PRIVACY POLICY

[Last Update: December 1, 2022]

 

This privacy policy (“Privacy Policy” or “Policy”) describes how Somekh Chaikin – KPMG (collectively with its affiliates and subsidiaries shall be referred to as “KPMG”, “we”, “us”, or “our”), a registered Israeli partnership and a firm in the KPMG Global organization collect and use and share Personal Data of its website visitors, available at the KPMG website ("website" and "user", "you" or "your", respectively).  

KPMG is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, KPMG is committed to the appropriate protection and use of Personal Data (sometimes referred to as “personal information”, “personally identifiable information” or “PII”) that has been collected online. Generally, our intent is to collect only the Personal Data that is provided voluntarily by online visitors so that we can offer information or services to those individuals, offer information about employment opportunities, and for marketing purpose. In addition, we automatically collect Personal Data solely as needed for the purpose of our website operation and security. It is highly recommended to review this Privacy Policy to learn more about how we collect, use, share and protect the Personal Data that we have obtained from user, as well as your rights related to your Personal Data, prior to accessing our website or providing us with Personal Data.

We collect and process Personal Data in compliance with applicable laws, including (and depending on your jurisdiction and the laws that apply to us and to your Personal Data) the Israeli Privacy Protection Law, 1981-1981 (“IPPL”) and the EU General Data Protection Regulation (“GDPR”).

This Privacy Policy is an integral part of our website Terms and Conditions  (collectively the "Terms"). Definitions used however not defined herein shall have the meaning ascribed to them under the Terms and Conditions.

Please note that you are not required by law to provide us with Personal Data (as defined below). Providing Personal Data to us is entirely voluntary, provided however, that we will not be able to provide you with certain services or information without obtaining your Personal Data (for example, we will not be able to contact you in response to your inquiry if we will not have your contact details or examine your applicability to a certain job position, if requested by you). KPMG shall be entitled to (however not obligated), to retain and store Personal Data in its database, as detailed under this Privacy Policy, and subject to applicable law.

If you provide us with Personal Data, for example by way of contacting us, you hereby represent and warrant that the information is provided voluntarily of your own free will, and that the information you provide will be accurate and up to date. To the extent that you provide us with information about another individual (for example, as a proxy), you have all the necessary authorizations for the purpose of providing such information.

 

Policy Amendments

We reserve the right to amend this Policy from time to time, at our sole discretion, with or without notice. The most recent version of the Policy will always be posted on the website. Any amendments shall be effective upon publication of the revised Privacy Policy. The updated date of the Policy will be reflected in the “Last Updated” heading. In the event of what we believe is a material amendment, we will make best efforts to provide applicable notification through the website or by other means of communication.  We recommend you to review this Policy periodically to ensure that you understand our most updated privacy practices.

 

Contact Information and Data Controller Information

Somekh Chaikin – KPMG incorporated under the laws of the Israel, is the Data Controller (as defined under the GDPR) and Database Owner (as defined under the IPPL) of your Personal Data collected through this website.

You may contact us and our privacy team as follows:

Somekh Chaikin – KPMG

Attn: Stuart Fund, Data Protection Officer

HaArba'a St 17, Tel Aviv-Yafo, Israel

 

The Types of Personal Data We Collect, Purpose of Use and Lawful Basis for Processing Personal Data

You can find here information regarding the types of information we collect, the purposes for which we process your Personal Data as well as our lawful basis for processing (which is applicable where the GDPR applies to the Personal Data collected). 

When you access, use or interact with this website, we may collect the following types of data:

"Non-Personal Data"

During your interaction with our website, we may collect aggregated, non-personal non-identifiable information which may be made available or gathered via your access to and use of the website. We are not aware of the identity of the user from which the Non-Personal Data is collected. The Non-Personal Data which is being collected may include your aggregated usage information and technical information transmitted by your device and for example, type of device, browser and operating system, default language, etc.

"Personal Data"

We may also collect, during your access or interaction with the website, individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual. The types of Personal Data that we collect as well as the purpose for processing such data, are specified in the table below. In addition, where applicable, the law in Europe (i.e., GDPR) allows us to process Personal Data, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds, and the table below further details such information.

 

Note that, we do not combine Personal Data voluntarily provided by you with the Non-Personal Data. However, if we do so, we will treat the combined information as Personal Data. We may however, anonymize Personal Data and use it in an aggregated form for internal statistics and analysis, in order to improve the website and Content offered therein.

 

 

The table below details the processing of Personal Data, the purpose, lawful basis and processing operations:

Data Set

Purpose and Operations

Lawful Basis

(Where the GDPR applies)

Online Identifier & Usage Data

When you access and interact with our website, we collect certain online identifiers such as Cookie ID, IP address or similar unique online identifiers generated. We may further collect information related to your use and interaction with our website such as directing campaign and URLs, pages viewed, access time and date, etc. 

