CME Group Candidate Privacy Notice

CME Group Inc. and each of its subsidiaries and affiliates (collectively known as “CME Group”, “we” and “us”) are committed to safeguarding the data we collect and hold about you ("Personal Data"). CME Group is the controller or processor of your Personal Data according to the privacy laws and regulations applicable to us. 

The purpose of this privacy notice (“Notice”) is to explain how we process your Personal Data so that you understand what we collect, what we do with it, who we disclose it to and the rights available to you. The processing we undertake may include the collection, storage, modification, access, or destruction of Personal Data, and may be completed manually or through automatic means, including through the use of artificial intelligence (“AI”) technologies.

Personal Data (also referred to as “personal information” or “data”) means any information that can be used to identify you, your device, or, if you live in California, your household. This includes direct identifiers such as your name and contact details, but also indirect identifiers such as data that we may collect when you access our services through our websites, mobile apps, or other online applications that link to this Notice (individually and collectively, our "Site"). 

If you have any questions about this Notice or how we use your data, our details are provided in the 'Contact Details' Section of this Notice (Section 15).

This Notice applies to you if you have any of the following relationships with us:

• Applicant - an individual who is applying for employment or engagement by CME Group.
• Candidate - an individual who attends a recruitment event or applies for a role at CME Group.

If you accept employment with or are otherwise engaged by CME Group, then you can find out more about how we use your data via our Colleague Privacy Notice and our Cookie Notice. For all other relationships with CME Group, you can find out more about how we use your data via our General Privacy Notice. 

We may collect, store, and use the following categories of Personal Data about you to the extent relevant, necessary and permitted by applicable local laws and depending on the nature of the relationship you have with us:

• Basic Personal Data
  Name, date of birth, telephone number(s), home address, personal email address, other contact details, educational qualifications and signature. 
• Demographic Data or Protected Class Characteristics
  Data such as gender, marital status, citizenship, residency or domicile and immigration status.
• Family Data
  Name, date of birth and other identifying information of your spouse, partner or dependents; next of kin; emergency contact and information concerning parental leave.
• Health Insurance Information
  Your details including your designated beneficiaries, expression of wish forms, notice coverage and national insurance number.
• Recruitment Information
  Copies of right to work documentation, references, background check outcome (if applicable), education history and level/qualifications, salary expectations and other information included in a resume/CV or cover letter or that you provide to us during an interview, assessment or otherwise as part of the application process.
• Professional or Employment-Related Data
  Details regarding professional experience such as title, location of employment, dates of employment, dates of leave, dates of absence, working hours, work days, work duties, professional biography, skills, interests, professional memberships and qualifications, experience information, and personality and assessment results (including results from aptitude tests or psychometric tests that may reveal details about your characteristics, psychological tests, behavior, attitudes, predispositions, abilities or aptitudes).
• Device Data
  Information about your interaction with areas of our Site, IP addresses, online identifiers, login and logout information, credentials, memorable information, session length, log-in location, browsing history, search history, information regarding your stated preferences and geolocation data.
• Compliance Data
  Government identifiers, including passport or driver’s license numbers, visa details, financial status metrics (e.g., credit ratings, bank statements and tax information), background checks.
• Security Data
  CCTV footage, photographs collected for physical security, records of telephone calls, recordings of meetings, and related information.
• Communications and Social Network Data
  Records of any communications between you, CME colleagues and others at CME Group, including copies of messages sent through our networks and written communications from or about you, and social media account information and Personal Data collected from social media accounts. 

In addition, we may also collect the following categories of Personal Data about you in compliance with applicable laws that may be of a sensitive nature:

• Information about Criminal Convictions and Offenses
  Information about criminal history as part of the recruitment process to assess/determine whether a candidate is appropriate for a position.
• Information about Sensitive Characteristics
  Details regarding your nationality, race or ethnicity, religious beliefs and trade union membership where required by applicable laws or provided voluntarily by you.
• Information about your Health
  Information needed to administer CME Group policies or regulatory responsibilities, such as any medical condition, disability, health and sickness records, including:
  • Drug and alcohol test results (where applicable); and
  • Information related to accidents on CME Group property reported in accordance with the law.

When we collect your Personal Data outside of the scope above or for purposes beyond those specified in this Notice, we will communicate this to you.

