Introduction
This Privacy Statement applies to our various audit and
assurance tools and other related online tools and mobile applications, referred to
below individually or collectively as an “Audit
Tool” or the “Audit Tools.” This
Privacy Statement describes the ways in which your personal information is
collected in connection with your use of the Audit Tools, the purposes for
which your personal information may be used, and how it may be shared.
When used in this Privacy Statement, “we,” “us,” and “our” refer to the entity within the
Deloitte Network that invited you to use an Audit Tool, and the “Deloitte Network” refers to Deloitte
Touche Tohmatsu Limited (“DTTL”), its
network of member firms, and their related entities. Please note that DTTL and
each DTTL member firm are legally separate and independent entities. To learn
more about Deloitte’s global network of member firms, please visit
www.deloitte.com/about.
In this Privacy Statement, we will refer to your information as “personal information.” We may sometimes
collectively refer to collecting, handling, storing, and protecting your
personal information as “processing”
such information.
Please note that the Audit Tools may contain links to other sites,
including, without limitation, sites maintained by entities within the Deloitte
Network, which may not be governed by this Privacy Statement. We encourage
users to review each site's privacy statement before disclosing any personal
information.
By using the Audit Tools, you are agreeing to the use of your personal
information as described in this Privacy Statement.
Information Collection
and Use
In order to get access to one or more of the Audit Tools, limited
personal information will be collected from you or the company or firm for
which you work, including your name, your company or firm name, your email
address, and your phone number. This information is used to manage your account
and verify your identity each time you log in to an Audit Tool. Your personal information
may also be used to inform you about project-related tasks, upcoming deadlines,
releases, and scheduled upcoming changes to the Audit Tools’ services and to
respond to your inquiries and requests.
In addition to the purposes described above, we may use your personal
information in connection with applicable legal or regulatory requirements,
requests from and communications with competent authorities, and protecting our
rights and/or property and that of our users.
Additionally, to the extent permitted by applicable local laws and
regulations on data protection and data security, and subject to application of
this Privacy Statement, we may use your personal information for marketing
purposes or to send you promotional materials or communications regarding
services provided by entities within the Deloitte Network that we feel may be
of interest to you. We may also contact you to seek feedback on services
provided by entities within the Deloitte Network or for market or other
research purposes.
You may request that we discontinue sending you emails or other
communications at any time.
Use of the Audit Tools may be subject to review, monitoring, and
recording at any time to help confirm compliance with the Terms
of Use and that only authorized parties are accessing the Audit Tools using
your user login and password.
Please note that this Privacy Statement covers the personal
information that is collected in connection with your use of the Audit Tools
only. Any other information provided to us via the Audit Tools will be used in
accordance with the terms of the relevant engagement letter or the Audit Tool’s
Terms of Use, as applicable.
Legal Basis for
Information Processing
We use your personal information for the purposes outlined above
because: (a) one or more entities within the Deloitte Network have a legitimate
interest in the effective delivery of services to you or a client of an
entity/entities within the Deloitte Network; (b) one or more of the entities
within the Deloitte Network are subject to legal or regulatory obligations,
such as providing information to a public body or law enforcement agency; or
(c) the information is required in order to provide services to you or a client
of an entity/entities within the Deloitte Network.
Log Information, Cookies,
and Web Beacons
The Audit Tools collect standard internet log information, including a
user’s IP address, browser type and language, access time, and referring
website address. When using a mobile application, the Audit Tools may also
automatically collect information relating to a user’s device, mobile network,
and the version of the application being used.
The Audit Tools use cookies (small text files stored on a user’s device)
to identify users when they connect to an Audit Tool. If an Audit Tool uses
cookies, a user’s browser must be enabled to allow cookies in order to access
that Audit Tool. Upon successful login, cookies are created and placed on the
user’s computer or device. In addition to information related to
authentication, information may be stored in the cookies in order to direct a
user to the correct site location. To ensure that the Audit Tools are well
managed and to facilitate improved navigation, we or our service providers may
also use cookies or web beacons (electronic images that allow a website to
count visitors who have accessed a particular page and access certain cookies)
to collect aggregate data.
Most browsers can be set to inform you when a cookie has been sent to
you and provide you with the opportunity to reject that cookie. However,
refusing a cookie may, in some cases, preclude you from using or negatively
impact the display or function of the Audit Tools or some of their areas or
features.
By using any of the Audit Tools, you agree that cookies can be placed
on your computer or device.
Please note that we also use analytics services provided by Adobe. You
may, however, opt out of having your anonymized browsing activity within the
Audit Tools recorded by Adobe’s analytics cookies. To learn more about Adobe’s privacy
practices and how to opt out of their cookies, please visit https://www.adobe.com/privacy/opt-out.html.
