- The information we collect;
- The choices that are available to you regarding how the information is used and to whom it is disseminated;
- Your rights to access and correct or update your personally identifiable information; and our pledge to have reasonable security procedures that are in place to protect against the loss, misuse or alteration of information under our control.
NOTICE: Information We Collect and How We Use It
Duff & Phelps collects two types of information about you when you visit our site: personal information (including, by way of example only, your name, address, telephone number and e-mail address) and non-personal, aggregate information (such as information regarding the pages on our site that you have visited and your IP address).
1. Personally-Identifiable Information And What We Collect
The only personally identifying information we collect and store about you is the information that you choose to provide to us. By registering or providing any of your personal information on this site, you consent to the collection, use and transfer of your information under the terms of this policy.
We will also gather your personally identifiable information when you send us an e-mail. We will use this information to respond to your e-mail. We may also use the information to send you notifications about our services. Business partners and professional visitors requesting access to specialized content areas of this Web site may be required to provide identifying information.
2. Sharing Your Information/Disclosure of Information
The information you provide to us will be held on our computers in the United States and may be accessed by or given to our staff working in the United States and elsewhere and third parties including companies within the Duff & Phelps group located in the United States, Europe and Asia who act for us for the purposes set out in this policy or for other purposes approved by you, where local law allows. Those parties process information and provide support services on our behalf.
Where you have consented when providing us with your details, we may also allow carefully selected third parties, including other companies in our group, to contact you occasionally about products and services that may be of interest to you. They may contact you by mail, telephone, fax or e-mail. If you change your mind about being contacted by these companies in the future, please let us know.
Finally, if our business enters into a joint venture with or is merged with another business entity, your information may be disclosed to our new business partners.
Countries outside the European Economic Area do not always have strong data protection laws. However, we will always take steps to ensure that your information is used by third parties in accordance with this policy.
Unless required to do so by law, we will not otherwise share, sell or distribute any of the information you provide to us without your consent.
3. Non Personally-Identifiable Information:
What We Collect
The Duff & Phelps Web site may collect non-personally identifiable information during your visit, such as type of browser, operating system, domain name or IP address. An IP address is a number that is automatically assigned to your computer whenever you're surfing the Web. Web servers -- the big computers that "serve" up Web pages -- automatically identify your computer by its IP address. When you visit pages on Duff & Phelps' Web site, our servers log your IP address. We do not link IP addresses to any personally identifiable information. This means that your session will be logged, but you remain anonymous to us. IP address information is used only to improve the service of the Duff & Phelps' site, and is then discarded at the end of each session on our site.
Duff & Phelps also collects information through "referrers" and various environmental variables. A "referrer" is information the Web browser passes along to Duff & Phelps' Web server that references the URL from which you came. "Environmental variables" include, among other things, the domain from which you access the Internet, the time you accessed our Web site, type of Web browser and operating system or platform used, the Internet address of the Web site you left to visit Duff & Phelps, the names of the pages you visit while at our Web site, and the Internet address of the Web site you then visit. We collect all of this information to allow us to detect broad demographic trends, to provide information tailored to your interests and to enhance your experience on Duff & Phelps' Web site. Duff & Phelps may store "referrer" information for a limited period of time prior to deleting this information.
To help us improve our Web site and to ensure that we make every effort to provide you with information and offers that are of interest to you, we may merge your personally identifiable information with click-stream data and other data we have (including cookies and offline data). We will provide notice of this, as well as an opportunity to opt-out of it, at the time and place of information collection and before data is entered on our system.
We may also develop a non-identifiable profile on you based on the pages within our site that you visit.
This Web site may contain links to other sites. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage our users to read the privacy statements of each and every Web site that they visit. This privacy statement applies solely to information collected when you visit our Web site.
Notification of Changes
Special Policy Regarding Information from Children Under Thirteen
This Web site is not targeted to children under the age of 13, and we do not knowingly request personally identifiable information from any child under the age of 13 without parental consent. When we do receive such information, we delete it as soon as we discover it and do not use it or share it with third parties.
Duff & Phelps provides the following choices regarding the use of your information. You may choose not to provide us with any contact information.
Security and data retention
We make every effort to have reasonable security procedures in place to protect the loss, misuse or alteration of information under our control.
We will permit only authorized employees, who are trained in the proper handling of customer information, to have access to that information. Employees who violate our security and privacy policies will be subject to our normal disciplinary process. We employ security measures to protect your information from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. We will retain your information for a reasonable period or as long as the law requires.
Accessing and updating
You are entitled to see the information held about you and you may ask us to make any necessary changes to ensure that it is accurate and kept up to date. If you wish to do this, please contact us. We are entitled by law to charge a fee to meet our costs in providing you with details of the information we hold about you.
Duff & Phelps, LLC and its affiliated entities (“Duff & Phelps”) respect the privacy of personal data that is collected or maintained by or on behalf of Duff & Phelps. In furtherance of this commitment, Duff & Phelps adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union (the “EU”) to the United States of America (the “US”) and is consistent with the Safe Harbor Principles published by the U.S. Department of Commerce which are located online at www.export.gov/safeharbor.
Except as otherwise noted herein, this Policy applies to all personal data Duff & Phelps handles, including on-line, off-line, manually processed and Human Resources data. For purposes of this Policy, "personal information" and "personal data" refers to information that:
- is transferred from the EU to the US;
- is about, or pertains to, a specific individual or can be linked to that individual (does not include information that is encoded/anonymized; publicly available information that has not been combined with non-public personal information or aggregate data that has been divorced from individually identifiable characteristics);
- is “sensitive personal information”: reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, health, trade union membership, biometric identifiers (finger and voiceprints) or criminal related proceedings or allegations.
