Troy A. Paredes
U.S. Securities and Exchange Commission
TERMS AND CONDITIONS OF USEBelow are the terms and conditions governing your use of Euromoney USA LLC ("IMN") this website and any products or services connected therewith. By using the website or services connected with the website, you acknowledge and agree to the following:
*Your Obligations. You represent and warrant that you have the capacity to agree to these Terms and you are at least eighteen (18) years of age. To the extent any individual accesses a Site or uses a Service as an employee, partner, director, agent or representative ("Agent") of any legal entity which is a Subscriber, the Agent warrants that he or she has authority to agree to these Terms on behalf of the relevant legal entity.
You will procure that you and any licensed user under your subscription will: (a) comply with all applicable laws in relation to the site and services, including without limitation, laws relating to the use of Intellectual Property; (b) not use the site or the content outside the scope of permitted use and will not infringe any Intellectual Property or other rights in or relating to the site or the services or of any third party; (c) not copy, reproduce, recompile, decompile, disassemble, reverse engineer, upload, download, transmit, create derivative works from or otherwise exploit or tamper with the site or any software embodied in any site or service; (d) not prevent or restrict the use of any site or service by other authorized users nor hack into or cause damage to any server or other equipment operated by us; and (e) comply fully with these Terms.
*No IMN Warranties or Representations. IMN makes no warranty, express or implied, concerning any use of this website or any service or product provided in connection with this website. The services and products provided by IMN are provided on an "AS IS" basis. IMN disclaims any implied warranty of merchantability or fitness for a particular purpose, including any warranty for the use or the results of the use of the products or services. IMN is not responsible for correcting, maintaining or updating the data and services made available on this website.
Any material and analysis provided by or through IMN or this website is not a recommendation that must be followed or an offer, or solicitation of an offer to buy or sell any financial product; IMN does not recommend that you enter into a particular transaction or represent that any product or service described on this website is suitable for you or your company. Nor is any information displayed here promoting any particular financial product, service or trading strategy in any jurisdiction where such an offer or solicitation, or trading strategy may be prohibited. As all prudent investors know, some transactions, including but without limitation, those involving high-yield securities, give rise to substantial risk and any investment decision you may make is your own. You should not enter into any transactions unless you have fully understood all such risks and have independently determined that such transactions are appropriate for you. Any discussion of the risks contained herein with respect to any product should not be considered to be a disclosure of all risks or complete discussion of the risks mentioned.
*Restricted Use. As a user of this website, you are not permitted to display, modify, copy, print or otherwise use the information made available to you here only for your own use. You are not permitted to publish, transmit, or otherwise make this information available in any format to any third party without the prior express written consent of IMN. You also are not permitted to change or remove any copyright (©), trademark (®, SM, TM) any other notices displayed with the information. IMN can modify the information at any time and for any reason at its sole discretion. Unless expressly stated otherwise herein, no rights are granted to you regarding the information on this website from IMN or any other source, including third party providers of information for this website, which shall under no circumstances be liable to you in any way.
*IMN Monitoring. Your use of the products and services on this Web site may be monitored by IMN in any lawful manner, and that the resulting information may be used by IMN for its internal business purposes or in accordance with the rules of any applicable regulatory or self-regulatory organization.
*Website or Internet failure. IMN shall have no liability, contingent or otherwise, to you or to third parties, or any responsibility whatsoever, for the failure of any connection or communication service to provide or maintain your access to this service, or for any interruption or disruption of such access or any erroneous communication between IMN and you. IMN also does not warrant or represent that the website shall be completely secure, specifically including without limitation, that no unauthorized person shall intercept or access information transmitted by you.
*Website Access. Access to this website is restricted by password and only authorized IMN registrants may use the website. Any unauthorized access shall be the responsibility of the Registrant and his or her company and IMN shall not be liable for any damages arising out of such unauthorized access. You agree to: (1) Keep your password confidential; (2) prohibit others from using your account; (3) refrain from using other Users’ accounts; (4) refrain from selling, trading, or otherwise transferring your account to another party; and (5) refrain from charging anyone for access to any portion of DirectConnect, or any information arising therefrom. You are also responsible for anything that happens through your account unless you can demonstrate that your account was accessed without your knowledge or fault.
*User Communication. To the extent permitted while using DirectConnect, you can use and participate in groups, free to post and delete comment on the website. You are solely responsible for your interactions with other users. IMN may limit the number of connections you may have to other users and may at its sole discretion prohibit you from contacting other users through use of the Services or otherwise limit your use of the Services.
