Notice of Certification Under the Data Privacy Framework

Effective as of 4 July 2024

Bloomberg L.P., and its affiliates, Bloomberg Finance L.P., Bloomberg SEF LLC, Bloomberg Tradebook LLC and Bloomberg Data Management Services USA LLC, (collectively, “Bloomberg” or “we”) comply with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Bloomberg has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal information received from the European Union in reliance on the EU-U.S. DPF and from the UK (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Bloomberg has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal information received from Switzerland in reliance on the Swiss-U.S. DPF.

Bloomberg’s Privacy Polic[y/ies] in combination with this Notice describe our privacy practices with respect to personal information that Bloomberg receives from the EU, the UK and Switzerland in reliance on the Data Privacy Framework (DPF) program.

If there is any conflict between the terms in this Notice or our applicable Privacy Policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Personal information processed

Bloomberg provides news, research, communications, compliance, archiving and trading solutions. In order to provide these products and services, Bloomberg processes personal information which customers, partners, service providers, suppliers and vendors provide to Bloomberg. For certain products and services, customers also instruct Bloomberg to process personal information on their behalf. The categories of personal information includes contact and related information, identification information, services and usage information, communications, transcripts and recordings. Personal information may, at times, concern categories of sensitive personal information, including information relating to political opinions, biometric data, religious or similar beliefs, sexual orientation, commission of or alleged commission of offenses. For further details regarding the personal information we collect and process, please see our relevant Privacy Polic[y/ies] available here.

Purpose(s) of processing

Personal information is processed to provide and promote products and services, provide security, maintain accounts and records, and provide technical support and technical infrastructure to facilitate the provisions of product and services. For further details regarding the personal information we process and the purposes of processing, please see our relevant Privacy Polic[y/ies] available here.

Inquiries and complaints

If you have any inquiries or complaints about our handling of personal information under the DPF, you may contact us at privacy@bloomberg.com. We will endeavor to respond to your query promptly. If your inquiry or complaint cannot be resolved through our internal processes, or if we have otherwise not been able to timely respond to or address your inquiry or complaint to your satisfaction, you may contact VeraSafe, our alternative dispute resolution provider in the United States. You can contact VeraSafe through the VeraSafe dispute resolution system at no cost to you. In compliance with the DPF, Bloomberg commits to refer any unresolved complaints concerning our handling of personal information received in reliance on the DPF to VeraSafe. If neither Bloomberg nor our third-party dispute resolution provider resolves your complaint, you may pursue binding arbitration through the Data Privacy Framework Panel, subject to certain conditions (for more information on such conditions, please click here).

Disclosure of personal information to third parties

Bloomberg uses a limited number of authorized third parties to assist in the provision of certain products and services. These third parties provide the technical infrastructure, technical support, identity and access management and data storage services. Bloomberg remains responsible for the processing and onward transfer of the personal information it receives from the EU, UK or Switzerland under the DPF program. Accordingly, Bloomberg remains liable in the event these third parties fail to meet their obligations to limit access, use and disclosure of personal information in compliance with Bloomberg’s own DPF compliance obligations.

Rights with respect to personal information

Individuals located in the EU, UK or Switzerland have the right to access their personal information, and to limit the use and disclosure of their personal information consistent with the DPF Principles by contacting privacy@bloomberg.com.

U.S. Federal Trade Commission enforcement

The Federal Trade Commission has jurisdiction over Bloomberg’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.

Third party requests for personal information

Bloomberg may be required to disclose personal information where we have an obligation to comply with applicable law, or in response to a valid subpoena or court order, including to meet national security or law enforcement requirements.

Amendments to this Notice

We may amend this Notice from time to time consistent with the DPF Principles. This Notice will include an effective date and last updated date as applicable to reflect any amendments.