Digital Fitness Assessment App - Privacy Statement

PricewaterhouseCoopers (“PwC”, “we”, “us”, or “our”) is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data in this Application, and also provides information about individual’s rights in relation to the use of this Application.

You have been given access to this Application either because (1) you are an employee of a client of PwC, and your employer has asked for you to be provided access in order for PwC to render services to your employer, (2) you are a member of or associated with an organization which has provided your access, (3) you have been given temporary access to this Application using a code provided by PwC, (4) you have been given access to this Application by PwC as a member of PwC’s Talent Acquisition Network, or (5) you are a PwC employee, partner, or contractor who has been given access to this Application solely in connection with your role at a PwC member firm (your firm). If you are a PwC employee, partner, or contractor, your employment or other agreement with your firm regarding your role applies to your use of this Application.

This privacy statement applies to personal data provided to us, either by you or by others (such as your employer or the organization or PwC team providing you access). When collecting and using personal data, our policy is to only collect what we need and to be transparent about why and how we process personal data. 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.

By using this Application and providing personal data to us, you acknowledge that you have read this privacy statement, and, to the extent your consent is necessary and valid under applicable law, you consent to the collection, use and disclosure of such personal information by PwC and any third party recipients in accordance with this privacy statement.

Definitions

In this privacy statement we use the following terms:

Application refers to the Digital Fitness Assessment Application tool, which enables organizations and individuals to assess and grow their digital fluency. The application is encompassed of three key features: a Digital Fitness Assessment, Digital Fitness Plan, and a Content Library of Digital Topics and Topics regarding COVID19. The Digital Fitness Assessment is a proprietary PwC assessment. Upon receiving their score, users can select a fitness plan which keeps them accountable for digital learning within the application, based on their selection. Users can then build their digital fluency across the four base pillars by consuming bite-sized thought leadership in the form of "artifacts" across content categories.

Personal data or personal information is how we sometimes refer to your information or information about you. Personal data is any information relating to you and from which you may be identified.

Processing is how we sometimes refer to the handling, collecting, protecting or storing of your personal information. We process personal data in this Application for numerous purposes, as set out below.

Definition of PwC

‘PwC’, ‘we’ and ‘us’ refer to the PwC network and/or one or more of its member firms. Each member firm in the PwC network is a separate legal entity (PwC firm). For further details, please see www.pwc.com/structure.

Collection of personal data

PwC may collect information about you in various ways, but generally only where (i) you specifically and voluntarily provide it to PwC or (ii) your organization provides information to us in connection with their offering of the Application to you. The information we collect about you through the Application includes your name, e-mail address, and answers you provide to the questions in the Application. If you are a teacher, we collect state and grade taught. If you are provided the application by PwC’s Talent Acquisition team, we collect information about the degree(s) you are pursuing or have achieved, and your status as a student.

PwC may also collect information about you when you use this Application, for example, logs of your activities on the site (for example, when you view a document).

We do not intend to collect sensitive personal information about you through this Application and no sensitive personal information is required for this Application to operate. Sensitive personal information includes race or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; physical or mental health; genetic data; biometric data; sexual life or sexual orientation; and criminal records. We ask that you not provide sensitive information of this nature about yourself or anyone else.

Use of personal data

The purposes for which we collect your personal information in connection with the Application and the purposes for which PwC may use it are:

  • authenticating the identity of the Application’s users, authorizing access to the Application (including preventing unauthorized access) and for other security-related purposes, including system monitoring
  • providing services to your organization – if you are provided access through your employer, PwC may provide your employer information relating to your use of the Application
  • informing organizational workforce, learning & development, and/or digital strategy for your organization - if you are provided access through your employer or if you are a PwC employee, partner or contractor, PwC may use your information to provide the services described in this bullet point 
  • providing information about PwC jobs and other opportunities -- if you are provided access as a member of PwC’s Talent Acquisition Network or have been given temporary access to the Application using a code provided by PwC, PwC may share information relating to your use of the Application with the PwC Talent Acquisition team
  • if you consent, providing additional information about the Application or marketing other PwC products and services to you 
  • operating, administering, managing and improving the Application
  • benchmarking, including analysis of trends related to job roles
  • maintaining our administrative or client relationship management systems
  • analyzing how the Application and associated services perform
  • complying with PwC’s obligations, including applicable laws

This processing is necessary for the purpose of our legitimate interests in running a business and such interests are not overridden by the rights and freedoms of the individuals concerned. In addition, processing is necessary for the purpose of our own legitimate interests in maintaining the security of our data, the quality of our services and maintaining our reputation, and such interests are not overridden by the rights and freedoms of the individual affected.

