As used in this Privacy Statement, “Personal Data” means any information relating to you as a natural person, when you can be identified or are identifiable. Any operation performed on Personal Data, such as handling, collecting, protecting, and storing your Personal Data,- is referred to  as “processing”.

This Privacy Statement sets out how we will collect, handle, store and protect any Personal Data you make available to us when:

a. You use our Website (as defined below);

b. You are accessing Deloitte Luxembourg premises for any reason;

c. We are offering or providing our services to you or our clients you are related to. Deloitte Luxembourg provides various services and performs many activities that form part of the operation of our business, which you can find details on our Website under the tab “Services” or which are further detailed in the agreement between Deloitte and you or the client you are related to;

d. We are performing any other activities that form part of the operation of our business, including our marketing and communication activities (such as alumni or clients’ events).

This Privacy Statement also contains information about the Personal Data we use, when and how we share your Personal Data with other members of the Deloitte Network and other third parties (for example, our service providers) and the way you can exercise your privacy rights. It may be amended or supplemented by adhoc privacy statements specifically shared with you.

This Privacy Statement applies to Deloitte Luxembourg. “Deloitte Luxembourg” and hereinafter “we”, “us” or “our” refers to one or more entities of Deloitte Touche Tohmatsu Limited (“DTTL”)[1], its network of member Firms and their related entities in Luxembourg as identified here:

• Deloitte General Services (“DGS”), société à responsabilité limitée, having its registered office at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg;
• Deloitte Tax & Consulting (“DTC”), société à responsabilité limitée, having its registered office at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg;
• Deloitte Audit, société à responsabilité limitée, having its registered office at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg;
• Deloitte Solutions (“DSO”), société à responsabilité limitée, having its registered office at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg;
• Fiduciaire Générale de Luxembourg (“FGL”), société à responsabilité limitée, having its registered office at 26, Boulevard de Kockelscheuer, L-1821 Luxembourg;
• Deloitte Legal, société à responsabilité limitée,  having its registered office at 1, rue Heienhaff, L - 1736 Sennigerberg
• Deloitte LIS (”DLIS”), société à responsabilité limitée, having its registered office at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg.

If you are using our Website, this Privacy Statement applies to DGS as a controller of your Personal Data.

If, however, you are reviewing this Privacy Statement as it is part of a contract, offer, proposal, newsletter, or other communication in general from us, this Privacy Statement applies to the entity of Deloitte Luxembourg that you or the client you are related to have a relationship with.

When we refer to ‘our Website’ or ‘this Website’ in this Privacy Statement we mean the specific webpages of deloitte.com relating to ‘Location: Luxembourg’ in the upper right-hand corner, and to specific webpages with a URL commencing ‘https://www.deloitte.com/lu/’

Deloitte.com is comprised of various global, country, regional and practice specific websites, each of which is provided by 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.

Please note that other country and regional websites may be linked to our Website, whereby the content is provided by other entities within the Deloitte Network and not by us. Such websites, as well as other websites that may be linked to our Website, are not governed by this Privacy Statement. We encourage visitors to review the Privacy Statements on each of these countries specific or regional websites before disclosing any Personal Data on their dedicated pages.

The categories of Personal Data that we may process vary depending on the services we provide you or our clients with, how you use our Website, the Deloitte’s events you attend and whether you access Deloitte premises.

While limited Personal Data are collected through our Website (mainly contact details and technical and security data), various categories of Personal Data can be collected strictly in relation to the services we provide or the specific relationship we may have with you. Those may at times include:

