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BDO USA PRIVACY POLICY
LEGAL NAVIGATION
* Website Terms and Conditions
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Last Updated: August 30, 2023
This Privacy Policy ("Privacy Policy") describes how BDO USA1 and its
subsidiaries (except as described below) (together, "BDO USA" or "we" or "us" or
“our”) collect, use, and disclose the Personal Information we collect from or
about you when you:
* Use the BDO USA website (www.bdo.com) or any other websites, blogs or pages
that link to this Privacy Policy (together, the "Sites");
* Communicate with us electronically, such as via email; and
* Interact with us offline, including in person, at an event or via phone.
Before submitting Personal Information to us or using the Sites, please review
this Privacy Policy carefully.
Certain BDO USA services or subsidiaries may use different privacy policies to
provide notice to you about how your Personal Information is used and disclosed.
To the extent that BDO USA services or subsidiaries post or reference a
different privacy policy, that different privacy policy, not this Privacy
Policy, will apply to your Personal Information collected in the context of
those services or by that subsidiary.
NOTE TO BDO USA CLIENTS
If you are a client of BDO USA, please refer to our BDO USA Client Data Privacy
Policy for information about how we use and disclose the Personal Information we
collect about you in the context of our client relationship with you. Unless we
state otherwise in our communications with you or in client engagement
documents, this Privacy Policy does not apply to the Personal Information we
collect in the context of our client relationships.
BDO USA AS A SERVICE PROVIDER
Most of our clients are businesses, and we may receive and process Personal
Information when we provide services to those clients. When this happens, we
process your Personal Information pursuant to our contract with our client. That
client’s privacy policy applies to your Personal Information, not ours.
HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION
"Personal Information"
is information that identifies, relates to, describes, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with you
or your household, such as your name, email address, IP address, telephone
number, and broader categories of information such as your professional,
educational or health information, commercial information, and internet
activity.
We may collect Personal Information directly from you and automatically through
our use of cookies and other data collection technologies on our Sites. We may
also collect your Personal Information from third-party sources, such as social
media platforms (if you interact with us through your social media account),
references you list on applications and forms, and third parties to whom you
direct us to collect your Personal information. We will treat Personal
Information collected from third-party sources in accordance with this Privacy
Policy.
The categories of Personal Information that we collect from you depends on your
interactions with us. For example, we may collect:
* Identifiers, such as your name, postal address, phone number, e-mail address,
IP address, online identifiers, account names, associated passwords, social
media profiles and other similar identifiers. We may collect this information
to verify your identity and information, to communicate with you, to create
your BDO USA Account (“Account”) and to facilitate your use of our Sites.
* Protected Characteristics, provided with special protection under applicable
law, such as your age, race, citizenship, gender, medical information, and
disability information.
* Professional and Employment-Related Information, such as information about
your current and former employment, professional degrees and certifications,
education background, information about references you list on your
application form, certain Identifiers (in order to contact you), and other
employment-related information, including your employment goals and
objectives. We may collect this information to process and manage your
profile when you interact with us regarding networking events or our
professional services, or if you submit an employment or other application to
us. We may also collect information provided by you in the course of
evaluating or engaging you for employment or other positions. This
information may include your first and last name, email address, CV, resume,
cover letter and any other information provided by or about you, including
information from references and background check providers.
* Commercial Information, such as products and services purchased from us
through the use of our Sites. We may collect this information to conduct
business analytics and improve our services to you.
* Internet or other Electronic Activity Information, such as your browsing
history, search history, which pages you visit on the Sites, other pages you
visit on the Internet, and which browser you used to view the Sites. Please
review the “Cookies and Other Technologies” section to learn more about our
use of cookies and tracking technologies. We may collect this information to
understand your use of the Sites and of your Account.
* Profile Information, such as information about your preferences and
characteristics (including inferences drawn from other personal information).
We may collect this information in order to understand your preferences and
tailor our services and communications to you. In addition, if you visit our
premises, we may collect information to protect the health and safety of our
personnel, clients, guests, and the general public, such as health and travel
information.
