Last updated April 2023

KPMG¹ 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 information (sometimes referred to as “personal data”, "personally identifiable information" or "PII") that has been collected online.

Please review this Online Privacy Statement ("Privacy Statement") to learn about how we collect, use, share and protect the personal information that we have obtained. For more details about how we manage your personal information, please read the KPMG China Privacy Statement.

1.1  What information we collect

1.1.1 How we collect personal information

We obtain personal information about you if you choose to provide it voluntarily to us — for example, through visiting KPMG websites to make enquiries about our services, obtain information, apply for jobs, contact mailboxes or register for certain services. In some cases, you may have previously provided your personal information to KPMG (for example, you are a job candidate or former employee of KPMG).

If you choose to register or login to a KPMG web site using a third-party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Facebook, WeChat and/or Weibo) with KPMG, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address for the purposes above mentioned. Other information we collect may depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service to understand and set how much information you want shared with us.

This Privacy Statement also covers other means by which we collect information, for example, through automatic collection of personal information as described in Section 1.3, and in addition, how we collect information from in person discussions, telephone conversations, offline questionnaires and letters and through non-electronic communications (i.e., collection through means other than KPMG’s online systems).

We may also collect personal information via indirect means, such as (to the extent allowed under applicable laws and regulations) your information that has been legally publicized via public registers and news articles. 

1.1.2 Purposes of Collection and Processing

By registering and/or submitting personal information to KPMG, you are also acknowledging that KPMG may use this information in accordance with this Privacy Statement. Your personal information is not used for any other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example:  

• If you register to a KPMG web site and provide any personal information (including information about user preferences, where appliable), we will use this information to register a user account, create and update user profile, authenticate registered users, determining the organisation that you work for or represent, and/or personalise or enhance user experience. 
• We will be using the contact details you provided to KPMG to reach out to you or provide you with our feedback, if you have left such information when expressing interest or raising inquiries (including any requests for proposals and quotations) on our professional products, services and capabilities. We may further use such information to conduct our client acceptance process at pre-engagement stage. We will not use such personal information for our direct marketing without your prior permission or unless we are otherwise permitted to do so by the applicable law (refer to Section 3 for further information). 
• Where you register or login using a third-party single user sign-in we may also recognize you as the same user across any different devices you use and personalise your user experience across other KPMG sites you visit. 
• If you send us your personal information via a resume or application form etc. to apply for a position with KPMG, we will use such information to match you with available job opportunities, proceed with recruitment, and/or (to the extent allowed by appliable law) maintain such personal information of yours as a qualified candidate. More details in this regard could be covered by other privacy terms and policies that we may present to you in such process.
• In some cases where you have registered for certain services, we may store your email address temporarily until we receive confirmation of the information you provided via an email (i.e.: where we send an email to the email address provided as part of your registration to confirm a subscription request) or required by the applicable law.
• To provide yourself or our client with our feedback, professional advice and/or other deliverables which would fall under the professional services that our clients have engaged us to provide (refer also to Section 1.1.3 below).
• To administer, maintain and ensure the security of our information systems, applications and websites.
• To comply with legal and regulatory obligations and professional standards, including relating to anti-money laundering, terrorist financing, fraud and other forms of financial crime, and/or for auditor independence checks.

1.1.3 Scope of Applicability

Unless expressly stated with further notes, this Privacy Statement does not cover the processing of your personal information if such information of yours is made accessible to KPMG in the course of a professional engagement by our client. Such client (e.g. the organization that you work for) may engage KPMG to review and analyse personal information which they control and which is relevant to you. In such cases, the method, scope and purpose that we collect and process your personal information are subject to our agreement with such clients and to the extent they’ve entrusted KPMG for the purpose of such engagements. 

In the event that you use another KPMG website and you are presented with a specific privacy statement under the name of KPMG, you should also read through the details in the specific privacy statement which is customised based on this Privacy Statement, to understand how your personal information will be collected and processed by the particular website.

1.2 The legal grounds we have to use your personal information

KPMG generally collects only the personal information necessary to fulfil your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

