Privacy Policy Statement

Privacy Policy

Introduction

This privacy statement describes why and how PricewaterhouseCoopers LLP (“PwC”, “we”, “us”, or “our”) collects and uses personal data in connection with PwC Suite, which includes Family Office and Global VAT Online (“application”) and provides information about your rights as a user of the application (“you”, “user” or “individual”).

Personal data is any information relating to an identified or identifiable living person. This privacy statement applies to personal data provided to us, both by you or by others and any personal data created in connection with your use of the application.
We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities in connection with the application, please go to the relevant sections of this statement.

Security

We adhere to internationally recognised security standards. Our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO/IEC 27001: 2013. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 20 January 2021.

Data controller and contact information

The data controller is PricewaterhouseCoopers LLP (the limited partnership registered in England under registration no. OC303525 and with its registration address at 1 Embankment Place, London, WC2N 6RH).

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Data Protection Officer

PricewaterhouseCoopers LLP

1 Embankment Place

London

WC2N 6RH

Email: UK_privacy_information_management@pwc.com

Collection of personal data

We will collect personal data in connection with the application as described below.

Personal data provided directly by you:

We collect personal data that is specifically and voluntarily provided by you, such as your name, company address, email address, telephone number, marketing preferences and login information to allow you to register for certain areas of the site, to respond to enquiries for further information, distribute requested reference materials to you.
You are able to email us through the website. Your message will contain your screen name and email address, as well as any additional information you may wish to include in the message.
We may collect other personal data provided directly by you in order to provide our services (such as financial and business information).

If you decide to register and obtain the service via the application, you will be asked to provide certain information as part of the registration process. You do not have to fill in the "optional" boxes - and if you don't, it will not prevent us from providing the services or responding to your enquiry but it is always helpful for us to receive this optional data as it may enable us to better understand your business needs. You must fill in the "mandatory" boxes marked * as otherwise it may prevent us from providing the services or responding to your enquiry.

Personal data inferred or derived from your use of the application:

We use small text files called ‘cookies’ which are placed on your hard drives to assist in providing a more customised website experience. The use of cookies is now standard operating procedure for most websites. However if you are uncomfortable with the use of cookies, most browsers now permit users to opt-out of receiving them. In that case you will be unable to use this registration process and may find other functionality in the site impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish. Please see the cookies information sectionfor further details.

Use of personal data

Unless otherwise stated above, our lawful basis for the processing of personal data in connection with the application is the legitimate interests pursued by us in making the application available, providing connected professional services and developing our business.

We use personal data for the following purposes:

to provide the application (and enable you to securely log in to the application), to provide you with relevant information and respond to enquiries and to provide services

We use personal data to enable you to securely log in to the application, to provide information that we think will be of interest about us and our services (e.g. industry updates and insights, other services that may be relevant and invites to events) and respond to enquiries) and to provide services as follows

to provide services to you which may be further described in service-specific privacy statements provided to you
to administer, manage and develop our businesses and services

We may process personal data in order to run our business, including:

managing our relationship with clients and prospective clients;
developing our businesses and services (such as identifying client needs and improvements in service delivery);
maintaining and using IT systems;
hosting or facilitating the hosting of events; and
administering and managing our systems and applications.

security, quality and risk management

We have security measures in place to protect our and our clients’ information (including personal data), which involve detecting, investigating and resolving security threats. Personal data may be processed as part of the security monitoring that we undertake; for example, automated scans to identify harmful emails. We monitor the services provided to clients for quality purposes, which may involve processing personal data stored on the relevant client file. We have policies and procedures in place to monitor the quality of our services and manage risks in relation to client engagements. We collect and hold personal data as part of our client engagement and acceptance procedures. As part of our client and engagement acceptance, we carry out searches using publicly available sources (such as internet searches and sanctions lists) to identify politically exposed persons and heightened risk individuals and organisations and check that there are no issues that would prevent us from working with a particular client (such as sanctions, criminal convictions (including in respect of company directors), conduct or other reputational issues).

to monitor the performance of the application, how it is being used and to make improvements and to troubleshoot any issues with the application
complying with any requirement of law, regulation or a professional body of which we are a member

As with any provider of professional services, we are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data. This processing is necessary for us to comply with a legal obligation; for example, when conducting customer due diligence checks to comply with anti-money laundering regulations and, where we do not have a legal obligation, we have a legitimate interest in processing personal data as necessary to meet our regulatory or professional obligations.

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

We share personal data processed in connection with the application as follows:

Other PwC member firms

We share personal data processed in connection with the application with other PwC member firms for administrative purposes and to provide advice from PwC member firms in different territories. Our business contacts are visible to and used by PwC users from other PwC member firms to learn more about a contact, client or opportunity they have an interest in. Please see our website privacy statement for further information.
For details of our member firm locations, please click here.
We have the European Commission approved standard contractual clauses in place with the other PwC member firms to provide appropriate safeguards for personal data transferred outside of the EU. The standard contractual clauses are available here.

Third party organisations that provide applications/functionality, data processing or IT services to us

We are part of a global network of firms and in common with other professional service providers, we use third parties to help us run our business and these third parties may be located in other countries. Further details about the processors (such as IT service providers) used by PwC and locations of processing are provided here.