If you violate this Agreement while posting, that content may be removed without further notice or the rights of others posting here. Nothing you post here is confidential or proprietary and you are cautioned that other posters or viewers may use any information posted here. By posting here you agree that IMN is not responsible for the misappropriation or misuse of any information posted on this website.
*Privacy. Any submissions, including private personal information, like names, addresses and so on, are voluntary and you waive any and all rights you have to the protection of that information. By submitting ideas, suggestions, documents or other matter ("Submissions"), you agree that: (a) the Submissions are not confidential or proprietary information; (b) IMN has no obligation to keep the submissions confidential; (c) IMN can use or disclose the Submissions for any purpose, in any way, in any media worldwide; (d) if asked, you will irrevocably assign to IMN all rights to your Submissions; and (f) you are not entitled to any compensation of any kind from IMN under any circumstances.
*Content by Becoming a User of DirectConnect: As part of obtaining registration access to DirectConnect, unless you opt out, you may receive invitations to network from other conference attendees. We may also send you emails to keep you updated on developments in the site and services. Your registration for and/or subscription to such an email service and your use of the content received through these email services will be subject to these terms. You can unsubscribe to our email service by changing your email preferences on the website.
*License. If you comply with all your obligations under this Agreement, IMN grants you a limited, revocable, nonexclusive license and right to access the Services, through a generally available web browser, mobile device or application view information and use the web pages and in accordance with this Agreement for your use only. Any other use of DirectConnect is strictly prohibited. All rights not expressly granted in this Agreement, including, without limitation, title, ownership, intellectual property rights, and all other rights are retained by IMN.
*Anti-Hacking. You expressly agree not to use or attempt to use any "virus," "spyware," "malware," "adware," "Trojan horse" "deep-link," "scraper," "bot," "spider," "data-mining," "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 this website or content. You also agree not to obtain or attempt to obtain through any means any materials or information on the website that have not been intentionally made available either by their public display on the Web Site or through their accessibility by a visible link or portal. You further agree not to violate the security of the website or attempt to gain unauthorized access to the website, data, materials, information, computer systems or networks connected to any server, through hacking, password mining or any other method.
*No Linkage. You expressly agree not to link or attempt to link to this website or the web pages contained herein.
*Third Party Information. Some of the information you access here is the property of third parties, made available here with the express permission of those third parties. IMN is not responsible for the content of any third party information provided on this website. You are cautioned that any further use of that information by you may be subject to the rights of those third parties and you may be required to obtain a license to use any such information. Failure to obtain third party permission may be a violation of federal law. You should contact the third party provider of the information to ascertain the requirements for using the information.
*Copyright and Trademarks. The layout of the website pages, graphics and pictures used and the collection of individual contributions are protected by copyright. All copyrights belong either to IMN, the third-party content providers or both. Either IMN or the third-party content providers own all trademarks and service marks depicted here.
*Indemnification. You agree to indemnify hold harmless and defend IMN, including our employees, officers, agents and contractors and our related entities and their employees, officers, partners, agents and contractors ("Indemnified") and continue to keep the Indemnified indemnified from and against any actions, proceedings, claims, demands, costs (on a full indemnity basis including, without limitation, reasonable legal and accounting fees) brought or made against the Indemnified by any person arising in connection with your use of the Website or content, or a breach of your representations and warranties in the Terms and Conditions of Use or this Agreement, or your violation of any of the Terms and Conditions of Use or this Agreement or any other activity in which you engage on or through, and from and against any damage, loss(whether personal or property, and whether direct or consequential, including without limitation consequential financial loss), cost or expense suffered or incurred by any Indemnified as a direct or indirect consequence thereof.
*Changes in Terms and Conditions. IMN may at any time revise the terms and conditions by which you may access the website or use IMN products or services. By using this website and IMN products and services, you agree to be bound by any such revisions and should therefore periodically visit this page to determine the then current version of this document.
*Limitation of Liability. Neither we, nor any of our suppliers, officers, employees, partners, affiliates, subsidiaries, successors and assigns, agents or representatives (our "Representatives") will be liable to you for:
(a) any incidental, punitive, indirect, special or consequential damage, loss or expenses, including but not limited to any loss of business, contracts, revenue, or profits, any business interruption, security breach, loss of data, loss of goodwill or reputation or other pecuniary loss suffered by you, even if we or any of our Representatives have been advised of their possible existence; nor? (b) any direct damage loss or expenses arising from loss of customers, loss of profits, loss of anticipated profits or loss of savings.
