Privacy Statement

In the course of providing services to you or our clients and performing due diligence checks in connection with our services (or discussing possible services we might provide), we will 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 it to us (for example in a form on our Website, where you sign up for events, newsletters or submit any request)
• 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 or others. For example, to improve your experience when you use our 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) and Web beacons 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:

• your name; age; date of birth; gender;
• your contact information, such as your address and contact details (including email and mobile telephone number);
• country of residence; family circumstances (for example, your marital status and dependents);
• employment and education details (for example, the organization you work for, your job title and your education details);
• government identifiers (from passport, driver licence or national ID) ; financial and tax-related information (for example your income and tax residency);
• your postings on any blogs, forums, wikis and any other social media applications and services that we provide;
• your IP address; your browser type and language; your access times; details of how you use our products and services; details of how you like to interact with us and other similar information;
• information we collect when you access our premises; and any complaint details.

The personal data we collect may also include so called ‘sensitive’ or ‘special categories’ of personal data, such as details about your: dietary requirements (for example, where Deloitte would like to provide you with lunch during a meeting), health (for example, so that we can make reasonable accommodations for you in our buildings, products and services) and sexual orientation (for example if you provide us with details of your spouse or partner).

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 our client, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.

Where we are provided with personal data about you by our client or another third party, we take steps to ensure that they have complied with the privacy laws and regulations relevant to that information. This may include, for example, that the client or other third party has informed you of the processing, and has obtained any necessary permission for us to process that information as described in this privacy statement.

Use of personal information to provide services to our clients

We will use your personal data to provide you or our client with the requested services. As part of this, we may also use your personal data in the course of correspondence relating to the services. Such correspondence may be with you, our client, other members of the Deloitte Network, 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
• 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 a tax return
• about a client’s employees to contact him during the performance of our services and keep them informed of the project’s progress or in order to communicate them our projects’ deliverables.

Use of personal information for other activities that form part of the operation of our business

We may also use your personal data for the purposes of, or in connection with:

• applicable legal, regulatory or professional requirements
• requests and communications from competent authorities
• client account opening and other administrative purposes
• financial accounting, invoicing and risk analysis purposes
• services we receive from our professional advisors, such as lawyers, accountants and consultants;
• investigating or preventing security incidents;
• protecting our rights and those of our clients; or
• the use of third-party data sources to help us verify and improve the information we hold about key business relationships with individuals.

We may also use your personal data regarding our client relationship management, which may involve:

• sending you thought leadership or details of our products and services that we think might be of interest to you;
• contacting you to receive feedback on services;
• contacting you for other market or research purposes; and
• sending you event invitations.

In all above cases, we give you the opportunity to decline our offers and requests at any time in our communications.

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 to provide you with a more personalised experience and draw your attention to information about our products and services that may be of interest to you e.g. events or newsletters;
• to manage and respond to any request you submit through our Website including your enrolment to a Deloitte event or any subscriptions.

In respect of the use of personal data in connection with providing services to our clients and activities relating to our business we rely on one ore more of the following lawful grounds:

• you have explicitly agreed to us processing your information for a specific reason;
• the processing is necessary to perform the agreemnt we have with you or to take steps to enter into an agreement with you;
• the processing is necessary for compliance with a legal and regulatory obligations we have such as keeping records for regulatory or tax purposes or providing information to a public body or law enforcement agency; or
• the processing is necessary for the purpose of a legitimate interest pursued by us or a third party, which might be (a) to provide our services to you or our clients and other third parties and ensure that our client engagements are well-managed;(b) to prevent fraud;(c) to protect our business intersts; (d) to ensure that complaints are investigated; (e) to evaluate, develop or improve our services or products; or (f) to keep you or our clients informed about relevant products and services and provide you with information, unless you have indicated at any time that you do not wish us to do so.

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: (a) you have given us your explicit consent to process that data; (b) we are required by law to process that data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations (or other legal obligations imposed on us); (c) the processing is necessary to carry out our obligations under employment, social security or social protection law; (d) the processing is necessary for the establishment, exercise or defence of legal claims or (e) you have made the data public.

In connection with one or more of the purposes outlined in the “How we use information about you?” section above, 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; competent authorities (including courts and authorities regulating us or another member of the Deloitte Network); your employer and/or their advisers; your advisers; organizations that help us reduce the incidence of fraud and other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “How we use information about you?” section above.

Our Website hosts various blogs, forums, wikis and other 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 Economic Area whose laws may not provide the same level of data protection. In such cases, Deloitte will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations. We may also need to disclose your personal data if required to do so by law, a regulator or during legal proceedings.

We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional purposes.

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
• physical security measures, such as staff security passes to access our premises.

Although we use appropriate security measures once we have received your personal data, the transmission of data over the internet (including by e-mail) is never completely secure. We endeavor to protect personal data, but we cannot guarantee the security of data transmitted to us or by us.

You have various rights in relation to your personal data. In particular, you have a right to:

• obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you
• ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete
• ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data
• withdraw consent to our processing of your personal data (to the extent such processing is based on consent)
• receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract)
• object to our processing of your personal data.

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

Deloitte Legal ehf. Att. Privacy
Dalvegur 30
201 Kópavogur, Iceland

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

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

When we make changes to this privacy statement, we will amend the revision date at the top of this page. The modified or amended privacy statement will apply from that date. We encourage you to review this statement periodically to remain informed about how we are protecting your information.