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Welcome to Deloitte Caribbean & Bermuda Countries - English
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PRIVACY NOTICE

Last updated: 14 September 2023

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INTRODUCTION

We are committed to protecting your privacy

WE ARE COMMITTED TO PROTECTING YOUR PRIVACY.


This Privacy Notice explains what Personal Information we, DCB Holding Ltd. with
registered office at Woodburne Hall, Road Town, Tortola, VG1110, British Virgin
Islands (also known as "Deloitte Caribbean and Bermuda Countries" or "Deloitte
CBC"), collects about you, what we use it for, who we share it with and how we
protect it. It also sets out your rights and who you can contact for more
information or queries.

This Privacy Statement applies only to the specific webpages of deloitte.com
designated as “Caribbean & Bermuda Countries” and which are provided by Deloitte
Touche Tohmatsu Limited (“DTTL" or "Deloitte Global”). Such webpages only are
referred to below as “this Website”.

Deloitte CBC operates as a network of affiliated country practices under the
banner of a single DTTL member firm. “Country practices” refers to any Deloitte
legal entity operating in the Bahamas, Barbados, Bermuda, the British Virgin
Islands, the Cayman Islands and Trinidad & Tobago (also referred to below as
“we”, “us” or “our”). This Privacy Statement explains how we protect visitors’
information gathered via this Website.

When used in this Privacy Notice, “we”, “us” and “our” refer to Deloitte CBC. In
this Privacy Notice, information about you, which may be referred to as personal
data in some jurisdictions, is referred to as “Personal Information”. Personal
Information refers to information that identifies, relates to, describes, is
capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular individual.

We may also sometimes collectively refer to handling, collecting, protecting,
and storing your Personal Information as “processing” such Personal Information.

This Privacy Statement may be supplemented by privacy statements that are
specific to each country practice. For more details please review the specific
privacy statement governing that country practice:
• Bahamas
• Barbados
• Bermuda
• British Virgin Islands
• Cayman Islands
• Trinidad & Tobago


As used in this Privacy Notice, "Deloitte Network" refers to one or more of
DTTL, its network of member firms and their related entities. DTTL and each of
its member firms are legally separate and independent entities. Please
see www.deloitte.com/about for a detailed description of the legal structure of
DTTL and its member firms.



ABOUT OTHER AREAS OF DELOITTE.COM



Deloitte.com includes webpages provided by other entities of the Deloitte
Network, which are designated according to the geography identified in the upper
right-hand corner of the webpage. These webpages are provided by the designated
entities and are not the responsibility of Deloitte Global. Such webpages, as
well as other websites that may be linked to the Website, are not governed by
this Privacy Notice. We encourage you to review the applicable privacy notices
on those webpages, which will inform you about who the related controller is and
provide further information with respect to its processing of your Personal
Information.



WHAT PERSONAL INFORMATION WE COLLECT



We may collect and process your data because:

i.  you give it to us (for example, (1) through the webpages of this website or
any other website or application of Deloitte Global which links to this Privacy
Notice (collectively referred to as the “Website”), or (2) through any other
mode of interacting with you relating to Deloitte communications, such as online
or offline newsletters and magazines, that reference this Privacy Notice or link
thereto (“Communication”));

ii.  other people give it to us (for example, other entities of the Deloitte
Network or third- party service providers that we use to help operate our
business); or

iii.  it is publicly available.

When other entities of the Deloitte Network or other third-parties give us
Personal Information about you, we make sure they have complied with the
relevant privacy laws and regulations. This may include, for example, that it
has informed you of the processing, and has obtained any applicable and
necessary permission for us to process that information as described in this
Privacy Notice.

Log information, cookies and web beacons: We may process Personal Information
from you when you interact with the Website or Communications. For example, we
or our service provider(s) may also use cookies (small text files stored in a
user's browser) or web beacons (electronic images that allow us to count users
who have accessed particular content and to access certain cookies) to collect
aggregate data. Where applicable, additional information on how we may use
cookies and other tracking technologies, and how you can control these, can be
found in the Cookie Notice on the applicable Website. 

More information on how we use cookies and other tracking technologies on
Deloitte CBC's Deloitte.com website can be found in its Cookie Notice. 

The Personal Information we process may include your: name; current job title;
company name; (professional) e-mail address, country of residence, telephone and
fax number(s), physical address(es); business & industry interests; gender; date
of birth; marital status; employment and education details (such as learning
history, work experience and skills); CV; geolocation; certificate or license
number; account number; photograph, video or audio recording identifiable to an
individual; your postings on any blogs, forums, wikis and any other social media
applications that we provide; your IP address; your browser type and language;
your access times; complaint details; correspondence with you; the newsletters
you subscribe to; information relevant for entities of the Deloitte Network to
provide services to you; details of how you use Deloitte products or services,
 details of how you like to interact with us, and other similar information
relevant to our relationship, information we collect when you access our
premises; and any other information that you voluntarily provide to us. We may
also collect or obtain Personal Information from you because of the way you
interact with us or others.

