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CSI'S Privacy Policy Preview

TO BE EFFECTIVE AS OF:  December 18, 2019

Privacy Policy Sections

  1. COLLECTION OF PERSONAL DATA
  2. USE OF PERSONAL DATA COLLECTED
  3. COLLECTION AND USE OF OTHER DATA
  4. OUR ADVERTISING
  5. DISCLOSURE OF PERSONAL DATA COLLECTED
  6. YOUR CHOICES
  7. HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL DATA
  8. LINKS
  9. SECURITY MEASURES
  10. DATA INTEGRITY
  11. RETENTION PERIOD
  12. CROSS BORDER TRANSFER OF PERSONAL DATA
  13. USE OF THE SITE BY MINORS
  14. SENSITIVE PERSONAL DATA RESTRICTIONS
  15. CONTACT INFORMATION FOR CSI
  16. ADDITIONAL INFORMATION FOR THE EEA
  17. ADDITIONAL INFORMATION FOR CALIFORNIA

This Privacy Policy explains how Moody's Analytics Global Education (Canada), Inc., which operates under the brand name Canadian Securities Institute or CSI ("CSI" or "we" or "us" or "our"), collects your Personal Data (defined below) as part of the provision of educational services on those web sites of CSI and certain of its service providers that post or link directly to this Privacy Policy (collectively, the "Site") and through offline means, how we use, disclose, and protect such data, and the choices you have concerning our use of such data. Please read this Privacy Policy carefully. CSI may from time to time update this Privacy Policy. Any changes to this Privacy Policy will become effective when we post or link to the revised Privacy Policy on the Site. Please review the "LAST UPDATED" legend at the top of this page to determine when this Privacy Policy was most recently revised.

You do not have to provide us with any Personal Data to visit the public portions of the Site. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of the Site or access the educational services offered by CSI. 

This Privacy Policy shall also apply to any CSI mobile application and other forms of CSI online activity that reference this Privacy Policy. In such instances, the term "Site" shall include the applicable mobile application or other CSI online activity whenever that term is used herein. In connection with your use of any CSI mobile application, your Personal Data (and Other Data, as described below) may also be collected and used by your mobile device manufacturer, the mobile application store from which you obtained the CSI mobile application, your telecommunication provider, or other third parties involved in the delivery of the application or data to your mobile device, and such collection and use shall be subject to the privacy policy of the applicable third party. CSI is not responsible for any third party's privacy practices.

 

TYPES OF DATA COLLECTED

We gather your Personal Data and Other Data as described below. 

  

COLLECTION OF PERSONAL DATA

"Personal Data" is information that identifies you or can be used to identify or contact you (e.g., your name, email address, address, birthdate and/or phone number). Personal Data will also be deemed to include the testing, performance and completion data related to any courses and/or seminars you enroll in as part of the educational services provided by CSI. We may need to collect and process Personal Data in order to provide requested information, products or services to you (including the Site) or because we are legally required to do so.

  • CSI requests various pieces of Personal Data from you when you register for educational services, on the Site and otherwise. The registration process requests that you provide Personal Data (including but not necessarily limited to your name, date of birth, primary and secondary email addresses, business address, business phone number and company affiliation) and agree to the terms and conditions of the applicable CSI educational services in effect at the time of registration.
  • CSI may collect Personal Data voluntarily provided by you, including in emails, online forms, order and registration forms, surveys, promotion participation, online chats, phone calls, and through other means.  In some cases, your employer (or other organization that is sponsoring your registration in the educational services provided by CSI) may provide your Personal Data to CSI on your behalf.
  • CSI may request Personal Data from our customers to comply with applicable anti-money laundering laws and other applicable laws.
  • We may use third-party payment services (each, a "Payment Service") to collect payments made through the Site. If you wish to make a payment through the Site, you may be directed to a webpage that is hosted by a Payment Service (or a Payment Service's service providers) and not by CSI. Any Personal Data that you provide through a Payment Service page will be collected by the Payment Service and not by CSI, and will be subject to Payment Service's privacy policy, rather than this Privacy Policy. CSI has no control over, and is not responsible for, a Payment Service's use of information collected through a Payment Service.
  • CSI collects Personal Data through various other means, including participation at conferences and events, individual introductions, from employers that enroll their employees in our educational services, and from selected third-party business partners. From time to time, we may also acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our products and services.

