renewal notices and notifications of changes to Dow Jones products and services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
You can access, review, correct, update, delete or modify your registration or subscription profile information and modify your marketing preferences by contacting Dow Jones Customer Support at service@dowjones.com or by calling 1-800-DOWJONES (1-800-369-5663)(U.S. only). Local contact information for Risk & Compliance Services is available here. You can also object to or restrict the processing of your Personal Data. If you are in the European Economic Area (“EEA”), you can also exercise your right to data portability.
Where you have provided your consent for our use of your Personal Data, you have the right to withdraw your consent and we will apply your preferences going forward.
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.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions you began prior to requesting such change or deletion.
Subject to certain limitations, California Law permits our customers who are California residents to request certain information regarding our disclosure of Personal Data during the preceding calendar year to third parties for their own direct marketing purposes. To make such a request, California residents can write to us at privacypolicy@dowjones.com, Attn: DM Disclosure Manager, and include your name and the address to which you would like us to respond.
Dow Jones may periodically update this Privacy Policy without prior notice to reflect changes in our practices. Please look at the Effective Date at the top of this Privacy Policy to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the Risk & Compliance Services. We will notify you by posting a prominent notice on the Risk & Compliance Services indicating we have updated this Privacy Policy. Your use of the Risk & Compliance Services or your provision of Personal Data to us following these changes means you acknowledge you have read and accept the revised Privacy Policy.
Some browsers or other tools include “Do Not Track” (DNT) features which, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, Dow Jones does not currently respond to DNT signals.
Your Personal Data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than in your country.
If you are located in the EEA, we will implement appropriate safeguards to protect your Personal Data as required if we transfer it outside the EEA.
The Risk & Compliance Services may be linked to sites operated by third parties, and may offer content, functionality, games or applications developed and maintained by third parties. Some of these third party sites may be co-branded with a Dow Jones logo, even though they are not operated or maintained by us. Dow Jones is not responsible for the privacy practices of any such third parties, and once you leave the Risk & Compliance Services, you should check the applicable privacy policy of the other service.
If you have questions about this Privacy Policy or how we or our service providers handle your Personal Data, please contact our Chief Privacy Officer and Data Protection Officers at privacypolicy@dowjones.com
Or you may write to:
Attention: Privacy
Dow Jones & Company, Inc.
4300 U.S. Route 1 North
Monmouth Junction, NJ 08852
If you are located in the EEA, the entity responsible for the collection and processing of Personal Data in connection with the Dow Jones Services is Dow Jones & Company, Inc. (U.S.) (contact information provided above). If you have a corporate subscription agreement, the entity responsible for the collection and processing of your Personal Data is the entity with whom your company has a direct relationship.
We will respond to your questions and complaints about our processing of your Personal Data. If you are not satisfied with our response, you can contact a supervisory authority. Please do not disclose any sensitive Personal Data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.