We collect and process this data  through our or third parties’ cookies and tracking technologies for analytic, marketing and advertising purposes. In addition, we process such data for operation, security and fraud prevention purposes.

This information will also typically be used in aggregate form to conduct web site trend and performance analysis.

 

Where we collect such data for analytic and advertising purposes, we process the data based on your consent which we will obtain through our cookie notice and consent management  platforms (“CMP”).  You may withdraw consent at any time by using the cookie preference settings.

Where we collect such data for other purpose, such as where required for operation and security, we process your data based on our legitimate interest.

Contact Information

If you voluntarily contact us, by any means of communication we make available (including email or digital forms), for information or other inquiries, you may be requested to provide us with certain information such as full name, email address, phone number, the name of the organization on behalf you are contacting us and you position, as well as the content of your inquiry that may include additional information, as provided at your discretion.

We will collect and use this data to address your inquiry, contact you, respond to your inquiry and provide you with the requested information.

We may further retain our contact history and correspondence, in the event we find it applicable (e.g., in the event of a future claim, or to improve our services).

We may also share such information with other member firms of KPMG Global, in the event we find that you inquiry is applicable to such firms.

In addition, we may use this data to send you newsletter and other marketing materials, subject to applicable law and as described below.

 

We process such data and use it for the described purposes, based on our legitimate interest to respond to your inquiry or make sure the applicable KPMG member firm will respond.

Newsletter and Mailing List

In the event you sign up to receive our newsletter or other marketing materials, or, subject to applicable law, where you have provided us with your contact information and haven’t opted-out from receiving marketing materials, we may use your contact information, such as name, email address and phone number, to send you promotional messages.

We will use this data in order to send you our newsletter and other marketing materials, offers, updates, invitations to webinars and events, etc., however all – in relation to our products and services.

These messages contain content defined as "advertisement" or " direct marketing" under the Israeli law.

You may opt-out of receiving our marketing materials at any time by contacting us or otherwise following the instructions included in each communication.

We will further store this data in order to include you, and maintain, our marketing and mailing lists, as well as the "opt-out" list (solely the necessary information for such purpose), to ensure we respect your choice and comply with applicable laws in this regard.

 

Where you sign up to receive our marketing materials, we process your data based on your consent. You may withdraw consent at any time through the “unsubscribe” link within the email or by contacting us directly.

We may further use your data to send you such marketing materials, based on our legitimate interest, where you have expressed your interests in our services or products, subject to applicable law.

In addition, we will further maintain a suppression file – meaning lists of applicable emails of phone number that have requested to opt-out, under our legitimate interest and to ensure we comply with such preference and choice.

Recruitment

In the event you apply for a job position via our website, we will process your contact information, such as name, email address and phone number, as well as the resume and curriculum vitae (CV) you will submit, and the information you choose to include therein.

We will use this data to process your job application, for our internal recruitment management purposes, for further recruitment steps (e.g., interview), and to enable us to comply with corporate governance and legal and regulatory requirements.

Following the completion of the recruitment process, we may further retain and store the data (including other interactions with us under such process) as part of our internal record keeping, including for legal defense from any future claim, as well as, where we find applicable and subject to applicable law requirements, to contact you in the future for other job position we believe will suit your qualifications.

If you are hired by us, your data may be used in connection with your employment and our corporate management.

We may use third party’s services and platforms to manage the recruitment process and to receive CV’s, meaning our website will incorporate such technologies to which your CV and related data will be upload, as shall be indicated in our website

We process such information (including use, store and retain it) for the described purposes, based on our legitimate interest. 

Please note, in the event, you send us your CV, your provision of Personal Data in connection with recruiting is voluntary, and you determine the extent of information you provide us. We do not request or require sensitive personal data concerning religion, health, sexual orientation, or political affiliation in connection with recruiting.

In addition to the processing operations detailed above, we may use certain Personal Data to prevent potentially prohibited or illegal activities, fraud, misappropriation, infringements, identity thefts and any other misuse of the website and to enforce the Terms, as well as to protect the security or integrity of our databases and the website, and to take precautions against legal liability. Such processing is based on our legitimate interests.

Furthermore, we process may use certain Personal Data this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency, as well as to comply with applicable law requirements

Please note that, the actual processing operation per each purpose of use and lawful basis detailed in the table above, may differ. Such processing operation usually includes set of operations, some made by automated means, such as collection, storage, use, disclosure by transmission, erasure or destruction. Transfer of Personal Data to third party countries as further detailed in the Data Transfer section is based on the same lawful basis as stipulated in the table above.

