Privacy Policy

Last Updated: May 24, 2018

Accountability

Crowe Soberman is responsible for the personal information under our control and has designated a Privacy Officer who is accountable for compliance with our Global Privacy Policy. We also require that comparable protection of personal information is in place with any third parties used by us to process such information. Questions can be directed to Crowe Soberman’s Privacy Officer as indicated below:

Privacy Officer, Crowe Soberman LLP
Chartered Professional Accountants
2 St. Clair Avenue East
Suite 1100
Toronto, Ontario
M4T 2T5
Phone: 416 964 7633
Fax: 416 964 6454
Email: [email protected]
Website: www.crowesoberman.com

Crowe Soberman LLP is a member of Crowe Global, a Swiss Verein. Each member firm of Crowe Global is a separate and independent legal entity.

Purpose

We recognize the importance of your privacy and the sensitivity of personal information. Crowe Soberman is providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we receive through our Services. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information.

Scope

This Privacy Policy applies to Personal Information that is collected by Crowe Soberman in the course of our business, including on the Crowe Soberman website (“Site”), mobile applications, blogs, and other online or offline services (together with any and all future online and offline services managed by or on behalf of Crowe Soberman, the “Services”). This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services. All individuals whose responsibilities include the collection of Personal Information on behalf of Crowe Soberman are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally in the jurisdictions where our clients and Site visitors reside.

Transparency/Notice

Types of Personal Information We Collect
We use the term “personal information” to mean any information that can be used to identify an individual. Our primary goals in collecting personal information are to both provide and improve our Services, to provide professional services to you, and to allow you to enjoy and easily navigate our Site with the most accurate and relevant information to you and/or your organization. The types of Personal Information we may collect (directly from you or from a Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Crowe Soberman and the requirements of applicable law. Some of the ways that we may collect Personal Information include:

• directly to Crowe Soberman through your engagement of our Services (offline),
• through the distribution of requested reference materials,
• resumes, work history information, or application forms, submitted to us,
• when you contact us for further information,
• via surveys, quizzes, or benchmarking surveys
• via registration for events, courses and conferences (online or offline),

As you navigate the Site, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.

How Crowe Soberman Uses Your Information
All the personal information we hold about you will be processed by our staff in North America and no third parties will have access to your personal data unless there is a legal obligation for us to provide them with this. We have set out below the legal bases for the Firm to process your data:

• Some of our processing is necessary for compliance with a legal obligation.
• We may also process data if it is necessary for the performance of a contract with you, or to take steps to enter into a contract. An example of this would be processing your data in connection with providing you with services.
• We will also communicate with you information about other services we can offer you and update you about our activities.
• Where your information is used other than in accordance with one of these uses, we will first obtain your consent to that use.
• User Data obtained by the Site is used for internal business purposes of Crowe Soberman and in connection with a visitor’s request. This data is not shared with others for unrelated purposes unless stated in this Privacy Policy or otherwise communicated to the Site visitor.

Crowe Soberman’s intention is not to seek any sensitive information through our Site unless legally required for recruiting purposes.

Crowe Soberman makes every practical effort to avoid excessive or irrelevant collection of data. If a visitor believes the Site has collected excessive information, we encourage the visitor to contact us at [email protected] to raise any concerns.

Except for instances where visitors explicitly choose to receive specific Crowe Soberman marketing or other informational materials, Crowe Soberman will not use personal data collected from our Site to distribute marketing or informational materials.

Consent
By continuing to use the Site and by providing any personal data (including sensitive personal data) to us via the Site or email addresses provided on the Site, visitors are consenting to our use of your personal data as set out in this Privacy Policy.

Cookies, Pixel Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
We, as well as Third Parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Site. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our Site, applications, messaging, and tools, and to recognize you across devices.

• Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
• A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
• Our Site includes social media features such as the Facebook “Like” button and LinkedIn (that might include widgets such as the share this button or other interactive mini-programs). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third Party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.
• We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Site. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.