*Termination. You may terminate this Agreement, for any or no reason, at any time, when IMN receives notice from you. IMN may terminate the Agreement and your account for any reason or no reason, at any time, with or without notice. This cancellation shall be effective immediately or as may be specified in the notice and may include disabling your current and future access to DirectConnect. IMN may also suspend or terminate this Agreement if you invite other users with whom you do not know to connect; abuse the any DirectConnect messaging services; creating multiple or false profiles; infringe on any intellectual property rights, violating any provisions in this Agreement, disparage IMN or its executives, Board members, affiliates, staff or other related entities or persons, or exhibit any other behavior that IMN, in its sole discretion, deems contrary to the purpose of the website.
*No Waiver. Failure by either party to exercise any right or remedy under these Terms does not constitute a waiver of that right or remedy.
*Entire Agreement. These terms (including any terms incorporated by reference in these terms), constitute the entire agreement between you and us with respect to your access to and use of the website or receipt of any service and supersede all prior agreements, negotiations and discussions between you and us relating to the same.
*Law and Jurisdiction. Where you visit, register and/or subscribe to a this site or related service (as indicated on this website or otherwise notified to you), these terms (and any dispute or claim arising out of or in connection with these terms, including non-contractual disputes or claims), to the maximum extent permissible under the law of the territory that you are located in, will be governed by the laws of the State of New York. Any action to enforce these terms shall be brought in a federal court or a state court located in the state of New York, county of New York, and you agree to submit yourself to the personal jurisdiction of those courts in any such action.
*Force Majeure. We shall not be deemed to be in breach of these Terms by reason of any delay in performing, or any failure to perform any service or our obligations in relation to these Terms, if the delay or failure was due to any cause beyond our reasonable control, including but not limited to acts of God, explosions, floods, fire or accident, war or threat of war, terrorism or threat of terrorism, sabotage, civil disturbance, epidemics, prohibitions or measures of any kind on the part of any governmental, parliamentary or local authority, import or export regulations or embargoes, or industrial actions or trade disputes (whether involving our employees or of third parties).
*Severability. If any provision of these Terms is found to be wholly or partially invalid, void or unenforceable by any court having competent jurisdiction or by virtue of any legislation or any other reason, that provision shall be invalid, void or unenforceable to that extent only and no further and the validity and enforceability of the remaining provisions of these Terms shall not be affected.
*Notices. Any notice given pursuant to these Terms shall be made by email or first class post, in the case of you, to the address provided on your registration form and, in the case of us, to the address posted on the website or otherwise notified to you in relation to any relevant service. Any such notice shall be deemed to have arrived if sent by post within three (3) days of posting and if sent by email at the time of transmission.
Euromoney Institutional Investor PLC (“Euromoney”, “we”, “us” or “our”) is an international business-information group covering asset management, price discovery, data and market intelligence, and banking and finance. The group also runs an extensive portfolio of events for the telecoms, financial and commodities markets.
For a full list of our brands and group companies, please click on this link. Euromoney and its group companies are committed to respecting the privacy of every person who visits, registers with or subscribes to our websites, publications, events and other products or services.
Euromoney is the primary data controller of personal data collected through this website or that we may collect in different ways as described in this Privacy Notice. If you are contacted by our other group companies, they will also be controllers of your personal data. This means that they are responsible for how your personal data is used, just as we are. You may contact any of these companies directly, or you can contact Euromoney by emailing firstname.lastname@example.org or writing to the Data Protection Officer at Euromoney Institutional Investor PLC, 8 Bouverie Street, London EC4Y 8AX, United Kingdom.
This Privacy Notice was updated on 23 May 2018
This Privacy Notice outlines the information we may collect about you in relation to your use of our products and services (“personal data”). It also explains the legal rights that you have in relation to your data and how you may exercise these rights.
Some of our group companies may collect and use personal data for different purposes; those companies have their own websites and privacy notices.
We will process your data for the following lawful purposes: with your consent; to fulfil our obligations to you; and where there is a legitimate interest to do so.
When possible, we rely on your consent to use your data for the purposes described in this Privacy Notice. We also process personal data to fulfil our contractual obligations to you, for example, when you register for any of our services, subscribe to a publication, sign-up for an event or purchase a product from us, we will need to process some of your personal data. This will also include details of the person/people responsible for payment (if different).
