Japan

This Japan Addendum ("Japan Addendum") supplements this Policy to the extent that the Act on the Protection of Personal Information (Japan) applies in relation to the processing of personal information in Japan by S&P Global Ratings Japan Inc., S&P Global SF Japan Inc., Standard & Poor's International LLC, Japan Branch, IHS Markit Japan GK (together "S&P Global Japan") and/or S&P Global entities located outside Japan. If there are any inconsistencies between this Japan Addendum and the rest of this Policy in relation to S&P Global's process of personal information subject to the APPI, this Japan Addendum prevails.

S&P Global will comply with applicable Japanese data protection laws and regulations and not use personal information for purposes which are not set forth in this Policy or otherwise communicated to the data subject. The process for submitting a claim or request is set out in this Privacy Policy and Addendum.

Joint-use of personal information inside of S&P Global Group

S&P Global Japan jointly uses personal information with other entities in the S&P Global group who may use personal information to provide information about our Services to our clients and related support and training, conduct certain market research, contact clients, or engage in other activities detailed in this policy. S&P Global Japan may also have certain products that collect business information about individuals in Japan. Such information includes: address, name, company name, department name, job title, phone number, fax number, e-mail address, billing information, history of personnel changes and professional employment history, records of job interviews with S&P Global Japan, your areas of interest, etc.

A list of our group companies is available here.

Name, address and name of representative of the person responsible for the management of said personal data  

S&P Global Ratings Japan Inc, S&P Global SF Japan Inc. 

Marunouchi Kitaguchi Bldg. 28th Floor, 1-6-5 Marunouchi, Chiyoda-ku, Tokyo 100- 0005  Representative Director Takenari Yamamoto

Standard & Poor’s International LLC Japan Branch 

Marunouchi Kitaguchi Bldg. 28th Floor, 1-6-5 Marunouchi, Chiyoda-ku, Tokyo 100- 0005  Representative in Japan Sachiko Katayama 

IHS Markit Japan GK

3-1-1 Kyobashi, Chuo-ku, Tokyo 104-0031

Contact information regarding handling of personal information

If you have any questions or concerns about our disclosure, correction, deletion, utilization, or other processing of your personal information (including how we secure your personal information), please contact our Privacy Compliance Team via email at privacy@spglobal.com or Japanprivacy@spglobal.com or via mail, at: Marunouchi Kitaguchi Bldg. 28th Floor, 1-6-5 Marunouchi, Chiyoda-ku, Tokyo 100- 0005, Tel: +81-(0)3-4550-8000.

S&P Global Market Intelligence Privacy Notice for Japan

S&P Global Market Intelligence’s inclusion of your business contact information in our resources for capital markets professionals

S&P Global Market Intelligence, a division of S&P Global, Inc., with its registered address at 55 Water Street, New York, NY 10041, United States (President and CEO: Doug Peterson), has collected your business contact information (such as your name, job title and/or function, business phone number, business postal address and business email address) (“Information”) from multiple sources, from your counterparties throughout the global capital markets community, or from you, as described below, to include within our comprehensive resource of contacts in the global capital markets community.

About the S&P Global Market Intelligence Data

S&P Global Market Intelligence data allows investors and capital markets professionals to work more efficiently in the market by helping to identify the appropriate recipients to receive information in connection with a particular financial opportunity. Capital markets professionals greatly benefit from having their Information conveniently available in our resources.

The primary purpose of the data is to provide the S&P Global Market Intelligence clients with a comprehensive resource regarding individuals and companies in the global capital markets community (“Capital Markets Participants”), which they may use to facilitate relevant business-to-business communication and information exchange with such contacts (see “How We Share Your Information” below) and for marketing of S&P Global Market Intelligence products and services (see “Marketing” below).

Please review this Privacy Notice to understand how S&P Global Market Intelligence processes your Information, including how we collect, use, and store your Information.

To enable S&P Global Market Intelligence to maintain the accuracy of its data and to ensure we comply with your jurisdiction's data privacy laws:

We encourage you to review your Information. To update your Information, please use the link in “Your Information and opt-out” below.

If you prefer that we do not process your Information as described in this Privacy Notice, you may opt-out by using the options set out in “Your Information and opt-out” below.

