Bloomberg will not hand over client data to agencies unless the law requires it
Bloomberg says it will not disclose client data in response to third-party requests from law enforcement, governmental or regulatory agencies unless the law requires it, for example valid and properly served legal process such as a subpoena or search warrant. "Client data" may include personal information. This general rule is subject to the urgent-request reservation in the last paragraph of the main statement (see the emergency card).
Supporting quotations
Bloomberg will not disclose client data (which may include personal information, together “client data”) in response to third party requests from law enforcement, governmental, or regulatory agencies except where required to do so by law (for example, in response to valid and properly-served legal process such as a subpoena or search warrant)
Notwithstanding any of the foregoing
Qualifications & exceptions
Applies to requests from law enforcement, governmental or regulatory agencies; "client data" is defined as data that "may include personal information".
The subpoena and search warrant examples are illustrations of valid legal process, not a complete list.
Qualified by the "Notwithstanding any of the foregoing" reservation for good-faith emergency requests involving imminent danger of death or serious physical injury.
Not stated here
The text does not list which legal process types count as "required by law" beyond the two examples.
The text does not say which countries or jurisdictions' laws it means.
Sharing & Disclosure · Company commitment
Bloomberg will tell clients about requests and direct access, with two exceptions
Bloomberg says it will take reasonable steps to notify its client about any legally binding request for the client's data before disclosing it, and will notify its client if it becomes aware of any direct access by public authorities to client data. It does not do either if (1) applicable law prohibits it from notifying, or (2) there are clear indications of unlawful conduct in connection with the client's use of Bloomberg services.
Supporting quotations
Bloomberg will take reasonable steps to notify its client about any legally binding request for the client’s data prior to disclosing client data in response to that request
will notify its client if Bloomberg becomes aware of any direct access by public authorities to client data
(1) Bloomberg is prohibited by applicable law from doing so, or
(2) there are clear indications of unlawful conduct in connection with the client’s use of Bloomberg services.
Qualifications & exceptions
Prior notice is "reasonable steps" and applies to a legally binding request before disclosure; the direct-access notice applies when Bloomberg "becomes aware" of it.
Both notices fall away if applicable law prohibits notifying, or if there are clear indications of unlawful conduct in connection with the client's use of Bloomberg services.
Qualified by the emergency reservation, which begins "Notwithstanding any of the foregoing".
Not stated here
The text does not say how or how far in advance clients are notified.
The text does not say who decides whether there are "clear indications" of unlawful conduct.
The notice promise names "its client"; it does not mention individual users.
Sharing & Disclosure · Company commitment
If Bloomberg responds, it will try to give the minimum information allowed
When Bloomberg does respond to a disclosure request, it says it will attempt to provide the minimum amount of information permissible, based on a reasonable interpretation of the request. This is a commitment to attempt, tied to a reasonable reading of the request.
Supporting quotations
Bloomberg will attempt to provide the minimum amount of information permissible, based on a reasonable interpretation of the request.
Qualifications & exceptions
The commitment is to "attempt" to give the minimum "permissible", measured against a reasonable interpretation of the request.
Not stated here
The text does not say who decides what is reasonable or what the minimum permissible amount is in practice.
Sharing & Disclosure · Restriction or exception
Bloomberg reserves the right to answer urgent emergency requests
Notwithstanding the rest of the main statement, Bloomberg reserves the right to respond to urgent law enforcement requests if it believes in good faith that an emergency involving imminent danger of death or serious physical injury justifies the disclosure. This sits alongside, and can override, the general promises not to disclose without legal compulsion, to notify clients first and to review legality, because it applies "Notwithstanding any of the foregoing".
Supporting quotations
Notwithstanding any of the foregoing, Bloomberg reserves the right to respond to urgent law enforcement requests if Bloomberg believes in good faith that an emergency involving imminent danger of death or serious physical injury justifies such disclosure.
Qualifications & exceptions
Applies to urgent law enforcement requests only, and only where Bloomberg believes in good faith that an emergency involving imminent danger of death or serious physical injury justifies disclosure.
It is a reserved right ("reserves the right"), not a promise to disclose.
The qualifier is Bloomberg's own good-faith belief.
Not stated here
The text does not say whether client notice or the minimum-information effort still applies to an emergency disclosure.
The text does not say what steps Bloomberg takes to confirm the emergency.
Cross-references
narrows (model-proposed): Bloomberg will not hand over client data to agencies unless the law requires it — exception_to: The emergency reservation begins "Notwithstanding any of the foregoing" and lets Bloomberg respond to urgent requests on a good-faith belief of imminent danger of death or serious physical injury, an exception to the rule that it will not disclose client data unless the law requires it.