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KROLL PRIVACY POLICY

 * INTRODUCTION
 * WHO IS COLLECTING DATA
 * DATA WE COLLECT
 * PROCESSING OF PERSONAL DATA
 * HOW DATA IS PROCESSED
 * STORAGE OF PERSONAL DATA
 * DISCLOSURE/SHARING OF PERSONAL DATA
 * CROSS-BORDER TRANSFERS
 * YOUR RIGHTS
 * AUTOMATED DECISION MAKING
 * PROVIDING INFORMATION TO KROLL
 * THIRD PARTY WEBSITES OR SERVICES
 * CONTACT US 

 

INTRODUCTION

Kroll, LLC (formerly Duff & Phelps LLC), including all affiliates and
subsidiaries (collectively "Kroll"), is committed to complying with the
applicable data privacy and security requirements in the countries in which it
operates. Kroll complies with internationally recognized standards of privacy
protection, and with various privacy laws globally including, but not limited
to, the EU General Data Protection Regulation (GDPR). This Privacy Notice
applies when providing valuation advisory, corporate finance, restructuring,
governance, risk, investigations, disputes, intelligence, diligence, compliance
and regulatory consulting, cyber risk, or other services (the "services") to its
customers.

Please see separate privacy policies regarding the below services:

 * Restructuring Advisory Privacy Notice which applies when an insolvency
   practitioner of Kroll is appointed as office holder and data processing is
   carried out as part of their statutory duties.
 * Restructuring Administration Privacy Notice which applies when Kroll provides
   Restructuring Administration Services.
 * Settlement Administration Privacy Notice which applies when Kroll provides
   Settlement Administration Services

If you are a California resident, please see our CCPA Privacy Policy to learn
about your rights under the California Consumer Privacy Act.

If you are a Virginia resident, please see our Virginia Privacy Notice to learn
about your rights under the Virginia Consumer Data Protection Act.



WHO IS COLLECTING DATA?

Data will be collected by Kroll LLC (or its affiliates and subsidiaries,
collectively "Kroll"). This policy applies to personal data which is collected
and/or used by Kroll in its capacity as a data controller as that term is
defined in the GDPR and similar privacy laws, for the purposes set out below
under Processing of Personal Data.

When Kroll provides services to clients, we sometimes process personal data as a
data processor, meaning that we process the data solely on the instructions of
our clients, who determine the purpose and means of processing and exercise
overall control of the data (for example, the hosting of client data on our
web-based due diligence portal). Therefore, if you have questions or wish to
exercise your rights relating to your personal data, you may need to contact the
client (and controller) on whose behalf the processing of your data is carried
out. If we receive a request from you relating to data controlled by a client,
we will pass the request to the appropriate client (and controller) where
permitted by applicable privacy law.



DATA WE COLLECT

Kroll collects the following categories of personal data:

Contact data: We may collect information about data subjects such as name and
contact details (email, phone number, etc.) in order to communicate and
facilitate the provision of our services with our clients or potential clients.
For example, contact details of individuals who work for or on behalf of the
clients, in order to carry out the client’s engagement with Kroll.

Services data: Personal data may be provided to us by clients to the extent
required to perform the services. Kroll may also acquire personal data from a
third party at the direction of our client as required to perform services.

Marketing information: We may collect information to respond to inquiries
regarding our products and services or to provide you with information, reports,
or updates.

Website visitor information: when you visit our website, we may collect
information about your visit such as your IP address and the pages you visited
and when you use our services we may collect information on how you use those
services. Please see our Website Use and Cookies Policy for additional
information.

Clients and other Third parties who provide personal information to Kroll must
do so in compliance with applicable data privacy regulations.



PROCESSING OF PERSONAL DATA

We collect personal data to offer and administer our services and products.
These include valuation advisory, corporate finance, restructuring, governance,
risk, investigations, disputes, intelligence, diligence, compliance and
regulatory consulting, and cyber risk services.

