Effective Date: January 18, 2023
1. INTRODUCTION
Dow Jones & Company, Inc. and its subsidiaries ("Dow Jones", “our”, “us”, or “we”) want you to be familiar with how we collect, use and disclose information from and about you because we respect your concerns about privacy, and we want to maintain your trust.
This Privacy Notice explains how we collect, use and disclose personal data about you when you use our websites, mobile sites, applications ("apps"), and other online products and services that link to this Privacy Notice, subscribe to our print newspaper, attend our conferences or events, and receive our newsletters or emails (collectively, the "Dow Jones Services"). If there is a conflict between this Privacy Notice and a Dow Jones Services corporate subscription agreement, the Dow Jones Services corporate subscription agreement will take precedence.
By using the Dow Jones Services, you acknowledge you have read and accept this Privacy Notice.
The Dow Jones Services are intended for general audiences and we do not knowingly collect personal data from minors under 16 years of age.
2. DATA WE COLLECT
Dow Jones collects personal data to offer services you have requested or that we believe are of interest to you, to manage the relationships we have with our customers and our partners, and to perform activities based on your consent. Dow Jones may obtain information about you from a variety of sources. This includes personal data you provide to us directly, data we obtain from other sources, and data we gather through automated means.
2.1 Data You Provide to Us
We collect personal data that you provide to us when you interact with the Dow Jones Services, including the following:
2.2 Data We Receive from Other Sources
We may receive personal data about you in connection with the Dow Jones Services from publicly and commercially available sources, Dow Jones Affiliates (defined in Section 4.1), business partners (such as social networking services), and, if applicable to you, the third party provider of your subscription (such as your employer or educational institution). Such personal data may include:
2.3 Data Collected By Automated Means Through Our Services
We gather by automated means (such as cookies, web beacons, web server logs and similar technologies) certain information through the Dow Jones Services. Such data may include:
For more information on the various types of automated means we use to gather information, please see our Cookie Notice.
3. HOW WE USE THE DATA WE OBTAIN
We may use the personal data we collect from and/or about you for the business and commercial purposes set forth below.
3.1 To Provide and Manage the Dow Jones Services
This may include:
3.2 To Measure And Improve Our Products And Services
We strive to improve the Dow Jones Services through various means, such as performing data and statistical analysis on user subscriptions, purchases and usage behaviors.
3.3 To Allow You To Share User-Generated Content
Certain features on the Dow Jones Services give you an opportunity to interact with us and others. These features include collaboration tools, community forums, chats, submitting a letter to the editor, creating community profiles, rating, tagging, and commenting on articles. If you choose to use these features, any information you choose to share (such as your name, user name, email address, picture or image, likes, status, and comments) becomes public. We are not responsible for any information you choose to submit and make public through these interactive features.
3.4 To Deliver Interest-Based Advertising (aka Targeted Advertising)
As described in this Privacy Notice and our Cookie Notice, we, as well as our third-party service providers, may obtain information about your online activity to provide you with advertising about products and services tailored to your individual interests. We also engage third party online advertising companies, advertisers and ad networks to help deliver these ads to you. These third parties may collect information about your activities on our Dow Jones Services and on other websites, including offline purchases, for such purpose.
To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising. To learn how to opt out of online interest-based advertising (or, as it may be called in some jurisdictions, targeted advertising), please follow the instructions in the Your Choices and Rights section below.
We participate in the IAB Europe Transparency and Consent Framework (the “Framework”) and comply with its specifications and policies. The goal of the Framework is to inform users located in the European Economic Area or Switzerland (collectively, “EEA”) or the United Kingdom about the storing and/or accessing of information on their devices and the personal data about them that is being processed, the purposes for such processing and the companies that are seeking to process their data for such purposes, and to provide users with choice over such processing. For more information on the Framework, please visit the following site: https://iabeurope.eu/transparency-consent-framework/.
3.5 To Protect The Rights Of Dow Jones And Others
Dow Jones may use your personal data as we believe to be necessary or appropriate in order to:
We may combine information we obtain about you for the purposes identified in this Section 3 above.
4. DATA SHARING
We may share your personal data with:
4.1 Our Subsidiaries and Affiliated Businesses
We may share your personal data with our subsidiaries and affiliated companies (collectively, “Dow Jones Affiliates”) for the purposes described in this Privacy Notice, including for each company's marketing purposes if you have consented to such use. A list of Dow Jones Affiliates is available in annual reports accessible here. Users who visit Dow Jones Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Notice.