In addition to the Personal Data which you provide to us directly (e.g., via an online application, attending an interview, completing a test/assessment, sending us an e-mail, or making a call to us, etc.), we may also collect and derive data about you through the following means:

• Automated Means – for example, when you interact with areas of our network.
• Cookies and Similar Technologies – when you visit our website or use of any of our mobile applications, we may employ cookies and similar technologies. See Section 15 below for further details.
• Publicly-Available Information – from a company website, internet searches, online share dealing portals or from social media platforms such as LinkedIn.
• Third Party Sources – including an employment and/or recruitment agency, former employer or your other reference providers, job sites we utilize from time to time, background check providers or credit reference agencies, government agencies, higher education institutions and other related sources.

You may not be required to provide us with certain information requested and the provision of such is voluntary. However, some information is necessary for the purposes described in this Notice. If you fail to provide certain information requested as mandatory, we may not be able to process your application successfully. For example, if we require references for the role that you have applied for and you fail to provide us with such details, we may not be able to progress your application in relation to that role.

We may receive certain Personal Data about you from various third parties from time to time, including:

• CME Group – including CME Group systems, colleagues, and departments, as needed to facilitate our business operations, services and products and to fulfill our legal obligations to you.
• Electronic devices – including data sourced from any electronic devices (e.g., mobile devices and laptops) used to access our services.
• Publicly Available Government and Non-Government Data – information about you that is available from the government or otherwise publicly available (e.g. company website, internet searches, online share dealing portals). 
• Social Media Platforms – such as publicly available information sources from social media pages or via services provided via social media platforms (e.g., LinkedIn, WeChat, Weibo, Facebook, X (formerly Twitter), etc.).
• Third Party Agencies – who may provide us with information that they have collected from you on our behalf (e.g., companies that perform background checks on behalf of CME Group).
• Third Parties That You Have a Relationship With – if you are a customer or otherwise, service user, of a third party and we have a relationship with that third party, we may receive information from them. During the hiring process, with your consent, we may also receive information from former employer(s) or your other reference providers.

The purposes for which we may process your Personal Data are as follows to the extent relevant, necessary, and permitted by applicable law:

Additional information

For some roles, we are required by law to undertake criminal background screening checks and we can process your Personal Data in this way because processing is necessary for the purposes of complying with a regulatory requirement. Background checks assist in verifying an individual’s qualifications and in identifying issues that pose a reputational or security risk or have the potential to pose such risks. This will be done both during onboarding and will be confirmed every three years as part of CME Group’s Global Background Check Policy. In any other circumstances, we will only collect and process Information about Criminal Convictions and Offenses to the extent permitted by local law, or with your explicit consent and in accordance with applicable law.

Subject to the foregoing, we will only conduct criminal background screening if your recruitment exercise has been successful and we have offered you a role at CME Group. In such an instance, our offer will be conditional upon satisfactory completion of such background screening checks.

We may de-identify, aggregate or anonymize your Personal Data in such a way that you may not reasonably be re-identified by us or any other party. We may use such de-identified information as permitted under applicable local law.  To the extent we de-identify any Personal Data and are not required to re-identify it to comply with applicable laws, we will make reasonable efforts to maintain and use such data in a de-identified form and will not attempt to re-identify the data.

If you are located in the People's Republic of China ("PRC", for the purpose of this Notice, excluding the Hong Kong SAR, the Macau SAR and Taiwan), we process your Personal Data based on lawful basis permitted under Chinese data privacy laws (and not based on Legitimate Interest).

If you are located in the Dubai International Financial Centre (“DIFC”), we process your Personal Data based on lawful basis permitted under DIFC data protection laws. Where the basis is listed as Legitimate Interest, our specific interests being pursued include, but are not limited to:

• Operational Security and Efficiency: Maintaining the security and efficiency of our platforms, protecting our systems from risk, and ensuring business continuity for the administration of our business and management of your account.
• Safety and Asset Protection: Ensuring physical security and fraud prevention for the protection of our people, property, and assets.
• Service Improvement: Analyzing user interaction, account preferences, and feedback to develop, personalize, and improve the quality and relevance of our products and services.
• Legal Protection: Enforcing and defending our legal rights, property, and safety, and cooperating with governmental and regulatory bodies.

We may disclose your Personal Data to CME Group entities, service providers or other third parties for various purposes, to achieve our business objectives, and/or to comply with applicable laws as described in this Section.

