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PRIVACY STATEMENT


LAST REVISED: 15 MAY 2022

This privacy statement explains what Personal Data we gather about you, what we
use those Personal Data for and who we give those Personal Data to, when we are
acting as Controller for these Personal Data.  It also sets out your rights in
relation to your personal data and who you can contact for more information or
queries.  Click on the links below to take you to the more detailed sections of
this statement:

 * Who this privacy statement applies to and what it covers
 * About other areas of our Website
 * What type of Personal Data we collect
 * How we use Personal Data about you and for which legal grounds
 * Whom we disclose your Personal Data to
 * Protection of your Personal Data
 * How long we keep your Personal Data for
 * Your rights
 * Right to complain
 * Supplementary information on some processing
 * Changes to this privacy statement

1.1 Who this privacy statement applies to and what it covers

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

Deloitte General Services (“DGS”), société à responsabilité limitée, having its
registered office at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg;

Deloitte Tax & Consulting (“DTC”), société à responsabilité limitée, having its
registered office at 20, Boulevard de Kockelscheuer, L-1821  Luxembourg;

Deloitte Audit, société à responsabilité limitée, having its registered office
at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg;

Deloitte Solutions (“DSO”), société à responsabilité limitée, having its
registered office at 20, Boulevard de Kockelscheuer, L-1821  Luxembourg;

Fiduciaire Générale de Luxembourg (“FGL”), société à responsabilité limitée,
having its registered office at 26, Boulevard de Kockelscheuer, L-1821
Luxembourg;

Deloitte LIS (”DLIS”), société à responsabilité limitée, having its registered
office at 20, Boulevard de Kockelscheuer, L-1821 Luxembourg.

This privacy statement sets out how we will collect, handle, store and protect
Personal Data when:

a. you use our Website (as defined below)
b. offering or providing our various services to you or our clients
c.performing any other activities that form part of the operation of our
business, including our marketing and communication activities.

When we refer to ‘our Website’ or ‘this Website’ in this privacy statement we
mean the specific webpages of deloitte.com relating to ‘Location: Luxembourg’ in
the upper right hand corner, and to specific webpages with a URL commencing
‘https://www2.deloitte.com/lu/’

Deloitte.com is comprised of various global, country, regional and practice
specific websites, each of which is provided by DTTL or one of its independent
member firms or their related entities (collectively, the “Deloitte Network”).
To learn more about DTTL, the member firms of DTTL and their related entities,
please see About Deloitte .

If you are using our Website, this privacy statement applies to DGS as a
controller of your Personal Data. If, however, you are reviewing this privacy
statement as part of a contract, offer, proposal, newsletter or other
communication in general from us, this privacy statement applies to the entity
of Deloitte Luxembourg that you have a relationship with.

Deloitte Luxembourg provides various services and performs many activities that
form part of the operation of our business. You can find details on
our Website under the tab “Services”.

We are committed to protecting your privacy and handling your Personal Data in
an open and transparent manner.

This privacy statement also contains information about the Personal Data we use,
when and how we share your Personal Data with other members of the Deloitte
Network and other third parties (for example, our service providers) and the way
you can exercise your privacy rights.

 “Personal Data” as used in this privacy statement, means any information
relating to an identified or identifiable natural person. We may sometimes
collectively refer to handling, collecting, protecting and storing your Personal
Data as “processing” such personal data.

1 A UK private company limited by guarantee. DTTL and each of its member firms
are legally separate and independent entities. DTTL (also referred to as
"Deloitte Global") does not provide services to clients.

1.2 About other areas of our Website
Please note that other country and regional websites may be linked to our
Website, whereby the content is  provided by other entities within the Deloitte
Network and not by us. Such websites, as well as other websites that may be
linked to our Website, are not governed by this privacy statement. We encourage
visitors to review the privacy statements on each of these country specific or
regional websites before disclosing any Personal Data on their dedicated pages.
1.3 What Personal Data we collect

We may collect or obtain Personal Data directly because you give it to us (for
example by completing a form on our Website or attending one of our events) or
indirectly because other people give that Personal Data to us (for example your
employer or adviser or our client in order to provide the agreed services or
third party service providers that we use to help operate our business) or
because those data are publicly available. In case of indirect collection, we
may not be the primary controller of your Personal Data.