4.2 Subscription Providers
If your subscription is provided in whole or in part by your employer, educational institution or other third party, we may share with them information about your access to and use of your subscription, including for subscriptions through educational institutions, your name and email address.
4.3 Our Service Providers
We may share some or all of your personal data identified above, as necessary for the specific services, with our service providers, who provide services on our behalf (e.g., sending email or Text Messages on our behalf, processing payments, fulfilling orders or delivering subscriptions). These third party service providers are not authorized to use it for any other purpose than the specific service they are providing on our behalf.
4.4 Our Business Partners
We may share your data with business partners to provide you with co-branded services or features that you participate in, such as conferences, events, contests, sweepstakes or other promotions ("Co-Branded Services"). These Co-Branded Services may be hosted by the Dow Jones Services or on the third party's service. The business partner’s use of your information will be governed by its privacy notice.
4.5 With Third Parties for Direct Marketing
If you subscribe to the U.S. edition of The Wall Street Journal or Barron’s print publications, we may share your print mailing address with unaffiliated third party companies whose products and services may be of interest to you. While many of our subscribers appreciate receiving offerings from these companies, if you prefer that we do not share your information for this purpose, please refer to the Your Choices and Rights section below.
The above paragraph does not apply to personal data collected through our WSJ Amenity Text-To-Me Service. We do not share such personal data with unaffiliated third party companies for marketing purposes.
4.6 With Social Networking Services
We may share your information when you log into or connect a social media service account with the Dow Jones Services. In that case, the information provided may depend on your settings. The social networking service's use of the shared information will be governed by its privacy notice.
4.7 For Legal Requirements and Proceedings
We may disclose your personal data to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal process or other government measures, and to comply with other legal obligations. We may also disclose information if we believe disclosure is necessary or appropriate in connection with suspected or actual fraud or illegal activity.
4.8 With Other Third Parties To Complete A Corporate Transaction
We may disclose information we have about you in the event we sell or transfer all or part of our business or assets (including in the event of a merger, reorganization, dissolution or, liquidation) to the third party or its advisors involved in such corporate transaction.
5. YOUR CHOICES AND RIGHTS
5.1 Your Choices
We offer you many choices and you may have certain rights in connection with the personal data we collect about you.
5.1.1 Email Communications
You may ask us to remove your information from our marketing mailing lists by changing your account settings through the appropriate link on the website account services page. For example, WSJ subscribers and registered users may update their marketing and newsletter preferences at the following link: Wall Street Journal Emails and Alerts. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link at the bottom of each email.
5.1.2 Push Notifications and Text Messages
If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app. You can opt out of text message alerts at any time by following the instructions in the text message you receive.
5.1.3 Sharing Print Customer Information With Unaffiliated Third Parties
If you are a WSJ U.S. edition or Barron’s print subscriber, you may also opt out from our sharing of your print mailing address with unaffiliated third parties for their direct marketing by contacting Customer Service.
5.1.4 Browser Controls
You have choices about whether cookies or similar technologies are placed on your computer or mobile device. For more information, visit our Cookie Notice.
You may also choose to opt out of our use of data that we or our third party service providers collect about your activities to provide you with tailored advertising about products or services of interest to you. To learn more about how to opt out of such interest-based advertising, please see the “How You Can Manage Cookies” section in our Cookie Notice or visit the consumer opt-out pages at DAA or NAI.
5.1.5 To Change Mobile App Privacy Settings
You may change the privacy settings for Dow Jones apps by accessing and updating privacy settings and permissions within the mobile app or on your mobile device.
5.2 Your Rights
Subject to applicable law, you may have certain rights to access, review, update, correct inaccuracies in, and/or delete your personal data in our custody and control by submitting a request here. For security purposes, we will seek to verify your identity – in part by requesting certain information from you – as part of our process. For instance, you may need to provide your name and email address. For certain types of requests, we may also need to ask you for additional information to verify your identity. Once we have verified your identity, we will respond to your request as appropriate.
5.2.1 The right to access and rectification or correction
You may have the right to access, correct or update your personal data at any time. Additionally, online subscribers and registered users may access their personal data online by signing onto their accounts and visiting the appropriate account management sections of our websites. Please note that if you have subscribed or registered for our print and online editions, or for more than one of our publications or services, you may need to update your information for each separately.
