Last Updated" August 18, 2023
CRISIL Limited and its subsidiaries (collectively or individually, as applicable, referred to as “CRISIL” or “our” or “we” or “us”) respect your privacy and are committed to protecting your personal data. This Global Corporate Privacy Policy (“Privacy Policy”) describes how we collect, store, use, disclose and process your personal data and tells you about your privacy rights.
Our websites, products, applications and services (collectively the “Services”) are not intended for children and we do not knowingly collect data relating to children as part of our Services. Generally, a child is a person under 16 years of age (under EU law), but you may check to see if your local laws have a different age limit for legal purposes. By accessing or using our Services or otherwise giving us your information, you will be deemed to have the capacity to enter into a legally binding contract in accordance with applicable law in the jurisdiction from which you are accessing our Services. You will consequently be deemed to have read, understood and agreed to the practices and procedures outlined in this Privacy Policy and agree to be bound by its terms.
INDEX
- INTRODUCTION
- THE DATA WE COLLECT ABOUT YOU
- HOW WE COLLECT YOUR PERSONAL DATA
- HOW WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
- APPENDIX
1. INTRODUCTION
About CRISIL
CRISIL is one of the leading providers of ratings, data, research, analytics and solutions, with a strong track record of growth, a culture of innovation and a global footprint.
Changes To The Privacy Policy
We review and update this Privacy Policy from time to time. When we do, we will note the date of the version on the Privacy Policy and post it on this website. You can tell when we last updated this Privacy Policy by checking the “Last Updated” date at the top of this Privacy Policy. You also may obtain historical versions of this Privacy Policy by contacting us.
Your Duty To Inform Us Of Changes To Your Personal Data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third-Party Links
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. This Privacy Policy does not apply to information that is collected by any third-party website or service that you may access through the Services.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). CRISIL may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender;
- Contact Data includes billing address, delivery address, email address and telephone/mobile numbers;
- Financial Data includes bank account details and/or payment instrument details;
- Transaction Data includes details about payments to and from you and other details of products and Services you have purchased from us;
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website;
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage Data includes information about how you use our website, products and Services;
- Biometric Data means personal data resulting from technical processing of an individual’s physical, physiological, biological, or behavioral characteristics, which allows or confirms the unique identification of such individual. For example, an individual’s deoxyribonucleic acid (DNA) that can be used, singly or in combination with each other or with other identifying data, to establish individual identity. Biometric information includes, but is not limited to, imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns or rhythms, and sleep, health, or exercise data that contain identifying information.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
CRISIL also collects, uses and shares aggregated data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
CRISIL may collect certain Special Categories of Personal Data OR Sensitive Personal Data or Information (or such similar data known by any other term under the applicable law) about you. Such data is only collected and processed with your consent or in performance of our contract with you, unless otherwise required or permitted under the applicable law We may collect information about criminal convictions and offences in those jurisdictions where the processing of such information is legally admitted.
Except in jurisdictions that require an explicit consent of data subjects for processing certain types of personal data, usually we rely on other Lawful Basis for processing any type of personal data.
If You Fail To Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with or avail from you certain goods or services). In this case, we may have to cancel a product, service or the arrangement you have with us but we will notify you if this is the case at the time.
3. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect personal data from and about you including through the following:
- Direct interactions. You may give us your Identity Data, Contact Data and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or Services;
- apply for a job or gain employment with us;
- offer to do business with us;
- visit or create an account on our website;
- use our mobile applications;
- disclose information on our social media pages, message boards, comment fields, chat areas or other community forums;
- subscribe to our Services or publications;
- request marketing to be sent to you;
- attend our webinars or seminars;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our website or applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. For more information on the cookies collected on our website, please visit our Cookie Policy.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Public Sources: CRISIL may process your personal information that is available on public platforms such as websites of government organizations, regulatory bodies, your employer or other public platforms where you have explicitly made your information available. CRISIL is not responsible or liable for personal data that you post in public forums or otherwise choose to make public. We have the right but not the obligation to monitor any activity and remove information from comment fields, message boards, events and other interactive sections of the Services.
- Technical Data from the following parties:
- (a) Analytics providers such as Google and Adobe based outside the EU. Generally, analytics services do not identify individual users. Many analytics services allow you to opt out of data collection;
- (b) Data collection technology which is deployed by CRISIL when you visit or use the Services. This can be used to collect information such as IP address, browser type, browser language, time zone, language settings and operating system on your device, how long you spend on various webpages, which webpages you view, your search queries, error and performance reports, the webpages that you visited before and after using the Services. Other data collection technology is deployed by advertisers, other website operators (also known as ‘publishers’), and networks and other third parties with which CRISIL partners to operate and provide the Services. Data collection technology helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, measuring the success of marketing campaigns, compiling statistics about use of the Services and helping us analyze technical and navigational information about the Services and to detect and prevent fraud; and
- (c) Search information providers:
- Contact Data, Financial Data and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
- Identity and Contact Data from data brokers or aggregators based inside or outside the EU.