Your Personal Data shall not be used by us for purposes other than as described above, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards.

 

How We Collect Your Data:

We may collect information either automatically or voluntarily provided by you. Automatic collection of information is usually made through the use of cookies (as detailed below) and similar tracking technologies, such as web beacons, tracking pixels, unified ID etc.

 

Data Sharing – Categories Of Recipients We Share Personal Data With:

We may share your Personal Data with third parties, including between our partners and with trusted partners or service providers. You can find here information about the categories of such third-party recipients.

Category of Recipient

Types of Data That Will Be Shared

Purpose of Sharing

Within the global organization of KPMG firms

All types of data

We may share information about you with other member firms in the KPMG global organization as part of international engagements, and with KPMG International Limited, its related entities and other KPMG firms where we believe, for example, your inquiry is applicable to such member firms or where required to meet our legal and regulatory obligations around the world.  Other parts of the KPMG organization are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for KPMG firms and their clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run KPMG’s business.

Trusted agents and service providers

 

 

All types of data

We may disclose Personal Data to our trusted agents and service providers, constructors and business partners, (including, but not limited to, our Cloud service provider, our CRM provider, etc.) so that they can perform requested services on our behalf. Thus, we share your data with such third-party entities, for the purpose of storing such information on our behalf, or for other processing needs. These entities are prohibited from using your Personal Data for any purposes other than providing us with requested services.

Any acquirer of our business

All types of data

We may share Personal Data, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, our affiliated companies or acquiring company will assume the rights and obligations as described in this Policy.

Compelled disclosure

Subject to your request

We may share Personal Data, in the event your request us to do so. In such event, the provisions of your Personal Data will be subject to such third parties' policies and practices only.

Enforcement of our rights and security detections.  

All types pf data

We may disclose Personal Data to enforce our policies and terms of use, as well as defend our rights, including the investigation of potential violations thereof, alleged illegal activity or any other activity that may expose us, you, or other users to legal liability, and solely to the extent required. In addition, we may disclose Personal Data to detect, prevent, or otherwise address fraud, security, or technical issues, solely to the extent required.

Legal and law enforcement

 

Subject to law enforcement authority request.

We may disclose certain data to law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other user to legal liability, and solely to the extent necessary to comply with such purpose.

 

Where we share information with services providers and partners, we ensure they only have access to such information that is strictly necessary. These parties are required to secure the data they receive and to use the data for pre-agreed purposes only, while ensuring compliance with all applicable data protection regulations (such service providers may use other Non-Personal Data for their own benefit)

 

Cookies Policy

We or our third-party service providers may use cookies and other similar tracking technologies or methods of web and mobile analysis to gather, store, and track certain information related to your access of, activity and interaction with our website.  

A “cookie” is a small piece of information that a website assigns to your device while you access such website. Cookies are very helpful and may be used for a variety of different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences. Cookies are also used to help customize your experience and for advertising purposes (including personalized advertising). You can find out more information about cookies at www.allaboutcookies.org.

See below the list of third-party cookies and other tracking technologies currently used as part of the website:

COOKIES

PURPOSE

PRIVACY POLICY

Facebook

Marketing, Analytics and examining Performance purposes,

for example, in order to obtain information on the number of users who reached the site through various publications on Facebook.

Further, intended for the operation of the website's page, as well as for the prominent functionality of the website which are intended for the business landing pages of KPMG on Facebook.

https://www.facebook.com/about/privacy/update
https://www.facebook.com/policies/cookies

Google Analytics

 

 

Google AdSense

These cookies are intended for marketing purposes as well as analysis and statistics regarding the use of the website for the purpose of improving the website and its contents.

www.google.com/policies/privacy/partners 

https://tools.google.com/dlpage/gaoptout

For information on our use of Google products, click here

 

Microsoft

These cookies are intended for the purposes of the operation of the website, for the functionality of the operation and security of the website.

https://privacy.microsoft.com/en-us/privacystatement

 

Cookies opt-out

Most browsers will allow you to erase cookies from your computer’s hard drive, block acceptance of cookies, or receive a warning before a cookie is stored. However, if you block or erase cookies your online experience may be limited.

Please see the following links for more information with respect to how you can block or erase cookies via your particular browser: Google Chrome; Firefox; Internet Explorer; Safari; Edge; Opera.