Our uses of such Technologies fall into the following general categories:

1. Operational. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Site, services, applications, and tools. This includes technologies that allow you access to our site, applications, and tools; that are required to identify irregular site behavior, prevent fraudulent activity and improve security; or that allow you to make use of our functions such as saved search, or similar functions;
2. Performance. We may use cookies, web beacons, or other similar technologies to assess the performance of our Site, applications, and tools, including as part of our analytic practices to help us understand how our visitors use our website, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our website content, applications, services, or tools;
3. Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.

If you would like to opt out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.

Cookie List

Third Parties
Crowe Soberman will only disclose Personal Information to third parties under the following circumstances:

• when explicitly requested by the client/user/visitor
• when required to deliver publications or reference materials requested by the client/user/visitor
• when required to facilitate conferences or events hosted by a third party
• when required to meet any other request of a client/user/visitor.

Categories of third parties that Crowe Soberman may share personally identifiable information with include federal, provincial, and local government entities and other members of the Crowe Global group.

The Site does not collect or compile personally identifying information for dissemination or sale to outside parties for consumer marketing purposes, or host mailings on behalf of third parties.

The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Crowe Soberman does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Data Retention
Crowe Soberman retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

Rights of Access, Rectification, Erasure, and Restriction
You may inquire as to whether Crowe Soberman is storing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. You may send an email to [email protected] or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by Crowe Soberman. Please include your full name, email address associated with your Account, and a detailed description of your data request.

Although Crowe Soberman makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Crowe Soberman is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Crowe Soberman determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Crowe Soberman will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Security and Safeguards
Crowe Soberman takes reasonable measures to ensure that your personal information is kept secure and prevent unauthorized access, modification or disclosure. Among the reasonable steps taken to protect your information are:

• Physical premises security;
• Restricted file access to personal information;
• Deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;
• Internal password and security policies.

Human Resources Data
With regard to Personal Information that Crowe Soberman receives in connection with the employment relationship, Crowe Soberman will use such Personal Information only for employment-related purposes. If Crowe Soberman intends to use this Personal Information for any other purpose, we will notify the Individual and provide an opportunity to opt-out of such uses.

Onward Transfer
Crowe Soberman does not disclose your personal information to any third party to enable them to market their products or services. For example, we do not sell or provide our client mailing lists to suppliers or other clients. Under certain circumstances, Crowe Soberman will disclose your personal information; for example:

• If we engage a third party to provide services to us;
• Where it is necessary to establish or collect payment;
• If the information is already publicly known.

Whenever we disclose your personal information to third parties for the purpose of providing services to us, we require such parties to maintain levels of confidentiality and security that are equivalent to our own practices.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. In such event, Crowe Soberman will endeavor to direct the transferee to use Personal Information in a manner that is consistent with the Privacy Policy in effect at the time such Personal Information was collected.

Data Transfers
All Personal Information collected via or by Crowe Soberman may be stored anywhere in the world, including but not limited to, Canada, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Crowe Soberman, you consent to the storage of your Personal Information in these locations.

Opt-Out Procedures
YOU HAVE THE RIGHT TO OPT‐OUT OF RECEIVING INFORMATION FROM CROWE SOBERMAN.
In accordance with the Canadian Anti-Spam Legislation, we must offer all email recipients the option to block future emails from Crowe Soberman LLP and its group of companies. Crowe Soberman provides that option in the footer of every email whether it is promotional in nature or related to the execution of engaged Services. Please note that if you decide not to provide us with the Personal Information that we request, or decide to opt-out of communications, we may not be able to provide you Services.

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Crowe Soberman’s storing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out by contacting [email protected] or clicking on the Unsubscribe option in the footer of every email.

About this Document

This Privacy Policy spells out the responsibility of Crowe Soberman (and related entities) and your rights as a client or other individual regarding the collection, use and disclosure of your personal information.

This Privacy Policy is subject to any amendments which will be posted on Crowe Soberman’s website and will also be available from Crowe Soberman’s Privacy Officer.