 

USE OF PERSONAL DATA COLLECTED

We use Personal Data for legitimate business purposes, including the following:

  • Educational Service Delivery. CSI shall use your Personal Data for items related to the delivery of educational services, including but not limited to, the creation of your student account, the delivery of online or in-person seminar training and related materials, mentoring and exam services, delivering testing results, maintaining your student performance and course completion record, and notifying you of updates regarding the educational services. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
  • Reporting to Regulators. CSI is requested in various cases to provide information to securities industry (and other) regulators that our students may be registered with, seeking registration with or are otherwise governed by (including but not limited to the Investment Industry Regulatory Organization of Canada or "IIROC"). CSI may provide your Personal Data to such regulators, including but not limited to, Personal Data sufficient to identify you, your course completion and course performance information, to the extent that such information is requested by the regulator. We will engage in these activities to comply with a legal obligation.
  • Other Communications. From time to time, we may use Personal Data about you to inform you of products, programs, services and promotions that we believe may be of interest to you. If your employer is a CSI customer, we may also inform you of such products, programs, services and promotions using Personal Data about you that your employer provided to CSI. If you would prefer that we not send electronic marketing messages to you, please see the "Your Choices" section below.
  • Promotions. We may operate sweepstakes, contests and similar promotions (collectively, "Promotions"). If you choose to enter CSI's Promotions, we typically ask you for certain Personal Data when you enter and, if applicable, win a Promotion. You should carefully review the rules of each Promotion in which you participate, as they may contain additional important information about our use of Personal Data about you. To the extent that the terms and conditions of such rules concerning the treatment of your Personal Data conflict with this Privacy Policy, the terms and conditions of such rules shall control. We will use your Personal Data to operate the Promotions.
  • Other Business Purposes. We may also use Personal Data about you for other business purposes, such as data analysis (for example, to improve the efficiency of our services), editorial and feedback purposes, providing customer support, customizing and improving the content and layout of the Site, completing business transactions (for example, to confirm content requested is received by customers), development and delivery of marketing and promotion plans and materials, statistical analysis of user behavior (for example, to understand what parts of the Site are of most interest to users), product development, conducting surveys and market research, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits, etc. We may also use Personal Data of journalist/media contacts for press release distribution or sharing other newsworthy developments related to our business activities. We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
  • Administrative Communications. CSI reserves the right to use Personal Data to send to you important information regarding the Site, your educational services, your account status, the educational services terms and conditions, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of the Site and/or the educational services. Because this information may be important to your use of the Site and/or your educational services, you may not opt out of receiving such communications. We will engage in this activity to manage our contractual relationship with you and/or to comply with a legal obligation.

 

COLLECTION AND USE OF OTHER DATA

We and our service providers may also collect and use the following types of data, referred to in this Privacy Policy as "Other Data":

  • Monitoring Data.
    • CSI and its service providers may collect and/or track other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of the Site ("Monitoring Data"). We use Monitoring Data to help us understand who uses the Site and to improve and market it, as well as our other web sites and services. 

      Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose. 
  • Aggregated Data.
    • We may aggregate Personal Data in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.
  • Cookies.
    • To enhance the Internet experience on the Site, CSI and our service providers may use 'cookies' on the Site. Cookies are data that a web server transfers to an individual's computer for recordkeeping and other purposes. We use cookies and other technologies to facilitate users' ongoing access to and use of our Site. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to automatically decline cookies, or to be given the choice of declining or accepting the transfer of a particular cookie, or cookies from a particular web site, to your computer. If cookies are disabled, however, all features of the Site may not operate as intended. Information about disabling cookies can be found on your Internet browser provider's web site.