• Your identification information, such as a copy of your national identity card or passport and social security card, which include identification numbers, age, date of birth, gender;
• Your contact details, such as your e-mail address, landline or mobile phone, home or professional address, country of residence;
• Your signature;
• Your professional, familial and social background and relationship, such as your lifestyle and social activities (for example, your hobbies); your marital status and members of your family; employment and education details (for example, your employer(s), your job title and your education details);
• Your photo or image or sound of your voice, as may be included in documentation made available to us, taken or recorded as a result of your participation to any type of events or activity organized or sponsored by Deloitte Luxembourg or if recorded in the context of video surveillance tools (to the extent legally permitted);
• Your financial, ownership and tax-related information, such as your income and tax residency, information about ownership / shareholding of companies, payment or bank accounts details, when necessary for us to provide our services;
• Your communications and behavioral data deriving from your postings on any blogs, forums, wikis and any other social media applications and services that we provide, metadata and related publicly available geo-localization data;
• Technical data associated with you, such as your IP address; your browser type and language; access logs (including access times; websites use and monitoring thereof) details of how you interact with us; devices used; location data and other similar information;
• Information related to your background, as provided by you or collected from our clients or on their behalf, open data or public records as part of our business acceptance processes and for our ongoing risk management processes, and this information may include special categories of Personal Data, to the extent legally permitted;
• Data relating to our relationship with you or with our clients, including especially Personal Data provided to us by or on behalf of our clients or generated by us to provide services to them or for the quality review of these services and this information, to the extent legally permitted, may include special categories of Personal Data;
• Information related to your communication with us, such as e-mails, text messages, recordings of telephone/skype conversations, voice mails, metadata and related geo-localization data, and data in relation to your interactions with certain types of communications we send to you (e.g. communications regarding our services, newsletters, events invitation or other types of marketing communications).

We may also directly or indirectly collect so called ‘sensitive’ or ‘special categories’ of Personal Data. The special categories of personal data that we may collect include:

• Information that you agree to share with, such as: dietary requirements (where Deloitte would like to provide you with lunch during a meeting) or medical information (so that we can make reasonable accommodations for you in our buildings, products and services).
• Information contained in documents that you share with us (such as your identification documents), such as your race or ethnicity, religious beliefs etc.
• Information that you otherwise disclose to Deloitte Luxembourg in Deloitte systems and applications available for you, or in case you have made this information public, such as your sexual orientation and political opinions.

Please note that we do not actively collect or otherwise process sensitive information, such as your race or ethnicity, religious beliefs, sexual orientation and political opinions and we would advise you not to disclose it whenever possible. However, it is possible that such information is contained in the documents that we may have access to comply with our legal and/or regulatory obligations or perform our professional duties as mentioned in clause 1.5.2 of this Privacy Statement (eg. identification documents) or can be deducted thereof by us. 

To the extent that we receive any sensitive Personal Data relating to you for any of the purposes outlined above, we will do so because either:

i. We are required by law to process that Personal Data in order to ensure we meet our ‘know your client’ and ‘anti-money laundering’ obligations or other legal obligations imposed on us, or they have been provided in this context (when such data are embedded in your identification documents);

ii. The processing is necessary for the establishment, exercise or defense of legal claims;

iii. You have made the Personal Data manifestly public; or

iv. You have given us your explicit consent to process that Personal Data.

When these sensitive Personal Data are transmitted to us by a third party, including you as our client, we assume that this third party can lawfull processes such Personal Data and has obtained your consent when legally required.

4.1 Direct or indirect collection

We may collect or obtain Personal Data directly because either:

(i) you provided it to us (for example by completing a form on our Website or attending one of our events); or

(ii) we had access to it indirectly because other people transferred that Personal Data to us (for example your employer or adviser, or our client in order to provide the agreed services, or third-party service providers that we use to help operate our business) or because those data are publicly available. In case of indirect collection, we may not be the primary controller of your Personal Data.

Where we are provided with Personal Data about you indirectly, mainly by our client, it shall remain the primary responsibility of our client to take steps to ensure that you are informed and  to comply with its own obligations under privacy laws and regulations relevant to that information. These steps may include, for example, that you receive from our client information on the processing of your Personal Data as described in this Privacy Statement. 

4.2 Use of Cookies and similar technologies

We (or our service providers) may also collect or obtain Personal Data from you from the way you interact with our Website or with certain types of our email communications through cookies and other tracking technologies such as Web beacons. These Personal Data are processed to, for example, improve your experience when you use this Website and ensure that it is functioning effectively.

Additional information on how we use cookies and other tracking technologies and how you can control them can be found in our cookie notice. 