• CME Group entities – to facilitate our business operations and for recruitment purposes.
• Law Enforcement Agencies – in relation to the detection and prevention of criminal activities, as permitted by applicable laws.
• Prospective Purchasers and Assignees – to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation or transfer of some or all our assets, in the event our business, or part of it, may be or is sold or reorganized.
• Regulators and Governmental Authorities – to comply with the law applicable to any member of CME Group, as permitted by applicable laws. This may include filing returns with tax authorities and making disclosures to our regulators (including, for example, the US Securities and Exchange Commission, the US Commodity Futures Trading Commission, the Health & Safety Executive and local financial regulation authorities and data protection authorities) and shareholders.
• Service Providers – to assist us in conducting our recruitment process. Such service providers may include IT or systems maintenance providers, systems or data hosts, communications providers, background screening and online assessment providers, recruitment and head-hunting agencies that have assisted us in conducting our recruitment process, record-keeping companies, accountants, auditors, or other professional advisors or other vendors that help support migration services.
• Third Parties as Required by Law – to comply with laws to which we are subject, as permitted by applicable laws. For example, we may share your Personal Data in response to a court order or subpoena, in response to a valid request from law enforcement.
• Third Parties for Other Purposes – to deliver relevant advertising and to measure and understand the effectiveness of our advertising and marketing; and to protect our legitimate business interests in protecting our rights; enforcing our Terms of Use; detecting, preventing, or responding to fraud, intellectual property infringement, or other illegal activities; and protecting the safety and security of tangible or intangible property belonging to us or a related third party.

We may also disclose de-identified or aggregated information to anyone and for any purpose permitted under applicable local law. To receive more information about the service providers or third parties to which we may disclose your data, you can contact us through the information provided in the 'Contact details' Section of this Notice (Section 15).

We may process information collected from or about you in any country in which CME Group operates, as permitted by applicable laws.

In some cases, your Personal Data may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for information under applicable laws (such as those in the EU/UK/EEA). When we conduct such transfers, we rely on your explicit consent (as required under applicable laws) or have put in place appropriate safeguards (including without limitation signing standard contractual clauses) in accordance with applicable legal requirements.

Information located outside of your home country may be subject to access by that country’s government or its agencies under a lawful order, as permitted by applicable laws.

We put in place appropriate procedures and safeguards in accordance with applicable legal requirements when conducting such transfers. For more information on the appropriate safeguards in place or to obtain a copy of these safeguards, please contact us through the information provided in the 'Contact Details' Section (Section 15).

People’s Republic of China (“PRC”):

All data, including personal data, as defined under the Personal Information Protection Law of the PRC, provided to us by you will be used, distributed, and maintained in accordance with this Notice, which forms a part of the contractual terms that you agree to.  If you, as an institution, are providing us with this data, you confirm that you have obtained all the necessary consents from the relevant data subjects concerned, and your processing, use and transfer of data to us complies with all applicable PRC data privacy laws. If you, as a natural person, are providing us with your Personal Data, you expressly give us consent to any processing, use or transfer of such data. In each data transfer above, you acknowledge and agree that the data may be transferred outside of the territory of the PRC.

This Section provides California residents with additional information regarding our collection, use, disclosure, and retention of their identifiable information (“California Personal Information”), as well as the rights that California residents may have under applicable law.

Categories of California Personal Information We Collect

The chart below describes the categories of California Personal Information we collect from the sources identified above in Sections 3, 4, 5 and 6 of this Notice, as well as the categories of third parties to whom we may disclose, “sell” or “share” (as those terms are defined under California law) each category of California Personal Information for the business and commercial purposes described in Section 6 of this Notice.

Do Not Sell or Share My Information

We may “sell”¹ or “share”¹ your California Personal Information for cross-contextual behavioral advertising. While CME Group does not engage in selling your data as part of a monetary transaction, the Company does engage in the sharing of data through web tracking technologies, like cookies. For more information on these technologies, please refer to our Cookie Notice. We have configured our cookie management tool to honor opt-out preference signals sent by Global Privacy Control ("GPC") within the browser. Due to technical limitations, the GPC signal is only honored within the particular browser. Beyond GPC, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our sites. For more information on these technologies, please refer to our Cookie Notice. We do not have actual knowledge of “selling”¹ or “sharing”¹ the personal data of consumers under the age of 16.

We do not use or disclose your sensitive California Personal Information for purposes other than permitted under applicable law.

Your California Privacy Rights

In addition to certain rights described in Section 10 of this Notice, you may have the following rights under California law:

• Not be discriminated against – not be unlawfully discriminated against for exercising your rights.
• Opt-out – opt-out of “sales” of California Personal Information or “sharing” of California Personal Information for cross-contextual behavioral advertising purposes (as these terms are defined under California law).

