KPMG Privacy Statement

Privacy

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") that has been received directly from you or through third parties authorized by you in electronic form or on physical media and processed by KPMG with or without the use of automation tools.

Generally, our intent is to collect only the personal information that is provided voluntarily by you so that we can offer information about KPMG (including events and job vacancies) and/or services to you or persons having civil law relations with you or for making decisions on cooperation or entering into contracts. Please review this KPMG Privacy Statement (hereinafter "KPMG Statement") to learn more about how we collect, use, share and protect the personal information that we have obtained. 

This KPMG Statement applies to the information processed via electronic resources of KPMG, including the web site as well as other web sites and resources of KPMG or its third-party contractors that contain the link to this KPMG Statement.

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 Cookies

    1.4 Children

2. Sharing and transfer of personally identifiable information

3. Choices

4. Your rights

5. Data security and integrity

6. Links to other sites

7. Changes to this KPMG statement

8. Policy questions and enforcement

 

1. Collection and use of personal information

1.1 What information we collect

1.1.1. General provisions

We obtain personal information about you if you choose to provide it directly or through third parties authorized by you. In some cases, you may have previously provided your personal information to KPMG (if, for example, you are a former employee or you already have business relations with KPMG). 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 we will use this information in the manner outlined in this KPMG 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. 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).

1.1.2. 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.

1.2 The legal grounds we have to use your personal information

KPMG generally collects only the personal information necessary to fulfill your request or to perform our contractual obligations. 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 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 dataprivacy@kpmg.ru outlining the purpose for which your contacts have been provided to us.

Examples of the ‘legitimate interests’ referred to above are:

• To offer information about KPMG (including events and job vacancies) and/or services, including to individuals who visit our website.
• 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 comply with regulation or regulatory guidance.
• To transfer personal data between other member firms of the KPMG network for internal administrative purposes as indicated in clause 2.1.

Special categories of personal data are defined according to the legislation and processed by KPMG only in accordance with applicable laws.

1.3 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.

1.4 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.

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, to perform contractual obligations 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 KPMG 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 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.

3. Choices

KPMG will 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.

4. Your rights

If KPMG processes 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 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: you have the right to object to us processing your personal information if we are not entitled to use it any more.

Automated decision-making: you have the right not to be subject to automated decision-making unless you provided your written consent or unless so required by federal laws.

Rights to withdraw your consent and/or send a complaint to supervisory authority: see Section 8 “Policy questions and enforcement” for more details.

• 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 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.

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 make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual's requests and/or perform contractual obligations, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until the person that has provided the personal information 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 KPMG 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 KPMG Statement

KPMG may modify this KPMG 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 KPMG 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 KPMG Statement. 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 being first raised.

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 your jurisdiction.

1  “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.