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This Privacy Statement applies to Deloitte Luxembourg as defined below (“Deloitte”, “we”, “us” or “our”).
It explains what Personal Data we gather about you, what we use those Personal Data for and who we share them with when we act as Controller.
It also sets out your rights in relation to your personal data and who you can contact for more information or queries.
If you are a job applicant, an employee or independent contractor of Deloitte, please refer to the relevant privacy statement made available to you on the Deloitte Luxembourg intranet or via adhoc communications or links for information on why and how your Personal Data is then processed by Deloitte.
Regarding specific Deloitte services, marketing events or platforms made available to you or an entity relevant to you, this Privacy Statement may be supplemented or replaced by adhoc privacy notices shared with you – directly or via an entity relevant to you -.
You may find more detailed information on how we process your Personal Data by clicking in the links below:
As used in this Privacy Statement, “Personal Data” means any information relating to you as a natural person, when you can be identified or are identifiable. Any operation performed on Personal Data, such as handling, collecting, protecting, and storing your Personal Data, is referred to as “processing”.
This Privacy Statement sets out how we will collect, handle, store and protect any Personal Data you make available to us when:
a. You use our Website (as defined below);
b. You are accessing Deloitte Luxembourg premises for any reason;
c. We are offering or providing our services to you or our clients you are related to. Deloitte Luxembourg provides various services and performs many activities that form part of the operation of our business, which you can find details on our Website under the tab “Services” or which are further detailed in the agreement between Deloitte and you or the client you are related to;
d. We are performing any other activities that form part of the operation of our business, including our marketing and communication activities (such as alumni or clients’ events).
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. It may be amended or supplemented by adhoc privacy statements specifically shared with you.
This Privacy Statement applies to Deloitte Luxembourg. “Deloitte Luxembourg” and hereinafter “we”, “us” or “our” refers to one or more entities of Deloitte Touche Tohmatsu Limited (“DTTL”)1, its network of member Firms and their related entities in Luxembourg as identified here:
If you are using our Website, this Privacy Statement applies to DGS as a controller of your Personal Data.
If, however, you are reviewing this Privacy Statement as it is 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 or the client you are related to have a relationship with.
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.
Please note that other country and regional websites may be linked to our Website, whereby the 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 countries specific or regional websites before disclosing any Personal Data on their dedicated pages.
The categories of Personal Data that we may process vary depending on the services we provide you or our clients with, how you use our Website, the Deloitte’s events you attend and whether you access Deloitte premises.
While limited Personal Data are collected through our Website (mainly contact details and technical and security 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:
We may also directly or indirectly collect so called ‘sensitive’ or ‘special categories’ of Personal Data. The special categories of personal data that we may collect include:
Please note that we do not actively collect or otherwise process sensitive information, such as your race or ethnicity, religious beliefs, sexual orientation and political opinions and we would advise you not to disclose it whenever possible. However, it is possible that such information is contained in the documents that we may have access to comply with our legal and/or regulatory obligations or perform our professional duties as mentioned in clause 1.5.2 of this Privacy Statement (eg. identification documents) or can be deducted thereof by us.
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 Personal 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 embedded in your identification documents);
ii. The processing is necessary for the establishment, exercise or defense of legal claims;
iii. You have made the Personal Data manifestly public; or
iv. You have given us your explicit consent to process that Personal Data.
When these sensitive Personal Data are transmitted to us by a third party, including you as our client, we assume that this third party can lawfull processes such Personal Data and has obtained your consent when legally required.
We may collect or obtain Personal Data directly because either:
(i) you provided it to us (for example by completing a form on our Website or attending one of our events); or
(ii) we had access to it indirectly because other people transferred that Personal 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 those data are publicly available. In case of indirect collection, we may not be the primary controller of your Personal Data.
Where we are provided with Personal Data about you indirectly, mainly by our client, it shall remain the primary responsibility of our client to take steps to ensure that you are informed and to comply 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 (or our service providers) may also collect or obtain Personal Data from you from the way you interact with our Website or with certain types of our email communications through cookies and other tracking technologies such as Web beacons. These Personal Data are processed to, for example, improve your experience when you use this Website and ensure that it is functioning effectively.
We may use your Personal Data before or while performing an engagement (including any engagement as auditor) in the following cases:
We may specifically use Personal Data:
We will use your Personal Data because (a) of our legitimate interests in the effective provision of the services to you or our client to which you relate; or (b) of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests.
