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Date Last Updated:  July 1, 2020

451 Research, LLC (“451 Research” or “we”) is committed to safeguarding the privacy of our members. 451 Research recently became part of the S&P Global Inc. family of companies (“S&P Global”).  To learn more about S&P Global’s privacy practices, please see the S&P Global Corporate Privacy Policy

 

This 451 Alliance Privacy Policy (“Privacy Policy”) explains who we are, how we collect, share and use personal data about you and how you can exercise your privacy rights.  This 451 Alliance Privacy Policy applies to your personal data unless the S&P Global Privacy Policy is more protective of your personal data. 

 

This Privacy Policy describes the personal data that we collect from you when you register, apply for 451 Alliance membership or otherwise use www.451Alliance.com or any software or web-based platform used to access our services (collectively, “Site”) or interact with us by telephone or otherwise offline.

 

S&P Global keeps certain activities of its business units separate from each other in order to preserve the independence and objectivity of each of these activities. As a result, your participation and personal information will never be shared with the S&P Global Ratings division. 451 Research and the 451 Alliance has established policies and procedures to maintain the confidentiality of non-public information received in connection with this program.

 

Data Controller


For purposes of this Privacy Policy, the data controller of the personal data that we collect from you is: 451 Alliance, Attn: Privacy, 55 Water Street, New York, NY 10041.  This means that we determine how and why the information we collect from or about you is used. If you have questions, please contact our Data Protection Officer at Privacy@spglobal.com or 451 Alliance, c/o S&P Global, Inc., 55 Water Street, New York, NY 10041.


Collection and Processing of Personal Data


When we refer to “personal data”, we mean information relating to an identified or identifiable person.  When we refer to “processing” of personal data, we mean to collect, store, analyze, share or otherwise do something with personal data.

 

The categories of personal data that we process are:

  • Personal details: given name(s), preferred name, gender (optional), date of birth/age (optional) and nationality (optional).
  • Contact details: telephone number(s), email address(es) and social media profile details (optional).
  • Professional details to help us assess your application for membership: title and work history, areas of expertise, job function, professional association memberships, educational history, qualifications, certifications and other information you choose to provide to us when you apply for membership.
  • Account settings.
  • Device/computer details: device/computer type and operating system, browser type and settings, device/computer identifiers (IP address, MAC address), language settings, dates and times of connecting to our Site and other technical communications information.
  • Usage information:  records of your use of our Site and other services including registrations, webpages accessed, links clicked, downloads and other details of content with which you interact, profile views, search queries and results. Please also see “Information Collected Automatically” (below) for more information.
  • Views, opinions and feedback that you choose to share with us: your comments, rating, views, opinions, posts via our Site, survey responses and public social media posts.

In general, we collect this personal data from or about you for the purposes described in this Privacy Policy or for purposes that we explain to you at or before we collect your personal data.  Specifically:

 

  • We collect your personal data when you provide it to us, such as when you contact us via email or telephone or register for a webinar or event or opportunity with our partner organizations.
  • If you are a 451 Alliance member or apply for membership, we collect your personal data in the course of receiving your application for membership, administering your 451 Alliance Membership, making surveys and surveys result available to you and providing discounts and other opportunities through our partners.
  • We collect personal data when you visit or register with our Site, such as when you sign up for one of our webinars or events or access resources available through our Site.  When you visit our Site, we automatically collect certain information from your device and browser, some of which is considered personal data. 
  • We receive personal data from our partner organizations when the partner asks us to promote partner opportunities or administers surveys or when you fill out a form requesting more information on one of our partner’s sites;
  • We collect personal data that you make public, including via our Site.
  • We collect personal data from third parties who provide it to us (e.g., our partner organizations, social media platforms via plugins).

Information Automatically Collected

We may collect certain information automatically from you when you interact with our Site and services.  Some of this information is collected by our vendors and service providers, such as the third-party survey-taking platform that we deploy to make surveys available for you.

 

Information we automatically collect includes your log-in events, IP or MAC address, device make, model and operating system, mobile network information, internet service provider, unique device identification number, advertising ID, browser type and language,  geographic location (e.g., country or city level location or time zone), information about how your device interacts with our Sites and services (such as the pages, screens and products accessed and links clicked) and other technical information.

 

We use this automatically-collected information:

  • for our analytics purposes;
  • to improve the quality and relevance to users of our Sites and services;
  • to develop and update our Sites and services;
  • for customer service;
  • to deliver tailored information about our services that we think may interest you, such as partner opportunities through emails and digital advertising; and
  • to identify unauthorized use or unauthorized distribution of our content and services, such as a possible security incident.