We may translate this Privacy Notice into other languages. If there are any inconsistencies between the English version and any other language version of this Privacy Notice, the English version will prevail.

About Us

S&P Global Market Intelligence and its affiliates are collectively referred to in this privacy notice as “S&P Global Market Intelligence”, “we”, “us” or “our.”

S&P Global, Inc. (NYSE: SPGI) provides essential intelligence. We enable governments, businesses and individuals with the right data, expertise and connected technology so that they can make decisions with conviction. From helping our customers assess new investments to guiding them through ESG and energy transition across supply chains, we unlock new opportunities, solve challenges, and accelerate progress for the world.

We are widely sought after by many of the world's leading organizations to provide credit ratings, benchmarks, analytics, and workflow solutions in the global capital, commodity and automotive markets. With every one of our offerings, we help the world's leading organizations plan for tomorrow, today.

S&P Global Market Intelligence is a business division of S&P Global, Inc. (“SPGI”). SPGI also has other divisions such as: S&P Dow Jones Indices, S&P Global Commodity Insights, S&P Global Mobility, and S&P Global Ratings, each of which provides different products and services. S&P Global Market Intelligence keeps the activities of its business divisions separate from each other in order to preserve the independence and objectivity of their activities in accordance with the S&P Global Divisional Independence and Objectivity Policy. S&P Global’s Market Intelligence division (“SPGMI”) produces information including price assessments and indices. SPGMI maintains clear structural and operational separation between its price assessment activities and the other activities carried out by S&P Global Market Intelligence and the other business divisions of SPGI to safeguard the quality, independence and integrity of its price assessments and indices and ensure they are free from any actual or perceived conflicts of interest.

What Information we Collect and Process

S&P Global Market Intelligence data contains information relating to Capital Markets Participants. We may collect and process any or all of the following types of Information about you: name, age, gender, company association, telephone number (general or direct business numbers, faxes, and/or mobile numbers), business email address, job title and/or -function, office address, work and education history, professional affiliations, public and private markets investments, -holdings and coverage, compensation, insider holdings and -activity, professional board- and committee memberships, as well as links to social media and professional networking sites.

How We Collect and Use Your Business Contact Information

We may collect your Information via:

• our research department, typically using publicly available sources – including content made public on professional network websites, other websites, public regulatory filings and public news sources;
• from your counterparties throughout the global capital markets community;
• from your company's website; or
• from conversations with you or other employees at your company.

In using public sources, we will collect only the necessary Information for the purposes described in this Privacy Notice and will review and verify all Information we collect from such sources.

We process the Information to compile the S&P Global Market Intelligence data. We then market the data to clients (both inside and outside of your jurisdiction), who license our products and services.

We may also use your Information to contact you in order to:

• verify the Information we collect about you from public sources; and
• obtain information from you on behalf of our clients – for example, compliance certificates in connection with the capital markets transactions in which you participate on behalf of your employer.

We may be required to process your Information in compliance with any applicable law, including any information privacy legislation in another country.

How We Share and Store Your Information

As described above, we may share or license your Information (as set out in “Information we Collect and Process” section above) via our products:

• internally within our family of affiliate companies pursuant to our internal data transfer arrangements; or
• externally to unaffiliated third parties so that they may use such Information for the purpose of contacting you regarding capital markets opportunities relevant to your business. These unaffiliated third-party capital market professionals (including banks, public and private companies, institutional and individual investors, research, asset management and wealth management firms) may contact you about their products and services in connection with particular market transactions or financial opportunities that they think may be relevant to your organization and/or business.

Such sharing of your Information will be in accordance with this Privacy Notice, and we will use reasonable efforts to enter into arrangements that require such third parties to limit their use of your Information to those consistent with this Privacy Notice, unless they obtain your consent to use your Information for any other purpose.

We will stop providing your Information to third parties for use as described above if and once you inform us of your opt-out request by following the instructions in “Your Information and opt-out” below. You may also ask any third party from whom you receive communication to stop processing your Information and to opt-out from their marketing or any other communication. Please note that we are not responsible or liable for any third party's data privacy policies, acts, or omissions.