Where you have provided your consent for our use of your personal data, you have the right to withdraw your consent and we will apply your preferences going forward.
5.2.2 The right to deletion
Under certain circumstances, you may have the right to request that we delete your data. Certain data may be exempt from such requests under applicable law. We may need to retain certain types of data so that we can provide the Dow Jones Services to you.
Individuals located in the EEA and UK may exercise their rights by submitting a request here or by contacting us as specified in the “Contact Us” section below. We will respond to your questions or complaints related to the processing of your personal data. If you are not satisfied with our responses, you have the right to lodge a complaint with a supervisory authority. However, we would like the opportunity to resolve any concerns you may have directly and appreciate hearing about any further issues.
5.3 For California Residents
5.3.1 California Shine the Light
Subject to certain limitations, California residents may ask us to provide them with a list of the types of personal data that Dow Jones has disclosed to third parties for their direct marketing purposes during the past 12 months, and the identities of such third parties. To make such a request, California residents can write to us at [email protected], Attn: Privacy Team, Re: CA Shine the Light, and include your name and the address to which you would like us to respond.
5.3.2 California Privacy Rights
The California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act of 2020 (“CPRA Regulations”), requires that we provide certain details about how we collect and use personal data, and give specific rights to California residents, which are detailed below. Where indicated, certain terms in this section 5.3.2 have the meaning given to them in the CCPA or CPRA Regulations (hereinafter collectively “CPRA”).
5.3.2.1 Notice to California Residents
The following chart lists the categories of personal data we may have collected about you during the past 12 months, the purposes and sources of collection, and third parties with whom it may have been shared.
In the chart, we reference relevant sections of our Privacy Notice (e.g., 3.1) and Cookie Notice (e.g., CN 5.5). For more detail about how we collect, use and share personal data, please see our full Privacy Notice and Cookie Notice.
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Categories of Data |
Categories of Sources |
Categories of Purposes of Use |
Categories of Third Parties To Whom Information May Have Been Disclosed – CPRA Business or Commercial Purpose |
Categories of Third Parties To Whom Information May Have Been Disclosed –CPRA Sale/Share |
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Identifiers We obtain from third parties, such as contact information, social media handles, and account number. |
2.1 Data You Provide to Us 2.2 Data We Receive From Other Sources |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.3 Allow You to Share User-Generated Content 3.4 Deliver Interest-Based Advertising 3.5 Protect the Rights of Dow Jones & Others |
4.1 Dow Jones Affiliates 4.2 Subscription Providers 4.3 Service providers 4.4 Business Partners for Co-Branded Services 4.6 Social Network Services 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising* 4.5 Third Parties for their Direct Marketing Purposes |
|
Device Information/Identifiers |
2.3 Data Collected by Automated Means |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.4 Deliver Interest-Based Advertising 3.5 Protect the Rights of Dow Jones & Others |
4.1 Dow Jones Affiliates 4.3 Service providers 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising* |
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Legally Protected Information |
2.1.1 Data You Provide to Us |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.5 Protect the Rights of Dow Jones & Others |
4.1 Dow Jones Affiliates 4.3 Service providers 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
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Commercial Information We receive from third parties, such as information about your transactions, purchase history, relationships with various product and service providers, and your use of certain applications. |
2.1 Data You Provide to Us 2.2 Data We Receive From Other Sources |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.4 Deliver Interest-Based Advertising 3.5 Protect the Rights of Dow Jones & Others |
4.1 Dow Jones Affiliates 4.2 Subscription Providers 4.3 Service Providers 4.4 Business Partners for Co-Branded Services 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising* |
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Financial Information You submit, such as credit or debit card information, verification number, and expiration date |
2.1 Data You Provide to Us |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.5 Protect the Rights of Dow Jones & Others |
4.2 Subscription Providers 4.3 Service providers |
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Biometric Information |
2.1 Data You Provide to Us |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.5 Protect the Rights of Dow Jones & Others |
4.3 Service providers 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
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Online/Internet Activity Information and Geolocation Data Information third parties obtain on our behalf, such as data about your visits to websites and use of apps that serve our advertisements, such as the pages, articles or ads you view and the actions you take on those websites or apps. |
