CME Group Colleague 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 below (Section 15). 

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

• Agents and Suppliers - an individual who has physical or logical access to CME Group.
• Contractors – an individual or a company that has undertaken a contract to provide materials or labor to perform a service or a job for CME Group.
• Current or Former Employee – an individual who is employed or has been employed by CME Group.
• Internal Consultant – an individual or group that serves internal clients in an advisory capacity at CME Group.
• Temporary Personnel – an individual who has been hired for a set period or to help with a large project at CME Group.

If you are an applicant or candidate for one of our job opportunities, then you can find out more about how we use your data via our Candidate 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, CME Group-issued physical and/or mobile identification credentials, vehicle registration, 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 previous or current professional experience such as title, location of employment, terms of employment or engagement, dates of employment, dates of leave, termination or separation details, dates of absence, working hours, work days, work duties, professional biography, skills, interests, professional memberships and qualifications, experience information, performance development goals, performance improvement plans, evaluations, financial performance and profitability, utilization details, 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), compliance/training records, information relating to workplace investigations and records of key fob or security card usage.
• Financial Data
  Payroll records, expenses, corporate card details, compensation history, benefit entitlements, and information collected regarding personal trading accounts, in accordance with CME Group policies.
• Device Data
  Details of resource usage or information about your interaction with areas of our network and details we collect from devices issued by CME Group to Colleagues (e.g., which devices were issued, device type, IMEI number of device, MAC address of device, operating system, phone number of mobile phone), details of resource or device usage (e.g., mobile data usage, battery usage, applications used, browser, calls made, text messages sent), information about your use of our computer or other communication systems (e.g., logs of applications used, downloads, uploads, and actions taken), IP addresses, online identifiers, login and logout information, credentials, memorable information, session length, log-in location, browsing history, search history, interaction with areas of our network, 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 badges/physical security, photographs taken in the workplace or at work events, biometric data, records of telephone calls, recordings of meetings, training or business presentations and related information.
• Communications and Social Network Data
  Records of any communications between you, other CME colleagues, customers and others at CME Group, including corporate mobile telephone details, 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.
• Service Usage
  Information collected when you are operating our services (e.g., one of our software applications), including transactions that you undertake, information that you select, logs of when you access the services and for how long, details of any failed login attempts and any information that you choose to download. When you are using one of our Artificial Intelligence (“AI”) tools, we will collect records of your prompts, user-provided input, generated output, refinements and feedback. 

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:

• Biometric Identifiers
  Fingerprint data captured for Financial Industry Regulatory Authority (FINRA) purposes and in certain situations when allowing access to individuals to our premises. See our Biometric Information Security Policy for more information. 
• Information about Criminal Convictions and Offenses
  Information about criminal history which may be provided while employed and be used in assessing whether to continue employing or engaging individuals.
• Information about Sensitive Characteristics
  Details regarding your nationality, race or ethnicity, religious beliefs, sexual orientation, military or military reserve service or status. and political opinions where required by applicable laws or provided voluntarily by you. This may also include information disclosed in ERG chat groups created for events, mental health, and career advice.
• 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: 
  • Workstation assessments; 
  • Consideration of any reasonable adjustments related to a disability;
  • Information related to accidents on CME Group property reported in accordance with the law; 
  • Onsite healthcare center records (including consent forms and other data processed as a part of receiving onsite healthcare center services);
  • Details of any absences from work (other than holidays) including time on sick leave (including absence certification and Fitness to Work certificates); and 
  • Information about your health and/or any medical condition provided because of any referral made by us to an independent occupational health provider or a medical practitioner who is responsible for your care.

Where 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 any Personal Data that you provide to us directly (e.g., at the time you applied to work with us, through the recruitment and onboarding process, 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 Siteor use any of our mobile applications, we may employ cookies and similar technologies. See Section 15 below for further details.
• During Work-Related Activities - we will collect Personal Data on an ongoing basis throughout the period of your working with us in the course of work-related activities, your use of our systems, and in administering our relationship with you.
• Third-Party Sources - including an employment and/or recruitment agency, former employer, benefits provider, healthcare provider, social media (such as LinkedIn) or online share dealing portals, background check provider or credit reference agencies, government agencies and other related sources.
• Workplace Monitoring - we will collect information about you automatically on an ongoing basis through workplace monitoring. See our Code of Conduct and Local Employee Handbooks for more information.

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 administer our relationship with you (such as paying you or providing a benefit) or perform the contract we have entered into with you, where applicable, or we may be prevented from complying with our legal obligations (such as to ensure the health and safety of our workers).

We may receive certain data about you from various third-parties from time to time, including:

• CME Group – 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 – data sourced from any electronic devices issued by CME Group (e.g., mobile devices and laptops).
• Publicly Available Government and Non-Government Data – information about you that is available from the government or otherwise publicly available.
• Social Media Platforms – such as email accounts, chat logs, and 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 You Have a Relationship With – if you are a customer of a third-party and we have a relationship with that third-party, we may receive information from them. During the hiring process, we may also receive information from a former employer 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 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 where legally required and permitted, in accordance with applicable law.

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 Interests).

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.

How will we use information about your dependents?

Subject to applicable law, we may collect Personal Data about your dependents to administer benefits to them in accordance with your benefit entitlements or to comply with our legal obligations under immigration law.

We may share Personal Data about your dependents in accordance with this Notice or with governmental authorities where we are legally required to do so. All Personal Data about your dependents will be processed by us in accordance with this Notice and applicable law.

Hong Kong only: you undertake to notify your dependents of this Notice.

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 – for payroll, administration and provision of benefits or employer-sponsored plans, maintenance of our standard record systems, workplace monitoring, expense reimbursement, travel and accommodations, relocation services, employee assessments, IT infrastructure, training, telephone services or wellness evaluations and services.
• 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 employment-related activities. Such service providers may include equity plan administrators, brokers, benefits providers, payroll companies, IT or systems maintenance providers, systems or data hosts, mobile credentialing system providers, communications providers, record-keeping companies, accountants, auditors, 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 or with your future employers where required by law.
• 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 below.

We may process Personal Data 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 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.

Personal Data 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. 

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 and 5 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.

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, we do engage in the sharing of data through web tracking technologies, like cookies. 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 California Personal Information 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 Cookie 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 Cookie Settings. 

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

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.

^{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 16). You may also exercise these rights via our Privacy Request Form or our Cookie 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 16).

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 and non-DIFC entities have designated CME Operations Limited as their representative within the EU/UK/EEA and Brokertec Europe Limited in the DIFC.

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