Where the locations of processing are outside of the EU, we have the European Commission approved standard contractual clauses in place to provide appropriate safeguards for personal data transferred outside of the EU. The standard contractual clauses are available here.

Third party organisations that otherwise assist us in providing goods, services or information

We may use other organisations to help us deliver our services as agreed with our client on an engagement-specific basis.

Auditors and other professional advisers
Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation

Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Data retention

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation).

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for records and other documentary evidence created in the provision of services is 7 years.

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Individuals’ rights and how to exercise them

You have certain rights over your personal data. Data controllers are responsible for fulfilling these rights. Where we decide how and why personal data is processed, we are a data controller.

Individuals’ rights are the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.

Please see further information about these rights and how to exercise them below.

Right of access

You have the right to obtain confirmation as to whether we process personal data about you, receive a copy of your personal data held by us as a data controller and obtain certain other information about how and why we process your personal data (similar to the information provided in this privacy statement).

You may exercise this right by emailing us at UK_privacy_information_management@pwc.com. We will aim to respond to any requests for information promptly, and in any event within the legally required time limits.

Right to rectification

You have the right to request for your personal data to be amended or rectified where it is inaccurate (for example, if you change your name or address) and to have incomplete personal data completed.

To update personal data submitted to us, please email us at suite.support@pwc.com. When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make updates, as appropriate, based on your updated information.

The right to erasure / right to be forgotten

You have the right to obtain deletion of your personal data in the following cases:

the personal data are no longer necessary in relation to the purposes for which they were collected and processed;
our lawful basis for processing is consent, you withdraw consent and we have no other lawful basis for the processing;
our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us, you object to our processing and we do not have overriding legitimate grounds;
you object to our processing for direct marketing purposes;
your personal data have been unlawfully processed; and
your personal data must be erased to comply with a legal obligation to which we are subject.

To request deletion of your personal data, please email us at UK_privacy_information_management@pwc.com.

The right to restrict processing

You have the right to restrict our processing of your personal data in the following cases:

for a period enabling us to verify the accuracy of the personal data where you have contested the accuracy of the personal data
your personal data have been unlawfully processed and you request restriction of processing instead of deletion;
the personal data are no longer necessary in relation to the purposes for which they were collected and processed but the personal data are required by you to establish, exercise or defend legal claims; and
for a period enabling us to verify whether the legitimate grounds relied on by us override your interests (where you have objected to processing based on it being necessary for the pursuit of a legitimate interest identified by us).

To restrict our processing of your personal data, please email us at UK_privacy_information_management@pwc.com.

The right to object to processing

You have the right to object to our processing of your personal data in the following cases:

our lawful basis for processing is that the processing is necessary for a legitimate interest pursued by us; and
our processing for direct marketing purposes.

To object to our processing of your personal data, please email us at UK_privacy_information_management@pwc.com.

Right to data portability

You have a right to receive your personal data provided to us and have the right to send the data to another organisation (or ask us to do so if technically feasible) where our lawful basis for processing the personal data is consent or necessity for the performance of our contract with you and the processing is carried out by automated means.

To exercise your right to data portability, please email us at UK_privacy_information_management@pwc.com.

Right to withdraw consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time. We do not generally process personal data based on consent (as we can usually rely on another legal basis). Where we rely on consent for processing, to withdraw your consent please email us at UK_privacy_information_management@pwc.com or, to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email received from us. Please see the “Use of personal data” section of this privacy statement for further details about our processing of personal data based on consent.

Cookie Information

Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most websites. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site.Cookies information

Types of cookie:

‘Session’ cookies remain in your browser during your browser session only, ie until you leave the website.
‘Persistent’ cookies remain in your browser after the session (unless deleted by you).
‘Performance’ cookies collect information about your use of the website, such as webpages visited and any error messages; they do not collect personally identifiable information, and the information collected is aggregated such that it is anonymous. Performance cookies are used to improve how a website works.
‘Functionality’ cookies allow the website to remember any choices you make about the website (such as changes to text size, customised pages) or enable services such as commenting on a blog.

Use of cookies by PwC:

The following table explains the way in which we use cookies on this website.

Cookie	Name	Purpose
Admin	admin_auth	This cookie is used to store an administrator's authentication status. Its use is limited to the admin console area.
CMS	october_session	This cookie is used to store a user's authentication status for the main Journey site to enable Journey to differentiate between first time and returning visitors in order to provide an improved user experience.
Webtrends	PWC_WOD	This cookie is used for the purpose of site analytics and performance. The cookie collects information about use of the PwC website, including IP address of user, pages visited, navigation through the site and session identifier. The information is aggregated with other such information for reporting to PwC on general website use and improvement.
Webtrends	ACOOKIE	This cookie is used for the purpose of site analytics and performance. The cookie collects information to enable provision of website services across PwC websites; the information collected is visitor identifier, specific PwC website visited and time of visit. The information is used to improve services to the website user (eg search results on the PwC site), and, when aggregated with other such information, for reporting to PwC on general website use and improvement.

By using this website, you agree that we can place these cookies on your computer/device for the above purposes.

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to UK_privacy_information_management@pwc.com. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work or the country in which an alleged infringement of data protection law has occurred within the EU. The Information Commissioner's Office (“ICO”) is the UK data protection regulator/supervisory authority. For further information on your rights and how to complain to the ICO, please refer to the ICO website.

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