We may determine that processing your personal data serves both of our legitimate interests. This is the case in relation to many of our research, customer survey, sales, marketing and advertising activities described in this Privacy Notice. These activities allow us to better understand your requirements, which in turn enables us to provide you with a better service. We review the bases for our processing decisions carefully and you can object to these activities at any time (see the “Your Rights” section of this Privacy Notice).
Our primary goal in collecting personal data from you is to give you a relevant customised experience of our products and services.
Registration, Free Trials & Subscriptions
When you register with our website and/or sign up for a free trial of our products or services, we may ask you to provide your name, address, email address and telephone number, and details relevant to your occupation or employer.
If you subscribe to one of our products or services, we will also ask for payment details. Credit/debit card payments are processed using a third party supplier and we do not retain the credit card data (see the Third Party Sites of this Privacy Notice). Address details may be shared with third party service providers engaged by us for order fulfilment, delivery and payment collection. This personal data is used by us to complete subscription requests.
Events & Conferences
If you have registered for an event through a group website we may collect personal data including: name, job title, company, address, telephone number and email.
This information is necessary so that we can complete your registration for the event and provide you with relevant event materials.
We may also provide delegate details (e.g. name, email) to event sponsors who, subject to your consent, may contact you for their own advertising and marketing purposes.
Advertising & Marketing
We use the personal data you provide us and which we collect from you to inform you about similar products and services which we provide. We may send you marketing communications that are sponsored by our partners and which are targeted to your interests based on information you have provided us such as job title, employer and/or industry. If you have consented to receive information from other Euromoney group companies, we may share your personal data with these companies so that they can fulfil your request to receive marketing materials in accordance with your preferences. We will not share your personal data with any third parties for their own marketing purposes unless you have provided your consent.
Each of the Euromoney group companies that may contact you is a data controller in relation to the personal data that you have agreed to share with them. If you have any questions or concerns, you may contact the individual company, or us – using the contact details set out in the “Who We Are” section.
You can opt out from receiving such materials at any time.
The personal data we may use for advertising and marketing purposes includes your name, email address, job title, phone number, company name/employer, geo location, postal address and data collected using cookies and other similar technology (Please read our separate Cookies Policy to find out more about which cookies we use, how they work and how you can control your cookie options).
Marketing materials are sent electronically, by post and we may occasionally call you.
Online Targeted Advertising
We use targeted advertising on our websites to display advertisements that are relevant to what we believe are your interests. In order to deliver relevant advertisements, we use third parties to deliver cookies that collect information about your IP address and how you interact with our sites (e.g. browsing information, which articles you have read etc.). This data is used by the third parties to determine which advertisements may be of interest to you.
We may also share your personal data with third parties to deliver targeted advertising to you on other websites (e.g. Twitter Tailored Audiences or Facebook Custom Audiences). This could include your email address, cookie data, and information obtained from third parties. Third party cookies may also be used to enable us to target advertisements to you on other websites that you visit.
Lead Generation and Scoring
We occasionally use the services of trusted third parties in order to ensure that the personal data we use for advertising and marketing purposes is accurate and up-to-date. To do this, we transfer personal data of individual leads (such as name, email, job title, location and phone number) to these third parties who conduct research to verify the data – primarily against public information.
We also use algorithmic software technology to help us improve the quality and relevance of marketing activities. The personal data analysed by the software includes email address, phone number, job title, address, purchase history and account information. This allows us to provide meaningful offers that are relevant to your specific profile.
Surveys, Market Research & Customer Feedback
We want to understand the needs of our readers and customers. We may therefore use the information you provide us – including your name and contact details – to contact you to request your feedback, or to participate in our customer and market research.
Public forums, message boards and blogs
Some of the pages on our group websites may include message boards, blogs or other facilities for generating content from users. Any information that is disclosed in these areas becomes public information and you should always be careful when deciding to post any personal data. User generated content is also subject to our site Terms & Conditions.
Business or Asset Sale
If we sell a business or assets we may need to disclose your personal data to the prospective buyer of such business or assets.
If Euromoney, or any of our group companies is sold or sells our assets or is acquired by a third party, then personal data about our customers will be acquired by that third party. A transfer of your personal data in these circumstances would be necessary so that the services you have contracted for can still be delivered, or so that you can continue to enjoy the benefits of our free products and services. You will receive notice if a new controller assumes responsibility for your personal data.
Additional Third Party Disclosures
We may disclose your personal data to other third parties in the following situations:
- To third party partners who help us by providing services such as technology, marketing, advisory or other services. These third parties only receive encrypted data and may only process personal data to provide those services to us.