2.3 Data Collected By Automated Means |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.4 Deliver Interest-Based Advertising 3.5 Protect the Rights of Dow Jones & Others |
4.1 Dow Jones Affiliates 4.2 Subscription Providers 4.3 Service providers 4.4 Business partners for Co-Branded Services 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising* |
|
Professional Information |
2.1 Data You Provide to Us |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.4 Deliver Interest-Based Advertising 3.5 Protect the Rights of Dow Jones & Others |
4.1 Dow Jones Affiliates 4.2 Subscription providers 4.3 Service providers 4.4 Business partners for Co-Branded Services 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising* |
|
Education Information |
2.1 Data You Provide to Us |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.4 Deliver Interest-Based Advertising 3.5 Protect the Rights of Dow Jones & Others |
4.1 Dow Jones Affiliates 4.2 Subscription providers 4.3 Service providers 4.4 Business partners for Co-Branded Services 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising* |
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Inferences Information Advertising Cookies remember what you have looked at or purchased on the Dow Jones Services and other sites, and may be combined with other information acquired from third parties such as demographics, offline purchases, and other marketing segment information, and we may share this information with other organizations, such as advertisers, in accordance with applicable law. |
2.2 Data We Receive From Other Sources 2.3 Data Collected By Automated Means |
3.1 Provide and Manage the Dow Jones Services 3.2 Measure and Improve our Products and Services 3.4 Deliver Interest-Based Advertising 3.5 Protect the Rights of Dow Jones & Others |
4.1 Dow Jones Affiliates 4.3 Service providers 4.7 Authorities, regulators or government entities 4.8 Other Third Parties to Complete a Corporate Transaction |
3, CN 4, and CN 5.5 Third parties who measure or deliver Interest-based Advertising* |
* We and select third parties use Advertising Cookies to choose and deliver ads we believe are relevant to you and your interests, to understand their effectiveness, and conduct market research. This involves accessing information from your browser or device, such as advertising and device identifiers, and processing this and other Personal Data, such as IP address. Advertising Cookies remember what you have looked at or purchased on the Dow Jones Services and other sites over time, and may be combined with other information received from third parties, such as demographics.
5.3.2.2 Notice of Financial Incentive
We may offer financial incentives to participate in certain surveys or focus groups. Details of the incentive, if applicable, including how to opt in or out and the basis for the value of the incentive, will be provided prior to your participation.
5.3.2.3 CPRA Privacy Rights
In addition to rights of access, correction and deletion, as described above, California residents may have certain rights under the CPRA, many of which are subject to limitations or exceptions:
Right to access/know and disclosure and portability
You may have the right to request, twice during a twelve month period, the following information that we may have collected about you for the time period from the date of your request to January 1, 2022:
Right to nondiscrimination
We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.
Right to opt out of the sale or sharing of your personal data
You have the right to opt out of the “sale” or “sharing” of your personal data with third parties who are not our service providers. California law broadly defines “sale” such that it may include allowing third parties to receive certain information, such as IP address and/or browsing behavior to deliver interest-based (also called targeted) advertising, or the sharing of a print mailing address with unaffiliated third party companies whose products and services may be of interest to you.
We do not knowingly “sell” or “share” (as defined under the CPRA) the personal data of minors under 16 years old.
Right to limit the use or disclosure of sensitive personal data
You may have the right to request that we limit the use or disclosure of your sensitive personal data (e.g. account numbers, racial or ethnic information) to uses necessary to provide the Dow Jones Services to you and for purposes permitted by applicable law (e.g. to ensure security and integrity). Dow Jones does not use sensitive personal data outside of these limited purposes.
5.3.2.4 How to Exercise your California Privacy Rights
California residents may exercise the Right to Access/Know, Right to Correct or Right to Delete by submitting a request through the following link: CA Privacy Rights or by calling us at 1-800-JOURNAL.
California residents may exercise the right to opt out of the “sale” of personal data by going to the home page of the Dow Jones Services used (e.g., WSJ, Barron’s, MarketWatch, Mansion Global, PEN/Financial News) and clicking on the “Do Not Sell or Share My Personal Information” link in the footer of the site or in the profile or settings page of the app. Note, opting out of interest-based advertising is a device-based action because interest-based advertising is delivered using Cookies. So you must use the link in the footer of the site or adjust your Cookies settings, as described in our Cookie Notice.
