Privacy

Privacy

KPMG Privacy Statement

The Policy was last updated on 26 January 2022

KPMG1 is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, KPMG is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, "personally identifiable information" or "PII") that has been collected online.

Generally, our intent is to process only the personal information that is provided voluntarily by online visitors so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this privacy statement ("Privacy Statement") to learn more about how we process, including how we collect, use, transfer  and protect the personal information that we have obtained.

1. Collection and use of personal information

   1.1 What information we collect

   1.2 The legal grounds we have to use your personal information

   1.3 Information required for marketing activities

   1.4 Personal data processing and protection policy

   1.5 Cookies

   1.6 Children

2. Sharing and transfer of personal information

2.1 Transfer within the network of KPMG firms

2.2 Transfers to third parties

3. Choices

4. Your rights

5. Data security and integrity

6. Links to other sites

7. Changes to this statement

8. Policy questions and enforcement

 

1. Collection and use of personal information

1.1 What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your personal information to KPMG (if, for example, you are a former employee). If you choose to register or login to a KPMG web site using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with KPMG, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

When you register or submit personal information to KPMG together with your consent we will use this information in the manner outlined in this Privacy Statement and applicable Personal data processing and protection policy. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a KPMG web site and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other KPMG sites you visit. For example, if you send us an email message requesting information about KPMG, we will use your email address and other information you supply to respond to your request. If you send us a resume or curriculum vitae (CV) to apply online for a position with KPMG, we will use the information that you provide to match you with available KPMG job opportunities.

In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

1.2 The legal grounds we have to use your personal information

KPMG generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

To comply with the applicable legislation allowing us to process personal information so long as we have ground under the law to do so, when we process your personal information, we will rely at least on one of the following processing conditions:

• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;

• Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;

• Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time and exercise other rights as provided by law by contacting KPMG at dataprivacy@kpmg.ru outlining the purpose for which your contacts have been provided to us.

• The right provided by applicable legislation: we have the right to process your personal data without your consent or additional grounds once such a right is expressly provided for by applicable law.

We would request your consent when you contact us via our websites or by email unless we have other legal grounds to process your personal data under applicable law:

When you submit a request for the provision of services your consent is necessary for the following purposes:

• To offer information and/or services to individuals who visit our websites;

• To customize individual’s online experience and improve the performance usability and effectiveness of KPMG's online presence;

• To conduct, and to analyze, our marketing activities;

• To meet our corporate and social responsibility obligations;

• To transfer personal data between other member firms of the KPMG network for internal administrative purposes as indicated in clause 2.1.

When contacting KPMG to request information regarding employment opportunities your consent is required for the following purposes:

• To get information on current job opportunities and KPMG talent pool;

• To verify the information provided by you for employment purposes at KPMG;

• To communicate with you on issues related to employment at KPMG;

• To customize individual’s online experience and improve the performance usability and effectiveness of KPMG's online presence;

• To conduct, and to analyze, our marketing activities;

• To meet our corporate and social responsibility obligations;

• To transfer personal data between other member firms of the KPMG network for internal administrative purposes as indicated in clause 2.1.

When contacting KPMG with a request for the purposes of obtaining other information or submitting other request to KPMG, not described above, your consent will be required for the following purposes:

• To provide information to persons submitting  a request to KPMG;

• To customize individual’s online experience and improve the performance usability and effectiveness of KPMG's online presence;

• To conduct, and to analyze, our marketing activities;

• To meet our corporate and social responsibility obligations;

• To transfer personal data between other member firms of the KPMG network for internal administrative purposes as indicated in clause 2.1.

We need your consent to process the personal data provided by you within the term required to achieve the respective goals or until withdrawal of your consent depending on what comes earlier.

By submitting your request you agree to the processing of personal data contained in your request in accordance with this Privacy Statement and Personal data processing and protection policy.

1.3  Information required for marketing activities

For promoting our services we develop various marketing activities: organize events (including webinars), publish content on topics of interest, send newsletters about our services, events and publications to the (potential) clients and persons related to them as well to the visitors to our events. We aim at making the information you receive up–to–date and corresponding to your interests. In order to achieve this we may require your personal information (full name, email address, place of work, job position, other contact information).

When you provide your personal information to KPMG or when you act as a contact person for communication with KPMG, e. g. during rendering the services under a contract, we may include information about you in our (potential) client relationship management system (hereinafter “CRM”) for confirming our business relations as well as for sending you invitations to complete a survey about the quality of the services we have rendered. The access to the information contained in CRM is limited to our authorized employees who need this information for maintaining business communication with KPMG clients (including potential clients). In certain cases (e. g. collaboration on international projects) such employees may also include the employees of KPMG member firms located in other countries of the CIS region, Georgia or Ukraine.

For collecting your personal information we may use the services administrated by the third parties (e.g. online registration platforms or websites for holding webinars). The relevant suppliers process personal information in accordance with their own policies and we are not responsible for the confidentiality or the information you provide to such platforms. To get more detailed information we recommend that you study the policies of the abovementioned service providers before submitting the data collection forms.

