Privacy notice

Last Updated: 28 September 2026

This Privacy Notice explains how DC Administration Services, Inc. collects and uses personal information in connection with the administration of the Credit Derivatives Determinations Committees (the DCs) and related processes. This Privacy Notice explains what personal information we collect, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have.

1. WHO WE ARE AND WHAT THIS PRIVACY NOTICE COVERS

When we refer to ‘DCAS’, ‘we’, ‘our’ or ‘us’ in this Privacy Notice, we refer to: DC Administration Services, Inc., whose registered office is at: c/o Citadel SPV, 85 Broad Street, 18th Floor, New York, NY 10004.          

DCAS acts as secretary to, and administer certain processes for, the DCs. For the purposes of this Privacy Notice, DCAS is the controller of personal information that it processes in connection with that role, which means that DCAS decides how and why that personal information is processed.

In this Privacy Notice:

  • DC Participants means organizations that participate in, serve on, or are otherwise involved with the DCs, including members and observers, and their representatives or contacts;
  • Auction Participants means organizations that participate in or are otherwise involved with a credit derivatives auction or related auction process;
  • UK GDPR means Regulation (EU) 2016/679 as it forms part of United Kingdom (UK) law;
  • EU GDPR means Regulation (EU) 2016/679 as it applies in the European Economic Area (EEA); and
  • CCPA means the California Consumer Privacy Act.

This Privacy Notice covers how we process personal information about representatives and contacts of DC Participants, Auction Participants and other organizations involved in DC-related processes, individuals who submit or are involved in requests submitted to the DCs for resolution (DC Requests), and individuals who contact DCAS through the website, by email or by other channels.

2. WHAT TYPES OF YOUR PERSONAL INFORMATION WE COLLECT

We can collect and use your personal information in connection with DC-related activities, including when you:

  • register or act as DC Participant, Auction Participant or other organisation involved in a DC-related process, or as one of their representatives or contact persons;
  • submit or are involved in a DC Request;
  • contact DCAS;
  • attend or participate in DC-related meetings, communications or auctions;
  • or provide information to us by email, through the website or by other channels.

This personal information may include:

  • identity and business contact information (such as name, title, job title, organisation you act for, email address and telephone number);
  • personal information relating to you contained in the communication between you and us (such as your name, contact details, signature block, and any personal information relating to you that is included in the content of emails, enquiries, attachments or other communications, for example information about your role or availability); and
  • personal information relating to you contained in any meeting and administrative records (such as attendance records or meeting invitations).

We may collect personal information directly from you or receive it from your organisation, a DC Participant, an Auction Participant, another organisation involved in a DC-related process, an administrator, or another person involved in the relevant communication, request, meeting, auction or process.

3. HOW WE USE YOUR PERSONAL INFORMATION AND OUR LAWFUL BASIS TO DO SO

We use the personal information we collect for a range of purposes, including:

  • administering the DCs processes;
  • responding to enquiries;
  • maintaining accurate records of DC Participant and Auction Participant representatives and other contacts; and
  • meeting legal and regulatory obligations.

As well as explaining how and why we use your personal information, where we process your personal information under the EU GDPR or the UK GDPR, we also need to tell you our “lawful basis” for doing so. Depending on why we collect your information, we rely on one of the following:

  • Consent – sometimes we may ask for your specific consent before collecting, using, or sharing your personal information. It’s entirely up to you whether to give this, and there’s no downside if you don’t. You can withdraw your consent at any time.
  • Legitimate interests – we may also use or share your information where we (or whoever we’re sharing it with) have a legitimate reason to do so, as long as this does not override your privacy rights (including to run and improve our activities and services; administering the DCs processes; responding to enquiries; maintaining accurate records; keep in touch with you; and keep our website and systems secure). Where we rely on legitimate interests, you have the right to object. See “Your data protection rights” section for full details.
  • Recognised Legitimate Interests – where we process your personal information under the UK GDPR, we may process your personal information for a recognised legitimate interest as set out in UK law – for example sharing personal information at the request of someone carrying out a public task or official function.
  • Legal obligation – sometimes we need to process your personal information simply to comply with the law – for example accounting and tax requirements, or responding to law enforcement requests.

4. WHO WE SHARE YOUR INFORMATION WITH

We may share your personal information with third parties, including:

  • service providers, including IT service providers, website providers, hosting service providers and data centres;
  • administrators, including any potential or current administrators for any DCs, auctions or any DC related processes;
  • DC participants or Auction Participants, or other persons involved in DCs or auctions;
  • our professional advisors, such as lawyers, accountants and auditors; and
  • courts, law enforcement or regulatory bodies.

5. INTERNATIONAL DATA TRANSFERS

We may store your personal information in or transfer your personal information to countries where our group companies, or other parties, such as service providers, administrators, DC Participants or Auction Participants and our professional advisors, are located, such as the UK, EEA, United States and Japan.

