Provision of systems and data backup solution and service

Data transfer for outsourcing and sub-outsourcing purposes

Luxembourg

All types of data (encrypted)

All

Secure storage of physical archive including secure destruction of archived documents

Data transfer for outsourcing purposes

Luxembourg

All types of data, including client identifying data

All

Sharing of collected AML-KYC documents between different Luxembourg Deloitte Entities in the context of the customer due diligence process required by Deloitte internal client and engagement acceptance policies and Law of 12 November 2004 on the fight against money laundering and financing of terrorism, as amended.

Service Provision / Data transfer other than for outsourcing purposes

Luxembourg  (for the Processor) and Poland and Portugal (for the Sub-Processors)

Client confidential and/or personal information: Personal Identification Information, Photographs, Contact Information, Professional Information, Financial Information, Beneficial Ownership Information.

All

Provision of internal audit services

Data transfer for outsourcing purposes

Luxembourg

All types of data

All

Provision of data center facilities

Service Provision / Data transfer other than for outsourcing purposes

Luxembourg

No data directly available (data: encrypted and physically segregated)

All

Operation and monitoring of IT infrastructure (servers, network), messaging system, backup systems

Data transfer for outsourcing purposes

Switzerland

All types of data

Tax Reporting Services offered to Swiss clients

Provision of data center facilities

Service Provision / Data transfer other than for outsourcing purposes

Switzerland

No data directly available (data: encrypted and physically segregated)

Tax Reporting Services offered to Swiss clients

Provision of a dashboarding solution for project management and production tracking by clients

Data transfer for outsourcing and sub-outsourcing purposes

Luxembourg

Aggregated client transaction data (no client identifying data)

CESOP Reporting Services

Service performance monitoring

Data transfer for outsourcing purposes

Luxembourg

Alerts might include details about specific transactions, user activities, or confidential service-related information.

All

Security log and alerts monitoring

Data transfer for outsourcing purposes

Luxembourg

Log data, which may include client emails data including, but not limited to, recipients’ names, document file names, title of the email

All