Privacy

Privacy Statement

Last Revised: 18 May 2018

Privacy Statement for Deloitte Website and Services

Introduction

Privacy Statement Summary 

In Deloitte, we are committed to protect privacy of information and personal data entrusted to us. We handle private information in an open, transparent manner.

The privacy statement set below, applies to personal data processed by Deloitte Limited, registered in Cyprus under registration number 162812 with registered office address at 24 Spyrou Kyprianou Avenue, 1075 Nicosia and by Deloitte Investment Services Limited, registered in Cyprus under registration number 163314 with registered office address at 24, Spyrou Kyprianou Avenue, 1075 Nicosia.

It describes what personal data or information we gather about you, when and why we use that information for and to whom we give the information.

It demonstrates your rights in relation to your data and indicates whom you can contact for additional information or queries. 

Read more about this privacy statement by referring to the specific paragraphs below:

-       To whom this privacy statement applies to and what it covers?

-       About other areas of deloitte.com

-       What information we collect?

-       How we use information about you?

-       The legal grounds we use for processing personal information

-       Who we disclose your information to?

-       Protection of your personal information

-       How long we keep your information for?

-       Your rights

-       Right to complain

-       Changes to this privacy statement
 

To whom this privacy statement applies to and what it covers?

You can find how we will collect, handle, store and protect personal information about you when:

  • providing services to you or to our clients,
  • you use “our Website”, or,
  • we perform any other activities that form part of the operation of our business.

We may refer to information that identify or may identify you or that may otherwise relate to you as “personal data” or “personal information”. We may also sometimes collectively refer to collecting, handling, using, protecting and storing your personal information as “processing” such personal information.

When we refer to “our Website” or “this Website” in this policy, we mean the specific webpages of deloitte.com designated as Cyprus in the upper right hand corner.

Deloitte.com comprises of various global, country, regional and practice specific websites, each of which is provided by Deloitte Touche Tohmatsu Limited (“DTTL”) or one of its independent member firms or their related entities (collectively, the “Deloitte Network”). To learn more about DTTL, the member firms of DTTL and their related entities, please see About Deloitte.

Particular instances that we share your personal information with other members of the Deloitte Network and other third parties (for example, our service providers or suppliers) are described below.
 

About other areas of deloitte.com

Please note that the other country websites contained within deloitte.com are provided by other entities within the Deloitte Network and are not provided by us. Such websites, as well as other websites that may be linked to this Website, are not governed by this privacy statement. We encourage visitors to review the privacy statements on each of these other websites before disclosing any personal information.

What information do we collect and where do we collect it from?

In the course of providing services to you as a client and particularly when performing due diligence checks in connection with our services (or discussing possible services we might provide to you as a prospective client), we may collect or obtain personal data about you.  We may also collect personal data from you when you use our Website.

We may collect or obtain such data because you give them to us (for example in a form on our Website or through our “know-your-client” procedures), because other people give that data to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or because it is publicly available.

We may also collect or obtain personal data from you because we observe or infer that data about you from the way you interact with us. For example, to improve your experience when you use this Website and ensure that it is functioning effectively, we (or our service providers) may use cookies (small text files stored in a user’s browser) which may collect personal data. Additional information on how we use cookies and other tracking technologies and how you can control these can be found in our Cookie Notice.

The personal data that we collect or obtain may include without limitation: your name; age; date of birth;  ID number; e-mail address; home address; country of residence;  family circumstances (for example, your marital status and number of dependents); employment and education details (for example, the organization you work for, your job title and your education details); financial and tax-related information (for example your income and tax residency); your IP address; your browser type and language; your access times; complaint details;  and other similar information.

The personal data that we may collect may also include ‘sensitive’ or ‘special categories’ of personal data, such as details about your health (for example, in relation to life and medical insurance), ethnic or racial origin. Please note that, when the processing of sensitive personal data is not allowed by law, an explicit consent from you will be required whenever we may have to obtain sensitive personal data about you so as to provide our services.

