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PRIVACY


PRIVACY






LAST UPDATED JULY 1, 2021

KPMG LLP (U.S.)1 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 by or provided to us through any of our websites, web-based
and mobile applications, meetings and events (in-person and virtual), marketing
materials and content and services that link to, post or otherwise refer to this
Privacy Statement (collectively, “Activities”). 

Please review this Privacy Statement to learn more about how we collect, use,
share and protect the personal information that we have obtained. By engaging in
Activities (e.g., using online services or visiting a KPMG office), you consent
to the collection and processing of your personal information as set forth
in this Privacy Statement.

 * 1. Collection and Use of Personal Information
   * 1.1 Automatic Collection of Personal Information
     * 1.1.1 IP Addresses
     * 1.1.2 Cookies
     * 1.1.3 Interest-Based Advertising
     * 1.1.4 Do Not Track
     * 1.1.5 Usage Analytics
     * 1.1.6 Web Beacons
     * 1.1.7 Location-based Tools
   * 1.2 Social Media Widgets and Applications
   * 1.3 Children
 * 2. Sharing and Transfer of Personal Information
 * 3. Choices
 * 4. Data Privacy Requests
 * 5. Data Security and Integrity
 * 6. Additional Disclosures for California Residents
   * 6.1 Information We Collect
   * 6.2 Purposes and Sources of Collection
   * 6.3 Disclosures of Personal Information
     * 6.3.1 Categories of Third Parties with Whom We Share Personal Information
     * 6.3.2 Disclosures of Personal Information for Business or Commercial
       Purposes
     * 6.3.3 Sales of Personal Information
   * 6.4 Your Privacy Rights
 * 7. Additional Non-U.S. Data Subject Notices
 * 8. Privacy Shield Frameworks
 * 9. Links to Other Sites
 * 10. Changes to This Privacy Statement
 * 11. Questions and Comments

1. Collection and Use of Personal Information

We and our third-party providers (including service providers, as referred to in
Section 6.2) collect the personal information that you provide when you engage
in any Activities. For example, when you register for a service or attend an
event, we may collect basic information about you such as your name, username,
password, email address, mailing address, phone number, date of birth, and other
personal and business demographic or contact information. You may also provide
us with certain employment information in connection with an application for
employment with KPMG. In some cases, you may have previously provided your
personal information to KPMG (e.g., if you are a KPMG alum). 

We use the personal information we collect (including through the automatic
collection of personal information, as described in Section 1.1) to: enable you
to engage in Activities; provide you with web-based and mobile applications;
communicate with you; provide you with information about KPMG’s products and
services; comply with applicable laws, regulations and/or professional
standards, including for auditor independence, anti-money laundering and
know-your-client checks; operate, maintain and enhance any of our Activities;
and fulfill your specific requests. For example, if you send us an email message
requesting information about KPMG, we will use your email address and other
personal information you supply to respond to your request. If you send us a
resume or curriculum vitae to apply online for a position with KPMG, we will use
the personal information that you provide to match you with available KPMG job
opportunities. Your personal information is used only for the purposes described
in this Privacy Statement, unless we (i) obtain your express permission, (ii)
provide an additional privacy notice, or (iii) as otherwise required or
permitted by law or professional standards.

In some cases where you have registered for certain Activities we may store your
personal information temporarily until we receive confirmation of the
information you provided via an email (i.e., where we send an email message to
the email address provided as part of your registration to confirm a
subscription request). Please note that your rights for any particular request,
product or service will be determined by the notice provided with such request,
product or service, and in the event of a conflict between this notice and that
notice, the specific notice provided with the request, product or service shall
control. 

KPMG only collects sensitive personal information when (i) you voluntarily
provide us with this information, (ii) you expressly permit us to use this
information, or (iii) such information is required or permitted to be collected
by law or professional standards. Sensitive personal information
includes personal information regarding a person's race, ethnicity, political
beliefs, trade union membership, religious or similar beliefs, physical or
mental health, sexual orientation or criminal record. Please use your discretion
when providing sensitive personal information to KPMG or permitting KPMG to use
such sensitive personal information. Do not provide sensitive personal
information to KPMG or permit KPMG to use such sensitive personal information,
unless you consent to (i) KPMG's use of that sensitive personal information for
its business purposes, and (ii) the transfer and storage of that sensitive
personal information to and in KPMG systems. 


1.1 Automatic collection of personal information

In some instances, we and our third-party providers use cookies, web beacons,
wayfinding technology, Wi-Fi, Bluetooth, Global Positioning System (“GPS”)
technology and other technologies (including other location-based technologies)
to automatically collect certain types of personal information when you engage
in our Activities (e.g., our web-based or mobile applications), as well as
through email messages that we may exchange or through collaboration platforms.
The collection of this personal information allows us to: customize your online
experience; improve the performance, usability and effectiveness of KPMG's
Activities; advertise and market our Activities; measure the effectiveness of
our Activities; and generate and analyze statistics about your use of or
engagement in our Activities. 

1.1.1 IP addresses

An Internet Protocol (“IP”) address is a number assigned to your
Internet-enabled device (including computers and mobile devices) 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 KPMG’s IT security and system diagnostic purposes.
This information may also be used to maintain and improve our Activities and to
generate and analyze statistics about the Activities and your engagement in
them.

1.1.2 Cookies

Cookies may be placed on your Internet-enabled device whenever you engage in our
online Activities. This allows our websites, applications or collaboration
platforms to remember your device and serves several purposes.

For some of our online Activities, a notification banner will appear requiring
your consent to collect cookies. If you do not provide consent, your 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 using 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 web
browser's cookies. 

Although most web browsers automatically accept cookies, you may be able to
choose whether to accept cookies via your web browser's settings. You may also
be able to delete cookies from your device. However, please be aware that if you
do not accept cookies, you may not be able to fully experience some of the
features of our online Activities.

Below is a list of the types of cookies used as part of our online Activities:

 

Purpose Description Type & Expiry Performance (i.e., User's Browser) Our online
Activities 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. 

Persistent, but will delete automatically after one (1) year if you no longer
engage in our online Activities.

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.
Further details on our use of Google Analytics are described in Section 1.1.5.
Persistent, but will delete automatically after two (2) years if you no longer
engage in our online Activities. 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 online Activities to social
media platforms 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 online
Activities. We encourage you to review each provider's privacy information
before using any such service. Further details on our use of social media
widgets and applications are described in Section 1.2.

Persistent, but will be deleted automatically after two years if you no longer
engage in our online Activities




Other third-party tools and widgets may be used on our individual websites or
portions of certain online Activities to provide additional functionality.
Depending on how you set your preferences in your browser and/or the cookie
banner, 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 properly.

Cookies by themselves do not tell us your personal information or otherwise
identify you personally.

BY ACCESSING, USING, OR ENGAGING IN OUR ONLINE ACTIVITIES, OR ENTERING YOUR
LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE,
OR A THIRD PARTY ACTING ON OUR BEHALF, CAN PLACE THESE COOKIES ON YOUR
INTERNET-ENABLED DEVICE

1.1.3 Interest-Based Advertising

We use "interest-based" ads, also known as “online behavioral advertising."
Interest-based advertising is advertising that is targeted to you based on your
web browsing and app usage over time and across websites or apps. You have the
option to restrict the use of information for interest-based advertising and to
opt-out of receiving interest-based ads. We may partner with ad networks and
other advertising providers (“Advertising Providers”) who serve ads on behalf of
us and others on non-affiliated sites. Some of these third parties may use
cookies and other technologies to collect information about your online
activities over time and across third party websites or online services to
deliver advertising based on your interests and preferences, as inferred from
your browsing history. Some of these ads may be personalized, meaning that they
are intended to be relevant to you based on information that KPMG and its
Advertising Providers collect about your visits to this site and elsewhere over
time.

To learn more about this type of advertising and how to opt-out of this form of
advertising, you may either visit www.aboutads.info to opt-out of sites and
services participating in the Digital Advertising Alliance (“DAA”)
self-regulatory program, or visit www.networkadvertising.org/choices to opt-out
of this form of advertising by members of the Network Advertising Initiative
(“NAI”). Note that electing to opt out will not stop advertising from appearing
in your browser or applications, although it may make the ads you see less
relevant to your interests. This opt-out works through cookies set on a
particular browser, so if you delete cookies from a web browser, or use a
different browser, you will need to opt out again.

Your choice to opt out on a particular browser or device will apply only to the
collection and use of information from that particular browser or device. Opting
out on a particular device will not opt you out of information collection on
other devices, nor will it limit cross-device sharing on those other devices. If
you use different browsers on a device or multiple devices, for each browser and
device you wish to opt out, please opt out each device and browser separately
at www.aboutads.info/choices.

1.1.4 Do Not Track

Our online Activities may not recognize web browser based “Do Not Track”
signals. However, as discussed in Section 1.1.2, you may be able to modify your
Internet-enabled device’s web browser settings to block all cookies, or to block
“third-party” cookies. Cookies that we set on our online Activities are
considered “first-party” cookies. Details on your ability to restrict or change
the personal information that we may collect about you are listed below under
the following sections of this Privacy Statement: Choice (Section 3), Access
(Section 4), Additional Disclosures for California Residents (Sections 6) and
Additional European Union Notices (Section 7). 

1.1.5 Usage Analytics

KPMG uses third-party usage analytics tools as part of our online Activities,
including Google Analytics, which may be subject to separate privacy policies.
More information about how Google Analytics is used by KPMG can be found
here: https://policies.google.com/technologies/partner-sites.

To provide website visitors with more choice on how their data is collected by
Google Analytics, Google has 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 us or to other web analytics services.

1.1.6 Web beacons

A web beacon is a small image file on a web page that can be used to collect
certain information from your Internet-enabled device, such as an IP address,
the time the content was viewed, a web 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 third-party providers may use web beacons to track the effectiveness
of third-party websites 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 online Activities (e.g., newsletters and other communications),
we and third-party providers operating on our behalf, 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 maintain and improve our
online Activities and such third-parties’ services.

Please be aware that if you opt to render some web beacons unusable, you may not
be able to fully experience some of the features of our online Activities.

1.1.7 Location-based tools

KPMG and its service providers may collect and use the geographical location of
your Internet-enabled device (e.g., via tracking beacons, Bluetooth or GPS) in
connection with certain Activities, but only with your express permission. With
respect to the collection of precise information about the location of your
device, once you have consented to the collection you may adjust or withdraw
this permission at any time by managing your “Location Services” preferences
through your device’s settings. This location data is collected for the purpose
of providing you with information regarding our Activities, products and
services which we believe may be of interest to you based on your geographic
location, and to improve our location-based Activities, responses to requests,
products and services.

Please be aware that if you opt to exercise your right to alter, or altogether
turn off, location-based services on your device, you may not be able to fully
experience some of the features of our Activities.

1.2 Social media widgets and applications

Our online Activities may include functionality to enable sharing via third
party social media platforms (e.g., Facebook, Twitter and LinkedIn), or allow
you to use your social media platform credentials to log into and access our
online Activities. These social media platforms may collect and use personal
information regarding your use of our online Activities (see details on
“Social Sharing” cookies discussed in Section 1.1.2). Please be aware that
certain personal information that you provide via such social media platforms
may be collected and used by the social media platform provider and such
interactions are governed by the privacy policies of those providers. We do not
have control over, or responsibility for, those companies, or their use of your
personal information. If you do not agree to such social media platform terms or
privacy policy, do not use such social media platforms. 

In addition, our online Activities may feature 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 information 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. 

1.3 Children

KPMG understands the importance of protecting children's privacy, especially in
an online environment. Our Activities are not intentionally designed for or
directed at children under the age of 13. It is our policy never to knowingly
collect or maintain personal information about anyone under the age of 13,
except as part of an engagement to provide professional services.

2. Sharing and transfer of Personal Information

We do not share personal information with unaffiliated third parties, except as
stated in this Privacy Statement, including as necessary for our legitimate
professional and business needs, to carry out your requests, to allow you to
engage in our Activities, and to market our products or services, including in
coordination with other service providers for joint-marketing purposes,
as required or permitted by law or professional standards, or otherwise with
your permission.

In some instances, KPMG may share personal information about you with various
third-party providers working on our behalf. KPMG requires these entities to
safeguard personal information in the same manner as KPMG.

KPMG may also disclose personal information in order to respond to lawful
requests of government or law enforcement agencies, including to meet national
security or law enforcement requirements or where disclosure is required by
applicable laws, court orders, government regulations, or professional rules. In
the event, that the ownership of KPMG or an affiliate or their assets changes as
the result of a merger, acquisition, or sale of assets, information owned or
controlled by KPMG may be transferred to another company. Information may also
be shared in connection with the consideration, negotiation or completion of a
corporate transaction in which we are acquired by or merged with another company
or we sell, liquidate, assign or transfer all or a portion of our assets.
These disclosures may also be needed for data privacy or security audits and/or
to investigate or respond to a complaint or security threat.

KPMG does not sell personal information to third parties. KPMG and our
third-party providers may use personal information in an anonymized form for
research and development. This data does not identify you individually, but
rather helps to identify trends in user preferences and behaviors. In addition,
we may share de-identified reports on user demographics and traffic patterns, as
well as de-identified information, with third parties. 

Cross-Border Collection and Transfer. We may directly collect personal
information from or about you if you are in a jurisdiction other than the U.S.
to provide you with services associated with the Activities. Similarly, if you
are in the U.S., we may transfer outside of the U.S. the information we collect
from or about you outside of the U.S. Regardless of where you are, we may
transfer certain personal information across geographical borders to other
member firms affiliated with KPMG International or to various third party
providers working on our behalf, or we may receive personal information in the
U.S. or elsewhere transferred from another member firm affiliated with KPMG
International or an unaffiliated third party. KPMG may also store personal
information in a jurisdiction other than where you are based, and such
jurisdiction may not provide the same level of protection for your personal
information as your home country. By providing your personal information to
KPMG, you understand that your personal information may be collected,
transferred and/or stored in a jurisdiction other than your home country. Each
member firm affiliated with KPMG International is required to safeguard personal
information in accordance with its contractual obligations and data protection
legislation applicable to its provision of services. Your personal information
will only be transferred if appropriate or suitable safeguards are in place. If
you are located outside of the U.S., you may have additional rights as described
in Section 7. 

3. Choices

We may require you to provide certain personal information in order to receive
additional information about our Activities. KPMG may 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 Activities (e.g., an online
newsletter), you will be able to unsubscribe at any time by following the
instructions included in each communication. If you decide to unsubscribe from
an Activity, we will try to remove your personal information promptly, although
we may require additional information or confirmation before we can process your
request.

As described in Section 1.1.2, if you wish to prevent cookies from tracking you
as you engage in our online Activities, you may be able to do so by changing
your web browser settings on your Internet-enabled device. Note, however, that
some portions of our online Activities may not work properly if you elect to
refuse cookies. In addition, Section 1.1.3 provides information about how you
can make choices around Interest-Based Advertising and the advertisements
presented to you by our Advertising Partners.

4. Data Privacy Requests

If you have submitted your personal information to KPMG, you may have the right
to request, under applicable law, that KPMG provide you with reasonable access
to your personal information, update or correct any inaccuracies in your
personal information, or delete your personal information, and, in any such
event, KPMG will make all reasonable and practical efforts to comply with your
request, so long as our doing so would be consistent with applicable law, KPMG’s
contractual requirements, and/or the professional standards applicable to KPMG. 

To make a Data Privacy Request, please contact us by:

 * Submitting a Data Privacy Request through our webform;
 * Emailing us-privacy@kpmg.com; or
 *  Calling toll-free at 1-844-977-1440.

5. Data security and integrity

KPMG has and requires its service providers to have security policies and
procedures in place to help protect personal information from unauthorized loss,
misuse, alteration or destruction. Despite KPMG’s efforts, however, security
cannot be guaranteed against all threats. We seek to limit access to your
personal information to those who have a need to know and require those
individuals to maintain the confidentiality of such information. We also make
efforts to retain personal information only for so long as the information is
needed for our professional, marketing or analytic purposes or to comply with
legal requirements, professional standards or an individual’s request, or until
that person asks that the information be deleted.

6. Additional Disclosures for California Residents

This section applies to any California residents about whom we have collected
personal information as part of engaging in our Activities.

For purposes of this section, “personal information” means information that
identifies, relates to, describes, is reasonably capable of being associated
with, or could reasonably be linked, directly or indirectly, with a particular
California consumer or household; “household” means a person or group of people
who: (i) reside at the same address, (ii) share a common device or the same
service provided by a business, and (iii) are identified by the business as
sharing the same group account or unique identifier. Personal information does
not include publicly available information or information that has been
de-identified.

6.1 Information We Collect

The types of personal information we collect about you will depend on
your relationship with KPMG. For example, in many cases, we may collect personal
information from our business clients during an engagement to provide products
and services to our clients; our collection and use of such personal information
is governed by our contract with that entity. In other cases, we may collect
personal information directly from consumers or households that engage in
Activities. 

We may collect the following categories of personal information about you or
members of your household:

 * Identifiers, which may include real name and alias; postal address; unique
   personal identifier; online identifiers as detailed below; IP address; email
   address; telephone number; account number, name and password; Social Security
   number; driver’s license number, passport number, state or other
   government-issued identification card number; and/or other similar
   identifiers;
 * Commercial information, which may include records of personal property;
   products or services purchased, obtained, or considered; account balances,
   payment history, or account activity; bank account information and other
   information relating to your financial institution; credit application,
   credit checks, and information from credit reporting agencies; and/or other
   purchasing or consumer histories or tendencies;
 * Biometric information, which may include fingerprints; facial scans; voice
   recognition information; genetic information; and/or other similar biometric
   identifiers;
 * Information relating to Internet activity or other electronic network
   activity, which may include cookie identifiers, clear gifs, browser type,
   Internet service provider (“ISP”), referring/exit pages, operating system,
   date/time stamp, clickstream data, device platform, device version and/or
   other device characteristics including your choice of settings such as Wi-Fi,
   Bluetooth and GPS data;
 * Geolocation data, which may include GPS data; locational information based
   upon your IP address; cell network data; and/or other similar locational
   data;
 * Audio, electronic, or visual information, which may include records of calls
   to or from our customer service centers; and/or video surveillance
   information;
 * Professional or employment-related information, which may include information
   regarding your current and previous employers; job title and
   responsibilities; assets; income; and/or other information related to your
   work history and/or prospective employment;
 * Education information, which may include academic record, degrees and
   educational history;
 * Inferences about you, which may include preferences and characteristics and
   other information we may infer from other personal information we have
   collected;
 * Information not listed above and related to characteristics protected under
   California or federal law; which may include gender; race and ethnicity;
   nationality; marital status; military service or veteran status; and/or date
   of birth; and
 * Other personal information not listed above and described in the California
   Customer Records Act, California Civil Code Section 1798.80(e), which may
   include signature, physical characteristics or description, insurance policy
   number, bank account number, credit card number, debit card number, and/or
   any other financial, medical or health insurance information.

6.2 Purposes and Sources of Collection

We may collect or use personal information for the following purposes:

 * Administer, maintain and improve our Activities;
 * Assessing third-party providers and service providers;
 * Auditing and compliance with policies, procedures, laws, regulations and/or
   professional standards, including for auditor independence checks;
 * Billing, payment and fulfillment;
 * Customer and client communications;
 * Customer and client relationship management;
 * Financial reporting and accounting;
 * General business administration;
 * Health, safety, and wellness of our workplace, facilities and workforce;
 * Internal analytics and benchmarking;
 * Marketing our Activities;
 * Marketing the products and services of KPMG International, other member firms
   affiliated with KPMG International or other third parties;
 * Protect against fraud and other malicious or illegal activity, including for
   anti-money laundering and know-your-client checks;
 * Provision and performance of the services; and
 * systems and data security.

We may collect personal information from the following sources, including, but
not limited to via applications and forms, collaboration platforms,
communications and interactions with us and through our in-person events or
meetings and online Activities such as websites and mobile applications:

 * Our clients and customers and prospective clients and customers, or their
   authorized representatives;
 * Our subsidiaries, affiliates, joint ventures, and other companies under our
   common control (collectively, "Affiliates");
 * KPMG International;
 * Other member firms affiliated with KPMG International;
 * Our service providers, such as customer relationship management providers,
   analytics providers, website hosting providers, systems administrators and
   communications delivery services;
 * Unaffiliated third parties with which we have a business relationship and/or
   promotional and joint-marketing partners;
 * Social media platforms providers, online communities and forums and online
   advertising providers and partners;
 * Employees, contractors, KPMG alumni and job applicants;
 * Government entities and databases, such as anti-fraud databases, sanctions
   list and court judgments; and
 * Publicly available sources.

6.3 Disclosures of Personal Information

6.3.1 Categories of Third Parties with Whom We Share Personal Information

We may share personal information as described in this Privacy Statement,
including with the following categories of third parties:

 * Affiliates. We may share personal information with our Affiliates. 
 * KPMG International. We may share personal information with KPMG
   International.
 * Member Firms. We may share personal information with other KPMG member firms
   affiliated with KPMG International.
 * Technical and Operational Service Providers and Business Partners. We may
   engage third parties to perform certain functions on our behalf. To do so, we
   may disclose personal information to our third-party business partners and
   service providers in order to maintain and operate the websites and provide,
   improve, and personalize the services, including to fulfill requests for the
   services and for other technical and processing functions, such as sending
   e-mails on our behalf, fulfilling orders, and technical support. We may also
   share personal information to service providers or other third parties to
   detect, protect against, and respond to security incidents or other
   malicious, deceptive, illegal, or fraudulent activity or other threats.
 * Marketing, Advertising and Analytics Providers. We may share personal
   information with third-party providers for marketing, advertising and
   analytics purposes.
 * Government Entities. We may share personal information with government
   entities and agencies, regulators, law enforcement, and other third parties,
   including to provide the services, comply with applicable laws and
   regulations, to respond to a subpoena, search warrant, or pursuant to legal
   process and to establish or exercise our legal rights or for fraud- or
   crime-prevention purposes.
 * Professional Service Firms. We may share personal information with other
   professional service firms in connection with our legal, regulatory and
   professional obligations and to establish or exercise our rights and defend
   against claims, including, for example, auditors, law firms, insurers and
   consultants.
 * Corporate Transactions. Subject to applicable law, we reserve the right to
   transfer some or all personal information in our possession to a successor
   organization in the event of a merger, acquisition, bankruptcy, or other sale
   or transfer of all or a portion of our assets. If any such transaction
   occurs, the purchaser will be entitled to use and disclose the personal
   information collected by us in the same manner that we are able to, and the
   purchaser will assume the rights and obligations regarding personal
   information as described in this Privacy Statement.

6.3.2 Disclosures of Personal Information for Business or Commercial Purposes

We may have disclosed the following types of personal information to third
parties or service providers for a business or commercial purpose in the
previous twelve (12) months:

 * Identifiers;
 * Commercial information;
 * Biometric information;
 * Information relating to Internet activity or another electronic network
   activity;
 * Geolocation data;
 * Audio, electronic, or visual information;
 * Professional or employment-related information;
 * Education information;
 * Inferences about you;
 * Information not listed above and related to characteristics protected under
   California or federal law; and
 * Other personal information not listed above and described in the California
   Customer Records Act, California Civil Code Section 1798.80(e).

6.3.3 Sales of Personal Information

We do not sell personal information and did not sell personal information in the
previous twelve (12) months.

6.4 Your Privacy Rights

You may be entitled by applicable law to exercise the following rights with
respect to your personal information:

 * Right to Know. You have the right to request what personal information we
   collect, use, disclose and/or sell, as applicable.
 * Right to Delete. You have the right to request that we delete the personal
   information that we have collected about you.
 * Right to Opt-out of the Sale of Personal Information. You have the right to
   request to be opted-out from the sale of your personal information. However,
   as described in Section 6.3.3, we do not sell personal information.
 * Right to Non-discrimination. You have the right not to receive discriminatory
   treatment by us for the exercise of the privacy rights described above. 

You may also authorize someone to exercise the above rights on your behalf. If
we have collected information on your minor child, you may exercise the above
rights on behalf of your minor child.

To exercise any of your rights, please contact us by:

 * Submitting a Data Privacy Request through our webform; 
 * Emailing us-privacy@kpmg.com; or
 * Calling toll-free at 1-844-977-1440. 

We will respond to authorized and verified requests as soon as practicable and
as required by law, including any reason for denying or restricting a request.
Please note that, where we have received your personal information through our
business clients or where we are otherwise operating as a service provider, we
may refer you to the business with whom you have a direct relationship in order
to implement your request, pursuant to applicable law. 

In addition, the above rights are subject to various exclusions and exceptions
under applicable laws, and under certain circumstances, we may be unable to
implement your request. 

7. Additional Non-U.S. Data Subject Notices

KPMG provides our Activities in the U.S. and does not direct such activities to
data subjects that are located outside of the U.S. However, in certain
circumstances, we do interact with or collect personal information about data
subjects outside of the U.S. In such circumstances, we typically collect
personal information from data subjects outside of the U.S. through a direct
collection of that information via our Activities. However, in some
circumstances, personal information may be transferred to us from KPMG
International, a member firm affiliated with KPMG International or an
unaffiliated third party outside of the U.S. Where this applies, we typically
receive your personal information because it is necessary to perform a contract
or pre-contractual measures with you or because of our legitimate interests. If
we receive personal information transferred by a member firm affiliated with
KPMG International or an unaffiliated third party, it would typically be
pursuant to the appropriate foreign regulator-approved standard contractual
clauses or based on another lawful basis. To know more about additional non-U.S.
data subject notices and rights, please review our Notice of Processing.

8. Privacy Shield Frameworks

KPMG complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S.
Privacy Shield Framework (collectively, “Privacy Shield”) as set forth by the
U.S. Department of Commerce regarding the collection, use, and retention of
personal information from the European Union, United Kingdom, and Switzerland,
as applicable to the U.S., in reliance on Privacy Shield. KPMG has certified to
the U.S. Department of Commerce that it adheres to the Privacy Shield Principles
with respect to such personal information. Please review our Privacy Shield
Statement for information about KPMG’s data practices regarding personal
information it has received from the European Union, United Kingdom, and
Switzerland pursuant to Privacy Shield. To learn more about the Privacy Shield
program, and to view our certification page, please
visit: www.privacyshield.gov.

Following recent decisions invalidating the adequacy of Privacy Shield, we no
longer rely on Privacy Shield for cross-border transfers of personal
information. As described in Section 7, we rely on the direct collection of
personal information from individuals located outside of the U.S., or we use
other bases, such as standard contractual clauses for cross-border transfers of
personal information from another entity to us.

 

9. Links to Other Sites

Please be aware that our Activities may contain links or refer you to other
websites, applications, social media platforms, collaboration platforms,
products and services maintained by KPMG International, other member firms
affiliated with KPMG International, or by unaffiliated third parties
(collectively, “Other Sites”). Other Sites are not governed by this Privacy
Statement, but by other privacy statements that may differ. KPMG is not
responsible for the content or practices of these Other Sites. We encourage
users to review the applicable privacy policies of these Other Sites visited
before disclosing any personal information.

10. Changes to This Privacy 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. We encourage you to periodically review
this Privacy Statement to be informed about how KPMG is protecting your personal
information. Your continued use after each such update is your consent to such
updated terms. 

11. Questions and Comments

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 by email at us-privacy@kpmg.com. You may also
contact us to communicate any concerns you may have regarding compliance with
this Privacy Statement.

 

1"KPMG,” “we,” “our,” and “us” refers to KPMG LLP, a Delaware limited liability
partnership and the U.S. member firm of the KPMG global organization of
independent member firms affiliated with KPMG International Limited (“KPMG
International”), a private English company limited by guarantee. KPMG
International and its related entities do not provide services to clients.



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