 

Some of this information is collected using cookies and similar tracking technology, as described in the next section.

Our Use of Cookies and Other Data Collection Technology

We use cookies and other data tracking technology to collect and use personal data about you.  We also may allow others to use cookies and similar technologies (e.g., pixels) to recognize you and/or your device(s) when you use the Site or services. 

 

Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as settings, browsing history and activities conducted while using the Site and services.

 

We also use “pixels” (also known as web beacons).  Pixels are transparent images that are used in collecting information about website usage across websites and over time.

 

Cookies that we set on the Site are called first-party cookies. Cookies set by any other party are called third-party cookies. Third-party cookies enable third-party features or functionality on or through the Site, such as analytics, marketing automation and customer support. The parties that set third-party cookies can recognize your computer both when it visits the Site and also when it visits certain other websites.

 

Cookies also are typically categorized as "session" cookies or "persistent" cookies. Session cookies are erased when your web browser is closed. For example, a session cookie tracks how you navigate through the Site so that you do not need to re-enter the same information during the same visit to the Site. Persistent cookies store your preferences and other information for your current and future visits – they are still stored in your browser when you reopen your browser. 

 

451 Research also uses other types of data collection technology, such as web beacons (also called a pixel tag or clear GIF). A web beacon is a piece of computer code that enables us to monitor user activity and website traffic. To learn more about cookies, web beacons and other data collection technology, visit www.allaboutcookies.org.

 

Why we use cookies and other data collection technology: Data collection technology helps us improve your experience of the Site by, for example, storing your website language preferences, so you do not have to select it each time you use the Services, compiling statistics about use of the Services, helping us analyze technical and navigational information about the Site, and detecting and preventing fraud.

 

We use the following cookies:

  • Strictly necessary cookies, which are required for the operation of the Site, such as to enable you to register or log in to the Services.
  • Analytical/performance cookies, which allow us to recognize and count the number of visitors to our website, to learn how users navigate the Site and to help us to improve how the Services function.
  • Functionality cookies, which are used to recognize you when you return to the Site.
  • Advertising cookies, which are used to deliver tailored information about our products and services that may be of interest or value to you and marketing and promotional emails (with your consent where required by applicable law).

We use Google Analytics to better understand how visitors use our Site. Please see https://policies.google.com/technologies/partner-sites for more information about how Google uses the information it collects through our websites.  For Google Analytics’ currently available opt-outs, please see https://tools.google.com/dlpage/gaoptout/.

Your control of cookies: Most browsers accept cookies automatically but allow you to disable them.  You can set your browser to not accept cookies, but doing so may prevent your ability to access or use certain portions of our Site. 

 

You also can opt-out of certain cookies using the following links: http://optout.networkadvertising.org and http://optout.aboutads.info

 

You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Some features of our Site may not work properly without cookies.  To learn more about cookies generally, visit www.allaboutcookies.org.


Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user or visitor does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including 451 Alliance, do not respond to DNT signals.

Lawful Basis for Processing Personal Data

Under certain privacy laws, we need to inform users about the lawful bases for our processing of their personal data.  Our legal bases depend on the context in which the personal data are processed.


  • Most of the time, the reason we process your information is to perform the Alliance Membership contract that you have with us.
  • We also process your personal data when the processing is in our legitimate business interests and not overridden by privacy or other fundamental rights and freedoms. For example, we process personal data for making surveys available, informing you about survey results, new Site features or partnership opportunities, continuously improving our offerings, fraud detection and legal compliance purposes. We may have other legitimate interests and will make clear our legitimate interests at the relevant time as appropriate..
  • From time to time, we may ask for your consent to use your personal data for certain specific reasons.  You may withdraw your consent at any time by contacting us.
  • In some cases, we also may have a legal obligation to collect personal data.  If we ask you to provide personal data to comply with a legal requirement, we will make this clear at the relevant time and advise you whether providing your personal data is mandatory and the possible consequences if you do not provide your personal data. 

If you have questions about or need further information concerning the legal basis on which we process your personal data, please contact privacy@spglobal.com.

