We at KPMG Oy Ab and KPMG Baltics OÜ (together “KPMG”), are dedicated to protecting the confidentiality and privacy of information entrusted to us. This Privacy Statement describes what personal data we collect and how we use that data and applies to all of our subsidiaries and affiliates.

This Privacy Statement applies to processing of personal data provided or collected in connection with our business operations, including personal data we may receive in the course of providing professional services. In some cases, we may provide additional Privacy Notices specific to certain products such as technology tools. Those terms are to be read in conjunction with this statement.

Our contact details

KPMG Finland

Address: Töölönlahdenkatu 3, 00100 Helsinki

Telephone: +358 20 760 3000

Email: privacy@kpmg.fi

 

KPMG Estonia

Address: Ahtri 4, 10151 Tallinn

Telephone: +372 6 26 87 00

Email: dpo@kpmg.ee

Our data processing activities

What personal data do we process and for what purposes?

Personal data related to our professional relationships and potential clients

• We process personal data to maintain our business relationship with our clients throughout this relationship and to provide professional services to them. This includes data processing for purposes such as responding to client requests or queries, seeking feedback, maintaining contact with our clients and keeping them informed of our services, industry developments, and events. We may also use this data to further develop our professional relationships and our service offerings.

o Categories of personal data we process for this purpose include e.g.

• Personal information such as name, position, and name of the employer.
• Contact details such as address, phone number and e-mail address.
• Data related to our professional relationship with clients, such as data concerning the services we have provided to clients or feedback our clients might have provided to us.

o  We mainly collect this data directly from our clients. In some cases, we also collect personal data from third parties such as the local Trade Register or other external databases.

Personal data related to our business or client engagements

• When providing our services to clients, we often obtain personal data. The data we process varies depending on the nature of the service we provide. We ask our clients only to share personal data with us when it’s necessary for the provision of our services.

o We provide a variety of services and therefore the nature of the data we collect in the course of providing our services varies. Categories of personal data we process for this purpose might include e.g.

• Personal details such as name, date of birth, nationality and country of residence and other personal details relevant to the particular service.
• Contact details such as address, phone number and email address.
• Employment details such as data on position, role, performance and experience, and other data related to one's employment.
• Financial details such as payroll data, income, benefits, investments and other financial interests, tax status and other details related to one's financial situation.
• Other data necessary for performing our services. Some of our services might involve processing of special category data, such as data related to trade union membership, data related to accessing or financing medical treatment, or tax data indicating an affiliation with a religious community. We only process this data when it’s strictly necessary and related to the service we’re performing.

o The majority of personal data we process for these purposes is supplied by our clients or by third party sources at the request of our clients. In the context of providing professional services to our clients, we may also process personal data of individuals with whom we do not have a direct relationship, such as employees, customers or suppliers of our clients.

Personal data related to the use of our website, newsletters and other communications

•  We process personal data to ensure the performance, functionality and security of our website. Please see the section Online Tracking Technologies for further information, including how to disable cookies and otherwise make choices with respect to such data collection.
• We also use third-party marketing automation providers. These industry standard technologies and practices enable us to gather statistics around email opening and clicks to better understand our service offerings meet our stakeholders’ needs

Personal data we process for operating and managing our business operations

• We process personal data when engaging service providers, other KPMG member firms, contractors or suppliers relating to the operation of our business. This data typically includes personal and contact details as well as data related to our business relationship. In most cases, we receive this data directly from the member firm, contractor or supplier.
• We also process personal data of visitors to our offices and premises. Visitor data is used to control access to our buildings as well as to protect the staff and information in our offices. We may require visitors to sign in at the reception. Some of our offices use CCTV monitoring.
• We process personal data of visitors to our events. We may request voluntary information about dietary requirements in order to cater to your needs when attending our events.

Personal data we process for administrative purposes

• We may also use personal data for administrative purposes such as accounting and tax purposes, as well as to fulfill our statutory duties and meet our other professional requirements.

o This includes processing that is necessary to comply with professional, legal and regulatory obligations that apply to our business, such as auditor independence or anti-money laundering requirements. For example, we process identification and background information as a part of our client acceptance and administration processes, and we request this data directly from our clients or collect the data from sources such as the local Trade Register or other external databases.

o We also process personal data for purposes related to invoicing, billing and financial administration. The data we process for this purpose typically includes contact details and financial information such as payment-related information.

o We may also process personal data to establish, exercise or defend legal rights, or for handling queries by supervisory authorities.

 

Our legal grounds for processing personal data

When processing personal data, we will rely on one of the following processing conditions:
 

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

Legal obligation: this is when we are required to process 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 personal information where it is in our legitimate interest in running a lawful business to do so, as long as the processing is compatible with your rights and interests. Our legitimate interests relate to processing personal data e.g.

o To offer information and/or services to individuals who visit our website.

o To prevent fraud or criminal activity and to safeguard our IT systems.

o To customize individual’s online experience and improve the performance usability and effectiveness of KPMG’s online presence.

o To conduct and to analyze, our marketing activities.

o To meet our corporate and social responsibility obligations.

o To assess any conflict of interest or challenge with regard to independence legislation or other professional standard.

Consent: in some cases, we will ask the data subjects for a specific permission to process personal information, and we will only process this personal information in this way if they agree to us doing so. A data subject may withdraw their consent at any time by contacting KPMG Finland at privacy@kpmg.fi and KPMG Estonia at dpo@kpmg.ee.

