Legal

Cookie Policy

Introduction

This policy ("Policy") sets out how KBRA Holdings, LLC and its affiliates and/or subsidiaries ("KBRA" or "we", "us", "our") uses HTTP cookies (or 'traditional' cookies), HTML5 web storage and other types of tracking technologies such as device fingerprinting, pixels, and scripts on its websites, (individually and collectively referred to in this Policy as our "Website"), social media pages and marketing, events and alerts emails to collect, store and/or share information about you (referred to as a "visitor" to the Website or a "subscriber" or "recipient", as applicable), your device, system and interactions with such Website, and marketing, events or alert emails, including in some instances personal data.

Some of the tracking technologies KBRA uses are essential for our Website to work properly and securely, and to comply with applicable law. If they are disabled, the Website may not work in some basic ways. These are referred to as "strictly necessary". Other tracking technologies are not essential, but we use them to help make our Website more enjoyable for visitors, or to improve our Website or emails, for example, by allowing us to collect information about how people use the Website or what email content is of interest. These other tracking technologies are referred to as "optional".

While you must accept the strictly necessary cookies in order to proceed to view or interact with our Website, you can choose whether to accept or reject any or all of the categories of optional cookies by using the options that appear in the banner on our Website. If you don't make a choice in the banner, no optional cookies will be deployed however, the banner will re-appear every time you visit our Website. It will not be possible to proceed to view and use the Website until you make a choice on the banner. You can also choose whether to accept optional tracking technologies in emails as further detailed below in the section Tracking Technologies in Emails. To find information on how to opt out of tracking on social media pages please see below in Links to Other Websites.

What Tracking Technologies does KBRA use?

We use the following tracking technologies for the general purposes outlined here. Please see further detail in the Cookie table below for purposes of individual tracking technologies:

TypeDescriptionSummary of Purpose

HTTP cookies and HTML5 web storage (referred to in this Policy as "cookies")

Small text files that depending on your settings or device can be stored on your computer, smartphone or other information-storing device. It allows our Website to remember your actions or preferences until the cookie is deleted or expires.

Necessary: (i) in seeking to protect our Website against cyber-attacks; (ii) to comply with applicable laws; and (iii) for core website functioning such as only allowing access to subscriber content where authorized.

Optional: (i) enhanced functioning of the Website; (ii) analytics about how the Website is being used; (iii) to assist with bug fixes on the Website by collecting information about visitors' use of the Website to understand where errors arise when using the Website; (iv) analytics about numbers of visitors and their behaviors when interacting with our Website, for example which pages or marketing and event campaigns or alerts are more popular so as to try and increase readership and engagement by our visitors and subscribers; and (v) collect information about visitors' use of the Website operations, like Website navigation, to improve visitors' interaction and reduce the number of clicks required to get to a particular page of interest.

Device Fingerprinting

A process of collecting information and characteristics from a device (such as time zone location, memory size) or a set of features and characteristics from a device to (i) collect information relating to usage of the Website and (ii) maintain and improve the Website so that it supports the device types used to access the Website.

Necessary: To protect our Website against cyber risks, specifically risks posted by bot traffic such as data scraping or denial of service attacks.

Optional: Analytics to assist with bug fixes on the Website by collecting information about visitors' use of the Website to understand where errors arise when using the Website

Tags

Tags allow website operators to track, report, and analyze a Website using a series of codes. We use two types of tags:

Pixels/Tracking Pixels: small, invisible pieces of code that work like a cookie, but instead of storing information in a browser, they deliver information to a server. They are HTML code snippets that are embedded in certain of our marketing and alert emails. When the email is opened, the pixel is triggered and sends a request to a server with information about the recipient, as detailed below.

Optional: (i) assess the appeal of our marketing, events and alert emails to improve our communications by measuring engagement and identifying what content or events are of most interest to recipients, (ii) understand which of our advertising partners has helped us reach new customers on their websites.

Scripts: a piece of program code used in conjunction with an optional cookie to provide enhanced Website functionality and to provide us with analytics. This code is executed on your device when you consent to certain optional cookies.