5.1 Use of Personal Data to provide services to our clients

We may use your Personal Data before or while performing an engagement (including any engagement as auditor) in the following cases:

• Provision of the agreed services as described in the agreement between you and/or our client and Deloitte Luxembourg, including
  • Financial Advisory
  • Consulting
  • Audit & Assurance
  • Risk Advisory
  • Corporate and accounting services
  • Tax Services
• Receive support from our services providers and/or subcontractors during the execution of our services as described in agreements between us and these service providers/subcontractors as well as between us and our clients, including
  • IT infrastructure and assets administration;
  • Software licensing;
  • Cybersecurity;
  • Subcontracted services.

We may specifically use Personal Data:

• about client’s employees to help those employees manage their tax affairs when working overseas
• about client’s employees and customers in the course of conducting an audit (or similar activity)
• about a client to help him/her complete a tax return using platforms imposed by the relevant tax administration;
• about client’s employees and customers for data sharing between Deloitte and its clients using adhoc platforms and other digital means to this effect;
• about client’s employees and customers to comply with our due diligence obligation and maintain client’s relationship, including initial client account opening, risk assessment and client acceptance process, financial accounting, invoicing and risk analysis purposes, ongoing relationship management which may involve ongoing risk assessment,
• about our existing or prospective clients and their employees for our marketing activities and the management of our client relationship management platform; or
• about our potential clients in the context of a proposal presented to them and to the extent required to showcase our expertise on the subject matter of the services proposed.

We will use your Personal Data because (a) of our legitimate interests in the effective provision of the services to you or our client to which you relate; or (b) of our legitimate interests in the effective and lawful operation of our business so long as such interests are not outweighed by your interests.

5.2 Use of Personal Data to comply with our legal obligations

We may also use your Personal Data for the purposes of, or in connection with:

• our obligations to comply with applicable legal or regulatory requirements related to anti-money laundering / know your customers (AML/KYC), independence, fight against corruption etc.;
• our tax, legal or regulatory reporting duties;
• our obligations under the data protection legislation;
• our legal obligations to ensure health and safety within our premises;
• our professional duties as approved statutory auditors or other regulated profession/entity; or
• our legal obligation to address requests and communications from competent authorities and courts as legally required. 

5.3 Use of Personal Data to protect people and assets

We may use your Personal Data based on our legal obligation and, in certain circumstances, on our legitimate interest to:

• protect our offices, IT infrastructure and assets;
• ensure the security of our network and information;
• ensure the safety of our employees, or contractors while present at our premises or travelling abroad;
• ensure the safety of our clients or visitors while present at our premises; and
• detect incidents or unlawful or dangerous behavior and to alert or assist enforcement authorities in such cases.

This may lead us to:

• use IT tools scanning correspondence of any kind or documents transiting through your professional devices in accordance with our procedures and policies (as made available to you from time to time) to identify risks and take adequate mitigation measures in accordance with applicable laws
• monitor access to the premises, infrastructure and assets and use thereof, including using video surveillance tools in specific public areas of our premises

For more information on how we process your personal data in the context of the operation of a video surveillance system (CCTV) in our premises, you can request our Video-surveillance Policy by email to our Data Protection Team (Section 12 of this document).

5.4 Use of Personal Data for other business purposes

We may also use your Personal Data based on our legitimate interest for the purposes of, or in connection with:

• Our duty to have a business continuity plan in place;
• Our need to be able to deal with complaints or legal disputes involving you and to protect our rights and those of our clients or even your rights, mainly in case of complaints and (potential) litigation;
• The development of our business activities and related marketing and promotional activities, including:
  • Contacting you to receive feedback on our services;
  • Sending you newsletters, thought leadership, details of our products and services that we think might be of interest to you or invitations to events, workshops or trainings that we organize or sponsor;
  • Contacting you for other market or research purposes;
  • The creation and distribution of business development materials, brochures, videos, and other materials used as part of our recruitment
• Services that we receive from our professional advisors, such as lawyers, accountants and consultants or other service providers (such as archiving, security services, IT or printing) either to execute our contractual obligations toward you or our clients or for legitimate business interest (support or development of our business activities and membership of Deloitte network);

Deloitte may send you marketing materials when obtained your explicit consent to do so or through Deloitte’s legitimate interest duly assessed and when not overriding your rights and freedom. If you do not want to continue receiving any marketing materials from us, you can click on the unsubscribe function when included in the communication or reply to the e-mail you received.