Where we process your personal information under the EU GDPR or the UK GDPR and we transfer this personal information outside the EEA and the UK, we make sure that such transfer is made in accordance with applicable law, including by relying on an adequacy regulation or adequacy decision, appropriate safeguards such as contractual protections approved by UK and EU regulators, or an exception or derogation where applicable law permits.

6. HOW LONG WE KEEP YOUR INFORMATION

We retain personal information to meet our legal, regulatory, tax, accounting or reporting requirements, fulfil contractual commitments, respond to queries or complaints, deal with regulatory investigations or disputes and protect our legal rights. We protect the personal information we retain using reasonable safeguards against unauthorised access, loss or misuse.

When deciding how long to keep personal information, we consider: the amount, nature, and sensitivity of the personal information, the potential risk of harm if it were used or disclosed without authorisation, the purposes we’re processing it for, and whether we could achieve those purposes another way. We also take into account any contractual provisions in force, statutory limitation periods, and applicable legal, regulatory, tax, accounting and industry standards.

7. YOUR DATA PROTECTION RIGHTS

Where we process your personal information under the EU GDPR or the UK GDPR, you have the following rights over your personal information (see Section 9 for your rights where we process your personal information under the CCPA):

  • Access you can ask to see the personal information we hold about you. Some exemptions apply, so you may not always receive everything we process.
  • Correct: you can ask us to correct any incomplete or inaccurate information we hold about you.
  • Erase: you can ask us to delete your personal information in certain circumstances.
  • Object: you can object to us processing your personal information where we rely on legitimate interests to do so.
  • Restrict: you can ask us to pause processing your personal information in certain circumstances.
  • Withdraw consent: where we are relying on your consent to process your personal information, you can withdraw your consent at any time. This will not affect the lawfulness of anything we did before you withdrew it.
  • Portability: you can ask us to provide the personal information you’ve given us or send it to a third party of your choice, in a structured, commonly used, machine-readable format This only applies where we’re processing your personal information based on your consent or contract and using automated means.
  • Complain: where we process your personal information under the UK GDPR, you can complain to us if you believe we haven’t complied with data protection law when processing your personal information. You can also lodge a complaint with the relevant supervisory authority.

These rights are subject to legal conditions and exemptions, and we may need to verify your identity before responding. You may submit a request to exercise any of the above rights by using the contact information in Section 8 below.

8. CONTACT US

For questions about this Privacy Notice or to exercise your data protection rights, you can reach us at the contact details provided here or by emailing us.

You may have the right to complain to us or to a data protection authority about how we use your personal information. Contact details for supervisory authorities in the EEA are available here and in the UK here, you may otherwise contact your relevant supervisory authority. Please note that some supervisory authorities will ask you to go through our internal complaints process first, before they look into your complaint.

9. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

For purposes of California privacy law, please note the following additional information:

We collect and use the following categories of personal information for the business and commercial purposes described in this Privacy Notice: identifiers; customer records under Cal. Civ. Code § 1798.80(e); commercial information; internet or other electronic network activity information; general location data based on your IP address; and inferences. See Section 2 above for more details.

We collect these categories of personal information from the following categories of sources, as more fully described in Section 2 above: directly from you; automatically from your devices; or from third parties like our service providers, your organisation, a DC Participant, an Auction Participant, another organization involved in a DC-related process, an administrator, or another person involved in the relevant communication, request, meeting, auction or process.

We use these categories of personal information for our business and commercial purposes described in Section 3 above. We disclose these categories of personal information to our service providers, administrators, DC participants or Auction Participants, our professional advisors, and with courts, law enforcement, or regulatory bodies. See Section 4 above for more details.

Where the CCPA applies to our processing of your personal information, you have the following rights:

  • Right to know: You can ask for more information about how we process your personal information, including  (i) the categories of personal information that we have collected about you; (ii) the categories of sources from which we have collected personal information about you; (iii) the business or commercial purpose for collecting your personal information; and (iv) the categories of personal information that we have disclosed about you for our business purposes and the categories of recipient to whom the personal information was disclosed.
  • Access: You can request a portable copy of the specific pieces of personal information that we have collected about you.
  • Correct or update: You can request that we correct, update, or modify the personal information we maintain about you.
  • Deletion: You can request that we delete the personal information that we maintain about you, subject to certain exceptions.
  • Do not sell my personal information or share my personal information for behavioral advertising: We do not “sell” or “share” your personal information as those terms are defined in the CCPA.
  • Opt-out of profiling and automated decision-making: We do not use your personal information to make consequential decisions using automated decision-making tools.
  • Limit the use of my sensitive personal information: We do not use or disclose sensitive personal information for purposes other than those specified under applicable California privacy regulations.

You may submit a request to exercise any of the above rights by using the contact information in Section 8 above. If you designate an authorized agent to make a privacy request on your behalf, please instruct the agent to identify himself/herself as your authorized agent when submitting the request to us.

We will not discriminate against you for exercising any of these rights. If you are not satisfied with the outcome of your request and would like to request further review, you may contact us as set out in Section 8 above.