Optional: (i) to assist with bug fixes on the Website by collecting information about visitors' use of the Website to understand where errors arise when using the Website and analytics about how the Website is being used and (ii) enhance the functioning of the Website, reduce the number of clicks required to get to a particular page of interest and developing our business by reviewing analytics of numbers of visitors and their behaviors when interacting with our Website to understand which content or marketing campaigns are more popular so as to try and increase readership and engagement with our visitors.

Session and Persistent Cookies

Cookies can be stored for varying lengths of time on your browser or device. Depending on your browser settings, session cookies are deleted from your computer or device when you close your browser, whereas persistent cookies will remain stored on your computer or device until deleted or until they reach their expiry date. For more information on deleting cookies from your browser see Managing and Disabling Cookies below.

1st and 3rd Party Cookies

KBRA uses both 1st party and 3rd party cookies. 1st party cookies are stored by KBRA, whereas 3rd party cookies are stored by a domain other than our Website. 3rd party cookies are covered by the relevant third parties' cookie policies and we recommend you review those third-party policies before submitting any personal data to those sites. We have identified in the tables below which cookies are stored by KBRA (1st party) and which are stored by a third party (3rd party). Some of the cookies are 1st party but the data is shared by us with the third-party supplier identified in the description.

Cookie Categories

The tables below provide detail as to the cookies we use, their individual purposes, duration, whether the cookie is placed by us or a third party and what category of cookie it is. We use OneTrust to allow you to set cookie preferences and to scan our Website frequently for tracking technologies so that the information we provide is up to date. If you use a public scanner, you may see small discrepancies, but these may be due to the type of browser you use or interaction with other sites.

Strictly Necessary Cookies

These cookies are necessary for the Website to function securely and properly and to comply with our legal obligations. They are stored when you visit the Website and in response to actions made by you to request services, such as logging in to the Website or setting your cookie preferences. You can set your browser to block or alert you about these cookies, but some parts of the Website will not then work.

NamePurposeExpiry1st Party Cookie / 3rd Party Cookie

OptanonAlertBoxClosed

This cookie is stored by a script from the cookie management tool we use, provided by OneTrust to comply with applicable laws relating to cookies. It is stored after you have seen a cookie information notice and closed it. It prevents us showing you the cookie notice more than once.

Persistent: 6 months

1st Party

OptanonConsent

This cookie is stored by a script from the cookie management tool we use, provided by OneTrust to comply with applicable laws relating to cookies. It stores information about the categories of cookies the Website uses and whether you have given or withdrawn consent for the use of each optional category of cookie.

Persistent: 6 months

1st Party

__cf_bm

This is a cookie associated with one of our suppliers, CloudFlare, and is used by us for cyber security, to help identify whether a human or bot is accessing the Website.

Persistent: 30 minutes

1st Party

cf_clearance

This is a cookie associated with one of our suppliers, CloudFlare, and is used to verify that the visitor is not a bot.

Persistent: 30 minutes

1st Party

dd_cookie_test_

This is a cookie associated with one of our suppliers, Datadog, and tests if cookies can be stored on the visitor's device for error logging.

(Instant deletion)

1st Party

k-session

This KBRA cookie is used to validate when the visitor to our Website has logged in to allow the Website to make subscriber content available to the visitor.

Session

1st Party

_c27f5

This KBRA cookie is a load-balancing cookie that indicates which KBRA server will be handling the visitor's interaction with the Website.

Session

1st Party

_5b23c

This KBRA cookie is a load-balancing cookie that indicates which KBRA server will be handling the visitor's download requests for KBRA publications.

Session

1st Party

auth0

or

auth0_compat

This cookie is associated with our supplier, Auth0, and is used to authorize and enable a KBRA subscriber to access content reserved for subscribers. This cookie is only applicable when a KBRA subscriber submits login details.

The auth0_compat cookie has the same purpose but is used on older browsers that cannot accept the modern cookie settings of the auth0 cookie.

Persistent: Max 3 days

1st Party

_csrf

This cookie is associated with our supplier, Auth0, and is used to protect the Website and its visitors from Cross-Site Request Forgery (CSRF) (cyber) attacks. This cookie is only applicable when a KBRA subscriber submits login details.

Persistent: Max 6 hours

1st Party

did

or

did_compat

This cookie is associated with our supplier, Auth0, and is used to prevent bots from logging in. This cookie is only applicable when a KBRA subscriber submits login details.

The did_compat cookie has the same purpose but is used on older browsers that cannot accept the modern cookie settings of the did cookie.

