1. Introduction

1.1 Purpose

This Policy describes the framework used by Scope CRAs and Scope SE & Co. KGaA (“Scope”) to collect and use personal data. It sets out the basis on which personal data collected from or provided by the data subjects will be processed by Scope.

“Data subjects” refers to users of Scope Ratings website, Scopes’ clients, subscribers or professional contacts.

“Personal data” means any information which relates to a specific individual (the “data subject”).

1.2 General Data Protection Regulation

The provisions set out in this Policy are regulated by and aligned with the General Data Protection Regulation – Regulation (EU) 2016/679 (“GDPR”) which can be consulted at https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en.

2. Personal data processed, purpose and lawfulness of the processing

The type of data that Scope may need to collect and process vary according to the business relationship with the data subject.

2.1 Professional contacts

Scope collects information for precontractual relationships, for the legitimate interest linked to the performance of its rating activities or based on the data subject’s consent when it has opted in on a contact form.

The types of personal data that the Scope collects and processes are:

• Name, company and professional contact details,
• Electronic communications, and
• Other documents linked to or obtained during exchanges.

The contact details are mainly obtained directly from the data subjects when they contact Scope directly or via its website. Some contact details may be obtained through common business contacts, such as related third parties to rating activities (e.g. banks acting as arrangers). Subsequent data, like electronic communications, are obtained directly from data subjects.

The personal data are processed for contracting purposes in case of prospective clients, or for communicating, sending newsletters or invites to Scope events.

2.2 Clients and Subscribers

Scope collects information that is necessary for the performance of the contract signed with Scope for the provision of its services, or to comply with legal (e.g. accounting) or regulatory (e.g. credit rating regulation) obligations when relevant.

The information that Scope collects and processes are:

• Name, company and professional contact details,
• Other professional involvements of contact people by clients if relevant,
• ScopeOne credentials if relevant (see the privacy notice of ScopeOne here),
• Electronic communications,
• Contracts, invoices and other documents linked to the execution of the contract.

Personal data are mainly obtained directly from the data subjects in the course of their relationship with Scope. Other professional involvements may be obtained from public sources for regulatory purposes.

Data are processed in the course of communications linked to the execution of the contracts, conflict of interest check when relevant, regulatory record retention and reporting when relevant, invoicing and accounting.

Website Users:  Scope’s websites uses Cookies, which in some cases track ScopeOne Users activity with the aim to provide them with a better and smoother customer experience, whenever they are visiting any of Scope’s websites; for further details on Cookies, please read the section on “Use of Cookies” under this Policy.

Scope may use the contact details obtained through any of the above processes for marketing purposes. When this is the case, the process is performed based on the legitimate interest of Scope and limited to topics within Scope activities.

3. Recipients and transfers

3.1 Professional contacts

Personal data, including electronic communications, is accessible to Scope’s sales departments.

3.2 Clients

Personal data is accessible to Scope’s sales departments for the contractual relationship purpose and for marketing purpose if relevant, to Scope’s accounting department for the invoicing purpose, and to the relevant analytical teams for the performance of the services.

All electronic communications with employees of the sales departments are accessible by the sales departments.

Regulated functions, such as internal audit, risk management or compliance, may have access to targeted data for control purposes.

3.3 Subscribers

Personal data is accessible to Scope’s sales department for the contractual relationship purpose and for marketing purpose if relevant, to Scope’s accounting department for the invoicing purpose. Regulated functions, such as internal audit or compliance, may have access to targeted data for control purposes.

Data collected through cookies are not sent to Scope recipients.

Scope implemented intragroup contractual clauses for the sharing of personal data between entities of the group. The clauses define the obligations of Scope’s entities in terms of roles, documentation, personal data management, information, exercise of rights, security, retention duration and breaches management.

Scope Ratings GmbH has one branch situated in Norway and one subsidiary situated in the UK, where personal data may be accessed by the sales department, analytical teams, and for the UK compliance department. Norway is part of the EEA, and therefore bound by the GDPR. UK has been declared an equivalent country in terms of data protection by the European union.

Scope may transfer your personal data to external processors, IT software or hosting providers, purely for maintenance or storage purposes. None of these transfers are made outside of the European union.

Scope may transfer your personal data to their supervisory authorities in the EU and the UK upon their request.

4. Retention Duration

Your personal data processed for legal, regulatory or contractual obligations are kept up to 10 years after the end of the contract.

Your personal data processed for contact reasons outside of the above are kept until you request the end of the contact or until Scope no longer has a reason to keep them. 

5. Data Subjects rights

You have the right to request access to your personal data, excepted when prohibited by law or regulation.

You have the right to request the portability of your personal data directly collected by Scope, under an electronic format readable by commonly used software.

You have the right to request the rectification of your personal data which have become inaccurate. If such data were collected based on documented evidence, Scope may request such documented evidence to process the rectification.

You have the right to request the erasure of your personal data, excepted when laws, regulations or contractual dispositions specify a retention period which is not yet ended.

You have the right to request the restriction of a processing of your personal data if the processing is unlawful, when the personal data are inaccurate, or if you oppose the deletion of your personal data for legal purposes.

You have the right to object to a processing based on the legitimate interest of Scope.

You have the right to withdraw your consent when you opted in to receiving Scope communications.

You can exercise your rights by either contacting your usual point of contact or by sending an email to Scope Data Protection Officer (privacy@scopegroup.com).

If Scope does not answer your exercise of right at your satisfaction, you can raise a complaint, either by the data privacy authority of which Scope depends, or by the data privacy authority of your country of residence.

6. Cookies and social media plug-ins

Scope uses Cookies while running its web platform: the function of these Cookies is to partially track the activities of platform/websites users with the aim of providing a better customer experience; usually, it is possible to customize the use of Cookies on each PC through the settings page.

Below is the list of the Cookies used by Scope Ratings website:

Cookie  name	Function
_ga	Cookie used by Google Analytics to distinguish users (https://developers.google.com/analytics/devguides/collection/analyticsjs/cookieusage)
_gat	Cookie used by Google Analytics to throttle request rate (https://developers.google.com/analytics/devguides/collection/analyticsjs/cookieusage)
_gid	Cookie used by Google Analytics to distinguish user(https://developers.google.com/analytics/devguides/collection/analyticsjs/cookieusage)

 

 

 

 

 

Scope Ratings website uses plug-ins for social media platforms which allow you to share information or to follow us on your social media profiles

When you click on the plug-in button, the social media will automatically receive the information on the page you visited and on the content you viewed.

For more details on how these social media process your data, you should refer to the data protection policy for each social media.

7. Administrative information

7.1 Controller

Scope Ratings GmbH
Lennéstraße 5
D-10785 Berlin - Germany
Phone +49 30 27891-0
Fax +49 30 27891-100
privacy@scopegroup.com
www.scoperatings.com

Managing Directors: Guillaume Jolivet, Matthias Böhm
Commercial Register Berlin: HRB 192993 B
VAT-ID: DE226486027

7.2 Data Protection Officer

Nexeo
65 avenue Edouard Vaillant
92100 Boulogne Billancourt
E-mail : dpo@nexeo.group

7.3 Supervisory Authority

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
D-10969 Berlin - Germany
mailbox@datenschutz-berlin.de