In addition to the purposes for collection described above, we also may collect
each category of information for the purpose of performing services for you and
maintaining our relationship with you, which include:
* Maintaining and servicing your Account, including managing your preferences.
* Taking steps to improve our services to you, including to run analytics,
improve our artificial intelligence tools, assess the quality of our
services, and for other related internal business purposes.
* Administering and improving our Sites, including to measuring the
effectiveness of the Sites, diagnosing problems with our server, analyzing
where Site traffic is coming from, and to identifying our Site users.
* Communicating with you to personalize your experience with the BDO USA and
improve our understanding of your needs, and to respond to inquiries you send
to us.
* Sending you messages promoting our products and services. You may opt-out of
receiving certain promotional e-mail messages from us as described in the
"Marketing Opt-Out" section below.
* Protecting the health and safety of our personnel, clients, guests, and the
general public.
* Complying with our legal, regulatory and risk management obligations,
including establishing, exercising and/or defending legal claims.
* For other purposes consistent with the context of the collection of your
information, or as otherwise disclosed to you prior to the use of your
information.
Some of the information we collect may be considered Sensitive Personal
Information under privacy laws, such as your health information and account
log-in information. We use your Sensitive Personal Information only for
legitimate business purposes, including to (i) perform services or provide goods
reasonably expected by an average person; (ii) detect security incidents; (iii)
resist malicious, deceptive, or illegal actions; (iv) ensure the physical safety
of individuals; (v) for short-term, transient use, including non-personalized
advertising; (vi) perform or provide internal business services; or (vii) verify
or maintain the quality or safety of a service or device.
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may share the categories of Personal Information described above in the
following circumstances to the following categories of third parties:
* We may share your Personal Information with companies or individuals that we
contract with in order to receive services (our “Service Providers”). These
services may include, among other things, providing products or services to
you on our behalf, creating or maintaining our databases, payment processing,
researching, and analyzing the people who request information from us,
preparing distribution communications, responding to inquiries, or processing
applications. We may also disclose to these Service Providers your health and
travel-related information in order to protect the health and safety of our
personnel, clients, guests, and the general public. Our policy is to inform
our Service Providers not to use or disclose your Personal Information for
any purpose other than for providing services to us.
* We may share your Personal Information with companies that we own or control,
or are owned or controlled by (our “Corporate Family”), including health and
travel-related information in order to protect the health and safety of our
personnel, clients, guests, and the general public.
* We may share your Personal Information with companies or individuals outside
of BDO USA who may use your Personal Information for their own purposes (a
“Third Party”). For example:
* Our clients.
* If you choose to submit Personal Information through the “Testimonials”
link, we may share your Personal Information publicly or with Third
Parties.
* From time to time, we may be required to provide Personal Information to a
Third Party in response to a court order, subpoena, government
investigation, or as otherwise required by law or legal process.
* We may share your Personal Information with Third Parties, such as law
enforcement agencies, other government agencies, or health authorities (i)
when we, in good faith, believe you or others are acting unlawfully, (ii)
when we believe it is necessary or appropriate to satisfy any law,
regulation or other governmental request, (iii) to operate our business and
Sites properly, (iv) to protect or defend our rights or the rights or
well-being of our users, even without a subpoena, warrant or court order,
or (v) we believe disclosure is necessary to protect the health and safety
of our personnel, clients, guests, and the general public.
* We may, as a result of a sale, merger, consolidation, change in control,
transfer of assets, reorganization, or liquidation of our company (a
"Reorganization Event"), transfer or assign your Personal Information to
parties involved in the Reorganization Event. You acknowledge that such
transfers may occur and are permitted by and subject to this Privacy Policy.
COOKIES AND OTHER TECHNOLOGIES
We may use "cookies" to keep, and sometimes track, information about you on our
Sites. Cookies are small data files that are sent to your browser or related
software from a Web server and stored on your computer's hard drive. Cookies
track where you travel on the Sites and what you look at. In doing so, a cookie
may enable us to relate your use of the Sites to your Personal Information. Many
other websites use cookies for very similar purposes.
