Privacy Statement

This privacy statement explains what personal information we gather about you, what we use that information for and who we give that information to, when we are acting as controller for these data. It also sets out your rights in relation to your personal information and who you can contact for more information or queries. Click on the links below to take you to the more detailed sections of this statement:

• Who this privacy statement applies to and what it covers?
• About other areas of our Website
• What type of information we collect?
• How we use information about you and for which legal grounds?

• Whom 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

1.1 Who this privacy statement applies to and what it covers?

This privacy statement applies to Deloitte Luxembourg. “Deloitte Luxembourg” and hereinafter “we”, “us” or “our” refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”)¹ , its network of member firms and their related entities in Luxembourg as identified here:

This privacy statement sets out how we will collect, handle, store and protect personal information when:

a. you use our Website (as defined below)

b. offering or providing our various services to you or our clients

c. performing any other activities that form part of the operation of our business, including our marketing and communication activities.

When we refer to ‘our Website’ or ‘this Website’ in this privacy statement we mean the specific webpages of deloitte.com relating to ‘Location: Luxembourg’ in the upper right hand corner, and to specific webpages with a URL commencing ‘https://www2.deloitte.com/lu/’

Deloitte.com is comprised of various global, country, regional and practice specific websites, each of which is provided by 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

If you are using our Website, this privacy statement applies to DGS as a controller of your personal information. If, however, you are reviewing this privacy statement as part of a contract, offer, proposal, newsletter or other communication in general from us, this privacy statement applies to the entity of Deloitte Luxembourg that you have a relationship with.

Deloitte Luxembourg provides various services and performs many activities that form part of the operation of our business. You can find details on our Website under the tab “Services”.

We are committed to protecting your privacy and handling your information in an open and transparent manner.

This privacy statement also contains information about the personal data we use, when and how we share your personal data with other members of the Deloitte Network and other third parties (for example, our service providers) and the way you can exercise your privacy rights.

“Personal data” or “personal information” is any information relating directly or indirectly to a living individual.

We may sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

¹ A UK private company limited by guarantee. DTTL and each of its member firms are legally separate and independent entities. DTTL (also referred to as "Deloitte Global") does not provide services to clients.

1.2 About other areas of our Website

Please note that other country and regional websites may be linked to our Website, which content is provided by other entities within the Deloitte Network and not by us. Such websites, as well as other websites that may be linked to our Website, are not governed by this privacy statement. We encourage visitors to review the privacy statements on each of these country specific or regional websites before disclosing any personal information on their dedicated pages.

1.3 What personal information we collect?

We may collect or obtain personal data directly because you give it to us (for example by completing a form on our Website or attending one of our events or by going through our recruitment process) or indirectly because other people give that data to us (for example your employer or adviser or our client in order to provide the agreed services or third party service providers that we use to help operate our business) or because it is publicly available. In case of indirect collection, we may not be the primary controller of your personal data.

We may also collect or obtain personal data from you because we observe or infer those 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) 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 categories of personal data that we may collect or obtain vary depending on the services we provide you or our clients with or how you use our Website. While limited personal data are collected through our Website (mainly contact details and technical data), various categories of personal data can be collected strictly in relation to the services we provide or the specific relationship we may have with you. Those may at times include:

• Your contact details such as your name; age; date of birth; gender; e-mail address; home or professional address; country of residence; national identifier;
• Your professional, familial and social background and relationship such as your lifestyle and social circumstances (for example, your pastimes); your marital status and members of your family); employment and education details (for example, your employer(s), your job title and your education details);
• Financial and tax-related information (including your income and tax residency, payment or bank accounts details);
• Communications and behavioural data deriving from your postings on any blogs, forums, wikis and any other social media applications and services that we provide;
• Technical data such as your IP address; your browser type and language; access logs (including access times; websites use and monitoring thereof) or data in relation of communications we send you regarding our events and services; details of how you interact with us; devices used; location data and other similar information;
• Identification and background information provided by you or collected from our clients or on their behalf, open data or public records as part of our business acceptance processes and for our ongoing risk management processes, and this information may include special categories of personal data;

• Data relating to our relationship with you or with our clients, including especially information provided to us by or on behalf of our clients or generated by us to provide services to them or for the quality review of these services and this information may include special categories of personal data;

We may also indirectly collect so called ‘sensitive’ or ‘special categories’ of personal data but this is limited to what is required to provide you or our clients with the relevant services. These sensitive data may include 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.

We will provide you or our clients with details of the specific personal data actually collected by Deloitte Luxembourg as controller, when you or our clients subscribe for our services or engage in a professional job application.

Where we are provided with personal data about you by our client, we take steps to ensure that you are informed and that our client complies with its own obligations under privacy laws and regulations relevant to that information. These steps may include, for example, that you receive from our client information on the processing of your personal data as described in this privacy statement.

