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Privacy Statement

Privacy Statement

Last updated 8 October, 2018

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 "personally identifiable information" or "PII") that has been collected in the course of our business activities, for example via e-mail, when entering into agreements, or online.

Generally, our intent is to collect only the personal information that is provided voluntarily and necessary so that we can offer information and/or services to customers and others or offer information about employment opportunities, or in case of a separate explicit request – also marketing information.
Please review this privacy statement ("Privacy Statement") to learn more about how we collect, use and protect the personal information that we have obtained.

 

 

1. Collection and use of personal information

1.1. Who processes your personal data?

The entity responsible for the processing of the personal data depends on the purpose of data collection.

For instance:

  • If you use services provided by one of the companies of the KPMG Group in Poland, i.e.: KPMG Sp. z o.o., KPMG Sp. z o.o. sp. k., KPMG Audyt Sp. z o.o., KPMG Audyt Services Sp. z o.o., KPMG Audyt Sp. z o.o. sp. k., KPMG Advisory Sp. z o.o. sp. k., KPMG Tax M.Michna Sp. k., KPMG Usługi Księgowe Sp. z o.o., D.Dobkowski Sp. k., KPMG Restructuring Sp. z o.o. (all companies have their registered offices in Warsaw, at ul. Inflancka 4a), hereinafter jointly “Companies of the KPMG Group in Poland,” or you are the representative or contact person acting on behalf of our client - the data controller will be the company that provides services
  • If you leave your data for the purposes of: 
    • Recruitment
    • Registration for the events held
    • Receiving current information in form of subscription
    • Receiving marketing information ordered; participate in a dedicated programme (e.g. “Alumni”)
      the data will be processed by Companies of the KPMG capital group in Poland, as joint controllers.

1.2. What are the purposes of processing your personal data?

From our customers, suppliers or other third parties, as well as individuals representing them or co-operating with us on behalf of those entities, we process data which are necessary in order for us to provide advice and services within our combined service lines regarding Tax, Auditing and Advisory Services, including but not limited to: proper identification of contact persons and representatives of our clients or their employees, or co-workers, maintaining business contact, and in the event of potential dispute related to the service/co-operation we might process the personal information for the purpose of solving that dispute. As part of the particular matters and projects, we may process data such as your name, position, contact details or other relevant, necessary data as further defined and set out in the respective matters.

When you use our website, your personal data are collected and subsequently processed for purposes related to individual functionalities of the particular website. Consequently, depending on the website, in which you leave your data, in each case we inform you about relevant processing purposes. At the same time, being aware of the potential of our websites, we are able to identify the following known purposes of the processing of data:

  • Recruitment
  • Registration for a specific event or publication
  • Subscription of selected materials
  • Registration for a dedicated programme, contest or campaign
  • Submission of a request for proposal
  • Ordering marketing information
  • Submission of a contract request
  • Use of applications or online tools.

When you submit personal information 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.
In these instances, data is always submitted voluntarily. When you are the employee or co-worker of our clients and you are co-operating with us on its behalf, it might happen that we receive your contact information from our client when appointing its representing persons or persons contacting us on its behalf.

1.3. What are the legal grounds to process your personal data by KPMG?

Depending on the purpose of the processing of your data, Companies of the KPMG Group in Poland have proper legal grounds for processing of your data, including for instance:

  • When the processing is necessary to perform the agreement concluded with you or to take steps required by you before concluding the agreement – point (b) of Article 6(1) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR)
  • When you are asked to grant your consent to the processing of personal data for the specific purpose – point (a) of Article 6(1) of the GDPR
  • When we pursue our so-called legitimate interests, e.g. are accepting and answering your inquiry, solving the dispute, maintaining business contacts, identifying representatives, contacts persons or other employees or co-workers of our clients acting on behalf of our clients – point (f) of Article 6(1) of the GDPR
  • Processing is necessary for compliance with a legal obligation to which we are subject, e.g. we are required to make available personal data to state authorities – point (c) of Article 6(1) of the GDPR.