Persistent: Max 365 days

1st Party

appSession

This cookie stores session data, which ensures your authenticated state is maintained across requests on the Website.

Persistent: 24 hours

1st Party

mapbox.eventData.uuid

mapbox.eventData

These cookies are associated with our supplier, Mapbox which we use to make maps available on our KFI Web App. This cookie calculates aggregate usage statistics; as well as metadata about telemetry events that is only used locally. These cookies are only applicable when a KFI subscriber submits login details.

Persistent

1st Party

PHPREDIS_SESSION

This KBRA cookie is used to validate when the visitor to our Website has logged in to allow the Website to make subscriber content available to the visitor.

Persistent: 1 day

1st Party

auth0_session_*

This is a KBRA authorization cookie applicable only after a subscriber logs in and is used to keep the subscriber logged into the same session.

Persistent: 1 day

1st Party

centerLatitude

centerLongitude

zoom

These cookies are provided by our supplier, Bing in respect of Bing Maps and are used to navigate the map that appears on the Website as part of our Advanced Search tool.

Persistent: 35 days from when you last opened the Advanced Search tool on the Website

1st Party

deviceInfo1

These cookies are provided by our supplier, Bing in respect of Bing Maps and are used to control how the map in our Advanced Search tool appears on your particular device type.

Persistent: 15 days from when you last opened the Advanced Search tool on the Website

1st Party

_$Maps_centerLatitude_expiration

_$Maps_centerLongitude_expiration

_$Maps_deviceInfo1_expiration

_$Maps_zoom_expiration

These cookies are provided by our supplier, Bing and set the expirations for the Bing cookies centerLatitude, centerLongitude, deviceInfo1 and zoom, detailed above.

Persistent: 35 days from when you last opened the Advanced Search tool on the Website

1st Party

Functional Cookies

These are optional cookies. These cookies enable the Website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our Website. If you do not allow these cookies then some or all of these services may not function properly.

NamePurposeExpiry1st Party Cookie / 3rd Party Cookie

financialFormsOptions

landingPageState

These cookies allow the Website to remember filters you have configured when viewing tabular or chart data even after you close your browser session.

Persistent: 12 months

1st Party

Performance Cookies

These are optional cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our Website and fix errors. They help us understand which pages are the most and least popular and see how visitors move around the Website. If you do not accept these cookies we will not be able to fully understand where errors arise and debug the Website performance during your visit.

NamePurposeExpiry1st Party Cookie / 3rd Party Cookie

_dd_s

This cookie relates to one of our suppliers, Datadog, and if accepted, an associated script records the visitor's interaction and use of the Website (and through a device fingerprint, the operating system and browser) in order to report errors relating to that use, log browser errors if experienced by the visitor when using our Website so that we can identify more efficiently how to repair errors by understanding where they arise.

Persistent / Extended by 15 minutes every time the visitor interacts with the pages, up to a total of 4 hours

1st Party

_gid

This is a Google Analytics cookie and is used to distinguish one journey or session on our Website from another.

Persistent: 1 day

1st Party

_ga

_ga_xxxxxxxxxx

These are Google Analytics cookies used to distinguish one visitor to our Website from another.

Persistent: 6 months

1st Party

_gat_xxxxxxxxxxxxxxxxxxxxxxxxxx

This is a Google Analytics cookie used to rate-limit reporting back to Google Analytics, by grouping logs of reports together into one report, and so limiting the collection of data on high traffic websites.

Persistent: One minute

1st Party

_mkto_trk

This cookie is associated with an email marketing service we use, provided by Marketo, Inc and tracks your use of our Website. If you are a subscriber to our emails, this cookie allows our Website to link the visitor to our Website with the recipient of an email from one of our marketing, alerts or event campaigns to which you have subscribed or alert emails, when the recipient clicks the link in the email which brings them to our Website and provides certain limited data about that visitor. In respect of subscribers, we use this to measure (i) campaign or subscription effectiveness (ii) the number of subscribers engaging with our Website content from the relevant email. For non-subscribers, we use this to understand and measure general engagement with our Website.

Persistent: 6 months

1st Party

Additional Performance and Functional Cookies

These are optional cookies. These cookies relate to a third-party service we use, provided by Pendo and enable the Website to provide enhanced functionality and personalization. If you do not allow these cookies then the additional functionality will not be available to you.