5.5 Use of Personal Data collected via our Website, social media pages or applications

In addition to the purposes connected to the operation of our business referred to above and considering our legitimate interest to secure, promote and develop our business activities, we may also use your Personal Data collected via our Website or via our social media pages on Facebook, LinkedIn and other networks (“our Social Media Applications”):

• to manage and improve our Website, including monitoring its use;
• to ensure protection of our IT network;
• to tailor the content of our Website to provide you with a more personalized experience and draw your attention to information about our products and services that may be of interest to you;
• to promote our services, including sending market or regulatory updates, publications and details of events;
• to manage and respond to any request you submit through our Website.

Our Website and services are not designed for, or intentionally targeted at, children. It is not our policy to intentionally collect or store Personal Data about children. If we need to process Personal Data that pertain to children, in the context of any event or activity we might organize or service we may offer, you shall be informed appropriately. 

5.6 Use of Personal Data, including your image, during events

In addition to the purposes referred to above and given our legitimate interest to communicate about Deloitte or Deloitte activities, we may collect and use your personal data, including photos and videos containing your image or likeness, in the context of events, trainings or other activities (co-)organized or sponsored by us.

Photos taken and/or video recording (or extracts thereof) may be shared internally (on our Intranet) or with the Deloitte Network, published online (including on our Website, Deloitte social media applications or third-party websites), in the press or in any other publications released by Deloitte Luxembourg or broadcasted live, for the above-mentioned purposes.

Your registration to events (co-)organized or sponsored by Deloitte Luxembourg by default shall be interpreted as:

(1) your consent to have your pictures or audio/video recording taken;

(2) you consent to the use of these photos, audio/video recording by the various corporate media used by Deloitte Luxembourg to promote its business activities and support its corporate culture;

(3) you consent to sharing your registration details with the co-organizer indicated in the event invitation for the organization of, and follow-up on, the events.

If you disagree to the use of your or their photos, please notify in advance the contact person indicated as organizer of the event. You can also take some personal measures such as avoiding being in the field of any camera or using the features generally offered by the platforms selected to support the event to prevent your data to be video or audio recorded.

Please note that you may at any time withdrawn your consent to one or the other processing above detailed by contacting our Data Protection Team (Section 12 of this document).

6.1 Third parties to whom we may disclose Personal Data

In connection with one or more of the purposes outlined in the “How we use Personal Data about you and for which legal grounds” section above, we may disclose details about you to:

• Other members of the Deloitte Network which may be located in jurisdictions within or outside the European Economic Area (“EEA”) as part of global administration of the network, as required for you to use Deloitte applications, systems and to participate in trainings and/or when we delegate part of our business activity to one or more other members of the Deloitte Network;  
• Third parties that provide services to us and/or the Deloitte Network, such as printing or archiving providers, cloud-hosted solution providers, our providers of IT tools and infrastructure when necessary for testing or maintenance purposes, our legal advisers, third-parties when we delegate part of our services with our client’s approval, and insurers in case of incident or claim;
• Providers of cloud-hosted solutions used in the context of the provision of services to our clients (eg. file-sharing platforms);
• Public enforcement authorities such as the police (in case of unlawful act) or other competent authorities, including courts and authorities regulating us or another member of the Deloitte Network, to the extent legally permitted or required;
• Your employer and/or their advisers in the context of the services provided to you or your employer (potentially for your own benefit);
• Your advisers;
• Co-organizers of events, security companies and catering providers;
• Organizations that help us reduce the incidence of fraud 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 Personal Data about you and for which legal grounds” section above.

More details may be available in the contracts between Deloitte and you and/or the client or provider you are related to, the events’ invitations or adhoc privacy notice made available to you. Alternatively, you may contact our Data Protection Team (Section 12 of this document) for specific information relating to specific purposes.

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 purposes.

6.2 Social Media Applications

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 Data 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. We strongly advise you to read Social Media Applications privacy statements.