 

International Data Transfer

Due to our global operations, we may store Personal Data globally, including in the US, EU and the State of Israel. Thus, we may transfer certain Personal Data outside of your jurisdiction to outside companies working with us or on our behalf for the purposes described in this Privacy Policy. In the event that we need to transfer your Personal Data out of your jurisdiction, we will take appropriate measures to ensure that your Personal Data receives an adequate level of protection as required under applicable law. Furthermore, when Personal Data that is collected within the European Economic Area ("EEA") is transferred outside of the EEA to a country that has not received an adequacy decision from the European Commission, we will take necessary steps in order to ensure that sufficient safeguards are provided during the transferring of such Personal Data, in accordance with the provision of the standard contractual clauses approved by the European Union. Thus, we will obtain contractual commitments and or assurances from the data importer to protect your Personal Data, using contractual protections that the Israeli, EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses), or rely on adequacy decisions issued by the applicable regulator.

KPMG will not transfer the Personal Data you provide to any third parties for their own direct marketing use.

 

Data Retention

We make reasonable efforts to retain Personal Data only for so long: (i) as the information is necessary to comply with an individual’s request; ( ii) as necessary to comply with legal, regulatory, tax, accounting, internal business or policy requirements; (iii) until an individual asks for the deletion of his Personal Data if the retention exceeds the retention period (subject to applicable laws); or (iv) if we reasonably believe there is a prospect of litigation relating to your Personal Data. The period for which data is retained will depend on the specific nature and circumstances under which the Personal Data was collected.

 

Data Security and Integrity

KPMG has implemented physical, technical and administrative security measures that comply with applicable laws and industry and has reasonable security policies and procedures in place to protect Personal Data from unauthorized loss, misuse, alteration, or destruction. To the best of our ability, access to your Personal Data is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

Despite KPMG's best efforts, the security of data cannot be absolutely guaranteed against all threats. Thus, we cannot be held responsible for unauthorized or unintended access that is beyond our control, and we make no warranty, express, implied or otherwise, that we will always be able to prevent such access.

Please contact us at: us-islprivacy@KPMG.com if you feel that your privacy was not dealt with properly, in a way that was in breach of our Privacy Policy or if you become aware of a third party's attempt to gain unauthorized access to any of your Personal Data. We will make a reasonable effort to notify you and the appropriate authorities (if required by applicable law) in the event that we discover a security incident related to your Personal Data.

 

Your Choices and Rights

In general, you are not required to submit any Personal Data to KPMG, but we will require you to provide certain Personal Data in some cases, where required to address your inquiry, job application, etc., as well as for you to receive additional information about our services and events. KPMG will also ask for your permission for certain uses of your Personal Data, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as a newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

Furthermore, and depending on your jurisdiction, If we process Personal Data about you, you may have one or more of the following rights:

Access and correction: you have the right to access to your Personal Data that we process and store. If we agree that we are obliged to provide Personal Data to you, we will provide it to you free of charge. Before providing Personal Data to you, we may ask for proof of identity and sufficient information about your interactions with us. If the Personal Data we process about you is incorrect, you are entitled to ask us to correct any inaccuracies in the Personal Data, and the right to amend it (by correcting, deleting or adding information).

Object to processing: you have the right to object to the processing of your Personal Data, to the extent applicable.

Withdraw consent (opt-out): you have the right to withdraw your consent, subject to legal or contractual restrictions and reasonable notice.

Other Rights: in addition, you may have right to have your Personal Data deleted if we are excessing the retention period, or to have you Personal Data processing restricted in certain circumstances and to obtain copies of the Personal Data we process about you in electronic form.

You can make a request to exercise these rights in relation to your Personal Data by contacting us at: us-islprivacy@KPMG.com. KPMG will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

 

Links to Other Sites

Please be aware that our website may contain links to other sites (“Linked Sites”), including sites maintained by other KPMG firms that are not governed by this Privacy Policy but by other privacy policies that will often differ from one another. We encourage users to review the privacy policy of each Linked Site visited before disclosing any Personal Data. It is hereby agreed that KPMG has no control or responsibility with respect to these Linked Sites.  

 

Children

Our website, service available therein and the Content are not intended for use by children. KPMG understands the importance of protecting children’s privacy, especially in an online environment. In particular, our website is not intentionally designed for or directed at children under the age of 13 and we do not knowingly collect or maintain information about anyone under the age of 13. Please contact us at: us-islprivacy@KPMG.com if you have reason to believe that a child has shared any information with us.

 

Contact Us

KPMG is committed to protecting the online privacy of your Personal Data. If you have questions or comments about our administration of your Personal Data, or you have any concerns regarding compliance with our Privacy Policy, you may contact us by one of the communications means below:

  • By Email: us-islprivacy@KPMG.com
  • By Mail:

Somekh Chaikin – KPMG,

Attn: Stuart Fund, Data Protection Officer

KPMG Tower - 17 Ha'arba'a Street

PO Box 609

Tel Aviv 64739

Israel

info@kpmgedge.com

רחוב הארבעה 17 תל אביב

972-3-6848000

972-3-6848881

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