NamePurposeExpiry1st Party Cookie / 3rd Party Cookie

_pendo_accountId.

Applies to KBRA subscribers only. When accepted, this cookie's associated script applies a unique ID to the company listed when the visitor subscribed to our Website. This records the visitor's use of the Website and allows us to understand how different KBRA clients use and interact with the Website and our content.

Persistent: 100 days

1st Party

_pendo_visitorId.

This cookie identifies and associates a specific ID to each unique visitor to our Website. Its associated script records the visitor's use of the Website and allows us to understand how different visitors use and interact with the Website.

Persistent: 100 days

1st Party

_pendo_meta.

When the visitor accepts this cookie, it is used in conjunction with a script to identify if there are changes to the ID allocated to the visitor by the_ pendo_visitorId cookie and, for subscribers only when they are logged in, their company ID identified by the _pendo_accountId. cookie to maintain the accuracy of the data in the Pendo database.

Persistent: 100 days

1st Party

_pendo_lastStepAdvanced.,

_pendo_latestDismissedAutoAt.,

_pendo_finalDismissedAutoAt.

These cookies record the visitor's recent interactions with visitor information notices or tooltips ("Guides") on our Website so they do not see Guides they have already viewed.

Persistent: 10 seconds

1st Party

_pendo_guides_blocked.

This cookie detects whether the visitor has an ad blocker activated on their device to prevent errors arising (such as the visitor's browser crashing) when a Guide is due to appear on our Website.

Persistent: 30 minutes; or up to 4 hours if our Website doesn't detect an ad blocker.

1st Party

pendo_tabId

pendo_cd

previous_page_loads

When accepted, this cookie and its associated script allows us to follow the visitor's use of and interaction with our Website on a single tab of their browser, so as to distinguish it from any other use of our Website on other tabs in the same visitor's browser. This information is periodically shared back to help us understand how visitors interact with and navigate around our Website, so as to improve the visitors' experience.

Session

1st Party

Tracking Technologies in Emails

When you subscribe to alerts emails, we may also send you emails about our and/or KBRA affiliates events, services and products. With your consent, in those emails and any marketing emails you have subscribed to, or webforms relating to any of events we host or sponsor which you RSVP to, we use tracking pixels. For more information on the personal data we collect using these pixels, please see the Tracking Pixels section of the table in Cookies and Your Personal Data, below.

Unsubscribing from emails

If you wish to opt-out of receiving marketing or alert subscription emails from us, please update your preferences at https://www.kbra.com/account-preferences/ or click the link in the email footer at any time and delete any emails that you have received from us. You can also unsubscribe at any time by contacting us at [email protected].

Cookies and Your Personal Data

What we mean when we refer to 'personal data'

In this Policy, the term 'personal data' includes (i) "personal data", as such term is defined under the European Union General Data Protection Regulation (EU) 2016/679 and the United Kingdom General Data Protection Regulation; (ii) "personal information", as such term is defined under the California Consumer Privacy Act of 2018 ("CCPA") (Civil Code § 1798.100); and (iii) "private information", as such term is defined under the New York Stop Hacks and Improve Electronic Data Security Act ("SHIELD Act") (N.Y. Gen. Bus. L. §899-bb).

When we use cookies and tracking technologies, we process limited personal data as follows:

Type of Cookies/Tracking TechnologiesPurposeCategories of Personal Data ProcessedLegal Basis

Strictly necessary cookies

As described in the tables above

  • Unique user ID
  • IP address
  • Inferred country of IP address
  • Whether you have consented to any optional cookies and which categories (if any)

Necessary for (i) compliance with a legal obligation to which we are subject and (ii) the purposes of our legitimate interests, specifically our legitimate interests in securing our Website and making it available to you when processing that personal data, provided such interests are not overridden by the rights and interests of the data subjects concerned.

Optional cookies (and associated scripts)

As described in the tables above

  • Unique user ID
  • IP address
  • The visitor journey on the Website and, only when logged in, name and email and company
  • Browser
  • Operating System
  • Whether ad-blockers are installed on your device, whether you have already seen user guides on our Website.
  • Marketo cookie only: the IP address from which you are visiting our Website, a unique user ID, the time and date of the visit and the type of browser used, the URL of the previous website visited. This data is associated with any personal data submitted in any webform completed or the account of the subscriber (if the visitor is a subscriber).