- Identity and Contact Data from our vendors, service providers or partners for the purpose of screening candidates for employment or vendors for engagements.
- Your employer: We may receive personal information about you from your employer or business partner (for example, if you use Services covered by a subscription). The information we collect from your employer consists of your name, contact details and employment-related information.
- Third Parties: CRISIL may collect personal data about you from other third parties, such as CRISIL’s clients, marketing vendors, survey service providers, social media platforms, job aggregators, employment consultants and other sources to the extent permitted by applicable law. We use this information to reach out to you to further our data collection efforts, to maintain and correct our records, to add data fields, to enhance the marketing and delivery of our Services to you, or to consider you for employment. We collect personal information about persons who are directors, officers, managers, employees, trustees or shareholders or other stakeholders of organizations as part of our content collection process for some of our products. We obtain this from a variety of sources, including third-party content providers, public filings, and websites.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in any of the following circumstances:
- Where you have provided your consent to use such personal data.
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and such interests do not override your interests or fundamental rights which require protection of your personal data.
- Where we need to comply with a legal or regulatory obligation, or otherwise as required or permitted under applicable law.
Purposes for Which We Will Use Your Personal Data
We have set out below, in a table format, a description of the ways we may use your personal data, and the Lawful bases that we rely on to do so. Please refer to the Appendix to understand more about the various Lawful Bases.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of Personal data or Personal Information |
Lawful basis for processing |
|
To process and deliver/receive orders/services including:
|
(a) Identity Data |
|
|
To provide access to and share more information about our Service
|
(a) Identity Data |
|
|
To contact you for interviews to collect data, information and insights. |
(a) Identity Data |
|
|
Where we collect personal data from you on behalf of our client |
(a) Identity Data |
|
|
To administer our business and provide & improve our Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|
(a) Identity Data |
|
|
To deliver relevant website content and advertisements to you, make suggestions and recommendations to you about Services that may be of interest to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity Data |
|
|
Asking you to leave a review or take a survey |
(a) Identity Data |
|
|
Recruitment and employment related purposes such as evaluating performance, administration, providing and monitoring use of facilities, etc. |
(a) Identity Data |
|
|
To comply with applicable law, or for other purposes permitted by applicable law. |
(a) Identity Data |
|
|
Where you volunteer to be associated with CRISIL in any manner (including volunteering for, administering, or benefiting from social initiatives by or on behalf of CRISIL) |
(a) Identity Data |
|
Marketing
You will receive marketing communications from us if you have requested information from us or purchased Services from us or if you provided us with your details when you attended a conference or webinar with us or registered for a promotional campaign and, in each case, you have not opted out of receiving that marketing.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You have the right to withdraw consent to marketing at any time by contacting us or clicking on the unsubscribe link made available in our email communications to you. Where you opt out of receiving marketing messages, this will not apply to personal data provided to us as a result of a Service purchase, product/service experience or other transactions.
Cookies
We use cookies and similar tracking technology (collectively, “cookies”) to collect and use personal information and personal data about you, including to serve interest-based advertising. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
For more information about the cookies we use, please refer the Cookie Policy on our website.
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the Lawful Basis which allows us to do so.
5. SHARING OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table above.
- Internal Third Parties as set out in the Appendix.
- External Third Parties as set out in the Appendix.
- Third parties from whom we avail services for carrying out our business activities.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
CRISIL requires all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions unless the applicable law permits otherwise.
If you are a respondent to any of our market research surveys or other related surveys, we may share your name with our existing and prospective clients for the purpose of demonstrating our research methodology. If our clients wish to use it for any purpose that is not compatible with the purpose for which the personal data was collected by us, then they are required to comply with the requirements of the data protection laws applicable to their use of the personal data such as ensuring a lawful basis for processing and enabling data subject rights.
6. INTERNATIONAL TRANSFERS OF YOUR INFORMATION
CRISIL stores and processes personal data in its facilities or with service providers throughout the globe. Unless otherwise prohibited under the applicable law, your personal information may be transferred to, and processed outside the country in which you reside. These other jurisdictions may have data protection laws that are different from the laws of your country (and, in some cases, not as protective). When we conduct cross border transfers of personal data, we require that the recipient of the personal data provides the same or equivalent level of protection as we provide to the personal data in order to comply with the applicable law, and you consent to such transfers.
CRISIL has procedures to help ensure that personal data collected through the Services is used only for an authorized purpose and that the security, integrity and confidentiality of the personal data are respected and maintained. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies to protect personal information they transfer from countries located within the European Economic Area including the United Kingdom (“EEA”) to countries located outside of the EEA, in accordance with the applicable data protection laws. CRISIL also imposes contractual obligations including, standard contractual clauses in the form required under any applicable laws, on any third party that receives personal data from CRISIL to confirm that such third party also has procedures in place to ensure that personal data is used only for authorized purposes and that the confidentiality and security of the personal data are respected and maintained.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. DATA SECURITY
CRISIL has put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They are only permitted to process your personal data on our instructions and are subject to a duty of confidentiality.