Most Web browsers can be set to inform you when a cookie has been sent to you
and provide you with the opportunity to refuse that cookie. Additionally, your
Flash player can be set to reject or delete Flash cookies. Refusing a cookie
will generally not interfere with your use of the Sites. However, refusal of a
cookie may, in some cases, preclude you from using or negatively impact the
display or function of the Sites or certain areas or features of the Sites.
We may also use web beacons (a.k.a. clear GIFs, web bugs or pixel tags) to
personalize your experience on the Sites, to generate information about Site
traffic and trends, and to verify your viewing and/or receipt of communications.
Web beacons collect information automatically, such as the type of browser that
you use and your IP address. Web beacons may be used alone or in conjunction
with cookies. When web beacons are used with cookies, they may link this
information to other Personal Information that you have provided to us. Web
beacons usually are not visible to you.
Third Party Analytics
We use automated devices and applications, such as Google Analytics and Crazy
Egg, to evaluate usage of our Sites. We also may use other analytic means to
evaluate our Sites and services. We use these tools to help us improve the
Sites, performance, and user experiences. These entities may use cookies and
other tracking technologies to perform their services. We do not share your
Personal Information with these third parties. To learn how Google Analytics
collects and processes data, please visit: “How Google uses data when you use
our partners’ sites or apps” located at
www.google.com/policies/privacy/partners. To learn about how Crazy Egg uses the
analytics information it collects, please visit Crazy Egg’s Privacy Policy; to
opt-out of Crazy Egg’s analytics tracking, please visit
https://www.crazyegg.com/opt-out/.
How We Respond to Do Not Track Signals
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome)
incorporate a "Do Not Track" ("DNT") or similar feature that signals to websites
that a user does not want to have his or her online activity and behavior
tracked. If a website that responds to a particular DNT signal receives the DNT
signal, the browser can block that website from collecting certain information
about the browser's user. Not all browsers offer a DNT option and DNT signals
are not yet uniform. For this reason, many digital service operators, including
BDO USA, do not recognize or respond to DNT signals.
MARKETING OPT-OUT
If you would like to opt out of receiving promotional or marketing e-mail from
us, you may use the “unsubscribe” mechanism included in each marketing message.
You may let us know by sending us an email to bdousa@bdo.com with REMOVE in the
subject line, and stating the e-mail address you wish to be removed from our
mailing list. If you have an Account, you may be able to manage your
subscriptions through your Account. However, your option not to receive
promotional and marketing e-mail shall not preclude us from corresponding with
you, by e-mail or otherwise, regarding your existing relationship with us. Your
opt-out request will also not apply to correspondence that has already been
initiated.
CALIFORNIA PRIVACY DISCLOSURES
California residents are entitled to the following additional disclosures about
our data processing:
* In the preceding 12 months, BDO USA has collected the categories of Personal
Information detailed in “How We Collect and Use Your Personal Information”
above. The purposes for which BDO USA has collected Personal Information and
the sources of that information are also described above.
* In the preceding 12 months, BDO USA has disclosed Personal Information for a
business purpose as detailed in the How we Disclose Your Personal Information
section above.
* We may sell information in the context of our Investigative Due Diligence
(“IDD”) services. In the preceding 12 months, BDO USA has sold the following
categories of Personal Information to IDD clients: Identifiers, Protected
Characteristics, Professional and Employment-Related Information, Commercial
Information, Internet or Other Electronic Activity Information, and Profile
Information.
* We may also sell information to the extent our use of cookies and tracking
technologies for targeted advertising constitutes a “sale” under the CCPA.
This use of cookies and tracking technologies also constitutes “sharing”
under the CCPA. Your opt-out rights are described in the Your Rights section
below. In the preceding 12 months, BDO USA has sold or shared the following
categories of Personal Information to with our targeted advertising service
providers and partners: Identifiers, Internet or Other Electronic Activity
Information, and Profile Information.
* We do not knowingly sell the Personal Information of minors under 16.
