Global Privacy Policy

Last updated: 01/17/23

Welcome to the official website of Swaps Monitor Publications, Inc. (“Swaps Monitor”, “we”, “our” or “us”). We are committed to protecting the privacy of the information obtained as a result of our commercial activities and complying with all applicable laws and regulations governing the processing of personal data. We provide this policy to inform you of the personal data or information we may collect from you or other sources and how we may use and share that information.

Swaps Monitor is the sole owner of the information collected on this website.

What Personal Information We Collect and Use

“Personal Information” or “personal data” is any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

“Process” or “processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, acquisition, holding, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

We collect, retain and process—for as long as reasonably necessary to satisfy the purpose of its collection—such information as is needed to (i) deliver the services ordered by our customers (each, a “Licensee”); (ii) memorialize and enforce the contractual terms on which we supply services; (iii) administer, process and invoice our services; (iv) respond to questions or requests; (v) provide access to certain areas and features of this website or our servers; (vi) verify the identity of Licensees and their authorized users; (vii) communicate important messages or updates concerning Licensee accounts or website activity and systems, including access to our data through the private password-protected portion of the website (the “Portal”); (viii) tailor content, publications, advertisements and offers we believe may be of interest; and (ix) operate or improve the website or our systems, products or business.

We may collect, retain or process the following information:

  • Licensees: Name, address, email address, phone number, business or company affiliation, point of contact, title, credit card and other financial information related to payments for services, agreements executed with us, and other details Licensees may provide.
  • General Website Visitors: In general, you can visit this website without providing us with Personal Information. However, in order to access certain information, services or features, you may be asked to provide Personal Information and we may also employ “cookies” as described below. If you submit an electronic inquiry, we may collect your email address and any other information you provide.
  • Office Visitors: If you visit our offices, we may collect Personal Information about you, including, but not limited to, your title, name, address, phone number, email address, business or company affiliation.
  • Suppliers: We collect data from suppliers necessary to the management of supplier relationships, including, but not limited to, title, name, address, phone number, email address, invoicing and other payment information, and agreements executed with us.
  • Careers: If you submit your resume or other information to apply for a job with us, we may collect Personal Information about you, including, but not limited to, your title, name, address, phone number, email address, business or company affiliation, and other details you may provide.
  • Blog, Newsletter and Other Marketing Activity: If you provide your email address, name, title, telephone number, or address to Swaps Monitor, we may use that Personal Information to provide you with blogs, newsletters or other marketing activity. You may decline these communications at no cost and with no impact on your use of this website, access to the Portal, or our services.
  • Contact Us: If you communicate with us through the “Contact Us” link on this website, we may ask you for, and retain, information such as your name, address, company, telephone number and email address so we can respond to your questions and comments. We also may use the information you provide to communicate with you about topics that we believe may be of interest to you.
  • Email Communications: When you engage in email communications with any Swaps Monitor employees, we may retain records of your email address, along with other information, such as your name, title, address, phone number, email address, or company affiliation, as well as information about your engagement with emails, attachments and/or links that we send to you. We may use this information for a variety of business purposes, including for business development.
  • Research Contacts: Regardless of how we communicate with you, we will retain only such personal data—such as email addresses or phone numbers—necessary to contact you in furtherance of our research activities. We will not contact you for any other purpose.

Cookies and Other Tracking Technologies

When you visit this website, we collect certain information by automated means to help us improve the site and provide customized services and information. Like many companies, we collect this information through the use of “cookies” and other tracking technologies. Cookies are small text files that are downloaded to your computer’s memory and hard drive when you visit certain websites. Some cookies are automatically deleted when you close your browser or after a short period (“temporary cookies”), while others can be stored longer on your computer, sometimes until you delete them manually (“persistent cookies”). For example, we may use cookies to collect information about website activity or to tell us whether you are an existing or new visitor to our website.

We currently set the following cookies:

cookieyes-consent | duration: 1yr | CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors.

 

We require your affirmative consent before using cookies or other technologies that would track your personal data. If you wish to restrict, block or delete the cookies that are set by our website, you can do so using your browser settings. Most browsers allow you to control cookies, including whether to accept them and how to disable existing cookies. You may also set most browsers to notify you if you receive a new cookie. Please note that some features of the website or Portal may not function properly or may be slower without cookies. To make full use of the website and the Portal, your computer or mobile device will need to accept cookies.

