This privacy statement applies to Deloitte & Touche LLP with registered office addresses at One Capital Place, Grand Cayman and Citrus Grove, Grand Cayman, Cayman Islands and the entities we own or control (“Deloitte”, “we”, “us” or “our”).

We are committed to protecting your privacy and handling your information in an open and transparent manner. This privacy statement sets out how we will collect, handle, store and protect information about you when:

• providing services to you or our clients;
• you use “our Website”; or
• performing any other activities that form part of the operation of our business.

When we refer to “our Website” or “this Website” in this policy we mean the specific webpages of deloitte.com designated as Cayman Islands in the upper right hand corner, and to specific webpages with a URL commencing “http://www.deloitte.com/ky/en…”
Deloitte.com is comprised of various global, country, regional and practice specific websites, each of which is provided by Deloitte Touche Tohmatsu Limited (“DTTL”) or one of its independent member firms or their related entities (collectively, the “Deloitte Network”). To learn more about DTTL, the member firms of DTTL and their related entities, please see About Deloitte.

This privacy statement also contains information about when we share your personal data with other members of the Deloitte Network and other third parties (for example, our service providers).

In this privacy statement, your information is sometimes called “personal data” or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting and storing your personal information as “processing” such personal information.

Please note that the other country and regional websites contained within deloitte.com are provided by other entities within the Deloitte Network and are not provided by us. Such websites, as well as other websites that may be linked to this Website, are not governed by this privacy statement. We encourage visitors to review the privacy statements on each of these other websites before disclosing any personal information.

In the course of providing services to you or our client and performing due diligence checks in connection with our services (or discussing possible services we might provide), we will collect or obtain personal data about you. We may also collect personal data from you when you use this Website.

We may collect and process such data because (i) you give it to us (for example in a form on our Website), (ii) other people give it to us (for example your employer or adviser, or third party service providers that we use to help operate our business) or (iii) it is publicly available.
We may also collect or obtain personal data from you because we observe or infer that data about you from the way you interact with us or others. For example, to improve your experience when you use this Website and ensure that it is functioning effectively, we (or our service providers) may use cookies (small text files stored in a user’s browser) and Web beacons which may collect personal data.

Additional information on how we use cookies and other tracking technologies and how you can control.

The personal data that we collect or obtain may include:

• your name, age, date of birth and gender;
• contact information such as e-mail address; home address; mobile phone number;
• country of residence;
• lifestyle and social circumstances (for example, your hobbies);
• family circumstances (for example, your marital status and dependents);
• employment and education details (for example, the organization you work for, your job title and your education details);
• financial and tax-related information (for example your income and tax residency);
• postings or messages on any blogs, forums, wikis and any other social media applications and services that we provide;
• IP address, browser type and language, your access times;
• information in any complaints you make;
• details of how you use our products and services; or
• details of how you like to interact with us and other similar information relevant to our relationship.

The personal data we collect may also include so called “sensitive” or “special categories” of personal data, such as details about your:

• dietary requirements (for example, where Deloitte would like to provide you with lunch during a meeting);
• health (for example, so that we can make reasonable accommodations for you in our buildings, products and services); or
• sexual orientation (for example if you provide us with details of your spouse or partner).

The types of personal data and special categories of personal data that we collect may vary depending on the nature of the services that we provide to you or our client, or how you use our Website. In some rare circumstances, we might also gather other special categories of personal data about you because you volunteer that data to us or we are required to gather that data as a result of legal requirements imposed on us.

Where we are provided with personal data about you by our client or another third party, we take steps to ensure that the client or third party has complied with the privacy laws and regulations relevant to that information. This may include, for example, that the client or third party has provided you with notice of the collection (and other matters) and has obtained any necessary consent for us to process that information as described in this privacy statement.

If any information you give us relates to a third party (such as a spouse, financial dependent, or joint account holder), by providing us with such personal data you confirm that, in line with the above provisions, you have obtained any necessary permission to use it or are otherwise permitted to give it to us.

We understand the importance of protecting children's privacy. Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store information about children.

Use of personal information to provide services to our clients

We will use your personal data to provide you or our clients with services and this includes using your personal data in correspondence relating to those services.

Such correspondence may be with:

• you;
• other third parties or other members of the Deloitte Network;
• our service providers; or
• competent authorities.

We may also use your personal data to conduct due diligence checks relating to the services.

Because we provide a wide range of services to our clients or other third parties, the way we use personal data in relation to our services also varies. For example, we might use personal data about:

• a client’s employees to help those employees manage their tax affairs when working overseas;
• a client’s employees and customers in the course of conducting an audit (or similar activity) for a client;
• a client to help him/her complete a tax return; or
• a client’s employees, customers and investors in the course of undertaking a liquidation (or similar activity) for a client.

Use of personal information for other activities that form part of the operation of our business

We may also use your personal data for the purposes of, or in connection with:

• legal or regulatory requirements;
• requests and communications from competent authorities;
• client account opening and other administrative purposes;
• financial accounting, invoicing and risk analysis purposes;
• relationship management purposes, which may involve:
    – sending you thought leadership or details of our products and
        services that we think might be of interest to you;
    – contacting you to receive feedback on services;
    – sending you event invitations; and
    – other market or research purposes.
• recruitment and business development, which may involve the use of testimonials from a client’s employees as part of our recruitment and business development materials (with that employee’s permission);
• services we receive from our professional advisors, such as lawyers, accountants and consultants; or
• protecting our rights and those of our clients.

Use of personal information collected via our Website

In addition to the purposes connected to the operation of our business above, we may also use your personal data collected via our Website:

• to manage and improve our Website;
• to tailor the content of our Website to provide you with a more personalised experience and draw your attention to information about our products and services that may be of interest to you; or
• to manage and respond to any request you submit through our Website.