Exercising Your Rights

To exercise your rights to know, access, correct and delete, please review the additional information provided in Section 10 of this Notice. You may also exercise these rights via our Privacy Request Form or our Cookies Settings. To exercise your right to opt out of our “sale”¹ or “sharing”¹ of your California Personal Information, please submit a request through our Privacy Request Form or update your Cookies Settings.

Verification

We may request that you provide sufficient information that allows us to verify, to a reasonable degree of certainty, that you are the person about whom we collected California Personal Information. Authorized agents may also be required to provide a copy of your signed permission authorizing the agent to submit requests on your behalf.

Authorized Agents

To the extent that you elect to designate an Authorized Agent to make a request on your behalf, Authorized Agents may also be required to provide a copy of your signed permission authorizing the Agent to submit requests on your behalf, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

California Online Erasure. California residents under age 18 who are registered users of any of our services geared toward this age group may ask us to remove content or information that you have posted to CME Group websites or related platforms by contacting us using the information in the ‘Contact details’ Section of this Notice (Section 15). Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

^{1 As defined under California law.}

Subject to local law, you may have the following rights regarding your Personal Data. These rights may be limited or denied in some circumstances. For example, we may retain your Personal Data where required or permitted by applicable law.

• Access/Know –  subject to certain exceptions, you have the right to request a copy of your Personal Data and information relating to how it is processed, and, where that is the case, to request access to the Personal Data as well as further information. You may have the right to request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form.
• Rectify/Correct – request any incomplete or inaccuracies in the Personal Data we hold about you be corrected.
• Erasure/Deletion – request that we erase your Personal Data from our records., unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
• Restrict – request that your data is no longer processed by us where, e.g.: (i) you believe such data to be inaccurate; (ii) our processing is unlawful and you oppose to the erasure of the Personal Data and request the restriction instead; or (iii) we no longer need to process such data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims.
• Object –  where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to certain ways that we process your Personal Data. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of a legal claim.
  • Direct Marketing - you have the right to object to our use of Personal Data for direct marketing. Please note that we may need to retain certain Personal Data as required or permitted by applicable law.
• Transfer/Portability – request that your Personal Data be transferred to you or disclosed to a third party in a structured, commonly-used, machine-readable format, where this is: (i) Personal Data which you have provided to us; and (ii) we are processing that data on the basis of your consent or in order to perform our obligations under contract to you (such as to provide legal services).
• Withdraw your consent – where we are relying on your consent to process your Personal Data, then you can withdraw your consent at any time. This includes cases where you wish to opt-out from marketing messages that you receive from us.
• Lodge a complaint – you may be entitled to lodge a complaint with your local data protection authority if you believe that we have not complied with applicable data protection laws. For details about the competent supervisory authority for European residents, see https://edpb.europa.eu/about-edpb/board/members_en. In some jurisdictions, such as the United Kingdom, under applicable law, you may also be entitled to lodge a data protection related complaint directly with us. Where you have this right, you can contact us using the ‘Contact Details’ Section of this Notice (Section 15) or via CME Group social media pages. We may request that you provide sufficient information that allows us to verify, to a reasonable degree of certainty, that you are the person the Personal Data pertains to. 

In some jurisdictions, you may also have post-mortem privacy rights. For example, you may have the right to designate an individual to exercise your privacy rights in the event of your death or incapacitation, where applicable by law.

In certain jurisdictions, such as the PRC, you may have the right to opt-out of receiving personalized content and recommendations based on automated processing, including profiling.

In certain jurisdictions, such as the DIFC, where Personal Data is processed under a Legal Requirement or for the Performance of a Contract, we may be restricted from fulfilling requests to exercise the right to rectification, erasure, or objection. The expected impact on your rights in these instances is that your data will be retained and processed as necessary for us to meet mandatory regulatory or contractual duties, even if you request deletion or object to the processing.

Submitting Requests

To exercise your rights to know, access, correct, delete, restrict, object, portability, withdraw your consent under applicable local law, complain or if you are an Authorized Agent seeking to exercise rights on behalf of a consumer under applicable local law, please contact us on the details set out in the 'Contact Details' Section of this Notice (Section 15). You may also exercise these rights via our Privacy Request Form or our Cookies Settings.

Please note that some of your rights are not absolute and there may be certain circumstances where we are unable to fulfill a request that you have made. In some circumstances we may also require that you provide additional personal data to confirm your identity.

