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Privacy


PRIVACY STATEMENT


LAST REVISED: SEPTEMBER 06, 2022

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INTRODUCTION



This privacy statement explains what personal information we gather about you,
what we use that information for and who we give that information to. It also
sets out your rights in relation to your personal information 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 deloitte.com
 * What information we collect
 * How we use your personal information
 * The legal grounds we use for processing personal information
 * Who we disclose your personal information to
 * Protection of your personal information
 * How long we keep your personal information for
 * Your rights
 * Right to complain
 * Changes to this privacy statement




WHO THIS PRIVACY STATEMENT APPLIES TO AND WHAT IT COVERS



This privacy statement applies to Deloitte LLP with registered office address at
#200 – 8 Adelaide St. West, Toronto, Ontario, Canada. M5H 0A9, and our
affiliates and related entities (“Deloitte”, “we”, “us” or “our”).

We are committed to protecting your privacy and handling your personal
information in an open and transparent manner.

This privacy statement sets out how we will access, collect, use, store,
transfer, retain and protect (collectively referred to as “process”) personal
information about you when:

 * providing services to you or our clients
 * you use “our Website” or
 * performing any other activities that form part of the operation of our
   business.

When we refer to “our Website” or “this Website” in this policy we mean the
specific webpages of deloitte.com designated as Canada in the upper right hand
corner, and to specific webpages with a URL commencing ‘www2.deloitte.com/ca/’.

Deloitte.com is comprised of various global, country, regional and practice
specific websites, each of which is provided by Deloitte Touche Tohmatsu Limited
(“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.

This privacy statement also contains information about when we share your
personal information with other members of the Deloitte Network and other third
parties (for example, our service providers).

This privacy statement should be read in conjunction with any additional privacy
statements or notices available or provided to you by us at or before the time
you provide us with your personal information. For example, you may be required
to agree to a recruitment privacy statement before submitting an application to
a Deloitte career.




ABOUT OTHER AREAS OF DELOITTE.COM



Please note that the other country and regional websites contained within
deloitte.com are provided by other entities within the Deloitte Network and are
not provided by us. Such websites, as well as other websites that may be linked
to this Website, are not governed by this privacy statement. We encourage
visitors to review the privacy statements on each of these other websites before
disclosing any personal information.




WHAT INFORMATION WE COLLECT



We strive to limit the amount of personal information we collect to that
necessary and appropriate for the above purposes.

In the course of providing services to you, or our clients and performing due
diligence checks in connection with our services (or discussing possible
services we might provide), we will collect or obtain personal information about
you. We may also collect personal information from you when you use this Website
or through digital interactions with you. 

We may collect or obtain such personal information because you give it to us
(for example in a form on our Website), because other people give that personal
information to us (for example your employer or adviser, or third party service
providers that we use to help operate our business) or because it is publicly
available.

We may also collect or obtain personal information from you because we observe
or infer that personal information about you from the way you interact with us
or others. For example, to improve your experience:

 * with Deloitte’s services, we may consider the strength and frequency of, and
   feedback through our interactions; or   
 * when you engage you use this Website and ensure that it is functioning
   effectively, we (and / or our service providers) may use cookies (small text
   files stored in a user’s browser) and web beacons which may collect personal
   information. 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 personal information that we collect or obtain varies depending on the
purpose for processing that personal information and may include, but is not
limited to: your name; age; date of birth; e-mail address; home address; country
of residence; lifestyle and social circumstances (for example, your pastimes);
employment and education details (for example, the organization you work for,
your job title and your education details); your postings on any blogs, forums,
wikis and any other social media applications and services that we provide; your
IP address; your browser type and language; your access times; complaint
details; details of how you use our products and services; details of how you
like to interact with us and other similar information.

The personal information we collect may also include so called ‘sensitive’ or
‘special categories’ of personal information, such as details about your:
gender; dietary requirements (for example, where Deloitte would like to provide
you with lunch during a meeting); family circumstances (for example, your
marital status and dependents); financial and tax-related information (for
example your income and tax residency); health (for example, so that we can make
reasonable accommodations for you in our buildings, products and services) and
sexual orientation (for example if you provide us with details of your spouse or
partner).