      The Site may have a Cookie Policy that applies to its use of cookies and other similar tracking technologies. If it does, then the Cookie Policy will apply in addition to this Privacy Policy.
  • Tools.
    • We and our service providers may also use various common Internet tools such as 'pixel tags,' 'action tags,' 'web beacons,' '.gif tags,' 'JavaScript' or similar technologies (together, "Tools") in connection with Site pages and email messages in certain formats to, among other things, track the actions of Site users and email recipients, to determine the success of marketing campaigns and to compile statistics about Site usage and response rates. Tools allow us to count users who have visited certain pages of the Site, to deliver services, and to help determine the effectiveness of promotional or advertising campaigns. When used in email messages in certain formats, Tools can tell the sender whether and when the email has been opened.
    • CSI uses cookies and Tools to understand how the Site is used and to customize and enhance the Internet experience of individual users. When you revisit the Site, CSI may recognize you by a Tool and customize your experience. For example, once you have completed the registration process, a cookie and/or Tool will be used to avoid having you register again. We believe cookies and Tools add value to the user experience.
    • We may use Google Analytics, which uses cookies and other similar technologies, to collect and analyze information about Site use and to report on activities and trends. The service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google's practices by going to https://policies.google.com/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
    • We do not respond to browser do-not-track signals at this time.
  • Verification.
    • We may use third-party services to verify that you are a human user. Any information collected as part of such verification is subject to the privacy policy of the third-party service provider.
  • IP Addresses.
    • When you visit and interact with the Site, we and our third-party service providers may collect Internet Protocol (IP) addresses. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how the Site is used by our users, to improve the Site and to enhance user experience of the Site. We may also derive your approximate location from your IP address.

If we are required to treat Other Data as Personal Data under applicable law, then we may use and disclose it for the purposes described above, as well as for the purposes for which we use and disclose Personal Data as detailed in this Privacy Policy.

 

OUR ADVERTISING

We may use third-party advertising companies to serve advertisements regarding products and services that may be of interest to you when you access and use the Site, our apps and other websites or online services, based on information relating to your access to and use of the Site and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Privacy Policy, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/, and if you are in Canada, please visit https://youradchoices.ca. You may download the AppChoices app at www.aboutads.info/appchoices to opt out of this practice in mobile apps.

 

DISCLOSURE OF PERSONAL DATA COLLECTED

We may disclose Personal Data for the following purposes/to the following parties:

  • Paying Employer or Third Party. If your employer (or other third party) pays for your enrollment and/or participation in any educational services provided by CSI (either by way of payment directly to CSI or personal reimbursement to you of amounts paid to CSI), CSI may, from time to time at the request of such employer or third party, disclose to the employer or third party your performance data related to the particular educational services that such employer or third party has paid for. This only applies to the particular employer or third party that paid for the educational services to which the request for your performance data relates - a request for such performance information made by a subsequent employer or third party will be denied absent your express consent to such disclosure. To provide a general consent to disclosure of your performance data to employers that may request it from time to time, please login to your student profile through www.csi.ca and accept the information release consent form (the "IRCF").
  • Reporting to Regulators. Regulators may request that CSI provide information about licensed registrants or students who apply to be registered with the regulator or are otherwise governed by the regulator (including but not limited to IIROC) and CSI will provide this information. There are also rare occasions where CSI will report events to IIROC or other such regulators (e.g., in the case of significant academic infractions).
  • Third-Party Service Providers. We may provide Personal Data to third-party service providers, who provide services to us, including but not limited to, data analysis, order fulfillment, payment processing, provision of educational materials, provision of course completion certificates, course instruction and/or administration, examination and testing administration and other services.
  • Affiliate Communications. CSI may transfer Personal Data to its affiliates (a list of which is available at www.moodys.com/Affiliates_of_Moodys) to allow our affiliates to contact you regarding products, programs, services and promotions that they believe may be of interest to you, and such affiliates may otherwise use your Personal Data in accordance with the privacy policy applicable to them as specified in the affiliates list referenced above in this bullet. If you would prefer not to receive marketing communications from CSI or our affiliates, please see the "Your Choices" section below. CSI will be the party responsible for any jointly used Personal Data.
  • Strategic Partners and Co-Branded Sites. From time to time, we may enter into a special relationship with another company that is not owned by or affiliated with CSI to provide or promote joint products, services, applications, or features (together, "Jointly Offered Items"). These special relationships may include co-branded web sites ("co-branded pages"). Any information, including Personal Data, that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages, will be shared with our third-party partners. You should check these third parties' web sites for information regarding their privacy practices. PLEASE NOTE THAT THIS PRIVACY STATEMENT DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.
  • Third-Party Data Providers. If you subscribe to a CSI product or service that contains third-party data, we may be required to provide your Personal Data to the third party as part of our reporting obligations. We will only do so if a third-party data provider conditions your receipt of their data on knowing your identity.
  • Conferences and Events. When you attend a conference or event organized by CSI, your name and contact information may be shared with other attendees and co-hosts of the conference or event.
  • Promotions. We may share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to those Promotions. 
  • Assignment. We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
  • Law Enforcement; Emergencies; Compliance. We may use and disclose Personal Data about you to others as we believe to be appropriate: (a) in compliance with laws, rules, or regulations in any country in which CSI operates, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from government or public authorities, including government and public authorities outside your country of residence; (d) to enforce our Terms and Conditions; (e) to protect our operations or those of any affiliated entities; (f) to protect the rights, privacy, safety or property of CSI, its affiliated entities, you, or others; and (g) to permit us to pursue available remedies or limit the damages that we may sustain. For example, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
  • Qualifications Publications.  From time to time, CSI may publish lists of individuals (online or otherwise) that have completed various courses or certificates and/or hold various professional designations offered and maintained by CSI. Individuals may be identified by their name and business affiliations in such publications.

 

YOUR CHOICES

We give you choices regarding our use and disclosure of your Personal Data for marketing purposes.

  • If you wish to alter the manner in which your Personal Data is used by CSI to send marketing communications, please login to your profile through www.csi.ca and visit the CSI Email Preference Centre.
  • If you no longer wish to receive marketing-related emails from us on a going-forward basis, you may stop receiving these marketing-related emails by sending an e-mail to customer_support@csi.ca.
  • If you would prefer that we do not share your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes, you may cease this sharing by sending an e-mail to customer_support@csi.ca.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you exercise the third option as described above, we will not be able to remove your Personal Data from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Data (i.e., to which we have already provided your Personal Data as of the date that we implement your request). Further, please note that if you choose not to receive marketing-related messages from us, we may still send you important administrative messages, and you cannot elect to stop receiving such administrative messages, unless you choose to stop receiving services from us.

You may also indicate your choices regarding marketing-related emails by contacting us via postal mail or telephone using the information in the "Contact Information for CSI" section below.

Note that from time to time, CSI receives education verification requests from third parties seeking information regarding our students' academic records. Other than as set out herein, CSI will not provide such information to third parties unless you have affirmed the IRCF referred to above.

 

HOW YOU CAN ACCESS, CHANGE OR SUPPRESS YOUR PERSONAL DATA

If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, you may either visit your online student profile on the Site, call or email CSI educational services Customer Support (at 1-866-866-2601 (Canada & USA) or 416-364-9130 or customer_support@csi.ca) or make a request by contacting us using the information provided in the "Contact Information for CSI" section below. Note that to correct or change your surname, you will need to call Customer Support as this change cannot be made through the Site. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting the change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.