Safe Harbor Privacy Principles
- NOTICE: When Duff & Phelps collects personal information directly from individuals in the EU, Duff & Phelps will inform them about the type of personal information collected, the purposes of collecting and using that information, the types of third parties to which Duff & Phelps discloses or may disclose such personal information, and means to contact Duff & Phelps with privacy concerns. This notice is provided in clear and conspicuous language through this Policy, our engagement letters or other similar documents, [or/and] direct communication with individuals from whom Duff & Phelps collects personal information. Such notice is given at the time of the collection, or as soon as practical thereafter, and before Duff & Phelps uses or discloses the information for a purpose other than which it was originally collected.
- When Duff & Phelps receives personal information from its subsidiaries, affiliates or other entities in the EU, Duff & Phelps will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
- CHOICE: Duff & Phelps provides individuals with an opportunity to “opt-out” if such personal information is to be disclosed to a third party or used for a reason that is incompatible with the purposes for which it was originally collected. For sensitive personal information (i.e. personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sexual orientation of the individual), individuals will be given affirmative or explicit "opt-in" choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected. Furthermore, individuals are provided with clean and conspicuous, readily available and affordable mechanisms to exercise choice.
- DISCLOSURES AND TRANSFERS: Duff & Phelps obtains [written] assurances from its third party agents that they will safeguard personal information consistently with this Policy and the Safe Harbor Principles. If Duff & Phelps learns that an agent is using or disclosing personal information in a manner that is contrary to this Policy and the Safe Harbor Principles, Duff & Phelps will take reasonable steps to prevent or stop the use or disclosure of such personal information and will not be held responsible when a third party processes information in a way that is contrary to this Policy or the Safe Harbor Principles. Additionally, Duff & Phelps will not disclose personal data to third parties, unless one or more of the following conditions are true:
- Duff & Phelps has received the individual’s permission to make the disclosure;
- The disclosure is required by law or mandatory professional standards;
- The information in question is publicly available;
- The disclosure is reasonably related to the sale or disposition of all or part of Duff & Phelps’ business;
- The disclosure is reasonably necessary for the establishment of legal claim; or
- consistent with the purposes for which the information was collected, the information is provided to another Duff & Phelps entity or person (“transferee”) and the transferee has agreed [in writing] to provide an adequate level of privacy protection; is subject to laws requiring an adequate level of privacy protection; or subscribes to the Safe Harbor Principles.
- DATA SECURITY, INTEGRITY AND ACCESS: Duff & Phelps employs various physical, electronic, and managerial measures designed to protect the personal information Duff & Phelps creates, collects or maintains from loss, misuse, unauthorized access, disclosure, alteration or destruction. Duff & Phelps processes personal data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual, and to the extent necessary Duff & Phelps will take steps to ensure that personal information is accurate, complete, current and consistent with its intended use.
If an individual would like to update, correct or review his or her information, the individual may contact Duff & Phelps by means of the contact information listed below. To access such personal data, the individual may need to provide sufficient identification information (name, birth date, address, and social security number) and Duff & Phelps may request additional information as a security precaution. Additionally, Duff & Phelps reserves the right to limit or deny access to personal information where providing such information would be unreasonably burdensome or expensive or as otherwise permissible by the Safe Harbor Principles. In some circumstances, Duff & Phelps may charge a reasonable fee, where warranted, to access personal information.
Compliance & Dispute Resolution
Duff & Phelps will conduct self-assessments of its relevant privacy practices to verify adherence to this Policy. Any employee that Duff & Phelps determines is in violation with the Policy may be subject to disciplinary actions up to and including termination of employment.
Any questions or concerns regarding Duff & Phelps’ handling of personal information should be directed to Duff & Phelps’ General Counsel at the contact information listed below. Duff & Phelps will investigate and attempt to resolve any inquiries and disputes regarding the processing of personal data in accordance with this Policy and the Safe Harbor Principles. For complaints that cannot be resolved between Duff & Phelps and the complainant, Duff & Phelps has agreed to participate in the dispute resolution procedures of the panel established by the European data protection authorities to resolve disputes pursuant to the Safe Harbor Principle. If the dispute involves data collected in the context of an employment relationship, Duff & Phelps will cooperate with competent EU data protection authorities and comply with the advice of such authorities. In the event that Duff & Phelps or such authorities determine that Duff & Phelps did not comply with this policy, we will take appropriate steps to address any adverse effects and to promote future compliance.
Information Subject to Other Policies
Consistent with the Safe Harbor requirements, the following types of personal data may be subject to more specific privacy requirements:
- information received from or relating to clients or former clients may be further subject to the terms of any contractual arrangements with the client, applicable laws and professional practices;
- information relating to present or former Duff & Phelps personnel is subject to Duff & Phelps’ internal personnel data privacy policies, which are available to such personnel on Duff & Phelps’ intranet site and to former Duff & Phelps personnel upon request; and
- certain websites and electronic data storage centers may have their own privacy policies regarding the access and use of the personal data stored by these sites. These policies may be accessed through the websites in question.
Changes to this Policy & Communications
Consistent with the requirements of the Safe Harbor Principles, Duff & Phelps reserves the right to change this Policy at any time. The revised policy will be posted on this Web site or a similar Web site that replaces this Web site and the "effective date" of this Policy will be updated accordingly. This Policy and any of its amendments will be communicated to all EU employees.
For further information regarding the Policy, please contact Duff & Phelps at:
55 East 52nd Street
New York, NY 10055