1.4 Personal data processing and protection policy

Personal data processing and protection policy developed in compliance with applicable laws of the Republic of Belarus on protection of personal data and constitutes an internal regulatory document of KPMG LLC (the Republic of Belarus, 220012, Minsk, Platonova str., 49, office 26-7), KPMG Advisory FLLC (the Republic of Belarus, 220012, Minsk, Platonova str., 49, office 26-4), KPMG Technology LLC (the Republic of Belarus, 220012, Minsk, Platonova str., 49, office 26-28). Each of these companies is separately an independent controller of personal data, which receives your consent to the processing of personal data taking into account the requirements of the legislation of the Republic of Belarus.

1.5 Cookies

Our websites may use cookies. Where cookies are used, a statement will be sent to your browser explaining the use of cookies. To learn more, please refer to our Cookies Notice.

1.6 Children

KPMG understands the importance of protecting children's privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.

2. Sharing and transfer of personal information

2.1 Transfer within the network of KPMG firms

We share information about you with other member firms of the KPMG network as part of international engagements, and with KPMG International and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the KPMG network are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run KPMG’s business.

2.2 Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. For more information on such third parties, please see this link.

In addition, KPMG will transfer certain personal information across geographical borders to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. KPMG will also typically store personal information outside of the EEA. We typically send personal information to the following countries. If we do this, your personal information will continue to be protected by means of contracts we have in place with those organizations. Where applicable, outside the EEA such contracts will contain standard data protection clauses, which are in a form approved by the European Commission.

We transfer personal information outside the country if an appropriate level of protection of your rights is provided in these territories. The list of such foreign States is determined by the regulatory body. However, if the transfer of personal information is necessary to countries not included in this list, we undertake to inform you about the risks arising from the lack of an appropriate level of protection when obtaining your consent if there are no other legal grounds for the transfer of personal information to such countries.

KPMG will not transfer the personal information you provide to any third parties for their own direct marketing use.

3. Choices

In general, you are not required to submit any personal information to KPMG, but we will require you to provide certain personal information in order for you to receive additional information about our services and events. KPMG will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

As described in "Cookies" above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

If you refuse to provide us with consent to the processing of personal information when you receive a request from us, we will not be entitled to process such personal information for the requested purposes.

4. Your rights

If KPMG processes personal information about you, you have the following rights:

• Access, including obtaining information about the processing of personal data, about transfer of information to third parties, correction, alteration: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If the applicable legislation requires us to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.

• Object to processing, including withdrawal of your consent, require the termination of the processing of personal information and (or) its deletion: you have the right to object to us processing your personal information if we are not entitled to use it anymore.

• Other Rights: in addition, you have the right to appeal against our actions or omissions in relation to processing of your personal information to the relevant authority subject to applicable laws.

You can make a request or exercise these rights by contacting KPMG at dataprivacy@kpmg.ru, outlining the purpose for which your contacts have been provided to us, and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

In order to exercise your rights in accordance with applicable legislation you need to submit your request in a form of a written application at the location address of KPMG specified in clause 1.4. of this Privacy Statement or in electronic form at dataprivacy@kpmg.ru. You can revoke consent to the processing of personal information at any time during its validity by sending an application in another electronic form (other than an electronic document) to the specified address, if this consent was provided by you in the same form.

5. Data security and integrity

KPMG has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite KPMG's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also retain personal information only for so long i) as the information is necessary to comply with an individual's request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected; however, subject to requirements of i)-iii) above, personal information will not be retained longer than required according to the applicable legislation.

6. Links to other sites

Please be aware that KPMG web sites will typically contain links to other sites, including sites maintained by other KPMG member firms that are not governed by this Privacy Statement but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each Web site visited before disclosing any personal information.

By registering on any KPMG web site and then navigating to another KPMG web site while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the KPMG web site you are visiting.

7. Changes to this statement

KPMG may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how KPMG is protecting your information.

8. Policy questions and enforcement

KPMG is committed to protecting the online privacy of your personal information.

If you have questions or comments about our administration of your personal information, please contact our Data Privacy Liaison at dataprivacy@kpmg.ru. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement. We will acknowledge your email within 14 days and seek to resolve your concern within one month of receipt unless other terms are provided by applicable laws. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take more time to resolve within the time limits provided by applicable laws.

If you are not satisfied with the response you receive, you may escalate your concern to the Global Privacy Officer by sending an email to GlobalPrivacyOfficer@kpmg.com. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.

In any event, you always have the right to lodge a complaint with the regulator in charge of protecting personal information in accordance with applicable laws.

 

"KPMG”, “we”, “us” and “our” refers to the global organization or to one or more of the member firms of KPMG International Limited (“KPMG International”), each of which is a separate legal entity.

KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.