Please note that we do not sell any personal information received on behalf of
our clients, and we do not sell any personal information obtained in the course
of providing our other services, including Tax, Audit & Assurance and Advisory
(other than IDD) services.
Shine the Light: This Privacy Policy describes how we may share your
information, including for marketing purposes. California residents are entitled
to request and obtain from BDO USA once per calendar year information about any
of your Personal Information shared with third parties for their own direct
marketing purposes, including the categories of information and the names and
addresses of those businesses with which we have shared such information. To
request this information and for any other questions about our privacy practices
and compliance with California law, please contact us at privacy@bdo.com.
For an explanation of the rights you may have as a California resident, please
see the Your Rights section below.
YOUR RIGHTS
Depending on where you live, you may have the following rights, subject to any
applicable exemptions or limitations:
* The right to know and access your Personal Information, such as the
categories of Personal Information we have collected, the sources of Personal
Information, the purposes of collection, and how we used, disclosed, sold, or
shared Personal Information;
* The right to correct inaccurate Personal Information that we maintain about
you;
* The right to delete your Personal Information under specific circumstances;
* The right to opt out of the sale or sharing of your Personal Information, as
such terms are defined by applicable laws;
* The right to object or opt out of certain types of processing, such as
targeted advertising, direct marketing, and certain types of profiling and
automated decision-making;
* The right to request the restriction of processing of your Personal
Information;
* The right to data portability, which means requesting a copy of your Personal
Information in an accessible format;
* The right to withdraw your consent under certain circumstances; and
* The right to lodge a complaint with the relevant data protection supervisory
authority. Where applicable, you can find contact information for your data
protection supervisory authority on the European Data Protection Board’s
website, https://edpb.europa.eu/about-edpb/about-edpb/members_en, or through
other publicly available sources.
To the extent any of the above rights are applicable, you may exercise your
rights by contacting us at privacy@bdo.com, by phone at 1 (877) 236-0001 or by
completing our Consumer Request Form. If you wish to opt out of the sale of your
Personal Information in the context of our Investigative Due Diligence services,
you can submit your request by completing our Do not sell my Personal
Information request form. You may opt out of our use of cookies and other
technologies for targeted advertising purposes by navigating to the “Opt Out of
Targeted Advertising - Do Not Sell or Share My Personal Information” link in the
footer of the BDO USA website you are visiting or clicking through the option in
the banner that appears when you first visit our website. If you choose to
exercise any of these rights, BDO USA will not discriminate against you in any
way. If you exercise certain rights, understand that you may be unable to use or
access certain features of BDO USA’s Sites or services.
We will take steps to verify your identity before processing certain requests.
We will not fulfill your request unless you have provided sufficient information
for us to reasonably verify you are the individual about whom we collected
Personal Information. If you have an Account with us, we will use our existing
Account authentication practices to verify your identity. If you do not have an
Account with us, we may request additional information about you to verify your
identity. We will only use the Personal Information provided in the verification
process to verify your identity or authority to make a request and to track and
document request responses, unless you initially provided the information for
another purpose.
You may be able to use an authorized agent to submit a rights request on your
behalf. When we verify your agent’s request, we may verify both your and your
agent’s identity and request a signed document from you that authorizes your
agent to make the request on your behalf. To protect your Personal Information,
we reserve the right to deny a request from an agent that does not submit proof
that they have been authorized by you to act on their behalf.
Certain laws may give you a right to appeal any denials of your request to
exercise your rights. If we deny your request and you would like to submit an
appeal, please contact us at privacy@bdo.com.
LEGAL BASIS FOR PROCESSING
Where applicable under the European Union’s General Data Protection Regulation
(“GDPR”) or similar laws, the legal basis for our collection and use of your
Personal Information may include any of the following:
* Performance of a contract. We process your Personal Information as necessary
to perform our obligations under any contract with you, such as to provide
our Sites or services to you or complete transactions.
* Consent. We may ask for your consent to use your Personal Information,
including if we need your consent to process certain sensitive information
about you or engage in certain marketing activities. If we obtain your
consent as a legal basis for processing, you may withdraw your consent at any
time.