    Other examples of the ‘legitimate interests’ referred to above are:

  • To prevent fraud or criminal activity and to safeguard our IT systems.
  • To customize individuals’ online experience and improve the performance, usability and effectiveness of KPMG's online presence.
  • To conduct, and to analyze, our marketing activities (unless such activity requires by law a separate consent).
  • 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.

1.4. Are your “sensitive” personal data processed?

KPMG does not intentionally collect “sensitive” personal data, unless such a duty arises from applicable legal regulations, e.g. for the purposes of recruitment. Sensitive information includes personal data revealing racial or ethnic origin, political opinions, trade union membership, religious or philosophical beliefs, data concerning health or data concerning a user's sex life, sexual orientation, criminal record, as well as genetic and biometric data.

We request the users to carefully consider the disclosure of sensitive information to KPMG and not to provide sensitive information to KPMG, unless they grant their explicit consent to using this information by KPMG for the purposes of lawful activities of KPMG and storing such data in databases of KPMG. If you have any questions pertaining to whether the disclosure of sensitive information to KPMG is or can be required in the particular case, please contact use at DPO@kpmg.pl.

2. Automatic collection of personal information

In some instances, KPMG and its service providers uses 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.

Information collected in such a way no always constitutes personal data, i.e. it does not enable us to identify the particular user, but it may happen that connecting an IP address or location information to the specific e-mail of the user will be possible.

2.1. IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate will 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.

2.2. Cookies

Cookies may 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. 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. The aggregated statistical data cover 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.pl

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.pl

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 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.

 

2.3. 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.

2.4. Adobe Analytics

KPMG uses Adobe Analytics tools. More information on using Adobe Analytics tools by KPMG is available at: https://www.adobe.com/pl/privacy.html

 

2.5. 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 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 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.

2.6. Location-based tools

KPMG will 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.

3. Social media widgets and applications

KPMG web sites will typically include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications will 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 will often 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 data provided by users using any KPMG social media features can 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.

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 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.

 

5. Sharing and authorizing processing of PII

KPMG does not disclose personal data to unrelated entities, except for situations, when it is necessary in relation to our activities, to carry out your requests, or in situations required or permitted by legal regulations or professional standards. As part of providing our business activities, we may transfer personal data to e.g. tax authorities, other public authorities and financial institutions and pension companies or other third parties. If necessary and based on proper legal grounds, 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.

In certain instances, KPMG may disclose personal information to employees or collaborators of Companies of the KPMG Group in Poland (co-controllers) or – by entrusting their processing – may disclose them to external firms, providers of services or sellers operating on our behalf in order to fulfil your requestsor provide services for you.. In case of co-operation with service providers, we might disclose your personal information to our third party serviceproviders. 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 is necessary and allows them to provide their services.

Additionally, KPMG can entrust the processing of personal data to entities in third countries, i.e. outside the European Economic Area, and can send these data to associated KPMG firms or external entities cooperating with KPMG or operating on our behalf for the purposes described in this Privacy Statement. It includes IT infrastructure services provided by associated KPMG firms including KPMG International Cooperative. KPMG can also store personal data in locations subject to a jurisdiction other than of the place of stay or registered office of the particular user. However, data can be transferred to a third country only when (subject to other generally binding legal regulations), conditions guaranteeing the required degree of protection of natural persons set in the GDPR are met, e.g. an agreement containing standard contractual clauses requiring certain degree of protection of personal data was concluded with the entity that receives the data.

KPMG can make available personal data in relation to sale, assignment or any other transfer of the title to the website, and resulting disposal/transfer of rights to the website, to which the data in question are related, as well as at the request of authorities or law enforcement agencies, or when required by applicable laws, court judgement or other state regulations. The need to disclose personal data can result from audits of data privacy or security and/or when examining complaints or implementing security-related activities. KPMG does not sell personal data to third parties that could use this information for marketing purposes.

