Effective Date: December 2021
1. Information We Collect
We collect information in connection with the provision or potential provision of services, including, for example, transaction records, trade repository, clearance, settlement, custody and asset servicing, transaction processing services, or other services provided by our subsidiaries (collectively, the “DTCC Services” or “Services”). DTCC Services may be provided to customers, participants and members (collectively, “Customers”). DTCC Services are generally provided directly to businesses and the information we gather generally relates to these business customers. Personal information related to Customers and prospective Customers, including business representatives, agents, employees, administrators, and users of our Services that may be collected by us include, but is not limited to:
- First and last name,
- Job title,
- Areas of business coverage,
- Organization or department,
- Business address (including street and city name),
- Telephone or fax number,
- Email address, and
- Other information voluntarily provided to us.
Collection of such business contact information is required to enable us to provide Services to our Customers. Other information may be required to enable us to verify the identity or authority of Customer, or its representatives, agents, employees, administrators, and users or for “Know your customer” purposes, where applicable.
2. Additional Online Information Gathering
When visiting or using our websites or online services (collectively, “Websites”) we may collect certain information through automatic means, such as logging. This may include information such as IP address, type of browser and operating system used, information regarding internet service provider or the type of device used to access our Websites, date and time of such access, navigation to and through our site, search terms, bookmarks, document downloads, how long a web page is visited, and other sites visited that link to or from our Websites and may be tied to an individual when logged into our systems.
For convenience, we may provide links to websites, apps, or online services that are not operated by us. We are not responsible for the privacy practices of any websites, apps, or online services that we do not provide or operate. We recommend reviewing the privacy notices or policies of these third-party websites, apps, or online services in order to understand their information practices.
3. How We Use Information
We may use the personal information we gather for the following purposes:
- to provide and support DTCC Services, including uses or disclosures that are usual or customary to carry out the DTCC Services for which the information was given, or a related transaction;
- to communicate with Customers or provide more relevant communications, for example, in response to requests, questions, comments, or other site activities (e.g., whitepaper downloads, event registration);
- to maintain and manage accounts;
- to operate, evaluate and improve our business (including diagnosing technical and service problems; administering our Websites; identifying users of our Websites; developing new products and services; managing our communications; determining the effectiveness of our sales, marketing and advertising; analyzing and enhancing our products, services and Websites; and performing accounting, auditing, billing, reconciliation and collection activities);
- to perform data analyses (including market research, trend analysis, and financial analysis);
- to comply with applicable legal requirements and advice, government regulations, and our policies; and
- with your consent, to inform a prospective Customers and current Customers, or its representatives, agents, employees, administrators, and users about products, services, or opportunities that may be of interest to them.
We may also use the information we gather in other ways for which we provide specific notice at the time of collection. In addition, we may use your information with your consent or as approved by you from time to time.
4. Information We Share
Information we gather may be shared among DTCC and its subsidiaries and their service providers in order to support the purposes for which we may use information. We may entrust, delegate, and otherwise share information with:
Corporate Affiliates: We may share information we gather with our Affiliates for their everyday business purposes, to provide services or to perform marketing.
Service Providers: We may share information with third party service providers who help us provide, develop and offer products and services. If you choose to use a particular feature within some of our products, you may be presented with a link directing you to a third-party provider which may have privacy policies or notices that differ from ours. Other service providers process data at our direction and in accordance with this policy.
Regulators: We may share information and records we maintain with financial or other regulators and in response to requests by courts or government authorities, such as law enforcement agencies and officials.
Business Transfer: We may share information we have gathered in connection with the sale or merger of our business, affiliates, or the transfer of assets.
We may also use and share the information we gather: to enforce our rights and protect our property and interests and those of our Customers, members of the public, and others; to comply with applicable law, legal process, and legal advice; and for preventing fraud, theft, and injury to our Customers, ourselves, or others.
5. Information Safeguarding
We maintain an information security program setting forth standards for maintaining administrative, technical and physical safeguards to protect the personal information provided by our Customers against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. DTCC periodically tests the security protections of its information systems and monitors the effectiveness of its information security controls, systems and procedures.
6. Data Transfers
- Hong Kong
- United States
- United Kingdom
7. Data Retention
The personal data you submit to us will only be retained for as long as is required for the purposes for which it was collected. Contact information about individuals such as mailing list information is kept until a user unsubscribes to a publication or requests that we delete that information.
8. Individual's Rights
Customers have the right to request details of the information that DTCC holds about them such as their email address, contact information, or other personal information. Any requests for access to correct, rectify, or erase any inaccurate information gathered by DTCC or its subsidiaries can be directed to [email protected].
10. Your California Privacy Rights
If you are a resident of California, the California Consumer Privacy Act of 2018 (“CCPA”) grants certain rights to residents of California to access or delete the personal information that we have collected about you. You have the right to request what personal information we collected, used, or disclosed about you within the preceding 12 months. We do not sell the personal information we collect to third parties. Once we receive your request and confirm your identity, we will disclose to you the information we have collected about you, as required by the CCPA. Contact us at our address below for this information.
Our websites and services do not respond to a browser’s do not track request or similar mechanism.
11. Notice on Information Collected as Part of Proposed Rule Filings
If any written comments are received to our proposed rule filings, they will be publicly filed as Exhibit 2 to the filing, as required by Form 19b-4 and the General Instructions. Persons submitting comments are cautioned that, according to Section IV (Solicitation of Comments) of the Exhibit 1A in the General Instructions to Form 19b-4, the Commission/SEC does not edit personal identifying information from comment submissions. Commenters should submit only information that they wish to make available publicly, including their name, email address, and any other identifying information.
13. How to Contact Us