 

Why We Process Personal Data

We process personal data to:

  • Operate our Site, such as providing content to you, making available, surveys for you to complete and the results of the surveys, suggesting content that may be of interest to you based on your past activity and communicating with you via our Site.
  • Provide our services to you, such as communicating with you about our services and partners, recommending content that may interest you and recommending your content to others.
  • Promote our Site and services, such as communicating with prospective or current members by email, telephone, text message, social media or in person about news, new content and other information that we believe is of interest.
  • Secure our IT systems, such as conducting IT security audits, detecting fraud and blocking fraudsters from disrupting the Site and our services.
  • Improve our Site and our services, such as to better understand how our Site and services are used so that we can improve them and develop new features, to identify issues with our Site and our services and for our analytics purposes, such as to track usage of our Site, to measure the number of unique visitors to the different sections of our Site, to understand how people find our Site and to help us make our Site and services more useful.
  • Monitor compliance, such as to monitor user accounts for abuse of copyright and our Terms of Use.

Disclosure of Personal Data to third parties


We may disclose your personal data to: 

  • Our vendors and suppliers that process personal data on our behalf to assist us with survey administration and analysis, membership administration, information security and other services that enable us to operate our business.  Under certain data protection laws, these vendors and suppliers are referred to as “data processors” or “service providers”.  If a data processor or service provider (as applicable) processes your personal data on our behalf, we require by contract that the data processor or service provider only process the personal data in accordance with our prior written instructions;  use measures to protect the confidentiality and security of the personal data; and comply with all additional requirements under applicable data protection law.;
  • Our accountants, auditors, lawyers and other professional advisors, subject to binding obligations of confidentiality;
  • Potential acquirers and their professional advisers in connection with any proposed purchase, merger or acquisition of all or any part of our business (including a reorganization, dissolution or liquidation). We will inform the buyer that the terms of this Privacy Policy apply to your personal data;
  • Law enforcement, government regulators, courts or other third parties when we believe disclosure is necessary (i) as a matter of law; (ii) to exercise, establish or defend our legal rights; (iii) to protect your vital interests or those of any other person; or (iv) to report any actual or suspected breach of applicable law or regulation;
  • Any other person or entity with your consent to the disclosure.

Our Site may use social media and survey-taking plug-ins.  If you choose to interact with a plug-in, your personal data may be shared with the operator of the relevant plug-in.


We also share personal data with entities that control, are controlled by, or are under common control with us (our “Affiliates”) for the reasons described in this Privacy Policy and subject to binding obligations to process your personal data as least as protectively as described in this Privacy Policy.

 

International Transfer of Personal Data

As a result of the international nature of our business, we and our Affiliates may transfer and process your personal data outside the jurisdiction in which you reside.  When we and our Affiliates collect your personal data, we may transfer it to or process it in any of the countries in which we do business.

 

The vendors, suppliers and business partners with which we may share personal data are located in and transfer personal data to various jurisdictions around the world in order to help us offer the Site and our services to you. These other jurisdictions may have data protection compliance laws that are different from the laws where you reside (and, in some cases, not as protective).

 

We use appropriate safeguards to ensure that your personal data is protected in accordance with this Privacy Policy. These safeguards include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data that require protection of personal data in accordance with European Union data protection law.  Please contact us if you have questions about our safeguards for cross-border transfers of your personal data.

 

Protecting Personal Data

We use appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and other unlawful or unauthorized forms of processing.  No data transmission or storage can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your credentials for access to or use of our Sites.

 

Please notify us immediately of any unauthorized use of your credentials or access to your account by emailing us at 451Alliance@451alliance.com.

 

Data Accuracy

We take reasonable steps to ensure that your personal data that we process are accurate and, where necessary, kept up to date.  From time to time we may ask you to confirm the accuracy of your personal data.


Data Retention

The criteria for determining the period of time for which we will keep your personal data are as follows:  we will retain copies of your personal data in a form that permits identification only for as long as is necessary in connection with the purposes set out in this Privacy Policy, unless applicable law requires a longer retention period.  We may retain your personal data for the duration of any period necessary to establish, exercise or defend any legal rights.

 

When we have no ongoing legitimate business need to process your personal data, we follow our information governance procedures and either delete or anonymize your personal data, or if deletion or anonymization is not possible, then we securely store your personal data and isolate it from further processing until deletion is possible.

 

Please contact us for more information about the period of time for which we will process your personal data.

Children

The Site and services are not intended for use by minors (i.e., children under age 18 or the age of majority if older in a particular jurisdiction).  We do not knowingly collect personal data from minors.   Consistent with the requirements of applicable law, if we learn that a minor has improperly provided us with personal data, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the minor that he or she cannot use the Site or services and subsequently will delete that information. 


