Bloomberg Ethics Hotline Privacy Policy
Last updated: December 27, 2024
Collection and Use of Your Personal Information
Disclosure of Your Personal Information
Accuracy, Security and Retention of Your Personal Information
Rights with Respect to Your Personal Information
Transfer of Your Personal Information to Other Countries
Questions Regarding This Privacy Policy
Modifications to This Privacy Policy
This Privacy Policy applies to personal information collected through the Bloomberg Ethics Hotline and website but does not apply to any other information collected by Bloomberg L.P., its subsidiaries and affiliates (“Bloomberg”), unless otherwise expressly indicated by Bloomberg.
Use of the Bloomberg Ethics Hotline is entirely voluntary. You are encouraged to report misconduct or unethical behaviour directly to your Manager, or your Human Resources Business Partner, Compliance, Ken Cooper, Kate Wheatley, or Peter Grauer, depending on the nature of the possible violation. If you feel that you are unable to do so, you may use the Bloomberg Ethics Hotline to make your report.
Collection and Use of Your Personal Information
Bloomberg, or where relevant a designated service provider, collects personal information that you voluntarily provide, or which is provided in a report in which you are mentioned or described. This may include:
- Name, telephone number, email address and other contact information (unless you choose to report anonymously)
- Employment related information (such as whether you are employed by Bloomberg)
- The name or other personal information of the persons you name or describe in your report if you provide such information
- A description of the alleged conduct or behaviour, which may include location, time and persons involved
- Images or video footage
We use this information for carefully considered business purposes which include some or all of the following:
- to consider, investigate and act upon, as appropriate, information submitted through the Bloomberg Ethics Hotline
- to communicate with you
- for general statistical analysis and reporting purposes
- to verify your identity through a report key, personal identification number and/or password, where relevant
- to protect the interests, rights, safety, or property of Bloomberg or others and to monitor compliance with and enforce any terms of Bloomberg’s policies
- to operate our services, products and systems properly.
To assist us with the uses described in this Privacy Policy, information collected through the Bloomberg Ethics Hotline may be aggregated, analyzed or combined with personal or other information about you from other sources.
You are responsible for ensuring that the information you submit is accurate and truthful to the best of your knowledge. Bloomberg prohibits retaliation against an employee who in good faith raises a concern or reports suspected or actual misconduct.
If you choose to provide any sensitive personal information or special category data in connection with your use of the Bloomberg Ethics Hotline (for example, data relating to health, or racial or ethnic origin), you expressly consent to the use, processing and disclosure of such sensitive personal information or special category data for the purposes for which you provide it.
Disclosure of Your Personal Information
Bloomberg may disclose the personal information described above for the business purposes set out in this Privacy Policy to the following categories of recipients: (i) our affiliates; (ii) our designated service providers or vendors; (iii) your employer; (iv) authorized personnel within Bloomberg for the purposes of conducting an investigation or resolving an issue.
Bloomberg may also disclose your personal information to unaffiliated third parties if we believe in good faith that such disclosure is necessary to: (a) comply with any applicable law, rule, or regulation, or in response to a subpoena, court order, or other legal process, subject to Bloomberg’s Law Enforcement Data Request Statement; (b) protect the interests, rights, safety, or property of Bloomberg or others; (c) monitor compliance with and enforce any applicable terms of any agreement with Bloomberg or Bloomberg’s policies; (d) provide our services or products (including allowing a purchaser of Bloomberg or a Bloomberg division to continue to provide our services and products); (e) perform other activities related to such services and products; or (f) operate our systems and the systems of our designated service providers properly.
The collection, further use, and/or disclosure of your information by third parties is not the responsibility of Bloomberg. Rather, such collection, use, and/or disclosure is governed by the third parties’ privacy policies.
If you provide personal information of other individuals in the report you submit to the Bloomberg Ethics Hotline, Bloomberg may notify such individuals that they are the subject of or mentioned in a report to the Bloomberg Ethics Hotline. In some cases, another person identified in your report may access information concerning the report, and request correction of personal data that is inaccurate or incomplete in accordance with applicable law.