We may also collect or obtain Personal Data from you because we observe or infer
those Personal Data about you from the way you interact with us or with certain
types of our email communications. For example, to improve your experience when
you use this Website and ensure that it is functioning effectively, we (or our
service providers) may use cookies (small text files stored in a user’s browser)
and other tracking technologies, such as Web beacons, which may collect Personal
Data. Where you receive certain types of communications from us, such as a
marketing email, event invitation or newsletters, we (or our service providers)
may also use tracking technologies to collect some information about your
interactions with such communication (e.g. if you open the email, clicked on a
web link, unsubscribe). Additional information on how we use cookies and other
tracking technologies and how you can control these can be found in our cookie
notice.

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

·        Your  contact details such as your name; age; date of birth; gender;
e-mail address; home or professional address; country of residence; national
identifier;

·        Your professional, familial and social background and relationship such
as your lifestyle and social circumstances (for example, your  pastimes); your
marital status and members of your family; employment and education details (for
example, your employer(s), your job title and your education details);

·        Your photo or image or sound of your voice as may be included in
documentation made available to us, taken or recorded as a result of your
participation to any type of events or activity organized or sponsored by
Deloitte Luxembourg or if recorded in the context of video  surveillance tools
(to the extent legally permitted).

·        Financial and tax-related information (including your income and tax
residency, payment or bank accounts details) when necessary for us to provide
our services;

·        Communications and behavioral data deriving from your postings on any
blogs, forums, wikis and any other social media applications and services that
we provide, recordings of telephone/skype conversations, voice mail, e-mailing,
text messages, data in relation to your interactions with certain types of
communications we send to you (e.g. newsletters, events invitation or other
types of marketing communications), metadata and related publicly available
geo-localization data;

·        Technical data such as your IP address; your browser type and language;
access logs (including access times; websites use and monitoring thereof) or
data in relation to communications we send you regarding our events and
services; details of how you interact with us; devices used; location data and
other similar information;

·        Identification and background information provided by you or collected
from our clients or on their behalf, open data or public records as part of our
business acceptance processes and for our ongoing risk management processes, and
this information may include special categories of Personal Data, to the extent
legally permitted;

·        Data relating to our relationship with you or with our clients,
including especially Personal Data provided to us by or on behalf of our clients
or generated by us to provide services to them or for the quality review of
these services and this information, to the extent legally permitted, may
include special categories of Personal Data;

We may also directly or indirectly collect so called ‘sensitive’ or ‘special
categories’ of Personal Data but this is limited to what is required to provide
you or our clients with the relevant services. These sensitive data may include
details you agree to share with us about your: dietary requirements (for
example, where Deloitte would like to provide you with lunch during a meeting)
or health (for example, so that we can make reasonable accommodations for you in
our buildings, products and services.

We may sometimes receive information about your race or ethnicity, religious
beliefs, sexual orientation and political opinions when contained in documents
provided by you such as your identification documents or otherwise disclosed by
yourself in Deloitte systems and applications available for you, or in case you
have made this information public. We will not actively ask you to provide us
with such type of Personal Data and we would advise you not to disclose it
whenever possible and, to this effect, anonymize this information.

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

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

1.4 How we use Personal Data about you and for which legal grounds


1.4.1 USE OF PERSONAL DATA TO PROVIDE SERVICES TO OUR CLIENTS

We will use your Personal Data because (a) of our legitimate interests in the
effective delivery of, or as otherwise required in connection with, our services
to you or our client; or (b) of our legitimate interests in the effective and
lawful operation of our business so long as such interests are not outweighed by
your interests; As part of this, we may use your Personal Data before or while
performing an engagement (including any engagement as auditor) for:

 * Provision of the agreed services as described in the agreement between you
   and/or our client and Deloitte Luxembourg, including

                o   Financial Advisory

                o   Consulting

                o   Audit & Assurance

                o   Risk Advisory

                o   Corporate and accounting services

                o   Tax Services

 

 * Receiving support from our services providers and/or subcontractors during
   the execution of our services as described in agreements between us and these
   service providers/subcontractors as well as between us and our clients,
   including

                o   IT infrastructure and assets administration;

                o   Software licensing;

                o   Cybersecurity;

                o   Subcontracted services.