The storing of your Information in our resources, and sharing your Information with, or licensing your Information to, third parties as described above, may involve the transfer of your Information outside your jurisdiction. When we transfer your Information outside of your jurisdiction, we will put in place an adequate level of protection to ensure that any such transfers comply with applicable data protection laws in your jurisdiction. Where the transfer of data is subject to the Applicable Data Protection Law of the People’s Republic of China (Personal Information Protection Law), the China Standard Contract shall apply. “China Standard Contract” shall mean the Standard Contract on Cross-Border Transfer of Personal Information issued by the Cyberspace Administration of China on February 24, 2023.

Our Direct Marketing Communication to You

We may use your Information for the following marketing and promotional purposes:

• contacting you regarding updates on latest news, offers and promotions in connection with our products and services, including financial services technology, data, analytics, and software solutions; and
• sending you product-related news and direct marketing communication that we believe may be of interest to your organization and/or business.

We may contact you for such direct marketing purposes via email, mail, or by telephone.

You can opt-out from receiving these direct marketing communication by following the instructions in “Your Information and Opt-out” below.

Please note that regardless of whether you opt-out from receiving direct marketing, we may still:

• need to process Information in order to ensure that you receive no further marketing communication from us; and
• send you important administrative messages as part of your ongoing use of our products and services.

Security and Retention of Your Information

We retain your Information for as long as we reasonably require it for legal, business, or contractual purposes. In determining data retention periods, we take into consideration local laws, contractual obligations, our reasonable business requirements and your expectations and requirements. When the purposes for retaining your Information are achieved and we no longer need your Information, we will securely delete or destroy it. Please note that we may still be required to retain your Information in order for us to comply with applicable laws and regulations, and in certain cases it may not be technically possible to delete your Information (e.g., where your Information is contained within our internal archival records).

We are committed to maintaining the security of your Information. We employ reasonable organizational, technical, and administrative measures to secure and protect your Information from misuse and unauthorized access, disclosure, alteration and destruction. We permit persons working for us to access and use your Information only to serve legitimate business needs consistent with this Privacy Notice.

Your Rights

You have the right to access the Information that we process about you and to request that we correct or amend it (if you consider that it is inaccurate or incomplete) or delete it (if you consider that we do not have the right to hold it). You also have the right to object to your data being processed in a particular situation and to data portability (moving your Information elsewhere). These rights may not apply in some cases and, if you make a request, we shall inform you if that is the case. If you would like to exercise your rights, you can submit a written request to data.preferences@spglobal.com

We will investigate and attempt to resolve any complaints or disputes we receive regarding the processing of your Information. You may also have the right to make a complaint to your local Data Protection Authority. Please follow the instructions in “Your Information and Opt-out” below if you would like to access, correct, or amend your Information or request deletion of your Information.

Your Information and Opt-Out

To access, correct or amend your Information, to subscribe or opt-out from email communication, to amend your opt-out preferences, or to request deletion of your Information please follow the directions in the notice that was sent to you. If you have any questions or if you cannot locate the notice that was sent to you, please contact data.preferences@spglobal.com

Please note that if you do opt-out from any of the options, we may not be able to remove your Information from the data of third parties with whom we have already shared your Information and we may still need to process limited Information in order to ensure that you receive no further marketing communication from us.

How to Update and Keep Your Information Accurate

We will respond to your request to update your Information. We strive to keep your Information accurate and up to date through our collection of your Information in accordance with "How We Collect and Use Your Business Contact Information" above. New information will be combined with existing information and outdated or incorrect information will be removed.

When We Started to Provide Information?

From April 1, 2022, S&P Global, Inc., has been subject to the Act on the Protection of Personal Information of Japan (Act No. 57 of 2003, as amended) ("Act"). We have been providing your Information in accordance with the Act from April 1, 2022 onwards.

How to Contact Us

Your questions, comments and feedback are very important to us. For privacy-related issues or questions, please contact us at data.preferences@spglobal.com

For information on a general principles which we follow in in handling personal information we collect for the purposes other than stated herein please visit: https://www.spglobal.com/en/privacy/privacy-policy-english#personal-information-we-collect