Privacy Statement

This Privacy Statement applies for personal data processing activities carried out by Aktsiaselts PricewaterhouseCoopers (registered in the Republic of Estonia under the registry code 10142876 and with its seat at Tatari 1, 10116 Tallinn, Republic of Estonia) and AS PricewaterhouseCoopers Advisors (registered in the Republic of Estonia under the registry code 10325507 and with its seat at Tatari 1, 10116 Tallinn, Republic of Estonia; hereinafter together referred to as “PwC”, “us” or “we”).

Introduction

We are strongly committed to protecting personal data. This Privacy Statement describes why and how we collect and use personal data and provides information about individuals’ rights. We may use personal data provided to us for any of the purposes described in this Privacy Statement or as otherwise stated at the point of collection.

Personal data is any information relating to an identified or identifiable natural person. PwC processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.  

When collecting and using personal data, our policy is to be transparent about why and how we process personal data.  

Security

We take the security of all the data we hold very seriously. We adhere to internationally recognised security standards and our information security management system relating to client confidential data is independently certified as complying with the requirements of ISO/IEC 27001: 2013.  We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data we hold secure.

Legal basis for processing

Legal bases for each processing activity are specified in the relevant sections above. When we process personal information for our legitimate interests, we make sure to consider and balance any potential impact on a data subject (both positive and negative), and the data subject’s rights under data protection laws. Our legitimate business interests do not automatically override interests of the data subjects - we will not process personal data for activities where our interests are overridden by the impact on the data subject  (unless we have the consent or are otherwise required or permitted to by law).

When and how we share personal data and locations of processing

We will only share personal data with others when we are legally permitted to do so.  When we share data with others, we put contractual arrangements and security mechanisms in place to protect the data and to comply with our data protection, confidentiality and security standards.

We are part of a global network of firms and in common with other professional service providers, we use third parties located in other countries to help us run our business.  As a result, personal data may be transferred outside the countries where we and our clients are located.  

In respect of personal data being regulated by EU legislation, please note that: cross border transfers may include countries outside the European Economic Area ("EEA") and countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside the EEA are done lawfully. Where we transfer personal data outside of the EEA to a country not determined by the European Commission as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the EU requirements for the transfer of personal data outside the EEA, such as the European Commission approved standard contractual clauses. The European Commission approved standard contractual clauses are available here.

Personal data held by us may be transferred to:

• Other PwC member firms
  For details of our member firm locations, please click here. We may share personal data with other PwC member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from PwC member firms in different territories). Our business contacts are visible to and used by PwC users from other PwC member firms to learn more about a contact, client or opportunity they have an interest in (please see the Business contacts section of this Privacy Statement for more information about our processing of this type of data);
• Third party organisations that provide applications/functionality, data processing or IT services to us;
• We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data may be stored in any one of them;
• Third party organisations that otherwise assist us in providing goods, services or information;
• Auditors and other professional advisers;
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation;
• Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights.  We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Changes to this privacy statement

We recognise that transparency is an ongoing responsibility so we will keep this privacy statement under regular review.

This privacy statement was last updated on 22.05.2018.

Data controller and contact information 

The data controller is Aktsiaselts PricewaterhouseCoopers or AS PricewaterhouseCoopers Advisors, as applicable, that is a contracting party for the purposes of providing or receiving services or the entity you have contacted.

If you have any questions about this privacy statement or how and why we process personal data, please contact us at:

Tatari 1, 10116 Tallinn, Estonia

Email: ee_privacy@pwc.com

Individuals’ rights and how to exercise them

Individuals have certain rights over their personal data and data controllers are responsible for fulfilling these rights.  Where we decide how and why personal data is processed, we are a data controller and include further information about the rights that individuals have and how to exercise them below.

Access to personal data

You have a right of access to personal data held by us as a data controller. This right may be exercised by emailing us at ee_privacy@pwc.com or using a dedicated form accessed here and here.

Amendment of personal data

To update personal data submitted to us, you may email us at ee_privacy@pwc.com or, where appropriate, contact us via the relevant website registration page or by amending the personal details held on relevant applications with which you registered.

When practically possible, once we are informed that any personal data processed by us is no longer accurate, we will make corrections (where appropriate) based on your updated information.

Withdrawal of consent

Where we process personal data based on consent, individuals have a right to withdraw consent at any time.  We do not generally process personal data based on consent (as we can usually rely on another legal basis). To withdraw consent to our processing of your personal data please email us at ee_privacy@pwc.com or, to stop receiving an email from a PwC marketing list, please click on the unsubscribe link in the relevant email received from us.  

Right to restrict or object to our processing of personal data

You have the right to restrict or object to the processing of your personal information at any time, on reasonable grounds relating to your particular situation, unless the processing is required by law.

In such case, we will no longer process or restrict the processing of the personal data, unless we can demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defense of legal claims.

Other data subject rights

This Privacy Statement is intended to provide information about what personal data we collect about you and how it is used.  As well as rights of access, amendment and restriction or objection to processing referred to above, individuals may have other rights in relation to the personal data we hold, such as a right to erasure/deletion and the right to data portability.   

If you wish to exercise any of these rights, please send an email to ee_privacy@pwc.com. 

Complaints

We hope that you won’t ever need to, but if you do want to complain about our use of personal data, please send an email with the details of your complaint to ee_privacy@pwc.com. We will look into and respond to any complaints we receive.

You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate or turn to the court.