Disclosure of Information
to Third Parties
In connection with one or more of the purposes outlined in the
“Information Collection and Use” section above, we may disclose your personal
information to:
·
other entities within the Deloitte Network;
·
third parties that provide services to one or
more entities within the Deloitte Network, such as website and system hosting,
management, and support;
·
other entities within the Deloitte Network and
other third parties as part of a corporate transaction, such as a divesture,
reorganization, merger, or acquisition; and
·
competent authorities, including courts and
authorities regulating one or more entities within the Deloitte Network, in
each case to comply with legal or regulatory obligations or requests.
Please note that the Audit Tools are hosted in, and/or supported by
people located in, the United States, the Netherlands, Ireland, Singapore, Hong
Kong, and Malaysia. Additionally, some of the recipients of your personal
information referenced above may be based in countries or regions outside of
your home jurisdiction. Accordingly, any personal information that is collected
in connection with your use of the Audit Tools may be transferred to countries
or regions without data protection rules similar to those in effect in your
home jurisdiction. In such cases, we will ensure that there are adequate
safeguards in place designed to protect your personal information.
Where the recipient is outside of the European Economic Area (“EEA”), the adequate safeguard might be
a data transfer agreement with the recipient based on standard contractual
clauses approved by the European Commission for transfers of personal
information to third countries.
Further details on the transfers described above and the adequate
safeguards used by us with respect to such transfers are available from us by
contacting your engagement team directly or webmaster services using the “Contact
us” link in the applicable Audit Tool.
We may also share non-personal, de-identified, and aggregated
information with third parties for several purposes, including data analytics,
research, submissions, thought leadership, and promotional purposes.
Information Security
We have in place reasonable commercial standards of technology and
operational security designed to protect your personal information from loss,
misuse, and unauthorized access, disclosure, alteration, and destruction.
Information
Retention
We retain your personal information as long as is necessary for the
fulfillment of the purposes identified above in the “Information Collection and
Use” section or as otherwise necessary to comply with applicable laws and
professional standards. Where your personal information is no longer necessary
or relevant for our identified purposes, we will securely dispose of your
personal information.
Your Rights
You have various rights in relation to your personal information. In
particular, you have a right to:
·
obtain confirmation that we are processing your
personal information, and request a copy of the personal information we hold
about you; and
·
ask that we update the personal information we
hold about you, or correct such information that you think is inaccurate or
incomplete.
Depending on the jurisdiction in which you are located, you may also
have the right to:
·
ask that we delete the personal information that
we hold about you, or restrict the way in which we use such information; and
·
object to our processing of your personal
information.
If you are interested in exercising any of the abovementioned rights
or would like to raise a question about our use of your personal information,
please contact your engagement team directly or webmaster services using the “Contact
us” link in the applicable Audit Tool.
You may also use the above contact methods if you wish to make a
complaint relating to your personal information or privacy.
If you are located in the EEA and are unsatisfied with the way in
which we have handled your personal information or any privacy query or request
that you have raised to us, you may have a right to complain to the applicable Data
Protection Authority (“DPA”). For
additional information, or to be directed to the appropriate DPA, please
contact your engagement team directly or webmaster services using the “Contact
us” link in the applicable Audit Tool.
Special Notices to
California Residents
In response to California law, if you are a California resident, you
are entitled to request information concerning whether your personal
information has been disclosed to nonaffiliated third parties for their direct
marketing purposes. We do not share your personal information with
nonaffiliated third parties for such purposes.
Do Not Track
Preference
"Do Not Track" is a preference you can set in your browser
to let the websites you visit know that you do not want them collecting
information about you. The Audit Tools do not currently respond to a "Do
Not Track" or similar signal. We do not engage in the collection of
personal information about your online activities across third-party websites
or online services, and we do not allow third parties to collect such personal
information when you use the Audit Tools.
Changes to this Privacy
Statement
We may modify or amend this Privacy Statement from time to time at our
discretion. When we make changes to this Privacy Statement, we will amend the
revision date at the top of this page, and such modified or amended privacy statement
shall be effective as to you and your personal information as of that revision
date. We encourage you to review this Privacy Statement periodically to be
informed about how we are protecting your personal information.
Questions
If you have any questions or concerns regarding your personal
information or privacy while using the Audit Tools, please contact your
engagement team directly or webmaster services using the “Contact us” link in the
applicable Audit Tool.
English Version
This Privacy Statement was written in English (U.S.). To the extent
any translated version of this Privacy Statement conflicts with the English
version, the English version controls.