We will not pass your information to third parties for direct marketing. PwC may combine information you provide through the Application with other information to create outputs that we make available to others, provided you cannot be identified from those outputs.

Security

We take the security of all of the data we hold seriously. We have a framework of policies, procedures, and training in place covering data protection, confidentiality and security. We also have appropriate technical and organizational security measures in place to protect confidential information, including personal information about you, from loss, misuse or destruction, including unauthorized, accidental or unlawful disclosure or processing of your personal information. Our security procedures are monitored regularly and updated in line with technical progress.

Note that the transmission of data over the internet (including by e-mail) is never completely secure. Although we endeavor to protect personal data by using appropriate security measures once we have received it, but we cannot guarantee the security of data when it is transmitted to us by you or to you by us.

Children

PwC understands the importance of protecting children's privacy, especially in an online environment. Digital Fitness Assessment application is not intentionally designed for or directed at children under the age of 13 years. It is PwC's policy never to knowingly collect or maintain personal information about children under the age of 13.

Cookies

Cookies are small text files that are placed on your computer by the site that you visit. They are widely used in order to make sites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most sites. If you are uncomfortable with the use of cookies, you can manage and control them through your browser, including removing cookies by deleting them from your 'browser history' (cache) when you leave the site.

Managing cookies on your device

We use cookies to personalize content and to provide you with an improved user experience. By using this application you consent to the deployment of cookies. You can control and manage cookies using your browser (see below). Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

Using your browser to control cookies

Most browsers allow you to view, manage, delete and block cookies for a site. Be aware that if you delete all cookies then any preferences you have set will be lost, including the ability to opt-out from cookies as this function itself requires placement of an opt out cookie on your device. Guidance on how to control cookies for common browsers is linked below.

Google Chrome

Mozilla Firefox

MacOS Safari

Microsoft Internet Explorer

For information on additional browsers and device types please see http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.

Managing Analytics cookies

You can opt-out of having your anonymised browsing history within our mobile applications recorded by analytics cookies. We use the following service providers and you can learn more about their privacy policies and how to opt-out of their analytics cookies by clicking on following links:

Adobe: http://www.adobe.com/privacy/opt-out.html

Types of cookies

  • ‘Session’ cookies remain in your browser during your browser session only, i.e. until you leave the mobile application. ‘Persistent’ cookies remain in your browser after the session (unless deleted by you).
  • ‘Performance’ cookies collect information about your use of the app, such as pages visited and any error messages; they do not collect personally identifiable information, and the information collected is aggregated such that it is anonymous. Performance cookies are used to improve how a mobile application works.
  • ‘Functionality’ cookies allow the site to remember any choices you make about the mobile application (such as changes to text size, customized pages) or enable services such as commenting on a blog.

Use of cookies by PwC

The following table explains the way in which we use cookies in this application:

Name Purpose Type Duration
AMCV_###@AdobeOrg This cookie is used to identify a unique visitor. It is set using JavaScript to store a unique visitor ID in an AMCV_###@AdobeOrg cookie on the domain of the current site, where ### represents a random string of characters.

First party persistent

2 years from set/update

s_vi

This cookie stores the visitor ID provided by our analytics provider whenever a user first visits the site.

Third party persistent

5 years from set/update

s_cc

This cookie determines whether cookies are enabled in your browser.

First party session

Until end of session

s_fid

This cookie is a “fallback” visitor identifier where the s_vi cookie normally used for this purpose is blocked. It contains a randomly generated, unique id.

First party persistent

2 years from set/update

s_nr

This cookie stores the date of visit and if visitor is new or returning.

First part persistent

2 years from set/update

s_sq

This cookie stores information about the previous link clicked within the site.

First party session

2 years from set/update

In addition, the IdAM system you used to access the Application uses cookies. The cookies link on the IdAM log in screen provides further information about the cookies used by IdAM.

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 transfer or share personal data, in order to protect the data, we put contractual arrangements and security mechanisms in place that 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 information may be transferred outside the countries where we and our clients are located. This includes transfers to countries outside the European Economic Area (“EEA”) and to countries that may not have laws that provide the same degree of protection for personal information as your home country. We have taken steps designed to facilitate adequate protection for any information so transferred. 