- Where we are required by law or regulation to do so. In each case we will seek, where practicable, to minimise the amount of data that is disclosed.
- If required to protect the rights and interests of other users and/or Euromoney and its affiliates (including our employees, agents and contractors), or as otherwise set out in our Terms & Conditions. This may include exchanging information with other companies and organisations for the purposes of fraud protection.
We may include small pixel tags (small image files) within the emails we send you in order to determine whether our emails are opened and/or whether the hyperlinks inside our emails are clicked through. We may also collect browser, location and the device used to engage with our email communications. This information allows us to better understand whether we are meeting our users’ needs and how we can improve our communications. No other information is collected. You can opt out of receiving our direct marketing emails either by following the instructions in each email, or by contacting us (see the “Who We Are” section of this Privacy Notice).
Some of the Euromoney group companies are based outside the European Economic Area (EEA). If you have consented to being contacted by our group companies, then the transfer of your personal data will be made according to the terms of an international data sharing agreement that contains obligations approved by European data protection regulators. Any of our group companies that receive your personal data will be co-controllers of that data, which means they may determine how they process your personal data – although they may only use it for the purposes for which it was shared, unless you are informed of new or additional processing activities.
We may also transfer personal data to third party service providers as described in this Privacy Notice which are located outside the EEA. Where we conduct these transfers, we take all steps necessary to ensure that your data is treated securely and in accordance with applicable privacy legislation, either by only sending your personal data to jurisdictions that provide an adequate degree of legal protection for your data or by imposing approved contractual terms on these third parties.
We have a data retention policy that ensures we don’t use or store your personal data for longer than necessary. We consider the following issues to determine retention periods:
- Guidance from the UK Information Commissioner or other regulatory agency, or industry best practice recommendations;
- The business rationale for collection and expiry of the purpose for which personal data was collected;
- Our ongoing ability to ensure the accuracy of the data; and
- Legal and regulatory requirements.
We may occasionally need to keep personal data for either shorter or longer periods than specified in our retention policy. In such circumstances, application of the retention period to the data will be temporarily suspended. The suspension of an applicable retention period will be carried out in a manner that respects the rights and interests of all persons concerned.
You can use our Preference Centre to select the topics that are of interest to you so that we can send you publications and information about our products and services that are especially relevant to you. You can also choose the channels we use to contact you (email, phone, post, etc.) and can also opt-out of receiving marketing communications.
You have certain rights in relation to your personal data which include the following:
Access & Portability
You may request access to any personal data of yours for which Euromoney is responsible as controller. Unless there are legal or regulatory reasons for not doing so, we will confirm whether we process any of your personal data and if we do, we will provide you with the following information: the purposes of the processing, the categories of personal data, any recipients of your personal data, the applicable retention period and the data source. Copies of your personal data will be made available to you in a structured, machine-readable format.
You may also request that we transfer the personal data that you have submitted to us, to another controller, where it is technically feasible for us to do so.
If you have consented to our processing of your personal data, or if we are processing your personal data in order to fulfil our contractual obligations to you, then you can submit a request that we transfer your personal data to another data controller.
Rectification, Restriction, Objection
You have the right to request that Euromoney rectify any errors in the personal data that we process. In some circumstances, you may also be able to ask for the erasure of personal data, and/or request that the processing of your personal data be restricted. You may also object to the processing of your personal data for sales or marketing purposes.
How to Exercise Your Rights
To exercise any of these rights, please contact us by post or email at the following addresses:
Euromoney Institutional Investor PLC
8 Bouverie Street
London, EC4Y 8AX
Web form: Complete Subject Data Request Form
We may need to check your identity prior to processing a request.
Euromoney will do our best to respond to any questions and address any of your concerns. You are also able to register any complaints regarding the processing of your personal data directly with the UK Information Commissioner.
Euromoney is committed to keeping your personal data secure and we will take appropriate technical and organisational measures to protect your personal data from loss, unauthorised use, disclosure or destruction. Although we do our best to protect your personal data, we cannot guarantee that any transmission of data is without risk. We have therefore implemented information security policies and rules, staff training on information security, and technical measures to ensure the integrity of data that we have under our control.
All our employees, contractors and data processors (i.e. those third parties that process personal data on our behalf) are required to keep such data confidential and not to use it for any purpose other than the performance of services we have requested.
Our site may contain links to other websites – including, for example, providers of payment processing services. Euromoney is not responsible for the privacy and data collection practices of third party sites and we therefore recommend that you review the privacy policies and terms of service of each site you visit.
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