* Legitimate interests. We have a legitimate interest in using your Personal
Information for our business purposes, including operating, improving, and
marketing our business, Sites, and services.
* Compliance with a legal obligation. We may need to use your Personal
Information to comply with applicable legal requirements.
INFORMATION FOR VISITORS FROM OUTSIDE OF THE UNITED STATES
If you visit the Sites or provide us your Personal Information from outside the
United States, your information will be transferred to, stored, and processed in
the United States and other countries where BDO USA or its vendors operate in
accordance with this Privacy Policy and applicable laws. Please note that data
protection and consumer protection laws of the United States and such other
countries may differ from the data protection or consumer protection laws in
your country. By using the Sites or providing us with your Personal Information,
you understand that your Personal Information will be collected from and
processed in the United States and other countries where BDO USA or its vendors
operate, and acknowledge that your information may be subject to access by law
enforcement and other government entities, including courts and tribunals, in
accordance with laws applicable in those jurisdictions. Where applicable, we
have implemented appropriate cross border data transfer mechanisms when
transferring your Personal Information to a country outside of your home
jurisdiction, including the BDO Binding Corporate Rules.
DATA SECURITY AND RETENTION
We maintain one or more databases to store your Personal Information and may
retain it as reasonably required to serve you, run our business, and comply with
our legal obligations. In determining when your Personal Information is retained
or disposed, we may consider the nature and sensitivity of your Personal
Information, the potential risk of harm from unauthorized use or disclosure of
your Personal Information, the purposes for which we process your Personal
Information, and applicable legal requirements.
We have implemented reasonable safeguards designed to protect your information
from loss, misuse, alteration, or destruction. We also take reasonable steps
designed to ensure that third parties who work with us agree to protect the
Personal Information.
Without limiting any other terms that apply to our Sites and this Privacy
Policy, you understand that we cannot guarantee that your Personal Information
will be private or secure. Except to the extent provided by law, we are not
responsible or liable to you for any lack of privacy or security you may
experience. You are fully responsible for taking precautions and providing
security measures best suited for your situation and intended use of the Sites
and our services. Please be careful whenever sending Personal Information to us
via e-mail. E-mail is not a secure means of transferring information.
THIRD PARTIES
Our Sites, services and materials may contain references or links to third-party
websites and services. Except as described above regarding Service Providers, we
do not control what information third parties track or collect. Any access to
and use of such third-party websites and services is not governed by this
Privacy Policy but instead is governed by the privacy policies of those third
parties. We are not responsible for the information practices of such third
parties.
CHILDREN’S PRIVACY
We do not knowingly collect any Personal Information from children under 13
without prior verifiable parental consent. If BDO USA learns that a child under
the age of 13 has submitted Personal Information without parental consent, we
will take all reasonable measures to delete the information as soon as possible
and to not use such information for any purpose, except where necessary to
protect the safety of the child or others as required or allowed by law. If you
believe a child under 13 has provided us with Personal Information, please
contact us at privacy@bdo.com or the mailing address below.
QUESTIONS ABOUT OUR PRIVACY POLICY
If you have questions about this Privacy Policy, please contact us at
privacy@bdo.com. You can also send us physical mail to: BDO USA, 600 North Pearl
Street, Suite 1700, Dallas, TX 75201, Attention: Chief Compliance & Ethics
Officer.
CHANGES TO OUR PRIVACY POLICY
We may occasionally update this Privacy Policy to reflect changes in our
practices. When we post modifications to this Privacy Policy, we will revise the
"Last Updated” date at the top of this web page. If the changes are material, we
will endeavor to notify you in advance of such changes taking place. If you
object to any modification, your sole recourse is to notify us that you do not
agree and to stop using the Sites and providing us with your Personal
Information.
We encourage you to periodically review this page for the latest information on
our privacy practices.
--------------------------------------------------------------------------------
1 BDO USA refers to BDO USA, P.C., a Virginia professional corporation, also
doing business in certain jurisdictions with an alternative identifying
abbreviation, such as Corp. or P.S.C.
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