We use technical, administrative, and physical security safeguards and other reasonable security measures to protect the information that we collect or receive against loss and unauthorized access, use, modification, or disclosure. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable. Moreover, we are not responsible for the security of information that you transmit to us over networks that we do not control, including Internet and wireless networks. You should not share your username and password with anyone, and you should not re-use passwords across more than one website. If you have any reason to believe that your username or password has been compromised, please contact us as detailed in this Notice (Section 15).

1. Artificial Intelligence
   Like many other companies, CME Group may use artificial intelligence (“AI”) to help process your Personal Data for the purposes explained in this Notice, including to enhance operational efficiency and improve service functionality. 
   
   CME Group prohibits the use of AI technology by its colleagues for purposes such as sentiment analysis of individuals, deploying manipulative techniques to undermine a person's autonomy or free choice, or exploiting the vulnerabilities of specific groups (e.g., based on age or disability).
2. Automated Decisions
   Automated decision-making takes place when an electronic system uses Personal Data to make a decision without human intervention.
   CME Group may do this via monitoring, or surveillance activities on any content or materials located on any CME Group information resource or CME Group facility, in accordance with applicable laws.
   
   CME Group may provide information obtained in the course of its monitoring activities to a third party, including regulators and law enforcement agencies.
   
   Ultimately, we do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
3. Children's Data 
   Our website and services are generally not directed at persons/users under the age of 18. If we obtain actual knowledge that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that information. If you access our website from the EU/UK/EEA or if you access an EU/UK/EEA website, the age limit will be 16. If you access our website from the PRC or if you access a PRC website (if any), the age limit will be 14.
4. Data Retention
   CME Group retains Personal Data for the duration of the business relationship or where required, in accordance with our internal records management and retention policies, as well as regulatory requirements that may be applicable to us.
   
   To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve these purposes through other means, and the applicable legal requirements.
   
   When your employment or engagement is over, we may retain certain Personal Data for purposes such as complying with our legal obligations, resolving disputes, conducting workplace investigations, preventing fraud or misuse of our property or data, and protecting our rights and interests. We may be legally obligated, for example by local employment or tax laws, to retain Personal Data related to your employment for a period of time specified by law.
   
   We make reasonable attempts to ensure that all instances of such information (e.g., production, backups, etc.) are deleted in their entirety, including any of your Personal Data. For requests for access, corrections, or deletion please see "Contact Us" below (Section 14). 
   
   For requests for access, corrections, or deletion please see the "Contact Details" Section of this Notice (Section 15). 
5. CME Group as Processor or Service Provider
   This Notice will not apply to CME Group as a processor or service provider, and you should instead refer to the privacy notice of the organization that provides us with your Personal Data. where applicable.
   Under the applicable PRC data privacy laws, there is no distinction between "data controller" and "data processor". You should, however, still refer to the privacy notice of the organization that provides us with your Personal Data, where applicable, where we would be deemed a third-party data processor.

Please see our Cookie Notice for further information on how we use cookies and other tracking technologies on our website.

We reserve the right to update this Notice from time to time by publishing a new version online. For instance, there may be changes in the data we collect about you or the purposes for which we use your Personal Data.

Whenever there are significant changes to the Notice that materially affect previously collected Personal Data, we will provide additional notice to you, as required by applicable law.

You can see the date of the last revision at the beginning of this Notice.

If you have any comments, questions or concerns about how we process your data or to exercise any right, then please contact Privacy Compliance at Privacy@cmegroup.com. We can also be reached by post at below address and via telephone at the below telephone numbers.

ATTN: Privacy Compliance
CME Group Inc.
20 S. Wacker Drive
Chicago, IL 60606

 +1 312 930-1000
+1 866 716-7274 (US Only)

Privacy@cmegroup.com

You may also contact us via our Privacy Request Form.

For the purposes of data protection in the EU/UK/EEA, Singapore, India, or the DIFC:

• Your controller is the company which employs or engages you. This entity is responsible for deciding how we hold and use your personal data. The list of employing controllers, across CME Group can be found here. In addition, CME Group Inc. (our US parent company) is also a joint data controller. This Notice is provided for CME Group, and on behalf of Chicago Mercantile Exchange Inc.

• CME Group has a designated Data Protection Officer registered for a number of CME entities. They can be contacted at Privacy@cmegroup.com

• CME Group Inc., CME Mercantile Exchange Inc. and the above non-EU/UK/EEA entities have designated CME Operations Limited as their representative within the EU/UK/EEA.

The full list of companies across CME Group and the contact details of each company can be found here.