The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you, for example as a result of legal requirements imposed on us.

Where we have no direct contractual relationship with you but obtain your personal data about you by our client, we take steps to ensure that the client has complied with the privacy laws and regulations relevant to that information; this may include, for example, that the client has provided you with the relevant information notices in relation to how your personal data will be processed and disclosed to third parties such as Deloitte and has obtained any necessary consents for us to process your personal data as described in this privacy statement and/or our engagement with the client.

We understand the importance of protecting children's privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children. For the purposes of this privacy statement, “children” are individuals under the age of eighteen.
 

How we use information about you?

Use of personal information to provide services to our clients

We will only process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

(A)        Where we need to perform the contract we have entered with you or in order to take certain steps prior to entering into a contract with you.

We will use your personal data to provide you with our services. As part of this, we may use your personal data in the course of correspondence relating to the services.  Such correspondence may be with you or other members of the Deloitte Network and our service providers or competent authorities.  We may also use your personal data to conduct due diligence checks relating to the services.

Because we provide a wide range of services to our clients, the way we use personal data in relation to our services also varies. For example, we might use personal data:

  • about a client’s employees to help those employees manage their tax affairs when working overseas,
  • when we provide risk advisory services to corporate clients,
  • when we provide investment services to clients (such as investment advice)
  • when we offer human capital services (such as payroll services),
  • about a client’s employees and customers in the course of conducting an audit (or similar activity) for a client,
  • about a client to help him/her complete and submit a tax return, or
  • when we consider applicants for employment purposes.

If you do not provide the personal data we request from you, we may not be able to offer or continue offering our services to you.

(B)        Where we need to comply with a legal obligation

We are required to comply with certain legal and regulatory obligations, as well as certain industry standards, which may involve the processing of personal data. We may, for example, need to carry out identity verifications through our “know-your-client” procedures, set-up anti-money laundering controls and comply with our tax reporting obligations. We may also need to provide information to a public body or law enforcement agency when we are so required.

(C)        Where we have appropriate legitimate interests to use your personal data

In some cases, we may process your personal data to pursue business interests of our own or of third parties, provided your interests and fundamental rights do not override such interests. More specifically, we process your personal data:

  • to maintain our accounts and records,
  • to enhance the security of our network and information systems,
  • to identify, prevent and investigate fraud and other unlawful activities,
  • to safeguard the security of our people, premises and assets and prevent trespassing through video surveillance,
  • to manage our infrastructure, business operations and comply with internal policies and procedures,
  • for financial accounting, invoicing and risk analysis purposes,
  • to modify, personalize or otherwise improve our services,
  • to defend, investigate or prosecute legal claims,
  • for recruitment and business development purposes, and
  • in order to receive professional advice from our advisors including our lawyers, accountants and consultants.

(D)       Where you have given us your consent

We will only ask for your consent when we wish to provide marketing information to you in relation to our products and/or services that we think might be of interest to you.  If you give us your consent, we may also contact you for market or research purposes from time to time.

You may withdraw your consent to such processing at any time by contacting cyprivacy@deloitte.com or by clicking on the “Unsubscribe” function in any marketing communications, including emails, that we send to you.

SENSITIVE DATA

To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either:

(i)    you have given us your explicit consent to process that data;

(ii)   the processing is necessary to carry out our obligations under employment, social security or social protection law

(iii)  the processing is necessary for the establishment, exercise or defense of legal claims or

(iv)  you have made the data manifestly public.

Use of personal information collected via our Website

In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:

  • to manage and improve our Website,
  • to tailor the content of our Website and to draw your attention to information about our products and services that may be of interest to you, for example our seminars or presentations,
  • to manage and respond to any request you submit through our Website.
     

Who we disclose your information to?

