21/12/2024

Data usage guidelines

Last Updated: 28 March 2023

1. Purpose

TraditionData is the global brand under which the Compagnie Financière Tradition (CFT) group of companies offers the provision of data to clients and third parties. In this context, data includes a mix of products and services therefore below we have set out more detailed guidance on the use of our data. This guidance applies to any and all pricing, transaction, settlement and similar information provided electronically or via screen display in real-time, end-of-day, periodic or ad-hoc basis, regardless of the means or method of consumption (hereinafter, “Data”). This guidance sets forth TraditionData’s high-level governing requirements, expectations, rights, and prohibitions when dealing with clients that consume and utilize data.

2. Flexibility of Use

TraditionData’s business philosophy is rooted in flexibility and value to our customers. A key aspect of that value proposition is flexibility both in the services we offer and in our commercial model. We work with customers to ensure they benefit from accessing the highest quality financial data in the most efficient manner possible. Should you require additional flexibility in terms of usage or licensing, we encourage you to contact us to discuss your requirements.

3. Ownership and Licensing

TraditionData is the exclusive distributor of proprietary Data generated and/or supplied by any member of the Group of the Compagnie Financière Tradition (CFT) group of companies (“the Group”). All Data is packaged and provided on an anonymous basis and therefore does not contain specific transaction and client identifying information.

Any access to and use of the Data (including, but not limited to use in analytical tools, spreadsheets and risk management systems, redistribution, downloading, storage, forwarding of all or part of the data or use in any internal composite pricing) shall solely be in accordance with the terms of either:

a) a written TraditionData Master Service Agreement (including its Schedules) (“MSA”);

b) a written license granted by one of Tradition Data’s authorised distributors (“Distributor License”); or

c) access granted by a member of the Group in connection with the use of Data as part of an active brokerage relationship in a particular asset class (“Group License”).

We have set out in this document guidance pertaining to typical types of usage of the Data. If there is any inconsistency between this guidance and the terms of the MSA, Distributor or Group License, the terms of the MSA, Distributor or Group License shall prevail.

4. Application or Non-Display Usage

Use of the Data within any non-display applications and/or products (including but not limited to the following types of applications: market/credit risk, portfolio management and valuation, fund administration, back office, quantitative analysis, research, compliance and auditing, instrument pricing, programmatic/algorithmic trading) is only permissible where the specific activity or use is identified as a “Permitted Use” within a relevant MSA or License. Application Use fees will apply. Please contact your account manager or datasalesglobal@tradition.com for details.

5. Redistribution

Except to the extent expressly permitted in an MSA or License, the Data, whether in whole or in part, may not be redistributed (including to affiliates and/or group entities), leased, licensed, transferred, retransmitted, resold, disclosed or otherwise made available (wholly or in part) to any third party in any form whatsoever.

6. Derived Data

“Derived Data” means any data or other information that is created in whole or in part from the Data and that cannot be: (i) readily reverse-engineered to recreate the Data; or (ii) used to create other data that is a reasonable facsimile for the Data; Unless expressly set out in an MSA or License, permitted use shall not include any right to create or use Derived Data or to create any financial product which directly or indirectly refers to or references the Data, including any exchange-traded fund, market indices, institutional or retail fund, derivative contract or other tradable financial instrument and any other interest provided for commercial value, whether or not publicly traded.

Where our MSA or License permits the creation of Derived Data, it is on the basis that a customer may create Derived Data for its internal use and purposes only and provides always that: (A) none of the Data is directly or indirectly identifiable as part of the Derived Data; (B) the Derived Data is not in any way a substitute for any of the Data; and (C) none of the Data can be reverse engineered or otherwise ascertainable directly or indirectly as a result of receipt of the Derived Data.

7. Benchmarks

Unless expressly set out in an MSA or License, permitted use shall not include the right to use the Data directly or indirectly in connection with the Provision of a Benchmark as defined in article 3(1)(5) of EU Benchmark Regulation (Regulation (EU) 2016/1011) or as defined in the 2013 IOSCO Principles for Financial Benchmarks.

8. Audit

TraditionData seeks to work in an open and transparent manner with its customers particularly relating to understanding the usage cases around its Data. TraditionData recognises that there is no “one size fits all” model and welcomes discussions with customers where innovative rights over data usage are sought. TraditionData reserves the right to conduct an audit of customers data usage to ensure your compliance with its data policies and license grants.

9. Fees

TraditionData reserves the right to adjust the fees at the end of each calendar year by an amount equivalent to the Retail Price index (“RPI”) Increase. In addition, TraditionData may, from time to time, review the fees charged for its services to reflect enhancements and changes to the structure of its services. If such a review results in an increase, at least sixty (60) days written notice of such increase will be provided. “RPI Increase” shall mean, for any calendar year, the year-over-year increase, if any, of the UK Retail Price Index (as published by the UK government) over the previous calendar year, expressed as a percentage of the previous calendar year’s RPI.