PricewaterhouseCoopers LLP and its affiliated U.S. subsidiaries adhere to the EU - U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information that is transferred from the EEA, its Member States, the United Kingdom, and/or Switzerland to the United States. PwC has certified that it adheres to the Privacy Shield Principles within the scope of PwC’s Privacy Shield certification. To learn more, see our Privacy Shield Policy

Where we transfer personal information outside of the EEA to a country or framework not determined by the European Commission as providing an adequate level of protection for personal information, the transfers will be under an agreement which covers European Union requirements for such transfers, such as standard contractual clauses. The European Commission approved standard contractual clauses are available here.

Personal data held by us may be transferred to:

  • Your Employer
    If you are provided access through your employer, we may share personal data with your employer who may use this personal data for any purpose in connection with its implementation of the Application. Any questions about how your employer uses or further discloses your personal data should be directed to your employer.
  • Other PwC member firms
    For details of the locations of our member firms, please click here. We may share personal data with other PwC member firms where necessary to provide services to our clients (e.g. when providing services involving advice from PwC member firms in different territories) and our business contacts may be visible to and used by PwC users from multiple PwC member firms.
  • Third party organizations that provide applications/functionality, data processing or IT services to us
    In common with most service providers, 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, mobile application 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 client data may be stored in any one of them.

The third party providers may use their own third party subcontractors that have access to personal data (sub-processors). It is our policy to use only third party providers that are bound to maintain appropriate levels of security and confidentiality, to process personal information only as instructed by PwC, and to flow those same obligations down to their sub-processors.

  • Other disclosures
    We may also disclose personal information to other third parties under the following circumstances:
    • when explicitly requested by you;
    • for regulatory compliance purposes; and/or
    • as otherwise set out in this Privacy Statement.

We may also disclose your personal information to law enforcement, regulatory and other government agencies, and to professional bodies and other third parties, as required by and/or in accordance with applicable law or regulation. This includes disclosures outside the country or region where you are located. PwC may also review and use your personal information to determine whether disclosure is required or permitted.

How long will PwC retain my personal information?

We retain personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). We may, however, agree to specific retention periods with our clients for personal data obtained in connection with providing services to those clients.

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Individuals’ rights and how to exercise them

You may have certain rights under your local law in relation to the personal information we hold about you. In particular, you may have a right to:

  • request a copy of personal information we hold about you;
  • 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 personal information that we hold about you, or restrict the way in which we use such personal information;
  • restrict or object to our processing of your personal information;
  • request a copy or transfer of your data (data portability); and/or
  • withdraw your consent to our processing of your personal information (to the extent such processing is based on consent and consent is the only permissible basis for processing).

To exercise any of the abovementioned rights, please contact us as set forth below. We will process any requests in accordance with applicable law and within a reasonable period of time. We recommend you include a clear and precise description of your request. Please note that in some cases, especially if you wish us to delete or cease the processing of your personal data, we may no longer be able to continue to provide our products or services to you. We may charge for a request to access your information, if permitted by applicable law.

Data controller and contact information

The data controller for your information on the Application depends on how you use the Application. If you use the Application on behalf of a client or potential client of a PwC member firm, the data controller is the PwC Member Firm making the Application available to that client. If you use the Application in connection with your role at a PwC Member Firm, that member firm is the data controller. If you use the Application in connection with PwC promotional access or as part of PwC’s Talent Acquisition Network, the PwC member firm making the Application available to you is the data controller.

As noted above, each Member Firm in the PwC network is a separate legal entity. For further details, please see www.pwc.com/structure. See http://www.pwc.com/gx/en/about/office-locations.html for a list of countries in which PwC Member Firms operate.

If you have any questions or complaints about this privacy statement or the way your personal information is processed, or would like to exercise one of your rights set out above, please submit a request to exercise a legal right in relation to your personal data, or an inquiry if you have a question or complaint about the handling of your personal data. You may also have the right under applicable law to lodge a complaint with your local supervisory authority responsible for data protection matters.

Modifications

This privacy statement was last modified in March 2020. We may update this privacy statement at any time by publishing an updated version here. The new modified or amended privacy statement will apply from that revision date. Therefore, we encourage you to review this privacy statement periodically to be informed about how we are protecting your information.

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