Your consent (which you may withdraw at any time).

Tracking pixels in emails

To improve the effectiveness of our email campaigns to recipients. To do this, we review the data collected to see which emails were opened or forwarded and whether the links were clicked, to understand how many recipients were interested in the content. We can then provide more tailored content/event invitations to subscribers based off their positive interaction with similar content. We identify if the email was presented appropriately for browsers of the majority of devices used to view our emails and visit our Websites.

When you open a marketing event related or alert email from us that contains a tracking pixel, we process the following data:

When and how often you opened the email and click on any of the links in it. We also allocate a unique identifier and obtain the following data from your device: your IP address and inferred location, the type of device, browser and platform you are using, the last website visited before landing on a KBRA linked page, the hardware model, operating system and version and whether you are visiting the linked platform or site from a mobile device. If you RSVP to an event, the data you submit in the form is linked to this data.

(a) Your consent which you may withdraw at any time (please see more detail in the section Unsubscribing from emails above) and (b) our legitimate interests in (i) maintaining, operating and improving our emails using optimal presentation; (ii) providing our services to recipients and subscribers; and (iii) managing and improving our business and services by understanding which marketing campaigns, events and alerts were more successful or of interest to recipients, provided such interests are not overridden by the rights and interests of the data subjects concerned.

For further information on the data controller of any of the above personal data, please see the section entitled Data Controller Information below.

How we collect your data

We collect your personal data from you directly, where you interact with our Website or any of our marketing or alert emails that contain tracking pixels.

Who we share your personal data with

In addition to the third-party suppliers referred to in the cookie tables above, we disclose personal data to:

  • third parties, including consultants and professional advisers, who provide a service to us such as cyber security providers, cloud service providers, email and database management providers, Website and data analytics/modelling platform providers, and technology service providers including scanning and data destruction providers;
  • a public authority or third party in the event that we are required to do so by legal obligation;
  • a prospective seller or buyer of any of our assets or business; and
  • a third party where it is necessary to protect the vital interests of the data subject or another natural person.

Transfers of Personal Data (FOR CITIZENS OF THE EU AND UK)

As a global business, the personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) and/or United Kingdom (UK), including, in particular, to the United States where our primary servers are located. Your personal data may also be processed outside the EEA and/or the UK by KBRA employees or by one of our suppliers acting on our behalf. When transferring your personal data, in accordance with the requirements of applicable law, we will do so subject to appropriate safeguards to protect the privacy and integrity of such personal data including pursuant to specific contracts approved by the European Commission which give your personal data the same level of protection it has in Europe, or by confirming that the recipient is a member of the Data Privacy Framework, which requires the member to provide similar protection to personal data shared between Europe and the US.

Please contact us at [email protected] if you wish to obtain information concerning such safeguards.

Security Measures

We have in place appropriate technical and security measures to protect your personal data from unauthorized access, destruction, loss or misuse and require that our service providers do the same. We restrict access to your personal data to those who need to know it to carry out their function and any access is subject to an obligation of confidentiality. Neither the internet nor any electronic or physical system is ever fully secure and many factors outside our (or our service providers') control may impact the security of your data including unauthorized entry or use, hardware or software failure, may and we cannot guarantee its security when being transmitted. If you are a KBRA account holder, you must select an appropriately secure password and take measures to protect the confidentiality of any password and/or login details used to access our Website, log out when you are not using the Website and limit access to your device. You should be aware that your transmission of your data is at your own risk. Once we receive it, we will use appropriate measures to protect it.

How long do we hold your personal data?

We will not retain your personal data for longer than is necessary for the purposes for which it was collected, as required by law, regulatory guidance to which we are subject, and for the exercise of and to defend against legal claims which may be brought by or against us and for the exercise or defense of any legal claims.

Your rights

Under applicable data protection law you have the rights set out below. If you wish to exercise any of your rights please email [email protected], but please note these rights are not absolute and may not be exercised in certain circumstances, such as when the processing of your personal data is necessary to comply with a legal obligation or for the exercise or defense of legal claims. We will respond to any request in accordance with applicable data protection law, other applicable laws and regulatory guidance. All requests will be dealt with promptly and any information to which you are entitled will be provided within a reasonable timeframe as required by applicable law, subject to the exemptions stipulated in applicable data privacy laws. We may request proof of identification to verify your request.