The types of personal information and sensitive personal information that we
collect may vary depending on the legal requirements imposed on us, nature of
the services that we provide to you or our client, or how you use our Website. 

Where we are provided with personal information about you, we take steps to
ensure that the entity providing such information (“Transferor”) has complied
with the privacy laws and regulations relevant to your data. This may include,
for example, that the Transferor has provided you with notice of the collection
(and other matters) and has obtained any necessary consent for us to process
that personal information 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 process information about children.




HOW WE USE PERSONAL INFORMATION ABOUT YOU



Use of personal information to provide services to our clients


We will use your personal information to provide you or our client with
services. As part of this, we may use your personal information in the course of
correspondence relating to the services. Such correspondence may be with you,
our client and any third parties they appoint to work with us to provide the
services, other members of the Deloitte Network, our service providers or
competent authorities. We may also use your personal information to conduct due
diligence checks relating to the services.

Because we provide a wide range of services to our clients, the way we use
personal information in relation to our services also varies. For example, we
might use personal information:

 * about a client’s employees to help those employees manage their tax affairs
   when working overseas
 * about a client’s employees and customers while conducting an audit (or
   similar activity) for a client
 * about a client’s employees and customers while implementing new human
   resources or customer relationship management systems
 * to provide immigration assistance to an individual, either directly or on
   behalf of a client
 * to support a client during a forensic investigation
 * about a client to help him/her complete a tax return

Use of personal information for other activities that form part of the operation
of our business

We may also use your personal information for the purposes of, or in connection
with:

 * applicable legal or regulatory requirements
 * requests and communications from competent authorities
   
 * client account opening and other administrative purposes
 * financial accounting, invoicing and risk analysis purposes
   
 * client relationship purposes, which may involve: (i) sending you thought
   leadership or details of our products and services that we think might be of
   interest to you; (ii) contacting you to receive feedback on services; (iii)
   contacting you for other market or research purposes; or (iv) managing our
   own customer relationship management processes;
 * business development purposes (for example testimonials from a client’s
   employees may be used as part of our business development materials with that
   employee’s permission)
 * recruitment purposes for prospective Deloitte employees, partners and
   contractors, as well as to manage the employment, partnership and contractor
   relationship
 * services we receive from our professional advisors, such as lawyers,
   accountants and consultants
 * data analytics to better understand your interactions with us
 * protecting our rights and those of our clients and our service providers

Use of personal information collected via our Website

In addition to the purposes connected to the operation of our business above, we
may also use your personal information collected via our Website:


 * to manage and improve our Website
 * 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 manage and respond to any request you submit through our Website.




THE LEGAL GROUNDS WE USE FOR PROCESSING PERSONAL INFORMATION



We are required by law to set out in this privacy statement the legal grounds on
which we rely in order to process your personal information.

As a result, we use your personal information for the purposes outlined above
because: (a) of our legitimate interests in the effective delivery of our
services to you or our client; (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; (c) of the legal and regulatory obligations that
we are subject to, such as keeping records for tax purposes or providing
information to a public body or law enforcement agency; (d) the information is
required in order to provide our services to you or our client; (e) because you
have consented to such use of your personal information; (f) because you have
voluntarily provided us with your personal information for a specific purpose
(i.e., to receive thought leadership from us); or (g) you have made that data
public.

To the extent that we process any sensitive personal information relating to you
for any of the purposes outlined in the “How we use your personal information”
section above , we will do so because: (a) you have given us your explicit
consent to process that personal information; (b) we are required by law to
process that personal information in order to ensure we meet our ‘know your
client’ and ‘anti-money laundering’ obligations (or other legal obligations
imposed on us); (c) the processing is necessary to carry out our obligations
under employment, social security, social protection or other similar law; or
(d) the processing is necessary for the establishment, exercise or defense of
legal claims.

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 in the communication or e-mail unsubscribe@deloitte.ca.




