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Privacy

Privacy

Last updated 25 May, 2018

This website is operated by KPMG Oy Ab ("KPMG", "we" or “us”), a Finnish 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. KPMG International provides no client services.

This Privacy Statement concerns our website and the processing of personal data related to its use and personal data provided by the user.

KPMG is obligated to follow the provisions of the EU General Data Protection Regulation and the Finnish Information Society Code. KPMG is also dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of these fundamental obligations, KPMG is committed to the appropriate protection and use of personal data. Please review this Privacy Statement to learn more about what information we may collect about you through this website and how we use that information. KPMG may also collect personal data in the course of providing professional services (see below for further details).


Who is collecting your personal data?

KPMG Oy Ab
Address: Töölönlahdenkatu 3, 00100 Helsinki
Telephone: 020 760 3000

Email: privacy@kpmg.fi


2. Collection and use of personal data

2.1 How we collect personal data

Generally we collect your personal data from you directly (for example, when we deal with you in person or over the phone, when you send us correspondence (including via email), when you complete a questionnaire, form or survey, when you subscribe to our publications or when you use our website or our social media sites). We may also collect personal data about you from your use of our websites and information you provide to us through contact mailboxes or through the registration process on our websites. If you do not provide us with the personal data we have requested, we may not be able to complete or fulfil the service requested.  Such collection of personal data is based on your given consent to the processing.

Sometimes it may be necessary for us to collect your personal data from a third party. For example, we may collect your personal data from your employer where they are our client, from your personal representative, another KPMG member firm or a publicly available record. Such processing is necessary for the purposes of the legitimate interests pursued by us or a third party, such as your employer.

At times processing of your personal data may be necessary for compliance with a legal obligation to which we are subject.

2.2 What legal grounds are we using for personal data processing

We generally collect 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.

According to the data protection legislation we must have a legal ground for the processing of personal information. GDPR 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 privacy@kpmg.fi

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

  • To offer information and/or services 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 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.

2.3 What are the purposes for the use of collected personal data

We will use your personal data only for the purposes stated in this Privacy Statement, unless we obtain your specific consent to other uses.

KPMG collects, holds and uses personal data for a number of purposes including:

  • to provide professional services
  • to provide technology services and solutions
  • to respond to your requests or queries
  • to maintain contact with our clients and other contacts (including alumni), and keep them informed of our services, industry developments, seminars and other events
  • to allow you to register for certain areas of our website
  • to verify your identity
  • for recruitment purposes
  • when engaging service providers, other KPMG member firms, contractors or suppliers relating to the operation of our business
  • to conduct surveys
  • for seeking your feedback
  • for the performance, functionality, and security of our website
  • to meet any regulatory obligations
  • to perform internal statistical analysis, including of our databases and website
  • to profile website users based on consent
  • to target customers with personalised marketing messages based on their usage of our website
  • for any other business related purposes

2.4 What personal data we collect

You do not need to register your personal data in order to use this website. In general we collect only such personal data as is provided voluntarily by visitors to our website and is necessary in the circumstances. For example, you may provide information such as your name, title, work address and email address in order to register for certain services or to send or receive email to/from us through the site.

Some data is necessary for us to enable you to move around our website and use its features (this includes performance and functionality cookies, which are necessary to provide services requested by you).

The types of personal data we collect include:

Contact details
Your name, address, telephone number, email address

Status information
Job title, employer

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

If you wish to receive KPMG marketing materials, we may request various contact details depending on the type of marketing materials you would like to receive. This may include name, email address, physical address, and telephone number.

If you are interested in KPMG services, we will request contact details including your name, company, and email address in order that KPMG can discuss your requirements with you.

Where you are invited to attend KPMG-related events, we will record your response to the invitation.

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.

We don’t request sensitive personal data through our website, however, we will request voluntary information about your dietary requirements in order to cater for your needs when attending our events. By giving us this information you give your consent for KPMG to process that information. 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.

2.4.1 Marketing automation

KPMG uses a marketing automation tool that interacts with our CRM (Customer Relationship Management) database. Data used for marketing automation purposes is enriched by data on the user-specific usage of our website (profiling). KPMG uses CRM to develop our relationship with current and prospective clients and our marketing automation is used to assist with KPMG’s marketing campaigns – for example, when sending marketing materials or organising events.

KPMG tracks recipients’ engagement with our marketing emails. By this, we mean that we monitor if emails were successfully delivered, opened, or forwarded and by which users. We do this for reporting purposes - to check if our marketing campaigns are working and providing recipients with the information they want. 

You have the right object at any time to processing of your personal data for profiling and direct marketing purposes by contacting us via email at privacy@kpmg.fi.

2.4.2 Automatic collection of personal information

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

Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit 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 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).

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 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 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 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.

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 himself 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 you during your online visits in order to tailor the content or make suggestions of similar items you 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 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.

Location based tools

KPMG may collect and use the geographical area 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.

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 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.

3 How we share and transfer personal data

3.1 Transfer within the KPMG network

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.

3.2 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. This includes:

  • 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. 

In addition, KPMG will 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 will also typically 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 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.

4. Choices

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.

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 select to refuse cookies.

5. Data security and storage

KPMG has appropriate technical and organisational security policies and procedures in place to protect personal data and information from loss, misuse, alteration, or destruction. KPMG holds personal data in hard copy and electronic formats. 

We take security measures to protect the personal data we hold including physical (for example, security passes to enter our offices and storage of files in lockable cabinets) and technology (for example, restriction of access, firewalls, the use of encryption, passwords and digital certificates) security measures. We also have document retention policies and processes. In some cases, KPMG engages third parties to host electronic data (including data in relation to the services we provide) on our behalf.

Additionally, we aim to ensure that access to your personal data is limited to those who need to access it. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We use all reasonable efforts to retain personal data collected from you only for so long as we need such data in accordance with the purpose for which it was collected or until we are requested to delete it (if earlier). We apply reasonable efforts to assure that inaccurate, incorrect and outdated personal data is deleted or corrected without undue delay.

6. 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.

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.

9. 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 privacy@kpmg.fi. 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 KPMG Finland’s Privacy Office by sending an email to privacy@kpmg.fi. 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 competent supervisory authority in charge of protecting personal information.