Last updated 29 May, 2018
KPMG Baltics, UAB (address: Konstitucijos pr. 29, LT-08105 Vilnius, e-mail: firstname.lastname@example.org) (hereinafter - KPMG) as controller of personal data 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 collect 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 collect, use, share 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 Automatic collection of personal information
- 1.4 Social media widgets and applications
- 1.5 Children
- 1.6 Direct marketing
- 2. Sharing and transfer of PII
- 2.1 Transfer within the network of KPMG firms
- 2.2 Transfers to third parties and third countries
- 3. Choices
- 4. Access
- 5. Data security and integrity
- 6. Links to other sites
- 7. Changes to this statement
- 8. Policy questions and enforcement
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 will 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 will 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 we will use this information in the manner outlined in this privacy statement. 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. 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).
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.
The law allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely 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;
• Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
• 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 by contacting KPMG at email@example.com
Examples of the ‘legitimate interests’ referred to above are:
• To offer information and/or services to individuals who visit our website or offer information about employment opportunities.
• To address questions, inquired submitted by our web page.
• To prevent fraud or criminal activity and to safeguard our IT systems.
• 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 exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.
In some cases, the personal data that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.
1.3.1 IP addresses
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
Cookies will typically be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.
On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will
be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies.
Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features.
Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.
Below is a list of the types of cookies used on our web sites:
|Purpose||Description||Type & Expiry|
|Performance (i.e., User's Browser)
||Our web sites are built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content).||
Deleted upon closing the
|Security (e.g. Asp .NET) Cookies
||If you register for access to a restricted area, our cookies ensure that your device is logged for the duration of your visit. You will need your username and password to access the restricted areas.||Session
Deleted upon closing the browser
|Site Preferences||Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account.||
Deleted upon closing the
|Analytical||We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on kpmg.com for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites.||Persistent, but will delete automatically after two years if you no longer visit kpmg.com
|Site visitor feedback||We use a third party survey tool to invite a percentage of visitors to provide their feedback. Cookies are used to prevent visitors from being invited multiple times.
The first cookie (1) is set if the visitor is not invited to participate in the survey, and is used to ensure visitors are not invited after their first page view.
The second cookie (2) is set if the visitor is invited to participate in the survey, and is used to ensure the visitor is not invited again to participate for a period of 90 days.
Deleted upon closing the browser
Deleted automatically after 90 days or presenting survey invite.
|Social sharing||We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider's privacy information before using any such service.||Persistent, but will be deleted automatically after two years if you no longer visit kpmg.com|
Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.
Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.
BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.
1.3.3 Google Analytics
KPMG uses Google Analytics. More information about how Google Analytics is used by KPMG can be found here: http://www.google.com/analytics/learn/privacy.html
1.3.4 Web beacons
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. KPMG only uses web beacons in accordance with applicable laws.
KPMG or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.
In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
1.3.5 Location-based tools
KPMG may collect and use the geographical location of your computer or mobile device. This location data based on your request is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.
1.4 Social media widgets and applications
KPMG web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications will collect and use information regarding your use of KPMG web sites (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications will often be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.
In addition, KPMG web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any KPMG social media feature will typically be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we often have limited or no control.
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 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.
1.6 Direct marketing
We process your personal data to be able to send you direct marketing information, for example, regarding:
• Seminars, conferences
• KPMG-related events
• Industry developments
|Personal data categories||Legal basis||Storage period|
- Last name
|Your consent OR legitimate
interests of KPMG to provide you with information about KPMG services, events
and significant industry developments.
For as long as you choose to receive direct marketing from us – until you withdraw your consent or raise
complaints against such processing of personal data.
You have the right to withdraw your consent at any time or object to our direct marketing e-mails in the following way:
• Press ‘Unsubscribe’ link in the footer of the e-mail received
• Contact us via firstname.lastname@example.org
After we receive your request we will discontinue sending our direct marketing e-mails to you. The withdrawal of your consent does not affect the data processing carried out during the period your consent was effective.
In our data processing activities we use the services of Mailigen SIA, which receives your personal data from us as the data processor to send you direct marketing e-mails on behalf of us.
2.1 Transfer within the network of KPMG firms
We may upon particular circumstances 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. This share is based on a legitimate interest in transmitting personal data within the group of undertakings for internal administrative purposes or this processing is necessary for compliance with a legal obligation. If we do this your personal information will continue to be protected in order to ensure that the level of protection of natural persons guaranteed by the General data protection regulation is not undermined.
2.2 Transfers to third parties and third countries
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. In addition, KPMG may upon particular circumstances transfer certain personal information outside of the EEA to companies working with us or on our behalf for the purposes described in this Privacy Statement. KPMG may also store personal information outside of the EEA. We may send personal information to the following countries where there is a KPMG Member Firm. If we do this your personal information will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission.
KPMG will not transfer the personal information you provide to any third parties for their own direct marketing use.
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.
If KPMG processes personal information about you, you have the following rights:
• Ask questions: If you have questions or comments about our administration of your personal information, please contact us at e-mail email@example.com.
• Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged 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: you have the right to object to us processing your personal information if we are not entitled to use it any more
• Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.
You can make a request or exercise these rights by contacting KPMG at firstname.lastname@example.org 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.
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 make reasonable efforts to 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. You are entitled to request information about specific storage period regarding your data by contacting KPMG at e-mail email@example.com.
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.
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. Any changes to the processing of personal data as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.
KPMG is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personally identifiable information, please contact us at firstname.lastname@example.org. 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 20 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. 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 Lithuanian regulator in charge of protecting personal information, the State Data Protection Inspectorate / Duomenų apsaugos inspekcija (https://www.ada.lt). Note: Individuals have the right to complain typically to regulators in their place of work, residency or wherever the harm happened (in the EU).
Data Transfers to Third Parties
We do not share personal information with third parties, except as necessary for our legitimate interests - legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. This may include:
• Our service providers: we transfer your personal information to our third party service providers, such as our (IT) systems providers, our hosting providers, our payroll providers, consultants (such as legal advisers) and other goods and services providers. KPMG works with such providers so they can process your personal information on our behalf. KPMG will only transfer personal information to them when they meet our strict standards on the processing of data and security. We only share personal information that allows them to provide their services.
• If we are reorganized or sold to another organization: KPMG will typically also disclose personal information in connection with the sale, assignment, or other transfer of any element of KPMG’s business to which the personal information relates.
• Courts, tribunals, law enforcement or regulatory bodies: KPMG will disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government or professional regulations.
• Audits: disclosures of personal information will also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.
• Insurers: our professional rules and our business requirements mean that we carry significant insurance cover in respect of business activities (our ‘insurance programme’). This is required to assist each member firm of the KPMG network in covering the costs associated with claims which may arise in the event that it is alleged that something has gone wrong during the course of providing services to its clients. In order to make the insurance programme work effectively, the insurance programme involves a number of different participants in the insurance market (e.g. brokers, insurers and reinsurers, as well as their professional advisors and other third parties involved should there be a claim). Some of these insurance market participants will require that we disclose personal information about you to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance programme, where there is a claim that you are relevant to and to allow the insurance market participants to comply with their legal and regulatory obligations. Some of these insurance market participants will handle this information on our behalf (like our service providers described above), but others will want to process information about you independent of us.
1 KPMG Baltics, UAB, a Lithuanian limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity.