If you would like to exercise your rights under Law No. 133 as of 08.07.2011 on the protection of personal data, or if you have comments, questions or concerns, or if you would like to submit a complaint regarding the collection and use of your personal data, please feel free to contact the data controller:

“KPMG Moldova” LLC (hereinafter referred to as ”KPMG”), which is a data controller on the territory of the Republic of Moldova, with registered address in Chisinau, Stefan cel Mare si Sfant blv. 171/1, Republic of Moldova, company registration number 37019804, VAT number 0204495.

Email: ro-mdprivacy@kpmg.com .

Tel: +373 22 580 580.

Introduction

KPMG is dedicated to protecting the confidentiality and privacy of information entrusted to it, to ensure an adequate level of protection of personal data but also to establish requirements regarding the cross-border transmission of personal data. As part of this fundamental obligation, KPMG is committed to the appropriate protection and use of personal information (hereinafter referred to as “personal data”,) 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 data that we have obtained.

1. Collection and use of personal information

1.1. What information we collect

We collect 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 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. 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 data 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. If you send us a resume or curriculum vitae (CV) to apply online for a position within 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).

On our website we may collect the following personal data:

• Name, surname;
• Email address;
• Role within the Company/Organization;
• Location (country);
• Phone number;
• Cookies (as described below).

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.

The law allows us to process personal information, as long as we have a legal ground 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 for the realization of a legitimate interest of KPMG or of the third party to whom the personal data are disclosed, provided that this interest does not prejudice your interests or your fundamental rights and freedoms.

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 ro-mdprivacy@kpmg.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 prevent fraud or criminal activity and to safeguard our IT systems.
• To customize the 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, including our freedom to conduct a business and right to property.

may and with prior compliance with all the procedures provided by law.

1.3. Automatic collection of personal information

In some instances, 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.

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 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 will also typically be used in aggregate form to conduct web site trend and performance analysis.

1.3.2. Cookies

A cookie is a small text file that a website stores on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

• First-party cookies are cookies set by the website you’re visiting. Only that website can read them. In addition, a website might potentially use external services, which also set their own cookies, known as third-party cookies.
• Persistent cookies are cookies that are saved on your computer and are not deleted automatically when you quit your browser, unlike a session cookie, which is deleted when you quit your browser.

Cookies can also be used to establish anonymised statistics about the browsing experience on our sites.

Cookies may 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, except for the Persistent cookies mentioned below in the table. 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, their description and expiry term:

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. The aggregated statistical data covers items such as total visits or page views, and referrers to our web sites. For further details on our use of Google Analytics, see below.	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 on our 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 may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may typically 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

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

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 will 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 will 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 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 may 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 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 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 may 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.

1.5. Children

KPMG understands the importance of protecting children's privacy, especially in an online environment. In particular, our websites are not intentionally designed for or directed at children under the age of 18.

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 outside of the Republic of Moldova or 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 Republic of Moldova. We typically send personal information to the countries listed in this link. If we do this, your personal information will continue to be protected by means of contracts we have in place with those organizations.

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 KPMG may require you to provide certain personal information in order to receive additional information about our services and events. KPMG may 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" section 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.

4. Data retention

Considering the provisions of the legislation on knowing the clientele, the prevention of money laundering and the financing of terrorism, the provisions of the accounting law on the preservation of the supporting documents that are the basis of the records in the financial accounting and the need to defend/preserve rights in the context of a possible litigation, we will be able to retain personal data for a period of up to 10 years from the moment of termination of business relations or from the moment of the last occasional transaction. The images or recordings obtained through the internal monitoring and video surveillance system are kept for a maximum period of 30 days, except for situations expressly regulated by law or thoroughly justified cases. Personal data regarding the correspondence between us and the client will be stored for a period of up to 10 years from the moment of termination of business relations or from the moment of the last occasional transaction.

The technical data concerning website visitors will be stored for a period from 1 day to 90 days from the moment of their registration, unless the law provides otherwise.

Data regarding candidates who have submitted CVs or job applications will be kept until the goal is achieved (competition), and if there is no other legal basis for storage, they will be kept for a period of 6 months , and regarding the employees' personal data, they will be stored for the entire period of existence of the employment relationship, after which they will be kept in the form of an archive document for the period established by the Indicator of standard documents and their retention periods for the bodies public administration, for the institutions, organizations and enterprises of the Republic of Moldova, approved by the State Archive Service no. 57 of 27.07.2016).

5. Your rights

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

• Access: You have the right to obtain from KPMG, upon request, without delay and free of charge: a) confirmation that the data are or are not processed KPMG, as well as information regarding the purposes of the processing, the categories of data considered and the recipients or categories of recipients to whom the data are disclosed; b) the communication, in an intelligible form and in a way that does not require additional equipment, of the personal data that are the object of the processing, as well as of any available information regarding the origin of these data; c) information on the principles of operation of the mechanism through which the automated processing of Your personal data is carried out; d) information on the legal consequences generated by the processing of personal data for You; e) information on how to exercise the right to intervene (Correction) on personal data.
  
  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;

• Correction: you have the right to request from KPMG: a) the rectification, updating, blocking or deletion of Your personal data whose (and if) processing contravenes to the law, in particular due to the incomplete or inaccurate nature of the data; and to notify third parties to whom personal data have been disclosed about the operations carried out according to letter a), except in cases where such notification proves impossible or involves a disproportionate effort to the legitimate interest that could be harmed;
• 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, right of access to justice.

You can make a request or exercise these rights by contacting KPMG at ro-mdprivacy@kpmg.com 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.

6. 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.

In order to protect your data, we have adopted technical and organizational measures, especially against loss, tampering or unauthorized access. The measures adopted are regularly verified and are adapted constantly in accordance with the latest applicable technical standards.

7. 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.

8. 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. 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.

Section 8. Policy questions and enforcement

KPMG is committed to protecting the privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at ro-mdprivacy@kpmg.com. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

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 will acknowledge your email within 14 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 first being 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. You may also lodge a complaint with the local Data Protection Authority at the following contact details:

The National Center for the Protection of Personal Data:
MD-2004, Republic of Moldova, Chisinau City, Serghei Lazo Street, 48,
Post Code 2004, Chisinau, Republic of Moldova
Email: centru@datepersonale.md,
Telephone number: +373 22 820801
Website https://datepersonale.md/en/