Other tracking technologies may record information. For example, collecting IP addresses is standard practice on the Internet and is done automatically by many websites. Our Site does not respond to “do not track” signals. It is not our practice to link the information we record using cookies or other tracking technologies to any Personal Information you submit through the Site. We reserve the right to use cookies and other tracking technologies to identify a visitor. We may do so, for example, when we believe it is necessary to protect the website, our visitors, Licensees, or other third parties, or to protect our rights or defend against a claim relating to us, or when we believe that the law requires it.

Third-Party Websites

This website may contain links to websites owned and operated by third parties. Swaps Monitor does not control such third party websites and this policy does not apply to them. Your use of any linked website is solely at your own risk. To understand what information those websites collect, please review their privacy policies.

Sharing of Information

We do not sell, rent, trade or otherwise disclose Personal Information, except as described in this policy or as you may explicitly consent. We may share your Personal Information among Swaps Monitor entities, affiliates and consultants and with third-party service providers we have retained to perform services on our behalf. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.

We may disclose information about you (i) if we are required to do so by law, court order or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation or arbitration; (iv) to enforce our policies, contracts or other rights; (v) to collect amounts owed to us; (vi) when we believe disclosure is reasonably necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if in good faith we believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual reorganization, sale, lease, merger, joint venture, assignment, amalgamation or any other type of acquisition, disposal or financing of all or any portion of Swaps Monitor or of any of our assets (including should Swaps Monitor cease to operate, become insolvent, enter into receivership or any similar event occur). Should such an event take place, we will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this policy.

Protection of Information

We take commercially reasonable and appropriate steps to protect the Personal Information you share with us from unauthorized access or disclosure. While we strive to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

Cross-Border Transfer

Your Personal Information may be stored and processed in any country where we have offices or servers or in which we engage service providers. Your Personal Information may be transferred to countries outside your country of residence, including the United States, which may have different data protection and data processing laws than those in your country. Regardless, in all events, we shall apply the provisions of this policy to your Personal Information wherever it is located.

Children’s Privacy on this Website

This website is not intended for use by children under the age of 16. We do not knowingly collect Personal Information from anyone under 16 years of age. If you are under 16, please do not submit any Personal Information on this website.

Privacy Rights for California Residents

California’s Consumer Privacy Act (“CCPA”) grants California residents certain rights regarding the use of their Personal Information. These rights pertain only to residents of the State of California. They include the right to notice that Personal Information will be collected; the right to know what Personal Information has been collected, sold, or disclosed for a business purpose, and to whom it was sold or disclosed; the right to opt-out of the sale of Personal Information; the right to have your Personal Information deleted; and the right to non-discrimination as a result of exercising these rights.

If you are a California resident and would like to request certain information about the types of personal data we have collected or shared with third parties, please contact us. California residents may make one such request per year. Pursuant to the CCPA, we may deny that request, in whole or in part, pursuant to enumerated exemptions. If we deny your request, we will inform you of the basis thereof.

Privacy Rights for European Union Residents

To the extent required by law, we provide users with reasonable access to the Personal Information provided to us, including where appropriate and not subject to an exemption, a portable copy of the Personal Information and the ability to review, correct, delete, restrict, or object to the processing of such Personal Information. More information concerning the rights afforded under the European Union General Data Protection Regulations (“GDPR”) can be found here: https://gdpr.eu/tag/chapter-3/.

If you are a European Union resident and would like to request certain information about the types of personal data we have collected or shared with third parties, please contact us.

Although we make good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to where the information would compromise others’ privacy or other legitimate rights; where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question; or where the information is commercially proprietary. If we determine that access should be restricted in any particular instance, we will endeavor to provide you with an explanation thereof.

We do not intend to use any personal data collected from you for automated decision-making processes (including profiling).

EU residents may report privacy complaints directly to their local data protection authorities.

Changes to this Policy

We may update or change this policy from time to time and without prior notice. Any changes to this policy will become effective when we post the revised policy on this website.

Last Modified

November 2, 2022