WHO WE DISCLOSE YOUR PERSONAL INFORMATION TO



In connection with one or more of the purposes outlined in the “How we use your
personal information” section above, we may disclose your personal information
to: (a) other members of the Deloitte Network; (b) third parties that provide
services to us and/or the Deloitte Network; (c) competent authorities (including
courts and authorities regulating us or another member of the Deloitte Network);
(d) your employer and/or their advisers; (e) your advisers; (f) credit reference
agencies or other organizations that help us make credit decisions and reduce
the incidence of fraud, and other third parties that reasonably require access
to personal information relating to you for one or more of the purposes outlined
in the “How we use your personal information” 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
information that you contribute to these Social Media Applications can be read,
collected and used by other users of the application. We are not responsible for
the personal information processing activities of the Social Media Applications,
and subsequently any use, misuse, or misappropriation of any personal
information or other information that you contribute to any Social Media
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 we and some of the recipients of your personal information
referenced in this privacy statement may process your data in any province
within Canada or in countries outside of Canada altogether. In some cases, data
processing activities may take place where local laws may not provide the same
level of data protection that exist in your local geography. We will ensure that
there are adequate safeguards in place to protect your personal information that
comply with our legal obligations.

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 privacyoffice@deloitte.ca.

We may also need to disclose your personal information if required to do so by
law, a regulator or during legal proceedings. Your personal information may also
be shared as the result of any mergers with, acquisitions or divestitures of any
part our business with another organization.

We may share non-personal, de-identified or aggregated information with third
parties for several purposes, including data analytics, research, submissions,
thought leadership and promotional purposes.




PROTECTION OF YOUR PERSONAL INFORMATION



We use a range of physical, electronic and managerial measures to ensure that we
keep your personal information secure, accurate and up to date.

These measures include, but are not limited to:

 * education and training to relevant staff to ensure they are aware of our
   privacy obligations when processing personal information
 * administrative and technical controls to restrict access to personal
   information on a ‘need to know’ basis
 * technological security measures, including firewalls, multi-factor
   authentication, encryption and anti-virus software
 * physical security measures, such as staff security passes to access our
   premises
 * an appointed Chief Privacy Officer to oversee privacy matters for Deloitte

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.




HOW LONG WE KEEP YOUR PERSONAL INFORMATION FOR

We will hold your personal information on our systems for the longest of the
following periods: (a) as long as is necessary for the relevant activity or
services; (b) any retention period that is required by law or professional
standards; (c) the end of the period in which litigation or investigations might
arise in respect of the services or (d) as directed by Deloitte’s own internal
retention policies or practices, the length of which may vary depending on the
nature of the information that is held. Further, any copies of personal
information stored in our electronic backups will be destroyed in accordance
with that backup’s ordinary lifecycle.




YOUR RIGHTS



You have various rights in relation to your personal information. The rights
afforded to you may vary depending on your geographic location and the
applicable laws governing how we process your personal information. To the
extent prescribed by applicable law, you may 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
 * request certain information about how we process your personal information
 * ask that we update the personal information we hold about you, or correct
   such personal information that you think is incorrect or incomplete
 * ask that we delete certain personal information that we hold about you, or
   restrict the way in which we use such personal information
 * ask that we de-index or cease disseminating certain personal information that
   may be included in our websites
 * withdraw consent to our processing of your personal information (to the
   extent such processing is based on consent)

To exercise any of your rights, or if you have any other questions about how we
process your personal information, please email privacyoffice@deloitte.ca or
write to us at the Privacy Office address below:

Chief Privacy Officer
Deloitte Privacy Office
Deloitte LLP
8 Adelaide Street West, Suite 200
Toronto, ON M5H 0A9
Canada
privacyoffice@deloitte.ca

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

Where we are provided with personal information about you by our client or our
third parties, we encourage you to contact that client or third party directly
(i.e., your employer or service provider) if you have questions about how they
manage your personal information.




RIGHT TO COMPLAIN

If you are unhappy with the way we have processed your personal information or
any privacy query or request that you have raised with us, you have a right to
complain to the Data Protection Authority (“DPA”) in your jurisdiction. If you
would like to be directed to the appropriate DPA, please contact us.




CHANGES TO THIS PRIVACY STATEMENT



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

Privacy laws are rapidly evolving and, as a result, we may change this privacy
statement from time to time in our full discretion without any prior notice or
liability to you or any other person. Our processing of your personal
information will be governed by the version of this privacy statement in effect
at that time. The new modified or amended privacy statement will apply from the
revision date at the top of this page. Therefore, we encourage you to
periodically review this statement to be informed about how we are protecting
your information.







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