Links to Other Web Sites

Our Site contains links to other websites. We are not responsible for the privacy practices of such other websites. Please read about the privacy practices of any other website you visit before you use the website.

 

Your Privacy Rights

This section contains specific privacy notices for California residents and individuals located in the European Union.


IF YOU ARE LOCATED IN A JURISDICTION WITH DATA PROTECTION LAWS THAT OFFER YOU PRIVACY RIGHTS NOT DESCRIBED IN THIS PRIVACY POLICY, PLEASE CONTACT US AT Privacy@spglobal.com.  We respect your privacy rights and will do our best to accommodate your requests.

NOTICE FOR CALIFORNIA RESIDENTS


This California Privacy Rights Notice (“California Privacy Notice”) explains privacy rights available to residents of the State of California as required by the California Consumer Privacy Act of 2018 (“CCPA”). 

 

If this California Privacy Notice and any provision in the rest of our Privacy Policy conflict, then this California Privacy Notice controls for the processing of Personal Information of residents of the State of California.  In CCPA, California residents are referred as “consumers” and we refer to them in this California Privacy Notice as “California Consumers” and  “Personal Information” means information that identifies, relates to, describes, is capable of being associated with or could reasonably be linked, directly or indirectly, with a particular California Consumer or household. 

 

Your California Consumer Privacy Rights


CCPA offers California Consumers the following key privacy rights:


  • Right to Access Information: You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it and the third parties and service providers with whom we share it. 
  • Right to Request Deletion: You have the right to request that we delete certain Personal Information that we have collected from you.
  •  Right to Notice of Financial Incentive:  If we offer a financial incentive or price or service difference in exchange for your Personal Information, we will notify you in advance before collecting your Personal Information for this purpose and explain how you can opt in to the financial incentive or price or service difference.
  • Right to Opt-Out of Sale of Personal Information to Third Parties: You have the right to opt out of our sale of your Personal Information if and when we determine the purpose and means of processing of your Personal Information.  (In CCPA, “sale” means transferring or making available Personal Information to third parties for monetary or other valuable consideration.)  Sharing your Personal Information with our service providers is not a sale of your Personal Information because we make sure that our service providers are contractually obligated to use the Personal Information only to provide services to us and not to sell it. Please click here for details about whether and how to opt out of sale.  

 

Our California Notice at Collection of Personal Information


For CCPA purposes, 451 Research acts as a “business” with respect to your Personal Information, which means that 451 Research determines how and why the Personal Information that 451 Research collects from or about you is processed.

 

This Notice at Collection of Personal Information describes our Personal Information collection practices, including a list of the categories of Personal Information we collect and the purposes for which we collect Personal Information. 

 

The following table lists categories of Personal Information that generally match the categories in the definition of Personal Information in CCPA.  We indicate for each listed category the specific types of Personal Information in the category that we collect and why we collect it.  We provide information about how we use and disclose Personal Information and the sources from which we collect Personal Information above in this Privacy Policy. 

 

Category of Personal Information as listed in CCPA

Examples of Personal Information in CCPA Category that 451 Research Collects

Why 451 Research Collects this Personal Information

A. Identifiers

Name, postal address, email address, unique identifier, Internet Protocol address, account name, and similar identifiers.

 

We collect your IP address and your Device ID automatically.

 

We do not collect your social security number, driver’s license number or passport number.

 

We collect your name, telephone number(s), email address(-es) and contact address when you register with our Site.

 

We collect this Personal Information:

· To provide and recommend content to you

· To learn how users interact with our Site

· To improve our products and services and develop new features

· To customize your experience

· To promote our and our partners’ services to our members

· To communicate with you

· To identify issues with our Site and our services and troubleshoot problems

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Name, address, telephone number and current employer.

 

We do not collect your insurance policy number, medical information, or health insurance information.

We collect your name, address, telephone number, and employer when you register with our Site. We collect this Personal Information:

· To help us assess your application for membership

· To provide and recommend content to you

· To identify issues with our Site and our services and troubleshoot problems

· To learn how users interact with our Site

· To improve our products and services and develop new features

· To promote our Site and services

· To communicate with you

C. Protected classification characteristics under California or federal law

We may collect your gender if you choose to provide that information.