In connection with one or more of the purposes outlined in this privacy statement, we may disclose details about you to: other members of the Deloitte Network; third parties that provide services to us and/or the Deloitte Network including marketing partners such as advertising agencies; competent authorities (including courts and authorities regulating us or another member of the Deloitte Network); your employer and/or their advisers; your advisers; credit reference agencies or other organizations that help us make business decisions and mitigate the risk of potential fraud and misconduct, third parties who are involved in a potential or actual sale of all or a portion of Deloitte’s business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in this privacy statement.

Our Website may host various social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.

Please note that some of the recipients of your personal data referenced above may be based in countries outside of the European Union. In such cases, we will ensure that there are adequate measures and safeguards in place to protect your personal data that comply with our legal obligations and that direct recipients shall provide the same level of protection as within the European Union.

In addition, we may request you to provide us with your specific consent in cases of transfers to countries where no adequacy mechanism is in place.

Further details of the transfers described above and the adequate safeguards used by Deloitte in respect of such transfers (including copies of relevant agreements) are also available from us by contacting the Privacy Leader Deputy at Deloitte Limited, 22 360300 or by email at cyprivacy@deloitte.com.

We may share non-personal, de-identified and aggregated information with other members of the Deloitte Network for research and statistical purposes.
 

Protection of your personal information

We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:

  • education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
  • administrative and technical controls to restrict access to personal data on a ‘need to know’ basis;
  • technological security measures, including fire walls, encryption and anti-virus software; and
  • physical security measures, such as staff security passes to access our premises.
     

How long we keep your information for?

We will hold your personal data on our systems for the longest of the following periods:

(i) as long as is necessary for the relevant activity or services,

(ii) any retention period that is required by law,

(iii) the end of the period in which litigation or investigations might arise in respect of the services, or,

(iv) any retention period as per our Firm’s official retention policy [which can be made available upon request].
 

Your rights

You have various rights, under the Data Protection regulation, in relation to your personal data. In particular, you have a right to:

  • Receive access to your personal data. You may request to obtain from ourselves a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction [rectification] of the personal data about you which we process. This provides you with the opportunity to have any incomplete or inaccurate data we hold and process about you, completed and/or corrected.
  • Request erasure of your personal information. This right provides you with the opportunity request from us to erase personal data concerning you [known as the ‘right to be forgotten] where there is no good reason for us to continue to process it. Additionally, you also have the right to ask us to erase your data where you have exercised your right to object to processing (see Object to processing below).
  • Object to processing of your personal data, including profiling, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.

If you object to processing for direct marketing purposes, then we shall stop the processing of your personal data for such purposes.

  • Request the restriction of processing of your personal data. With this right you are able to ask us to suspend the processing of your personal data if:

-      The said data is not accurate,

-      it has been used unlawfully but you do not wish for us to delete it,

-      it is not relevant any more, but you want us to keep it for use in possible legal claims, or

-      you have already asked us to stop using your personal data but you are waiting for us to confirm if we are allowed to keep using it.

  • Request to receive a copy of your personal data in a format that is structured and commonly used and transfer such data to other organisations. You may request the transfer of your personal data directly by us to other organizations [data portability]
  • Withdraw your consent with regard to the processing of your personal data for certain purposes at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing which was based on consent before it was withdrawn or revoked by you.

To exercise any of your rights, or if you have any other questions about our use of your personal data, please send an email to cyprivacy@deloitte.com or write to us to the address below:

The Privacy Leader Deputy,

Deloitte Limited,

24 Spyros Kyprianou Avenue,

Cy-1075 Nicosia, Cyprus.

You may also use these contact details if you wish to make a complaint to us relating to your privacy.
 

Right to complain

If you are unhappy with the way we have handled your personal data or any privacy query or request that you have raised with us, you have a right to complain to the Office of the Commissioner for Personal Data Protection in Cyprus. If you would like to be directed to the Office of the Commissioner, please contact us.
 

Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

To let you know when we make changes to this privacy statement, we will amend the revision date at the top of the first page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your information.