California residents may request that we limit the use or disclosure of their sensitive personal data by going to the home page of the Dow Jones Services used and clicking on the “Limit the Use of My Sensitive Personal Information” link in the footer of the site or in the profile or settings page of the app.
For your protection, we will take steps to verify your identity before proceeding with your request as appropriate.
Authorized Agents
You may designate an agent to exercise your rights under CPRA as described above. If you use an authorized agent, we will take steps both to verify the identity of the person seeking to exercise his or her privacy rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through a signed written authorization or a power of attorney.
Once we have verified your identity (and your authorized agent, as applicable), we will respond to your privacy request as appropriate. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your privacy request. If we are unable to complete your privacy request in whole or in part, we will let you know why.
Retention of Data
We may retain your personal data for as long as reasonably necessary to fulfill the purposes described in the Privacy Policy or as required by law.
How We Have Responded To California Privacy Requests
To learn how we responded to California privacy requests received during the prior calendar year, click here.
5.4 For Virginia Residents
Virginia residents have certain rights in relation to their personal data, including the rights to request access to, correction or deletion of their personal data, to limit the use of sensitive personal data and to opt-out of the sale or sharing of personal data to a third party and/or the processing of personal data for the purposes of (i) targeted advertising and/or (ii) profiling.
Virginia residents may request to (i) opt-out of targeted advertising or (ii) limit the use or disclosure of their sensitive personal data by going to the home page of the Dow Jones Services they use and clicking on the “Do Not Sell or Share My Personal Information” link or the “Limit the Use of My Sensitive Personal Information” link in the footer of the site or in the profile or settings page of the app.
Virginia residents may exercise certain other rights with respect to their personal data by submitting a request here or by calling us at 1-800-JOURNAL.
5.6 For Nevada Residents
If you are in Nevada, you may have the right to request that we do not “sell” (as defined under Nevada law) your personal data by submitting a request here.
6. HOW WE PROTECT PERSONAL DATA
Dow Jones uses a combination of administrative, technical, personnel and physical measures to safeguard personal data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of personal data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us as set forth in the Contact Us section below.
7. OTHER IMPORTANT INFORMATION
7.1 Do Not Track Disclosure
Some browsers or other tools include “Do Not Track” (DNT) features which, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, Dow Jones does not currently respond to DNT signals.
7.2 Transfers of Personal Data
Your personal data may be stored, transferred to, and processed in any country where we have facilities and/or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than in your country.
If you are located in the EEA or United Kingdom (UK), we will implement appropriate safeguards to protect your personal data as required if we transfer it outside the EEA or UK.
7.3 Collection of Personal Financial Information by a Payment Service
In some cases, we may use an unaffiliated payment service to allow you to purchase a product or service or make payments (“Payment Service”). If you wish to purchase a product or service or make a payment, in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.
7.4 Links to Affiliates and Third Party Sites or Apps
The Dow Jones Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with a Dow Jones logo, even though they are not operated or maintained by us.
Dow Jones is not responsible for the privacy practices of such third parties, and once you leave the Dow Jones Services or click an advertisement, or sign up for a special offer, you should check the applicable third party privacy notice.
7.5 Updates to Privacy Notice
Dow Jones may periodically update this Privacy Notice without prior notice to reflect changes in our privacy practices and the Dow Jones Services. If we modify the Privacy Notice, we will update the Effective Date and the changes will become effective as of the date we post such Notice. We will notify you of any material changes by posting a prominent notice on the Dow Jones Services indicating we have updated this Privacy Notice.
8. CONTACT US
If you have questions about this Privacy Notice or how we or our service providers handle your personal data, please contact our privacy team at [email protected].
Or you may write to:
Attention: Privacy
Dow Jones & Company, Inc.
4300 U.S. Route 1 North
Monmouth Junction, NJ 08852
If you are located in the EEA or UK, the entity responsible for the collection and processing of personal data in connection with the Dow Jones Services is Dow Jones & Company, Inc. (U.S.) (contact information provided above). If you have a corporate or group subscription agreement, the entity responsible for the collection and processing of your personal data is the entity with whom your company, professor or school has a direct relationship (e.g. by contract).
Please do not disclose any sensitive personal data (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, or trade union membership), social security numbers, or criminal background information when contacting us.