Except as otherwise stated in the privacy policy applicable to the affiliate
providing the services,(Kroll Restructuring Administration’s policy is available
here  and Kroll Settlement Administration’s policy is available here ) , the
data you provide to us will be processed in accordance with the purposes
specified in this notice, namely:

 * For complying with obligations provided by laws, current regulations and
   legislation (e.g. tax regulations, anti-money laundering regulations)
 * Where the processing is necessary for the performance of a contract or in
   order to take steps at your request prior to entering into a contract (e.g.
   where you request certain Services as an individual client, or perform
   certain services as an individual service provider)
 * where the processing is necessary for our legitimate business interests in
   conducting and managing our business, including: To provide the products or
   perform the services requested by clients and individuals pursuant to a
   letter of engagement, statement of work, or similar To provide the products
   or perform the services requested by clients and individuals using our
   website or web applications Where permitted by applicable law, to advise you
   through e-mail, phone call, or post, in the framework of our ordinary
   commercial relationship, about other products or services similar to the
   products or services we have provided to you and that we think will be of
   interest to you For hosting of events (including webinars). We may use your
   data to manage your registration to a Kroll event, including sharing data
   with event co-hosts and tracking and facilitating event attendance. For
   improving Kroll’s communications with you. Emails sent to you by Kroll may
   include standard tracking, including open and click activities. Kroll may
   collect information about your activity as you interact with our email
   messages and related content. For operating and improving Kroll’s website and
   your customer experience. For example, we may collect and analyze data on
   your use of our website and process it for the purpose of improving our
   online experience. Please see our Website Use and Cookies Policy for
   additional information. For security purposes. For example, we may use your
   data to protect Kroll and its third parties against security breaches and to
   prevent fraud and violation of Kroll’s applicable agreements
 * For marketing purposes. For example, we may use your information to further
   discuss your interest in the Services and to send you information regarding
   Kroll and its group companies such as information about promotions, events,
   products or services. If you are located in the EU, UK, Australia, Japan, or
   Singapore, we will only send you marketing communications and updates about
   our products, services and events with your prior consent or based on our and
   your legitimate interests where permitted. In either case, you can withdraw
   your consent or opt-out or receiving such communications at any time. If you
   are not located in the EU, UK, Australia, Japan, or Singapore, you may
   opt-out of receiving marketing communications and updates at any time. You
   can manage your receipt of marketing and non-transactional communications by
   clicking on the «unsubscribe» link located on the bottom of Kroll’s marketing
   emails. Additionally, you may send a request to Kroll.privacy@kroll.com.
 * With your consent. Kroll also processes your data for other purposes if you
   have provided us consent for such specified purposes, where such other
   purposes will be clearly provided at the time you provide consent.

Whenever we process your personal data for our legitimate interests, we make
sure to consider and balance any potential impact on you and your rights under
data protection laws. Our legitimate business interests do not automatically
override your interests - we will not use your personal data for activities
where our interests are overridden by the impact on you (unless we have your
consent or are otherwise required or permitted to by law). You have the right to
object to this processing if you wish.



HOW DATA IS PROCESSED

Personal data is processed both manually and electronically in accordance with
the above-mentioned purposes and in compliance with current regulations. We
permit only authorized Kroll employees and Third-Party processors to have access
to your information. Such employees and Third-Party processors are appropriately
designated and trained to process data only according to the instructions we
provide them.



STORAGE OF PERSONAL DATA

Kroll will retain personal data for a reasonable period, taking into account
legitimate business needs to capture and retain such information. Information
will also be retained for a period necessary to comply with state, local,
federal regulations, or country specific regulations and requirements, and in
accordance with Kroll’s Document Retention Schedule.



DISCLOSURE/SHARING OF PERSONAL DATA

We only share your personal data with your consent or in accordance with this
policy. We will not otherwise share, sell or distribute any of the information
you provide to us except as described in this Privacy Notice.

 * We share personal data among Kroll-controlled affiliates and subsidiaries who
   act for Kroll for the purposes set out in this notice.
 * Kroll may share your information with external third parties, such as
   vendors, consultants and other service providers who are performing certain
   services on behalf of Kroll. Such third parties have access to personal data
   solely for the purposes of performing the services specified in the
   applicable service contract, and not for any other purpose. Kroll requires
   these third parties to undertake security measures consistent with the
   protections specified in this notice.
 * Kroll may be required to disclose personal data in response to lawful
   requests by public authorities, including meeting national security or law
   enforcement requirements.
 * If Kroll’s business enters into a joint venture with or is merged with
   another business entity, your information may be disclosed to our new
   business partners.

 

CROSS – BORDER TRANSFERS OF PERSONAL DATA

Kroll is a global firm with operations in over 30 countries. Personal
information may be transferred, accessed and stored globally as necessary for
the uses stated above in accordance with this notice, and in compliance with
local regulations.

Personal Data may be transferred to or processed in locations outside of the
European Economic Area (EEA), some of which have not been determined by the
European Commission to have an adequate level of data protection. In that case,
for personal data subject to European data protection laws, we take measures
designed to provide the level of data protection required in the EU, including
ensuring transfers are governed by the requirements of the Standard Contractual
Clauses adopted by the European Commission, or another adequate transfer
mechanism. Kroll entities have entered into intragroup transfer agreements based
on the Standard Contractual Clauses which allows for the processing and transfer
of personal data.