For example, we might use Personal Data:

 * about client’s employees to help those employees manage their tax affairs
   when working overseas
 * about client’s employees and customers in the course of conducting an audit
   (or similar activity)
 * about a client to help him/her complete a tax return using platforms imposed
   by the relevant tax administration;


1.4.2 USE OF PERSONAL DATA FOR OTHER ACTIVITIES THAT FORM PART OF THE OPERATION
OF OUR BUSINESS

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

 * our obligations to comply with applicable legal or regulatory requirements
   (such as anti-money laundering/know your customers obligations; tax, legal or
   regulatory reporting duties; professional duties as approved statutory
   auditors or other regulated entity);
 * our obligation to address requests and communications from competent
   authorities as legally required;
 * our legitimate interest to protect our offices, IT infrastructure and assets 
   as well as for the safety and security of our employees, clients, visitors or
   contractors while present at our premises and to detect unlawful or dangerous
   behaviors (including by monitoring access to the premises, infrastructure and
   assets and use thereof, implementing various cybersecurity programs and using
   video surveillance tools in specific public areas of our premises as
   disclosed therein);
 * our duty to have a business continuity plan in place;
 * the maintenance of the client’s relationship, including initial client
   account opening, risk assessment and client acceptance process,  financial
   accounting, invoicing and risk analysis purposes, ongoing relationship
   management which may involve: (i) ongoing risk assessment, (ii) sending you
   thought leadership or details of our products and services that we think
   might be of interest to you; (iii) contacting you to receive feedback on
   services; and (iv) contacting you for other market or research purposes; our
   recruitment needs (legitimate business interest);
 * our business development and related promotional activities (for example
   testimonials from a client’s employee may be used as part of our recruitment
   and business development materials with that employee’s permission or photos
   taken during events, workshops or trainings we organize or sponsor may be
   inserted in our brochures or videos posted on our Social Media Applications
   as below defined);
 * services we receive from our professional advisors, such as lawyers,
   accountants and consultants or other service providers (such as archiving,
   security services, IT or printing) either to execute our contractual
   obligations toward you or our clients or for legitimate business interest
   (support or development of our business activities and membership of Deloitte
   network)
 * alerting and assisting enforcement authorities in case of incidents or
   unlawful acts;
 * protecting our rights and those of our clients or even your rights, mainly in
   case of complaints and (potential) litigation.  


1.4.3 USE OF PERSONAL DATA COLLECTED VIA OUR WEBSITE

In addition to the purposes above connected to the operation of our business and
considering our legitimate interest (to secure, promote and develop our business
activities), we may also use your Personal Data collected via our Website:

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

You may wish to refer to our cookies notice for more details regarding the use
of cookies.

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

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

(ii) the processing is necessary for the establishment, exercise or defense of
legal claims;

(iii) you have made the Personal Data manifestly public or

(iv) you have given us your explicit consent to process that Personal Data.

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

Where we are legally required to obtain your explicit 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.

If you do not want to continue receiving any marketing materials from us, you
can click on the unsubscribe function included in the communication or e-mail.

1.5 Who we disclose your Personal Data to

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

·        other members of the Deloitte Network which may be located in
jurisdictions outside the European Union;

·        third parties that provide services to us and/or the Deloitte Network,
such as printing or archiving providers, security companies, catering providers,
cloud-hosted solution providers, our providers of IT tools and infrastructure
when necessary for testing or maintenance purposes, our legal advisers or
insurers in case of incident or claim;

·        providers of cloud-hosted solutions in the context of the provision of
services to our clients;

·        public enforcement authorities such as the police (in case of unlawful
act) or other competent authorities, including courts and authorities regulating
us or another member of the Deloitte Network, to the extent legally permitted or
required;

·        your employer and/or their advisers in the context of the services
provided to you or your employer (potentially for your own benefit);

·        your advisers;

·        organizations that help us reduce the incidence of fraud and other
third parties that reasonably require access to Personal Data relating to you
for one or more of the purposes outlined in the “How we use Personal Data about
you” section above.

Our Website hosts various blogs, forums, wikis and other social media
applications or services that allow you to share content with other users
(collectively “Social Media Applications”). Importantly, any Personal Data that
you contribute to these Social Media Applications can be read, collected and
used by other users of the application. We have little or no control over these
other users and, therefore, we cannot guarantee that any information that you
contribute to any Social Media Applications will be handled in accordance with
this privacy statement. 

Please note that some of the recipients of your Personal Data referenced above
may be based in countries outside of the European Union whose laws may not
provide the same level of Data Protection. In such cases, we will ensure that
there are adequate safeguards in place to protect your Personal Data that comply
with our legal obligations. Where the recipient is not a member of the Deloitte
Network, the adequate safeguard might be a data transfer agreement with the
recipient based on standard contractual clauses approved by the European
Commission for transfers of Personal Data to third countries.