We may also use your Personal Data for the purposes of, or in connection with:
We may use your Personal Data based on our legal obligation and, in certain circumstances, on our legitimate interest to:
This may lead us to:
For more information on how we process your personal data in the context of the operation of a video surveillance system (CCTV) in our premises, you can request our Video-surveillance Policy by email to our Privacy Team (Section 12 of this page).
We may also use your Personal Data based on our legitimate interest for the purposes of, or in connection with:
Deloitte may send you marketing materials when obtained your explicit consent to do so or through Deloitte’s legitimate interest duly assessed and when not overriding your rights and freedom. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function when included in the communication or reply to the e-mail you received.
In addition to the purposes connected to the operation of our business referred to 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 or via our social media pages on Facebook, LinkedIn and other networks (“our Social Media Applications”):
Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store Personal Data about children. If we need to process Personal Data that pertain to children, in the context of any event or activity we might organize or service we may offer, you shall be informed appropriately.
In addition to the purposes referred to above and given our legitimate interest to communicate about Deloitte or Deloitte activities, we may collect and use your personal data, including photos and videos containing your image or likeness, in the context of events, trainings or other activities (co-)organized or sponsored by us.
Photos taken and/or video recording (or extracts thereof) may be shared internally (on our Intranet) or with the Deloitte Network, published online (including on our Website, Deloitte social media applications or third-party websites), in the press or in any other publications released by Deloitte Luxembourg or broadcasted live, for the above-mentioned purposes.
Your registration to events (co-)organized or sponsored by Deloitte Luxembourg by default shall be interpreted as:
(1) your consent to have your pictures or audio/video recording taken;
(2) you consent to the use of these photos, audio/video recording by the various corporate media used by Deloitte Luxembourg to promote its business activities and support its corporate culture;
(3) you consent to sharing your registration details with the co-organizer indicated in the event invitation for the organization of, and follow-up on, the events.
If you disagree to the use of your or their photos, please notify in advance the contact person indicated as organizer of the event. You can also take some personal measures such as avoiding being in the field of any camera or using the features generally offered by the platforms selected to support the event to prevent your data to be video or audio recorded.
Please note that you may at any time withdrawn your consent to one or the other processing above detailed by contacting our Privacy Team (Section 12 of this page).
In connection with one or more of the purposes outlined in the “How we use Personal Data about you and for which legal grounds” section above, we may disclose details about you to:
More details may be available in the contracts between Deloitte and you and/or the client or provider you are related to, the events’ invitations or adhoc privacy notice made available to you. Alternatively, you may contact our Privacy Team (Section 12 of this page) for specific information relating to specific purposes.
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.
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 Data 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. We strongly advise you to read Social Media Applications privacy statements.
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.
Further details of the transfers described above and the adequate safeguards used by Deloitte in respect of such transfers are also available from us by contacting our Privacy Team (Section 12 of this page).
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:
Although we use appropriate security measures once we have received your Personal Data, the processing of data over the internet (including by e-mail) is never completely secure. We endeavor to protect your Personal Data, but we cannot guarantee the complete security of data transmitted to us and processed by us over the Internet.
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.
For example, we shall hold
More details may be available in the contracts between Deloitte and you and/or the client or provider you are related to, the events’ invitations or specific privacy notice made available to you. Alternatively, you may contact our Privacy Team (Section 12 of this page) for specific information relating to specific purposes.
As a Data Subject, you can contact us to exercise your following rights when Deloitte acts as a controller of your Personal Data:
Please note that where the provision of Personal Data by you or our client to Deloitte Luxembourg is a statutory or contractual obligation, failure to provide the Personal Data might render it impossible for Deloitte Luxembourg to provide you with those services and carry out our business activities, therefore it may lead to the termination of our relationship.
We also reinforce that your right of access is limited to your Personal Data and rights hold by other persons will need to be taken into account when reverting to you.
Deloitte Luxembourg shall be your contact for the exercise of your rights when it acts as data controller. In cases where Deloitte Luxembourg is acting as data processor, we will either (i) recommend that you contact the controller of your Personal Data; or (ii) redirect your request to the controller 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 contact our Privacy Team (Section 12 of this page).
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.
You can contact Deloitte Luxembourg at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg or through our Website via “Contact us”.
For questions, complaints or any kind of communication regarding this Privacy Statement and privacy and data protection matters within Deloitte Luxembourg you may contact our Privacy Team at DataPrivacy@deloitte.lu.
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.