6. 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 elect to refuse cookies.

7. Access to data and rights

In a majority of instances, if you provide us with personal data, you have relevant access thereto, which enables you to modify these data and correct any errors in these data. You can also send a request for updating or erasing certain data to DPO@kpmg.pl, as a result of which, KPMG will take relevant steps aimed at fulfilling this request, provided it is consistent with applicable legal regulations.

You should remember about your rights in relation to the processing of your personal data, referred to in the GDPR, i.e.:

  • Right of access to his/her own personal data (including obtaining the confirmation whether these data are processed or information about, e.g. purposes, sources, categories of data processed and their storage periods), which also includes the right to receive free copies of own data (for subsequent copies required by the data subject we may charge a reasonable fee taking into account the administrative costs )
  • Right to rectification (when data are inaccurate), which also includes the right to have incomplete personal data completed, but to this end, you may be required to provide a supplementary statement;
  • Right to erasure (so-called “right to be forgotten), when, e.g. the personal data are no longer necessary in relation to the purposes for which they were collected, consent to the processing was withdrawn or there are no other grounds for the processing of these data
  • Right to restriction of processing, when e.g. you contest the accuracy of the personal data – for a period enabling us to verify the accuracy of these data
  • Right to object to processing of personal data
  • Right to data portability, including the right to receive from us the personal data concerning you, which you provided to us, in a structured, commonly used and machine-readable format
  • Right to withdraw your consent to the processing of data (at the same time, the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal)
  • Right to lodge a complaint with the President of the Office for the Protection of Personal Data, when you conclude that the processing of personal data breaches provisions of the GDPR.

8. 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.

Additionally, one of the rules of the KPMG policy in this respect is storing personal information only for the period, during which:

  • They are necessary to fulfil your request
  • They are necessary to exercise the right or fulfil the duty arising from generally applicable legal regulations, policies, rules or other requirements binding in Companies of the KPMG Group in Poland or
  • Until you request erasure of this information.

The period of personal data storage depends on the specific nature and circumstances (especially purpose) of collecting your personal data.

However, personal information processed on the basis of the consent will be anonymized or deleted after you withdraw your consent.

Personal data collected during business relationship, related to our customers or business partners (if physical persons), or their representatives (including appointed contact persons) will be processed for the period of such co-operation, and upon realization thereof there personal data might be stored, if:

  • The provisions of law impose on KPMG an obligation to keep the personal data, including in particular, in order to meet the regulatory requirements concerning KPMG business activity
  • The storage of personal data by KPMG is necessary for the attainment of goals arising out of legitimate interests of KPMG.

In case of contact persons’ personal data we might process contact details for the purpose and duration of our business relations, unless (if applicable by GDPR), such person files an objection to such processing.

9. 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.

 

10. 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.

11. Policy questions and enforcement

KPMG is committed to protecting the privacy of your personal information. A Data Protection Officer has been appointed in KPMG who can be contacted by e-mail: DPO@kpmg.pl or by correspondence to the post address: KPMG Sp. z o.o. Data Protection Officer (DPO), ul. Inflancka 4A, 00-189 Warsaw. Data Protection Officer is your contact with respect to personal data matters who can also be addressed with any questions or comments concerning the personal data administration. You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

1 "KPMG", "we", "our", and "us" refers to the entities belonging to the KPMG Group in Poland: KPMG Sp. z o.o. sp. k., KPMG Audyt Sp. z o.o., KPMG Audyt Services Sp. z o.o., KPMG Audyt Sp. z o.o. sp. k., KPMG Advisory Sp. z o.o. sp. k., KPMG Tax M.Michna Sp. k., KPMG Usługi Księgowe Sp. z o.o., D.Dobkowski Sp. k., KPMG Restructuring Sp. z o.o. All of these entities have their registered offices in Warsaw, Inflancka 4a Str.