Where we do not usually seek to collect ‘sensitive’ or ‘special categories’ of
Personal Information (e.g., data relating to race or ethnic origin, religious or
philosophical beliefs, trade union membership, political opinions, medical or
health conditions, or information specifying the sex life or sexual orientation
of an individual), the Personal Information we collect may include so called
‘sensitive’ or ‘special categories’ of Personal Information, such as details
about your:

 * dietary requirements (for example, when we would like to provide you with
   lunch during a meeting);
 * health (for example, so that we can make it easy for you to access our
   buildings, events).

We will only process these special categories of Personal Information when we
are required to do so as a result of legal requirements imposed on us or after
obtaining your explicit consent.

If you choose not to provide, or – where applicable - object to us processing
the information we collect (see section “Your rights” below), we may not be able
to process your instructions or provide you tailored communication, service, or
assistance.

We understand the importance of protecting children's privacy. Our Website is
not designed for, or intentionally targeted at, children 15 years of age or
younger. It is not our policy to intentionally collect or store information
about children.



INFORMATION USE



USE OF PERSONAL INFORMATION FOR OUR WEBSITE

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

 * verifying your identity when you log in to a Website;
 * managing and/or improving our Website;
 * managing and promoting collaboration and communication;
 * providing and documenting training and qualifications;
 * tailoring the content of our Website to provide you with a more personalized
   experience; 
 * managing our relationship with you and responding to any request you submit
   through our Website; 
 * drawing your attention to information about products and services that may be
   of interest to you;
 * conducting data analysis including, for example, regarding usage of the
   Website and demographics analyses of Website users;
 * preventing fraud or criminal activity and safeguarding our technology systems
   and data security;
 * monitoring and enforcing compliance with applicable terms of use, and that
   only authorized parties are accessing the Website.
 * complying with applicable legal or regulatory requirements;
 * dealing with requests and communications from competent authorities;
 * relationship management, which may involve: (i) sending you thought
   leadership or details of products and services provided by entities within
   the Deloitte Network that may be of interest to you; (ii) contacting you to
   receive feedback on these services; and (iii) contacting you for other market
   or research purposes; 
 * inviting you to attend events, seminars, participate in forums, etc.;
 * surveying you on Deloitte, business, societal and/or other relevant topics;
 * recruiting programs and events and business development;
 * investigating or preventing security incidents;
 * conducting and analyzing our marketing activities;
 * protecting our rights and/or those of other entities of the Deloitte Network.



LEGAL BASIS FOR PROCESSING INFORMATION



We are required by law to set out in this Privacy Notice the legal grounds on
which we rely in order to process your Personal Information. We rely on one or
more of the following lawful grounds when we use your Personal Information for
the purposes outlined above:

 * the processing is necessary for compliance with a legal obligation we have
   such as keeping records or providing information to a public body or law
   enforcement agency;
   
   
 * the processing is necessary for the purposes of a legitimate interest pursued
   by us or a third party (and are not outweighed by your privacy interests),
   such as the effective delivery of our Website and related services offered to
   you; the effective and lawful operation of our Website or Communications; to
   prevent fraud or criminal activity or to safeguard our technology systems
   and/or data security; to support or protect our business interests; to ensure
   that complaints are investigated; to evaluate, develop or improve our
   services or products; or

 * you have consented to us processing your information for a specific reason,
   consent that you can always withdraw.

To the extent that we process any sensitive Personal Information relating to you
for any of the purposes outlined above, we will do so because either: (i) you
have given us your explicit consent to process that data; (ii) we are required
by law to process that data, or (iii) the processing is necessary for the
establishment, exercise or defense of legal claims or (iv) you have made the
data manifestly public.

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



SENDING YOU MARKETING INFORMATION



We and other members of the Deloitte Network may use your information from time
to time to inform you by letter, telephone, email and/or other electronic
methods about products and services (including those of third parties) that may
be of interest to you. Where we are legally required to obtain your consent to
provide you with certain marketing materials, we will only provide you with such
marketing materials where we have obtained such consent from you.

You may, at any time, ask us not to send marketing information to you by
following the unsubscribe instructions in Communications from us, or contacting
us by using the “Contact information” section below.



DISCLOSURE OF INFORMATION TO THIRD PARTIES



In connection with one or more of the purposes outlined in the “Information use”
section above, we may disclose details about you to: other members of the
Deloitte Network for legitimate business-related purposes; third parties that
provide services to us and/or the Deloitte Network; as part of a corporate
transaction (such as a sale, divestiture, reorganization, merger or
acquisition); competent authorities (including courts and authorities regulating
us or another member of the Deloitte Network) and other third parties that
reasonably require access to Personal Information relating to you for one or
more of the purposes outlined in the “Information use” section above.