Accuracy, Security and Retention of Your Personal Information
Any personal information you provide to Bloomberg is kept on secure servers. Bloomberg uses security measures appropriate to the provision of the relevant product or service, such as reasonable administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) to ensure the integrity of the personal information. Personal information is retained for as long as is necessary for the purpose for which it is collected, including legitimate business reasons, and/or legal and regulatory requirements. To determine the appropriate retention period, we will generally consider the following criteria: the length of time needed to achieve the purpose your information was collected for; whether you ceased using our services or products; the existence of any relevant legal proceedings; or applicable legal and regulatory requirements.
Rights with Respect to Your Personal Information
Depending on the jurisdiction, you may have the following rights with respect to your personal information:
- To access and request certain information about the processing of your personal information
- To obtain a portable copy of your personal information
- To correct personal information
- To delete personal information
- To restrict processing of certain personal information
- To object to the processing of personal information
- To withdraw consent, where this was the lawful reason for processing
- To lodge a complaint with the relevant supervisory authority
Please bear in mind that if you exercise such rights this may affect our ability to provide our products and services.
To exercise a right related to your personal information, please contact us by clicking here or by emailing privacy@bloomberg.com and include “Bloomberg Ethics Hotline” in the subject line of your inquiry. While Bloomberg will make reasonable efforts to accommodate your request, we also reserve the right to impose certain restrictions and requirements on such requests, if allowed or required by applicable laws. In the event that we cannot take action with respect to a request relating to your personal information, in certain jurisdictions, you may have the right to appeal that decision by e-mailing us at privacy@bloomberg.com.
Please note that it may take some time to process your request, consistent with applicable law.
If you choose to exercise these rights, we may ask that you provide sufficient information, including your state and country of residence, and contact information, in order for us to verify your identity and process your request. Depending on the types of requests, we may ask for additional information.
You may use an authorized agent to submit a request on your behalf related to your personal information. If you choose to use an authorized agent, you should supply your agent with written permission to act on your behalf in relation to your request, and your agent must provide us with proof of such authorization before we process your request.
Transfer of Your Personal Information to Other Countries
Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your country. By submitting your personal information, you consent to such transfers and processing, including to and in the United States. We implement appropriate safeguards to protect such personal information, which may include (without limitation) European Commission approved standard contractual clauses, to protect your personal information that is transferred. Bloomberg’s International Transfer Statement provides additional information about Bloomberg’s personal data protection, security and transfer practices and explains how those practices ensure there are appropriate safeguards in place to protect personal information and is available here.
California
If you are a California resident, the information below applies to you and supplements the information provided above.
Certain information that you may submit, may constitute “sensitive personal information” as that term is defined by the California privacy law. However, Bloomberg only uses such information to consider, investigate or act upon your report or as otherwise permitted under California privacy law.
The California privacy law’s definition of “sale” and “share” is broad, however Bloomberg does not “sell” personal information covered this Privacy Policy, nor do we share such personal information as that term is defined under California privacy law.
If you choose to exercise the rights set out in this Privacy Policy, you also have a right not to receive discriminatory treatment for exercising your rights.
The Site is intended for a general audience and is not directed at children under the age of 16, nor do we have actual knowledge that we “sell” or “share” the personal information of children under the age of 16. If you have knowledge that a child under the age of 16 has submitted personal information to us, we request that you contact us via one of the methods listed above so that we may delete the information.
Questions Regarding This Privacy Policy
If you have questions regarding this Privacy Policy, please contact us at privacy@bloomberg.com and include “Bloomberg Ethics Hotline” in the subject line of your inquiry. If you have complaints about Bloomberg’s processing of your personal information, you may have the right to contact the applicable supervisory authority.
Modifications to This Privacy Policy
Bloomberg reserves the right to change this Privacy Policy at any time by posting revisions on bloomberg.speakfullynow.com. Such changes will be effective upon posting.