Further details of the transfers described above and the adequate safeguards
used by Deloitte in respect of such transfers are also available from us by
contacting our DPO at DataPrivacy@deloitte.lu.

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

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.

1.6 Protection of your Personal Data

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

 * education and training to relevant Staff members to ensure they are aware of
   our privacy obligations when handling Personal Data
 * administrative and technical controls to restrict access to Personal Data on
   a ‘need to know’ basis
 * technological security measures, including fire walls, encryption and
   anti-virus software and other security controls performed as part of Deloitte
   cybersecurity program; or
 * physical security measures, such as Staff members security passes to access
   our premises.

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

1.7 How long we keep your Personal Data for

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

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

(ii) any retention period that is required by law

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

For example, we shall hold

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

Should you wish more details for a specific processing and specific Personal
Data, please contact DataPrivacy@deloitte.lu.

1.8 Your rights

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

 * obtain confirmation that we are processing your Personal Data and request a
   copy of the Personal Data we hold about you;
 * ask that we update the Personal Data we hold about you, or correct such
   Personal Data that you think is incorrect or incomplete;
 * ask that we delete Personal Data that we hold about you, or restrict the way
   in which we use such Personal Data in specific circumstances provided by law
   and especially when there is no longer a need to process your Personal Data
   or when we no longer have a valid legal ground to process them;
 * withdraw consent to our processing of your Personal Data (when  such
   processing is based on consent);
 * receive a copy of the Personal Data concerning you, which you have provided
   us with, in a structured, commonly used and machine-readable format and to
   transmit such Personal Data to another party (when the processing is based on
   consent or a contract to which you are a party and we are acting as Data
   Controller);
 * object to our processing of your Personal Data when processed for marketing
   or profiling purposes or based on legitimate grounds.

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

To exercise any of your rights, or if you have any other questions about our use
of your Personal Data, please contact our DPO at DataPrivacy@deloitte.lu

You may also use these contact details if you wish to make a complaint to us
relating to your privacy. 

1.9 Right to complain
If you are unhappy with the way we have handled your Personal Data or any
privacy query or request that you have raised with us, you have a right to
complain to the EU Data Protection Authority (“DPA”) in your jurisdiction. For
Luxembourg you may contact the National Commission for Data Protection (CNPD),
otherwise if you would like to be directed to the appropriate DPA, please
contact us. 
1.10 Supplementary information on some processing


1.1.1 EVENTS AND PROCESSING OF PHOTOS, IMAGES OR SOUND OF VOICE

We regularly (co-)organize or sponsor events for the purposes above described
and mainly marketing, trainings or other activities that form part of Deloitte
Luxembourg operations. In the course of these events, photos may be taken or
audio/video recording may take place using to this effect any available
technical means, such as those offered by the platforms or service providers
selected to support the event and/or live broadcasted.

Pictures taken and/or audio/ video recording (or extracts thereof) may be
published online (including on Deloitte social media applications) or in any
other publications released by Deloitte Luxembourg for the purposes described in
section “How we use personal data about you and for which legal grounds” and
generally made available on our website or on our corporate social media
channels.

When you register for any such event (as a speaker or as a participant), your
registration shall be interpreted as your consent to being taken in picture or
(audio/video) recorded as the case may be.

This registration shall also mean that you consent to the use of any data
(including slides, personal data, etc.) shown by you during the event, unless
you have notify Deloitte Luxembourg in advance to the contrary.

When we co-organize the events, your registration shall also be interpreted as
your consent to share your registration details with the co-organizer indicated
in the event invitation for the organization of, and follow-up on, the events.

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

You may also and at any time withdraw your consent to one or the other
processing above detailed by contacting our DPO at DataPrivacy@deloitte.lu.

The other provisions of this privacy statement remain applicable to this
processing.

1.11 Changes to this privacy statement

We may modify or amend this privacy statement from time to time.

To let you know when we make changes to this privacy statement, we will amend
the revision date at the top of this page and we encourage you to review our
Privacy Statement to stay informed. In case of direct collection of your
Personal Data by Deloitte Luxembourg, if we make changes that materially alter
your privacy rights, we will also provide you with an ad-hoc notification of
these changes, via email or other agreed communication means. 


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