CRISIL has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
CRISIL’s security management standards are in compliance with ISO 27001 (Information Technology – Security Techniques – Information Security Management System - Requirements), a widely recognized international security management standard.
You are responsible for maintaining the security of your account credentials and other authentication involved in obtaining access to password-protected or secure areas of the Services. CRISIL will treat access to the Services through your account credentials as having been authorized by you. We shall bear no liability in respect of such unauthorized use of your account. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided.
8. DATA RETENTION
We retain the personal data collected or otherwise processed by us, (i) for as long as necessary to fulfill the purposes for which you provided the information, (ii) for the purposes of satisfying any legal/regulatory, accounting, or reporting obligations, (iii) to resolve disputes, (iv) to enforce agreements, and (v) for such other purposes as are permitted under applicable law.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements that may require or permit retention for a longer duration.
You may contact us for more information about the period of time for which we will process your personal information.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ in the Appendix for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Your rights may include the right to access, correct, update, request deletion, restrict or object to the processing of your personal data and withdraw the consent you have provided to us, subject to applicable data protection laws. Please refer the Glossary for a detailed description of these rights.
If you wish to exercise any of the rights available to you under the applicable law, you may contact our privacy office at privacy1@crisil.com. You also have the right to reach out to the applicable data protection authority.
California
If you are a California resident, you may have the right under the CCPA to opt-out of any sale or sharing of your personal information by us to third parties. Although, we do not directly sell your personal information in the conventional sense of receiving money for it, but we may disclose or share your personal information with third parties. For example, we may disclose your personal data to data analytics companies that help us understand how visitors use our websites and applications; or if you are a respondent to any of our VOC surveys, we may disclose your personal information to our clients in order to demonstrate the research methodology applicable. Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.
To opt-out of our sale or sharing of your personal information, you or your authorized representative may submit a request in any of the following ways:
- Visit Do Not Sell My Personal Information OR
- email us at privacy1@crisil.com
No Fee Usually Required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, except when Argentine laws apply, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or we may refuse to comply with your request in such cases. However, we will inform you when that is the case. When Argentine laws apply, we may charge you a reasonable fee for you to access your data more than once every six months unless you can show a legitimate need for your data.
What We May Need From
You We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. If we do request additional information from you, it shall only be used for the purposes of (i) verifying your identity while you are seeking to exercise your rights under the applicable data privacy law; and (ii) for security or fraud-prevention purposes.
Time Limit to Respond
We try to respond to all legitimate requests within one month or within any such shorter period as is required by law. When a delay is both necessary and permitted by law, we will notify you and keep you updated.
Contact Details
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, you may contact our Privacy Officer using the details set out below.
Priyanka Sharma, Privacy Officer
Email address: privacy1@crisil.com
Postal address: Compliance Department, CRISIL Limited, CRISIL House, Hiranandani Business Park, Powai, Mumbai
Complaints
In the event that you wish to make a complaint about how we process your personal information, please contact us and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you reside, where you think we have infringed data protection laws.
10. APPENDIX
SPECIAL CATEGORIES OF PERSONAL DATA include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic data and biometric data.
SENSITIVE PERSONAL DATA OR INFORMATION means information relating to your password; financial information such as Bank account or credit card or debit card or other payment instrument details; physical, physiological and mental health condition; sexual orientation; medical records and history; Biometric information, or any detail relating to the above provided to or received by a body corporate.
CCPA means the California Consumer Privacy Act 2018 and its related rules as amended or replaced from time to time.
LAWFUL BASIS
Legitimate Interests means our interest in conducting and managing our business. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legal Compliance means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in CRISIL acting as independent controllers or processors and who are based India, US, Poland, Argentina, China, UK, Singapore, Switzerland and other jurisdictions where CRISIL has its operations, provides IT and system administration services and undertakes leadership reporting.
EXTERNAL THIRD PARTIES
- Service providers based in India, US, Poland, Argentina, China, UK, Singapore, Switzerland and other jurisdictions where CRISIL has its operations, including those who provide IT infrastructure and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in India, US, Poland, Argentina, China, UK, Singapore, Switzerland and other jurisdictions where CRISIL has its operations who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other government/regulatory authorities who require reporting of processing activities in certain circumstances.
- Clients based globally who may have access to the personal data of our employees, contractors or survey respondents.
YOUR LEGAL RIGHTS
The rights available to you may differ based on your geographic location. You may contact us for more information on the specific rights available to you. Some of the rights prescribed under various laws include the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. You may contact CRISIL using the contact information provided to update or correct your personal data whenever necessary.
Request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data, by contacting us. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, CRISIL may limit your access to the Services and/or not be able to offer or provide you with the product or services or initiate or continue any relationship with you.