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. If we need to process personal data that pertain to children, in the context of any event we might organize, you shall be informed appropriately.

1.4 How we use information about you and for which legal grounds?

1.4.1 Use of personal information to provide services to our clients

We will use your personal data to provide you or our client with our services. As part of this, we may use your personal data before or when performing an engagement (including any engagement as auditor) for:

• Provision of the agreed services as described in the agreement between our client and Deloitte Luxembourg, including
  

- Financial Advisory
- Consulting
- Audit & Assurance
- Risk Advisory
- Corporate and accounting services

• Tax Services Provision of the agreed support as described in the agreement between our service providers and Deloitte Luxembourg

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)
• about a client to help him/her complete a tax return
• to assist a client in respect of the services (such as HR support, restructuration, regulatory reporting, drafting policies,…).
  

1.4.2 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:

• our obligations to comply with applicable legal or regulatory requirements (such as anti-money laundering/know your customers obligations; tax, legal or regulatory reporting duties; our duties of employer, our professional duties as approved statutory auditors or other regulated entity);
• our obligation to address requests and communications from competent authorities as legally required;
• our legitimate interest to protect our offices, IT infrastructure and furniture (including monitoring access and use thereof);
• our duty to have a business continuity plan in place;
• the maintenance of the client’s relationship, including initial client account opening,risk assessment and client acceptance process, financial accounting, invoicing and risk analysis purposes, ongoing relationship management which may involve: (i) ongoing risk assessment, (ii) sending you thought leadership or details of our products and services that we think might be of interest to you; (iii) contacting you to receive feedback on services; and (iv) contacting you for other market or research purposes;our recruitment needs (legitimate business interest);
• our business development (for example testimonials from a client’s employee may be used as part of our recruitment and business development materials with that employee’s permission)
• services we receive from our professional advisors, such as lawyers, accountants and consultants or other service providers (such as archiving, security services, IT or printing) either to execute our contractual obligations toward you or our clients or for legitimate business interest (support or development of our business activities and membership of Deloitte network)
• protecting our rights and those of our clients or even your rights, mainly in case of complaints and (potential) litigation.

1.4.3 Use of personal information collected via our Website

In addition to the purposes connected to the operation of our business above and considering our legitimate interest (to secure, promote and develop our business activities), we may also use your personal data collected via our Website:

• to manage and improve our Website, including monitoring its use;
• 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;
• to promote our services, including sending market or regulatory updates, publications and details of events;
• to manage and respond to any request you submit through our Website.

To the extent that we receive any sensitive personal data relating to you for any of the purposes outlined above, we will do so because either (i) 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 or they have been provided in this context (when such data are on your identification documents); (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 defence of legal claims or (iv) you have made the data manifestly public.

Where we are legally required to obtain your explicit consent to provide you with certain marketing materials, we will only provide you with such marketing materials where we have obtained such consent from you.

If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function in the communication or e-mail.

1.5 Who we disclose your information to?

In connection with one or more of the purposes outlined in the “How we use information about you and for which legal grounds?” section above, we may disclose details about you to:

• other members of the Deloitte Network which may be located in jurisdictions outside the European Union;
• third parties that provide services to us and/or the Deloitte Network (such as printing or archiving providers, security companies, catering providers);
• competent authorities (including courts and authorities regulating us or another member of the Deloitte Network)to the extent legally permitted or required;
• your employer and/or their advisers in the context of the services provided to you or your employer (potentially for your own benefit);
• 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 Union whose laws may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations. Where the recipient is not a member of the Deloitte Network, 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 data to third countries or the EU/Europe privacy shield.

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 our Data Protection Officer (DPO) at DataPrivacy@deloitte.lu.

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.

1.6 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

• 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.

1.7 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.

1.8 Your rights

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 in specific circumstances provided by law and especially if there is no longer a need to process your personal data or if we no longer have a valid legal ground to process them;

• 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 and we are acting as data controller);

• object to our processing of your personal data when processed for marketing or profiling purposes or based on legitimate grounds.
  

Please note that where the provision of personal data by you or our client to Deloitte Luxembourg is a statutory or contractual obligation, failing to provide the personal data might render it impossible for Deloitte Luxemourg to provide you with those services and carry out our business activities, thus may lead to the termination of our relationship.

To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact our Date Protection Officer (DPO) at DataPrivacy@deloitte.lu

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

1.9 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 EU Data Protection Authority (“DPA”) in your jurisdiction. For Luxembourg you may contact the The National Commission for Data Protection (CNPD) otherwise if you would like to be directed to the appropriate DPA, please contact us.

1.10 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 this page and we encourage you to review our Privacy Statement to stay informed. In case of direct collection of your personal data by Deloitte Luxembourg, if we make changes that materially alter your privacy rights, we will also provide you with an ad-hoc notification of these changes, via email or other agreed communication means.