We (“PwC”, “us”, or “our”) are strongly committed to protecting personal data. This transparency notice 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 transparency notice or as otherwise stated at the point of collection.
Personal data is any information relating to an identified or identifiable living 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.
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.
To find out more please go to the sections of this statement that are relevant to you.
PwC processes personal data about contacts (existing and potential PwC clients and/or individuals associated with them) using a customer relationship management system (the “PwC CRM”).
The collection of personal data about contacts and the addition of that personal data to the PwC CRM is initiated by a PwC user and will include name, employer name, contact title, phone, email and other business contact details. In addition, the PwC CRM may collect data from PwC email (sender name, recipient name, date and time) and calendar (organiser name, participant name, date and time of event) systems concerning interactions between PwC users and contacts or third parties.
Personal data relating to business contacts may be visible to and used by PwC users to learn more about an account, client or opportunity they have an interest in, and may be used for the following purposes:
● Developing our businesses and services
● Providing information to you about us and our range of services
● Making personal data available to PwC employees for performing services and for offering new services
● Identifying clients with similar needs
● Performing analytics such as on market trends, relationships maps or sales opportunities.
In addition, the PwC CRM uses an algorithm to evaluate the strength of interactions between a PwC user and a contact. This ranking is primarily based on interaction frequency, duration, and regency and response time.
We will process our business contacts’ personal data based on our legitimate business interests or the consent, if the data subject has been requested to express one. We have an interest in marketing our services or providing communications which we think will be of interest to recipients.
Personal data will be retained on the PwC CRM for as long as it is necessary for the purposes set out above (e.g. for as long as we have, or need to keep a record of, a relationship with a business contact).
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 Union ("EU") and to 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 EU are done lawfully. Where we transfer personal data outside of the EU 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 EU, 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.
The data controller is PricewaterhouseCoopers Audit LLC or such PwC member firm, listed under this link, 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:
Central Tower, Floor 6, Suite 601
Sukhbaatar Square 2, SBD-8
Telephone: (+976) 7000 9089
Telecopier: (+976) 11 322 068
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.
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 email@example.com or using a dedicated form accessed here.
To update personal data submitted to us, you may email us at firstname.lastname@example.org 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.
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 email@example.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.
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.
This transparency notice 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 firstname.lastname@example.org
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 email@example.com. We will look into and respond to any complaints we receive.