If you are a European Union ("EU") / United Kingdom ("UK") Citizen

If you are a citizen of the EU or UK, the GDPR/UK GDPR provides you with specific rights with respect to your personal data. Your rights are as follows:

  1. The right to request access to a copy of your personal data and details of the processing. (An initial copy of your personal data is provided free of charge, but we may charge a reasonable fee, based on administrative costs, for any further copies that you request.)
  2. The right to ask us to correct any inaccurate or incomplete personal data we hold about you.
  3. The right to request that we delete your personal data in certain circumstances, including: (i) the personal data are no longer needed for the purpose for which they were collected; (ii) you withdraw your consent (where the processing was based on consent); (iii) you object to the processing and there are no overriding legitimate grounds justifying us processing the personal data (see further your right to object below); (iv) the personal data has been unlawfully processed; or (v) to comply with a legal obligation. This right does not apply where, for example, the processing is necessary (a) to comply with a legal obligation; or (b) for the establishment, exercise or defense of legal claims.
  4. The right to ask us to restrict or suspend our processing of your personal data in certain circumstances, including where you query the accuracy of the data, where the processing is unlawful or no longer necessary or where you have objected.
  5. The right to object to the processing of your personal data where our legal basis for processing your personal data is our legitimate interests (or those of a third party). In such a case, we will stop processing your personal data unless we can demonstrate compelling legitimate interests which override your interests, and you have a right to request information on the balancing test we have carried out. You also have the right to object where we are processing your personal data for direct marketing purposes. To do this, please refer to the sub-section entitled Unsubscribing from emails above.
  6. The right to request that we provide the personal data you provided to us in a structured, commonly used and machine-readable format or to transmit the personal data to a third party without hindrance, where technically feasible.
  7. The right to withdraw your consent at any time where we are relying on consent to process your personal data. The withdrawal of your consent will not invalidate any processing we carried out prior to your withdrawal and based on your consent.
  8. You have the right to lodge a complaint with the relevant data protection supervisory authority if you think that we are not complying with our obligations in relation to our processing of your personal data.
  9. The personal data you provide to us in respect of strictly necessary cookies is required to make the Website available to you securely and lawfully. If you do not accept the strictly necessary cookies, it will not be possible to proceed to view and use the Website.
  10. We use automated decision making and profiling as follows: in respect of marketing email subscribers, we use software to help us better understand how you like us to communicate with you and whether you may be interested in our products and services. For example, based on our records that you have recently shown an interest in a certain product, our software helps us identify related products and services that may interest you. We may then use this to contact you about these by post or telephone. You can object to any decision about you based solely on this automated processing (and profiling) that produces legal effects or otherwise significantly affects you.

If you are a California Resident

If you are a resident of California, the CCPA provides you with specific rights regarding your personal data, including the following:

  1. You may request that we delete any personal data that we have collected about you. This right is limited in a number of circumstances, for example, where it is reasonably necessary for us to maintain your personal data in order to comply with a legal obligation.
  2. You may request that we correct inaccurate personal data we hold about you.
  3. You have the right to know what personal data is being collected about you and the to request us to provide the following information: (i) the categories of personal data we collected about you in the preceding twelve (12) months; (ii) the categories of sources from which your personal data was collected; (iii) the business or commercial purpose(s) for which your personal data was collected; (iv) the categories of third parties with whom we shared your personal data; and (v) the categories of personal data we disclosed for a business purpose in the preceding twelve (12) months and, for each category identified, the categories of third parties to whom we disclosed that particular category of personal data.
  4. The right to direct us not to sell or share your personal data with third parties.
  5. The right to exercise your data subject rights without having to endure any form of retaliation or loss in your user experience.
  6. The right to direct us to only use your sensitive personal information (as defined under CCPA) (for example, your social security number, financial account information, your precise geolocation data, or your genetic data) for limited purposes, such as providing you with the services you requested.

During the past twelve (12) months, from California residents, we collected the categories of personal data described above in the columns entitled Categories of Personal Data Processed in the table in the section Cookies and Your Personal Data and disclosed such personal data to third parties for the purposes specified above under Who we share your personal data with.