 

LINKS

The Site may contain links to other Internet web sites, including social media sites and third-party hosted collaboration tools. These linked sites are not under CSI's control. We provide links only as a convenience, and CSI does not endorse or control, and is not responsible for, the privacy practices or the content of these linked sites. If you provide any Personal Data through any third-party web site, or choose to communicate with us using third-party collaboration tools or other social media platforms, your transaction will occur on that third party's web site (not the Site) and the Personal Data you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties. PLEASE NOTE THAT THIS PRIVACY POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES, INCLUDING, WITHOUT LIMITATION, AFFILIATED ENTITIES THAT DO NOT POST OR LINK DIRECTLY TO THIS PRIVACY POLICY.

 

SECURITY MEASURES

CSI has established reasonable organizational and technical measures to protect Personal Data within our organization from loss, misuse, or unauthorized access, disclosure, alteration or destruction. Please note that while CSI has endeavored to create a secure and reliable Site for users, no site is 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us of the problem immediately by contacting us using the information provided herein below in "Contact Information for CSI" (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem).

 

DATA INTEGRITY

CSI will use Personal Data only in ways that are compatible with the purposes for which it was collected, authorized by this Privacy Policy, or authorized by you. CSI will take reasonable steps to ensure that Personal Data is relevant to its intended use, and is accurate, complete, and current (as provided by you). CSI depends on you to update or correct your Personal Data whenever necessary.

 

RETENTION PERIOD

We will retain Personal Data about you for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

 

CROSS BORDER TRANSFER OF PERSONAL DATA

Your Personal Data may be stored and processed in any country where we have facilities or in which we engage service providers. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

If you are located in the European Economic Area ("EEA"): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available on the EU Commission's adequacy list online at: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission, to protect your Personal Data. You may obtain a copy of these measures at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.

 

USE OF THE SITE BY MINORS

This Site is not directed to individuals under the age of eighteen (18), and we request that these individuals do not provide Personal Data through this Site.

 

SENSITIVE PERSONAL DATA RESTRICTIONS

Unless we specifically request for information to comply with applicable anti-money laundering laws and other applicable laws, we ask that you not send us, and you not disclose, any sensitive Personal Data (e.g., social security numbers, passport numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us.

 

CONTACT INFORMATION FOR CSI

Questions or concerns regarding CSI data protection practices should be addressed to:

Legal Department
Moody's Corporation
7 World Trade Center at 250 Greenwich Street
New York, NY 10007

Phone: +1-212-553-1653 or 1-866-995-9659
E-mail: privacy@moodys.com

If you choose to contact CSI via e-mail about this Policy, please mark the subject heading of your e-mail "CSI Privacy Inquiry."

 

ADDITIONAL INFORMATION FOR THE EEA

You may lodge a complaint with the data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs.

For Germany, you may contact our German Data Protection Officer by sending an e-mail to privacy@moodys.com with the subject heading "CSI German Inquiry."


 

ADDITIONAL INFORMATION FOR CALIFORNIA

If you are a resident of California, the California Consumer Privacy Act ("CCPA") (Civil Code § 1798.100) provides you with specific rights regarding your Personal Data. These include:

  • You can request information about our collection and use of your Personal Data over the past twelve (12) months concerning: (i) the categories of Personal Data we collected about you, (ii) the business or commercial purpose for collecting your Personal Data, (iii) the categories of sources from which your Personal Data is collected, and (iv) the categories of third parties with whom we share your Personal Data.  You can request a list disclosing the categories of your Personal Data we have shared in connection with a business purpose.
  • You can request to receive a copy of your Personal Data in a commonly used and machine-readable format.
  • You can request that we delete your Personal Data, subject to certain exceptions. 

To exercise the rights described 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. We will not discriminate against you for exercising any of your privacy rights under CCPA or applicable law.

During the past twelve (12) months, we collected the categories of Personal Data described above from California residents. We also disclosed such Personal Data to third parties for the purposes specified above during the past twelve (12) months.

CSI does not sell your Personal Data.

You may exercise any of the rights described in this section, by contacting us using the information provided in the "Contact Information for CSI" section above.