We may process your personal data because:

• you have explicitly agreed to us processing your information for a specific reason;
• the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
• the processing is necessary for compliance with a legal obligation we have such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
• the processing is necessary for the purposes of a legitimate interest pursued by us or a third party, which may include to:
    – provide our services to you or our clients and other third parties
       and ensure that our client engagements are well-managed;
    – prevent fraud;
    – protect our business interests;
    – ensure that complaints are investigated;
    – evaluate, develop or improve our services or products; or
    – keep you or our clients informed about relevant products and
      services and provide you with information, unless you have 
      indicated at any time that you do not wish us to do so.

To the extent that we process any sensitive personal data relating to you for any of the purposes outlined above, we will do so because:

• you have given us your explicit consent to process that data;
• we are required by law to process that data in order to ensure we meet our “know your client” and “anti-money laundering” obligations (or other legal obligations imposed on us);
• the processing is necessary to carry out our obligations under employment, social security or social protection law;
• the processing is necessary for the establishment, exercise or defence of legal claims; or
• you have made the data public.

Please note that in certain circumstances it may be still lawful for us to continue processing your personal information even where you have withdrawn your consent, if one of the other legal bases described above is applicable.

In connection with one or more of the purposes outlined in the “How we use information about you” section above, we may disclose details about you to:

• other members of the Deloitte Network or third parties that provide services to us and/or the Deloitte Network;
• competent authorities (including courts and authorities regulating us or another member of the Deloitte Network);
• your employer and/or their advisers; your advisers;
• credit reference agencies or other organizations that help us make credit decisions and reduce the incidence of fraud;
• any other person or organisation after a restructure, sale or acquisition of any member of the Deloitte Network, as long as they use your information for the same purposes we did; and
• other third parties that reasonably require access to personal data relating to you for one or more of the purposes outlined in the “How we use information about you” section above.

Our Website hosts various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Importantly, any personal information that you contribute to these Social Media Applications can be read, collected and used by other users of the application. We have little or no control over these other users and, therefore, we cannot guarantee that any information that you contribute to any Social Media Applications will be handled in accordance with this privacy statement.

Information we hold about you may be transferred to other countries:

• where we do business;
• which are linked to your engagement with us;
• from which you regularly receive or transmit information; or
• where our third parties conduct their activities.

These countries may have less stringent privacy laws that may not provide the same level of data protection. In such cases, we will ensure that there are adequate safeguards in place to protect your personal data that comply with our legal obligations.

We may also need to disclose your personal data if required to do so by law, a regulator or during legal proceedings.

We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, thought leadership and promotional activity.

We use a range of physical, electronic and managerial measures to ensure that we keep your personal data secure, accurate and up to date. These measures include:

• education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal data;
• administrative and technical controls to restrict access to personal data on a ”need to know” basis;
• technological security measures, including fire walls, encryption and anti-virus software; and
• physical security measures, such as security passes to access our premises.

The transmission of data over the internet (including by e-mail) is never completely secure. So although we use appropriate measures to try to protect personal data, we cannot guarantee the security of data transmitted to us or by us.

We will hold your personal data on our systems for the longest of

• the period necessary for the relevant activity or services;
• any retention period that is required by law; or
• the period in which litigation or investigations might arise in respect of the services.

You may have certain rights in relation to your personal data. In particular, you may in some cases, have a right to:

• obtain confirmation that we are processing your personal data and request a copy of the personal data we hold about you;
• be informed about the processing of your personal data (i.e. for what purposes, what types, to what recipients it is disclosed, storage periods, any third party sources from where it was obtained, confirmation of whether we undertake automated decision-making, including profiling, and the logic, significance and envisaged consequences);
• ask that we update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
• ask that we delete personal data that we hold about you, or restrict the way in which we use such personal data; withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);
• receive a copy of the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal data to another party (to the extent the processing is based on consent or a contract);
• ask us to stop or start sending you marketing messages at any time by using the contact details below; and
• object to our processing of your personal data.

If you would like to access or see a copy of your personal data, you must ask us in writing. We will endeavour to respond within a reasonable period, and in any event in line with applicable data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.

To exercise any of your rights, or if you have any other questions about our use of your personal data, you can contact us by:

• sending a mailto:CBCConfidentiality@deloitte.com
• writing to The Privacy Officer, c/o Deloitte & Touche LLP, Citrus Grove, P.O. Box 1787, George Town, Grand Cayman KY1-1109, Cayman Islands

You may also use these contact details if you wish to make a complaint to us relating to your privacy. We will endeavour to respond satisfactorily to any request, query, or complaint you may have in respect of your personal data, but if you are dissatisfied with our response and wish to make a formal complaint, or if you simply wish to learn more about your rights, you have the right to communicate with the Cayman Islands Ombudsman:

Ombudsman
PO Box 2252
Grand Cayman KY1-1107
Cayman Islands
https://ombudsman.ky/data-protection

We and other members of the Deloitte Network may use your information from time to time to inform you by letter, telephone, email and other electronic methods about products and services (including those of third parties), event and webcast invitations, industry-focused publications and collateral, newsletters, regulatory and other firm updates that may be of interest to you.

You may, at any time, ask us and/or other members of the Deloitte Network not to send marketing information to you by following the unsubscribe instructions in communications from us, or contacting us in the way described in section 9 above.

If you wish to raise a complaint about how we are using your information, exercise any of the rights set out above, or if you have any questions or comments about privacy issues, you can contact us in the way described in section 9 above. 

We may modify or amend this privacy statement from time to time.

To let you know when we make changes to this privacy statement, we will amend the revision date at the top of this page. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to periodically review this statement to be informed about how we are protecting your personal information.