Privacy & Security

Moody's Privacy Policy

(May 6, 2004)

This Privacy governs the following websites operated by Moody's:

. www.moodys.com

· www.moodyseurope.com

· www.moodys.com.au

· www.moodys.ca

· www.moodys.de

· www.moodys.es

· www.moodys.fr

· www.moodys.it

· www.kmv.com

· www.moodyskmv.com

· www.mkmv.com

· www.moodysasia.com (each, a "Website").

This Privacy and Confidentiality Policy explains how we collect your personal information on our Websites, how we protect such information, and the choices you have concerning the use of such information. Please read this Privacy Policy carefully. Except as we disclose in this Privacy Policy, we will not sell, share, license, trade, or rent your personal information to others. For purposes of this Privacy Policy, "we", "us", and "our" means Moody’s Investors Service, Inc., Moody’s KMV Company, and their respective affiliates. The Moody’s Websites are intended for use by businesses and are not intended to be used by individuals for personal, family or household purposes.

This Privacy and Confidentiality Policy represents our current (as of May 6, 2004) data collection and usage practices. Moody's will from time to time review and revise these practices. We will post any changes to this Privacy Policy here. Please refer back to this Privacy Policy on a regular basis. By using our Websites or any of the products, offerings, features, tools or resources that we provide on our Websites, you agree to the terms of this Privacy Policy.

This Privacy Policy applies only to information collected by our Websites. We are not responsible for the privacy of any information you reveal or post in any public forum (e.g., message board or chat room), or for the privacy practices of websites that are operated or owned by third parties.

Collection of Personal Data

Personally identifiable information is information that identifies you or can be used to identify or contact you, e.g., your name, email address, address, or phone number ("Personal Data").Moody’s requests Personal Data from you when you register on any of our Websites. The registration process requests that you provide your name, business email address, business address, business phone number, and company affiliation, and agree to the terms of use agreement presented at the time of registration. In addition to information collected during registration, Moody’s may collect Personal Data knowingly provided by you in emails to our Websites, online forms, order and registration forms, surveys, and contest entries. In addition, on some sites including www.moodys.com and www.mkmv.com, you are able to maintain "portfolios", listing financial instruments in which you have a special interest. Providing this information is always at your option. If you provide such information you will be required to select a username and a password. To be useful, this information must be stored on the Website, and is accessible to any site visitor who knows your username and password. For this reason, please safeguard your username and password carefully.

In all of these cases, we will collect Personal Data from you only if you voluntarily submit such information to us. Unless you give us permission to do so, we will not sell, share, license, trade or rent your Personal Data other than as specified in this Privacy Policy.

You do not have to provide us with any Personal Data to visit our Websites. However, if you choose to withhold requested information, you may not be able to visit all sections or use all features of our Websites.

Collection of Nonpersonal Data

In addition to Personal Data, Moody’s may collect and/or track information that by itself cannot be used to identify or contact you, e.g., demographic information (like age, profession or gender), domain names, computer type, browser types, and other anonymous statistical data involving the use of our Websites ("Nonpersonal Data"). We use Nonpersonal Data to help us understand who uses our Websites and to improve and market our Websites.

Tracking Tools

To enhance the Internet experience on its Websites, Moody's may use various Internet technologies such as 'cookies,' ‘action tags,’ ‘web bugs,’ ‘.gif tags,’ and 'JavaScript' (together, "Tracking Tools"). Tracking Tools are files or tools that are placed on your computer in order to identify your Web browser and the activities of your computer on our Websites. Moody’s uses these technologies to customize and enhance the Internet experience of individual users. When you revisit a Website, Moody’s may recognize you by an Internet Tracking Tool and customize your experience accordingly. For example, once you have completed the registration process, a cookie will be used to avoid having you register again. You may decline Internet cookies, if any, by using the appropriate feature of your Web browser software, if available. If cookies are disabled, however, all features of a Website may not operate as intended. We believe Tracking Tool technologies add value to the user experience, and the information resulting from these technologies is not sold or otherwise made available to third parties.