 

We generally do not collect information about legally-protected classifications, including race, citizenship, marital status, sexual orientation/identity, medical condition, AIDS/HIV status, genetic information, military or veteran status, religion, disability, political affiliations or activities or status as a victim of domestic violence, assault or stalking.

When you chose to provide us with your gender identity, we use this information in connection with your membership.

 

 

D. Commercial information

Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

We create records of members’ and visitors’ activities to provide the services they have requested and to promote other available opportunities, such as our partners.

 

E. Biometric information

We do not collect information about your physiological, biological or behavioral characteristics.

N/A

F. Internet or other similar network activity

Usage details, search queries, information on a California Consumer’s interaction with online services and digital advertisements.

We collect information about your Site usage details and search queries automatically when you use our Site

· To identify issues with our Site and our services and troubleshoot problems

· To learn how users interact with our Site

· To improve our Site and services and develop new features

· To provide and recommend content to you

· To customize your experience

· To promote our Site and services

· To secure our IT systems

 

We collect information about your interactions with our digital advertisements and our partners.

G. Geolocation data

Physical location determined from IP address.

We collect your IP address automatically. We may be able to determine your general location based on the IP address.

H. Audio, electronic, visual, thermal, olfactory or similar information.

Voice recording.

We do not collect any thermal, olfactory, visual or similar information.

We conduct telephone interviews with our members and record these interviews when permitted. We will notify you at the beginning of the telephone call if a telephone call is recorded.

I. Professional or employment-related information

When you register with the Site, we may collect your organization’s name and your job title, work status, industry, area of IT involvement, department and job function. We may also collect your highest degree achieved, your educational institution and your major or area of study.

We may use information about your position and your organization to understand more about you in order to help us assess your application for membership, provide and recommend content to you, promote our Site and services and communicate with you.

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g, 34 C.F.R. Part 99))

None

N/A

 

K. Inferences drawn from other categories (A. – L above) to create a profile about a California Consumer

Profile reflecting your preferences and characteristic

We may analyze your actual or likely preferences through the Personal Information we collect and process as described in our Privacy Policy.

 

Since we may share Personal Information with other businesses and this sharing enables 451 Research to generate valuable consideration, it is possible that some of these categories were “sold” in the past twelve months.

How To Submit A Request To Exercise Your California Privacy Rights

To submit a request to exercise your privacy rights:

  1. Call us at 1-855-529-1761.
  2. Email us at CCPA@spglobal.com
  3. Submit a request to for details about whether and how to opt out of sale here.

Please note:

  • We may (and in some cases are required to) verify your identity before we can act on your request to exercise your privacy rights. 
  • We may not honor part or all your request – for example, certain information we collect may be exempt from this California Privacy Notice, such as public information made available by a government entity.  Please also note that Personal Information collected in many types of B2B transactions is exempt from most of CCPA’s requirements until January 1, 2021.  We will explain why we do not honor your request when we respond to you.

A different California law permits California residents to request a notice disclosing the categories of Personal Information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year.  At this time, 451 Research does not share Personal Information with third parties for their direct marketing purposes.

 

Notice for Individuals Located In EU

For personal data for which we are the data controller and for which applicable law grants you data protection rights, if you would like to review, correct, update, suppress, restrict or delete personal data that you have previously provided to us as or if you would like to receive an electronic copy of your personal data for purposes of transmitting it to another company (where this right to portability is provided to you by law), please submit your request to us using the contact information above.

In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data suppressed from our database or what other limitations you would like to put on our use of your personal data.  For your protection, we only fulfill requests for 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 and geographic location or place of residency before fulfilling your request.  We will try to comply with your request as soon as reasonably practicable and within the time periods required by applicable law.

Please note that we often need to retain certain personal data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion (e.g., when you register for a webinar, you may not be able to change or delete the personal data provided until after the completion of such webinar).  Our databases and other records may have residual personal data which will not be removed.  We also may not allow you to review certain personal data for legal, security or other reasons.

EEA residents have the right to lodge a complaint with a data protection authority about how we process your personal data.  Please see https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en for more information. 

Privacy Policy Updates

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments.  When we update our Privacy Policy, we will post the updated version and update the date at the top of this webpage.  We also will take appropriate measures to inform you in advance so that you have an opportunity to review the revised Privacy Policy before it is effective.  If your consent is required by applicable privacy laws, we will obtain your consent to changes before the revised Privacy Policy applies to you.


Contacting 451 Research

If you have comments, concerns or questions regarding this Privacy Policy, please contact us by email at: 451Alliance@451alliance.com