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 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.

Sharing personal data with third parties

We will not share personal data with a third party outside the KPMG network, except in limited circumstances.

Transfers within the KPMG network

We share personal data 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.

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. This includes:

Our service providers: in some cases our third party service providers, such as our (IT) systems providers, hosting providers, payroll providers, consultants (such as legal advisers) and other goods and services providers may process personal data on our behalf. KPMG will only transfer personal information to our service providers when they meet our strict privacy and information security standards. We only share personal information that is necessary for them to provide their services.

If we are reorganized or sold to another organization: in the event of a sale, assignment, or other transfer of any element of KPMG’s business, it may be necessary for us to disclose related personal information.

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 protection 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. Some of these insurance market participants (e.g. brokers, insurers and reinsurers, as well as their professional advisors and other third parties involved should there be a claim) will require that we disclose personal data to them. The information will be used by the insurance market participants in the underwriting and ongoing administration of the insurance programme. Some of our insurers process this data on our behalf, but others process personal data independent of us.

Data transfers, storage, and processing globally

KPMG may transfer certain personal information outside of the EEA to outside 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 routinely send, store or otherwise process your personal information in the following locations:

·   where there is a KPMG Member Firm;

·   where our Global Data Centers are located;

·   where our IT Support Providers are located; and

·   where our other service providers are located.

If we do this, any 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 or by another transfer mechanism in compliance with applicable Data Protection Legislation.

Data retention  

We retain personal data only for as long as it is necessary for the purpose of processing. The applicable retention period for personal data is defined according to our information management policies and varies depending on the processing activity, taking into account any applicable legal requirements and professional standards that may apply to us or our clients. 

We evaluate the applicable retention periods regularly. The data will be either erased or anonymized after the expiration of applicable retention period.

 

Your choice

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.

For preventing cookies tracking you, see section “Cookies” below.

Your rights

If we process personal information about you, you have the following rights:

 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 privacy@kpmg.fi 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.

Finally, you always have the right to lodge a complaint with the regulator in charge of protecting personal information, the national supervisory authority.

Use of online tracking technologies

Online identifiers: IP address, cookies, login information, browser type and version, time zone setting, geolocation information, operating system and version

Use of our website: URL clickstreams (the path you take through our site), services viewed, how long you stay on our pages, how you interact with our website

Third party social media add-ons: If you choose to register or login to a KPMG website 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.

Marketing automation: KPMG and its service providers use cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of KPMG's online presence, and to measure the effectiveness of our marketing activities.

IP addresses: An IP address is a number assigned to computer whenever accessing the internet. It allows computers and servers to recognize 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 website trend and performance analysis.

Cookies: Cookies may be placed on computer or internet-enabled device whenever visiting us online, if you give us your consent on the usage of cookies and the processing of your personal data. Cookies allow the site to remember your computer or device and serves a number of purposes.

On our website, a notification banner will appear requiring your consent to collect cookies. If consent is not provided, 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. The 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).	Session Deleted upon closing the browser
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.	Session Deleted upon closing the browser
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 and may also be used to provide targeted communication, marketing and content creation. 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.	1 Session Deleted upon closing the browser 2 Persistent 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. For further details on our use of social media widgets and applications, see below.	Persistent, but will be deleted automatically after two years if you no longer visit kpmg.com

Other third-party tools and widgets will be used on our individual web pages from time to time to provide additional functionality. Use of these tools or widgets will typically place a cookie on the device to make their service easier to use, and ensure interaction is displayed on our webpages properly.
 

Cookies by themselves do not tell us email address or otherwise identify visitors personally. In our analytical reports, we will 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.

Analytics Tools

KPMG uses analytics tools, such as Adobe Analytics. More information about how Adobe Analytics is used by KPMG can be found here: https://experienceleague.adobe.com/docs/analytics/technotes/privacy-overview.html

When you visit our website, marketing automation cookies are placed in your browser. They help identify you as a website visitor according to your specific browser and computer combination, and you are remembered in the event that you return to our website. If the user identifies themself by volunteering personal data, e.g. by filling in a contact form or clicking on links in an e-mail the cookie's unique user ID is linked to the personal data volunteered by the user. We may use the information provided by visitors during online visits in order to tailor the content or make suggestions of similar items one may be interested in.

Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from 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 websites 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.

Location based tools

KPMG may collect and use the geographical area of one’s computer or mobile device. This location data is collected for the purpose of providing information regarding services which we believe may be of interest to visitors based on the geographic location, and to improve our location-based products and services.

Social media widgets and applications

KPMG websites 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 may collect and use information regarding your use of KPMG websites (see details on 'Social Sharing' cookies above). Any personal data that you provide via such social media applications may 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 websites 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 data that you provide on any KPMG social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

Questions or comments about KPMG’s cookies activities can be addressed to privacy@kpmg.fi for KPMG Finland and dpo@kpmg.ee for KPMG Estonia.

 

Links to other sites

Please be aware that KPMG websites will typically contain links to other sites, including sites maintained by other KPMG 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 website and then navigating to another KPMG website while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the KPMG website you are visiting.

 

Data Security

 

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.

 

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.

KPMG Oy Ab is a Finnish and KPMG Baltics OÜ is an Estonian limited liability company and a member firm of the KPMG network of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee which provide no client services.