Where we receive requests to disclose personal data from law enforcement or
regulators, we carefully validate these requests, including reviewing the
legality of any order and challenging the order if there are grounds under the
law to do so, before any personal data is disclosed.



YOUR RIGHTS

Depending on the laws of the jurisdiction governing the processing of your
personal data, you may have certain rights under applicable data protection laws
including:

 * Access: You have the right to access personal information that Kroll holds
   about you.
 * Rectification: You have the right to ask us to rectify information Kroll
   holds about you if it is inaccurate or not complete.
 * Erasure: You can request that Kroll erase your personal data. We will keep
   basic data to identify you and retain it solely for preventing further
   unwanted processing.
 * Restrict Processing: You have the right to ask Kroll to restrict how we
   process your data. This means we are permitted to store the data but not
   further process it. We keep just enough data to make sure we respect your
   request in the future.
 * Object to processing: Where processing is based on legitimate interests, you
   have the right to object to Kroll processing your data. Kroll will
   discontinue processing your data, unless we can demonstrate compelling
   legitimate grounds for the processing. We will keep basic data to identify
   you and retain it solely for preventing further unwanted processing.
 * Portability: Where processing is based on consent or performance of a
   contract, you have the right to data portability. Kroll must allow you to
   obtain and reuse your personal data for your own purposes in a safe and
   secure way without this effecting the usability of your data. This right only
   applies to personal data that you have provided to Kroll as the Data
   Controller.

Please contact kroll.privacy@kroll.com to request access, rectification, or
erasure, or to restrict processing, to object to processing, to request data
portability. Please note that Kroll cannot facilitate the exercise of your
rights without proper verification of your identity.

Subject to legal considerations or certain exemptions, we may not always be able
to address your request, for example if it would impact the duty of
confidentiality we owe to others, or if we are legally entitled to deal with the
request in a different way.

Requests received via post may be delayed due to limited office access during
the Covid-19 pandemic. Please contact us by email to ensure your request is
received in a timely manner.



AUTOMATED DECISION MAKING

Automated decisions are defined as decisions about individuals that are based
solely on the automated processing of data and that produce legal effects that
significantly affect the individuals involved.

Kroll does not make automated decisions using personal data. If automated
decisions are to be made, affected persons will be given an opportunity to
express their views on the automated decision in question and object to it.



PROVIDING INFORMATION TO KROLL

If you choose not to provide certain personal information, it may be an
impediment to the exchange of information necessary for the execution of the
contract or provision of services, and we may not be able to provide you with
some services and you may not be able to participate in some of the activities
on our website(s).



THIRD PARTY WEBSITES OR OTHER SERVICES

We are not responsible for the privacy practices of any non-Kroll operated
websites, mobile apps or other digital services, including those that may be
linked through Kroll websites or services, and we encourage you to review the
privacy policies or notices published thereon.



CONTACT US

Please contact us at Kroll with questions, concerns, or complaints:

Requests received via post may be delayed due to limited office access during
the Covid-19 pandemic. Please contact us by email to ensure your request is
received in a timely manner.

Kroll Corporate Headquarters
55 E 52 Street
New York, NY 10055
kroll.privacy@kroll.com

If you are in the EU:

Kroll EU Data Protection Officer: Daniela Mosca

 * Email: daniela.mosca@kroll.com
 * Telephone +39.039.64.23.812
 * Post: Daniela Mosca at Kroll Advisory Holding SpA, Centro Direzionale
   Colleoni, Palazzo Cassiopea 3, 7th Floor, Via Paracelso 26, 20864 Agrate
   Brianza (MB) - Italy 

For data subjects located in the EU: if we are not able to satisfactorily
resolve your questions, concerns, or complaints, or if you believe that the
processing of your personal data infringes on your rights under applicable data
protection laws, you have the right, without prejudice to any other
administrative or judicial remedies, to lodge a complaint with a supervisory
authority, in particular, in the Member State of your habitual residence, place
of work or place of the alleged infringement. Contact information for the
supervisory authorities may be found here: EU Data Protection Authorities

Kroll Cayman Islands Representative

Where Kroll processes personal data in the Cayman Islands, the Cayman Islands
local representative, pursuant to the Cayman Islands Data Protection Act will
be  Kroll Advisory (Cayman) Ltd.


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