You may exercise any of the rights described in this section by (i) clicking here and completing the form linked; (ii) submitting a written request to (a) Legal Department at Kroll Bond Rating Agency, 805 Third Avenue, 29th floor, NY, NY 10022 or (b) [email protected]; or (iii) calling (646) 731-1240. To exercise any of the rights above, it may be necessary for us to verify your identity or authority to make the request and confirm the personal data relates to you. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. If you are making the request yourself, we will verify your identity through our existing authentication practices for your password-protected account. We will not discriminate against you for exercising any of your privacy rights under the CCPA or applicable law.

Data Controller Information

For the purpose of applicable data privacy laws, the data controller of your personal data is:

  1. for visitors to the Website generally (excluding KBRA Analytics Websites and emails): KBRA Holdings LLC;
  2. for customers of and subscribers to KBRA Analytics products or visitors to KBRA Analytics products Websites or content: KBRA Analytics, LLC;
  3. for customers of KBRA: Kroll Bond Rating Agency, LLC;
  4. for customers of KBRA Europe: Kroll Bond Rating Agency Europe Limited; and
  5. for customers of KBRA UK: Kroll Bond Rating Agency UK Limited.

In respect of any processing of personal data described in 2-5 above, KBRA Holdings, LLC acts as a joint data controller with the other data controller identified.

You are entitled to exercise your rights as a data subject against any or all of these joint controllers to the extent that it or they act as a joint controller of your personal data by directing any such requests to [email protected].

In limited circumstances (such as our use of social media and advertising on third party websites), we may also act as a joint controller with another non-KBRA party. In such circumstances, upon your request to exercise any of the above rights we will advise you if there is another controller who you should contact. Please note that any other such joint controller will also have its own privacy policy and cookie policy.

Managing and Disabling Cookies

Using the 'Manage Cookies' Link

The cookies identified above as strictly necessary cannot be turned off. Optional cookies are useful to us or to you but require your consent before we place them on or access them from your device. Our default setting is to turn off these optional cookies unless you consent to them. You can change your initial consent preference at any time. To do so, click on the 'Manage Cookies' link on any page of our Website. You may need to refresh your page for the settings to take effect. If you do not change your preference, your current preference will continue to apply. Turning off cookies will not get rid of any that have been downloaded in the past. These can only be removed by deleting them from your browser (for details on how to do this, see below in Browser Settings).

Browser Settings

Most browsers also have an option for turning off cookies, which prevents your browser from accepting new cookies. If you prefer not to be tracked, you can also activate the 'Do not track' feature available in all browsers. You can activate it by accessing your browser's 'Settings'. https://allaboutcookies.org provides instructions on how to manage cookies on different types of web browsers. You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Please note that you may also lose some saved information (e.g., saved login details, site preferences).

To block Google Analytics cookies specifically, you can install the "Google Analytics Opt-out Browser Add-on" provided by Google here: https://tools.google.com/dlpage/gaoptout.

Email Pixels

To withdraw your consent to tracking technologies in emails for marketing events and alerts, please follow the instructions in the section above entitled Unsubscribing from emails.

Our Website or emails may contain links to other websites, including social media platforms and media providers. Those websites and platforms have their own cookie and privacy policies and are not under KBRA's control. Please review those third-party policies before submitting any personal data on those sites. KBRA does not accept any liability or responsibility for such third parties. If you navigate to our Website from another third-party website or platform, they have their own cookie and privacy policies and are not under KBRA's control. Please review those third-party policies before submitting any personal data on those sites. Depending on their tracking technologies, we may receive their HTTP cookies which shares the details of that previous website you visited with KBRA. KBRA does not track or review this information and does not accept any liability or responsibility for such third parties.

Changes to This Policy

We may change this Policy from time to time. If we make any changes, we will post those changes in this document and update the "Last Updated" date at the bottom of this Policy. However, if we make material changes to this Policy, we will notify you by means of a prominent notice on our Website prior to the change becoming effective.

Contact Us

If you have any questions, comments, requests and complaints regarding this Policy, please contact [email protected].

In accordance with applicable laws, you may lodge a complaint with the data protection supervisory authority for your country or region, or where an alleged infringement of applicable data privacy law occurs.

Last updated: 3 December, 2024

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