Use of Personal Data Collected

Moody’s may use Personal Data it collects for its internal use, and for Moody’s own business purposes, including for editorial and feedback purposes, for marketing and promotion, for statistical analysis of users’ behavior, for product development, for content improvement, or to customize the content and layout of its Websites. Nonpersonal Data may be used for internal or external purposes such as researching and identifying market segments and needs. Moody’s will not disclose to third parties any of your Personal Data, except to the extent necessary to comply with applicable laws, rules, or regulations, with your express permission, or to preserve Moody’s legal rights in the Website content. Moody’s reserves the right to transfer such information among its own affiliated companies, to successors to the relevant portion of any of Moody’s businesses, or to independent contractors it engages to assist with or perform on Moody’s behalf any of the foregoing activities. In addition, Moody’s reserves the right to use Personal Data to contact you regarding your account status and changes to the subscriber agreement, this Privacy Policy, or any other policies, agreements or transactions relevant to your use of the Websites. Moody’s will take reasonable steps to maintain the integrity of the collected data so that it is reliable and appropriate for the foregoing uses.

Your Choices Regarding Personal Data Collection and Use

You may "opt-out" of having your Personal Data used by Moody’s to send promotional correspondence to you, by contacting Moody’s via postal mail, e-mail, or telephone at the address below. Moody’s will not share any personally identifiable information with an unrelated third party without giving you the opportunity to "opt-in" and give or deny us permission to do so.

Upon request via postal mail, e-mail, or telephone, Moody’s will provide to you a summary of any Personal Data retained by Moody’s regarding you. You may modify, correct, change or update Personal Data that Moody’s has collected via any Website or you may request that your Personal Data be removed from Moody’s database by contacting Moody’s via postal mail, e-mail, or the telephone number indicated below, provided, however, that such removal may require you to register again with Moody’s in the event you later wish to access Moody’s Websites. You should be aware that it is not technologically possible to remove or verify each and every record of information you have provided to us from our system. The need to back-up our systems to protect information from inadvertent loss means that a copy of your Personal Data may exist in archived systems. However, promptly after receiving your request, all Personal Data stored in databases we actively use and other readily searchable media will be updated, corrected, changed, deleted or confirmed to you, as appropriate, as soon as reasonably practicable.

Links

Each Website may contain links to other Internet websites. Moody’s does not endorse, and is not responsible for, the privacy practices or the content of these web sites. You should review the applicable privacy policies in connection with your use of such third party websites.

Security Measures

Moody's has established reasonable precautions to protect collected Personal Data from loss, misuse, unauthorized access, disclosure, alteration or destruction, which include contractual, administrative, physical, and technical steps. Technical measures include use of firewall protection and encryption technology where appropriate. Although Moody's takes reasonable precautions to assess the reliability of such technology, it relies on the representations of the vendors of those products and services as part of its security evaluation. Please note that while Moody’s has endeavored to create a secure and reliable site for users, the confidentiality of any communication or material transmitted to/from Moody’s via the Websites or e-mail cannot be guaranteed.

Jurisdiction

This policy shall be governed by the laws of the State of New York, without regard to conflicts of law rules, and the exclusive jurisdiction and venue for any dispute shall be New York, New York.

European Economic Area Users

When you provide us with your Personal Data, you acknowledge that this information may be stored and processed on servers located outside the European Economic Area ("EEA") and you consent to your Personal Data being exported outside the EEA and being stored and processed at our discretion on any of our servers wherever located.

Contact Information for Moody's

Questions or concerns regarding Moody's data protections practices should be addressed to:

Tom Hughes

Moody's Investors Service, Inc.

99 Church Street

New York, New York 10022

Phone: 212.553.7116

E-mail: privacy@moodys.com

BY USING OUR WEBSITES, YOU SIGNIFY YOUR ACCEPTANCE OF THIS PRIVACY POLICY AND OF US PROCESSING YOUR PERSONAL DATA IN ACCORDANCE WITH THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU SHOULD NOT USE OUR WEBSITES. YOUR CONTINUED USE OF OUR WEBSITES FOLLOWING THE POSTING OF CHANGES TO THIS PRIVACY POLICY WILL MEAN THAT YOU ACCEPT THOSE CHANGES.