6.3 Data transfer

Please note that some of the recipients of your Personal Data referenced above may be based in countries outside of the European Union whose laws 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. Where the recipient is not a member of the Deloitte Network, the adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission for transfers of Personal Data to third countries.

Further details of the transfers described above and the adequate safeguards used by Deloitte in respect of such transfers are also available from us by contacting our Data Protection Team (Section 12 of this document).

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 our Staff members to ensure they are aware of our privacy and confidentiality 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 other security controls performed as part of Deloitte cybersecurity program;
• physical security measures, such as Staff members security passes to access our premises;
• technological measures to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
• safeguards to ensure our ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident; and
• a process for regularly testing, assessing and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

Although we use appropriate security measures once we have received your Personal Data, the processing of data over the internet (including by e-mail) is never completely secure. We endeavor to protect your Personal Data, but we cannot guarantee the complete security of data transmitted to us and processed by us over the Internet.

We will hold your Personal Data on our systems for the longest of the following periods:

(i) as long as is necessary for the relevant activity or services

(ii) any retention period that is required by law

(iii) the end of the period in which litigation or investigations might arise in respect of the services.

For example, we shall hold:

• accounting documents (e.g. invoices or related correspondence) for a period of 10 years after the end of the accounting period to which they relate; or
• contractual documentation and related identification documentation for a period of 10 years as from the termination of the relevant contractual documentation.

More details may be available in the contracts between Deloitte and you and/or the client or provider you are related to, the events’ invitations or specific privacy notice made available to you. Alternatively, you may contact our Data Protection Team (Section 12 of this document) for specific information relating to specific purposes.

As a Data Subject, you can contact us to exercise your following rights when Deloitte acts as a controller of your Personal Data:

• obtain confirmation that we are processing your Personal Data and request a copy of the Personal Data we hold about you;
• ask to update your Personal Data or to correct the Personal Data that you think is incorrect or incomplete;
• ask that we delete your Personal Data or restrict the way in which we use such Personal Data when in specific circumstances when it was provided due to a legal requirement. The deletion of your Personal Data or restriction of the processing activity will only be applicable when there is no longer a need to process your Personal Data or when we no longer have a valid legal ground to process them;
• withdraw consent you previously provided us to the processing of your Personal Data (when such processing is based on consent);
• receive a copy of your Personal Data in a structured, commonly used and machine-readable format to transmit such Personal Data to another party (when the processing is based on consent or a contract to which you are a party and we are acting as Data Controller);
• object to our processing of your Personal Data when related to marketing or profiling purposes or based on legitimate grounds.

Please note that where the provision of Personal Data by you or our client to Deloitte Luxembourg is a statutory or contractual obligation, failure to provide the Personal Data might render it impossible for Deloitte Luxembourg to provide you with those services and carry out our business activities, therefore it may lead to the termination of our relationship.

We also reinforce that your right of access is limited to your Personal Data and rights hold by other persons will need to be taken into account when reverting to you.

Deloitte Luxembourg shall be your contact for the exercise of your rights when it acts as data controller. In cases where Deloitte Luxembourg is acting as data processor, we will either (i) recommend that you contact the controller of your Personal Data; or (ii) redirect your request to the controller of your Personal Data.

To exercise any of your rights, or if you have any other questions about our use of your Personal Data, please contact our Data Protection Team (Section 12 of this document). 

If you don’t agree with the way we have handled your Personal Data or if you have any privacy concern in this respect , you have a right to complain to the EU Data Protection Authority (“DPA”) in your jurisdiction. For Luxembourg you may contact the National Commission for Data Protection (CNPD), otherwise if you would like to be directed to the appropriate DPA, you may contact us. 

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 and we encourage you to review our Privacy Statement to stay informed. In case of direct collection of your Personal Data by Deloitte Luxembourg, if we make changes that materially alter your privacy rights, we will also provide you with an ad-hoc notification of these changes, via email or other agreed communication means.  

You can contact Deloitte Luxembourg at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg or through our Website via “Contact us”.

For questions, complaints or any kind of communication regarding this Privacy Statement and privacy and data protection matters within Deloitte Luxembourg you may contact our Data Protection Team at DataPrivacy@deloitte.lu.