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

Please note that some of the recipients of your Personal Information referenced
above may be based in countries without data protection laws similar to those in
the UK or in effect in your area of residence. In such cases, we will ensure
that you consented to the transfer or that there are adequate safeguards in
place to protect your Personal Information that comply with our legal
obligations. For example, the adequate safeguard might be a data transfer
agreement with the recipient based on standard contractual clauses approved by
the UK Information Commissioner’s Office (ICO) for transfers of Personal
Information to third countries.

Further details of the transfers described above, and the adequate safeguards
used by us in respect of such transfers, are available from us. For such
information, please contact us by using the “Contact information” section below.

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.



SELLING OF INFORMATION



We do not sell your personal information.



BLOGS, FORUMS, WIKIS, AND OTHER SOCIAL MEDIA



The Website may host various blogs, forums, wikis and other social media
applications or services that allow you to share content with other users
(collectively referred to as “Social Media Applications”). Any Personal
Information or other information that you contribute to any Social Media
Application can be read, collected and used by other users of that Social Media
Application over whom we have little or no control. Therefore, we are not
responsible for any other user's use, misuse or misappropriation of any Personal
Information or other information that you contribute to any Social Media
Application.



PRIVACY PRACTICES OF THIRD PARTIES



This Privacy Notice addresses only the use and disclosure of information we
collect through your interaction with the Websites or Communications. Other
websites or applications that may be accessible through links from the Websites
and Communications have their own privacy notices and Personal Information
collection, use and disclosure practices. We encourage you to familiarize
yourself with the privacy notices provided by these other parties prior to
providing them with information.



DO NOT TRACK



"Do Not Track" is a preference you can set in your web browser to let websites
and applications you visit know that you do not want them collecting information
about you. The Websites do not currently respond to a "Do Not Track" or similar
signal.



INFORMATION SECURITY



We use a range of physical, electronic and managerial measures to keep your
Personal Information secure, accurate and up to date. These measures include:

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

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



INFORMATION RETENTION



We will hold your Personal Information 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.



YOUR RIGHTS



You have various rights in relation to your Personal Information. In particular,
you have a right to:

 * obtain confirmation that we are processing your Personal Information and
   request a copy of the Personal Information we hold about you;
 * ask that we update the Personal Information we hold about you, or ask that we
   correct such Personal Information that you think is incorrect or incomplete;
 * ask that we delete Personal Information that we hold about you, or restrict
   the way in which we use such Personal Information; withdraw consent to our
   processing of your Personal Information (to the extent such processing is
   solely based on previously obtained consent);
 * receive a copy of the Personal Information concerning you, which you have
   provided to us, in a structured, commonly used and machine-readable format
   and to transmit such Personal Information to another party (to the extent the
   processing is based on consent or a contract); and
 * object to our processing of your Personal Information.

To help us maintain the accuracy of your Personal Information, please contact us
by using the “Contact information” section below if any of your personal details
have changed.

If you are unsatisfied with the way in which we have handled your Personal
Information or any privacy query or request that you have raised to us, you have
a right to complain to the data protection authority in the relevant Deloitte
CBC location or in your jurisdiction. For such information, please contact us by
using the “Contact information” section below.



VERIFICATION OF PERSONAL INFORMATION REQUESTS



For certain Personal Information requests, we must first verify your identity
before processing your request. To do so, we may ask you to provide us with your
full name, contact information, and relationship to Deloitte. Depending on your
request, we may ask you to provide additional information. Once we receive this
information, we will then review it and determine whether we are able to match
it to the information Deloitte maintains about you to verify your identity.



THIRD PARTY REQUESTS



If you are submitting a Personal Information request on behalf of someone other
than yourself, please contact us by using the “Contact information” section
below and include proof that you are authorized to make the request. This may be
in the form of a written authorization signed by the person whom you are acting
on behalf of or a valid power of attorney.



CONTACT INFORMATION



If you have any questions regarding this Privacy Statement, please contact
The Privacy Officer, c/o Deloitte & Touche LLP, Citrus Grove, P.O. Box 1787,
George Town, Grand Cayman KY1-1109, Cayman Islands, or send an email
to CBCConfidentiality@deloitte.com.

 

DGSL Privacy Services Limited, with registered office at 29 Earlsfort Terrace,
Dublin 2, Ireland, is appointed as our representative in the European Union to
act on our behalf if, and when, we undertake data processing activities to which
the EU General Data Protection Regulation (GDPR) applies. It can be contacted
at DTTLPrivacyEU@deloitte.com.



CHANGES TO THIS PRIVACY NOTICE



We may modify or amend this Privacy Notice from time to time.

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

This Privacy Notice was written in English. To the extent any translated version
of this Privacy Notice conflicts with the English version, the English version
controls.




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DTTL and each DTTL member firm and related entity is liable only for its own
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© 2024. For information, contact Deloitte Global.








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