The relevant data privacy laws in the Peoples’ Republic of China (hereinafter referred to as “Chinese Mainland” for the purpose of this Privacy Statement), Hong Kong SAR, Macau SAR and European Economic Area (EEA) where applicable, allows us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract entered with you;
• Legal obligation: 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;
• Legitimate interests: we may process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
• Your consent: we may occasionally ask you for specific and/or separate permission to process some of your personal information, and in such scenarios where we rely on consent as our legal ground, we will only process your personal information to the extent you agree for us in doing so. 
• Other appliable legal grounds:  KPMG may also rely on other legal grounds or legal principles of the applicable data privacy laws, depending on your location and how you interact with KPMG, to collect and process your personal information.  KPMG only collects "sensitive" personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive personal information includes personal information regarding a person's race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual orientation, criminal records, biometric data, specific identity, health data, financial accounts and individual whereabouts location tracking. Please use your discretion when providing sensitive information to KPMG. Under any circumstances,  you should not provide yours or any third parties’ sensitive personal information to KPMG unless we shall separately notify you (and these third parties) and you (and these third parties)  have given us your (and these third parties’) explicit  consent  for KPMG to use or process  your (and these third parties’)  sensitive personal information for legitimate and necessary business purposes and you (and these third parties)  have also consented for us to the transfer and  store such sensitive personal information  in KPMG databases.  If you have any questions about whether the provision of sensitive personal information to KPMG is, or may be, necessary or appropriate for particular purposes, please contact KPMG at cn-fmdataprivacy@kpmg.com.

1.3 Automatic collection of personal information 

In some instances, KPMG and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customise your online experience, improve the performance, usability and effectiveness of KPMG's online presence, and to measure the effectiveness of our marketing activities.

1.3.1 IP addresses 

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

1.3.2 Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves the purposes notified in this Privacy Statement.  

On our web sites, a notification banner will appear allowing you to manage your consent to collect cookies (cookie banner). Below is a summary of the categories of cookies collected on our websites, and how your consent may impact your experience of certain features as you navigate those websites:

• Strictly necessary cookies: these cookies are necessary for core features of this site to operate properly. Because they are needed for the site's operation, they are always set to "Active". You may disable these by changing your browser settings, but this may affect how the website functions.
• Performance cookies: these cookies collect data on user behaviour. On this basis, the website is adjusted to the general user behaviour in terms of content and functionality. The information collected is generally processed in aggregated form, unless a visitor has expressly consented to a personal evaluation. Performance cookies are only used to improve the performance of the website and to tailor the online experience to the needs of the users.
• Functionality cookies: functionality cookies enable the website to store information such as the user name or language selection and to offer the user improved and personalised functions based on this information. The information collected is only evaluated in aggregated form. Since we would like to offer you a website that is designed for optimum user-friendliness, we recommend that you activate these cookies. Functional cookies are also used, for example, to activate the functions you desire, such as the playback of videos.
• Targeting cookies or marketing cookies: these cookies are used to offer content that is more relevant to the user and adapted to his interests. They are also used to measure and control the effectiveness of campaigns. For example, they register whether a website has been visited or not, as well as which content has been used. This information is used to create an interest profile so that only content that is interesting for you is displayed. If you withdraw your consent to marketing cookies, this does not mean that you will see or receive less content as a result. Rather, it means that the content you see and receive is not tailored to your individual needs. 

You can manage your consent for targeting cookies using the cookie banner, or by updating your browser’s settings (often found in your browser’s Tools or Preferences menu) to not accept cookies.

Although most browsers automatically accept cookies, you can choose whether to accept cookies via the cookie consent banner or your browser's settings (often found in your browser's Tools or Preferences menu). If you wish to revoke your selection, you may do so by clearing your browser’s cookies, or by updating your preferences in the cookie banner.

Further information as about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org.

Below is a list of the types of cookies used on our web sites:

Other third party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors

1.3.3 Google Analytics

KPMG uses Google Analytics. More information about how Google Analytics is used by KPMG can be found here: https://www.google.com/analytics/terms/us.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

1.3.4 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. KPMG only uses web beacons in accordance with applicable laws.

KPMG or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

1.3.5 Location-based tools

KPMG may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

1.4 Social media widgets and applications

KPMG web sites may include functionality to enable sharing via third party social media applications, such as the LinkedIn, Facebook, WeChat and/or Weibo widget. These social media applications may collect and use information regarding your use of KPMG web sites (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, KPMG web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any KPMG social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

1.5 Minors

KPMG understands the importance of protecting minors' privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at individuals under the age of 18 (“minors”). It is our policy never to knowingly collect or maintain information about minors, except as part of an engagement to provide professional services (in such scenario, if you or your organization provides such information of any minors, you should ensure having obtained the consent of minors' parents or guardians), for the purposes of ensuring compliance with our auditor independence policies, or as otherwise required by law. We will protect the confidentiality and security of minors’ personal information in accordance with relevant applicable laws and regulations.

If you believe we have incorrectly obtained personal information of minors or without due consent from their parents or guardians, you may contact KPMG at cn-fmdataprivacy@kpmg.com. 

2. Sharing and transfer of personal information

2.1 Transfers to third parties

We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs and to the extent permitted by law, to carry out your requests, and/or as required or permitted by law or professional standards. This would include:

• Our service providers: KPMG work with reputable partners, service providers or agencies (“Service Providers”) so they can process your personal information on our behalf. KPMG will only transfer personal information to the Service Providers when they meet our strict standards on the processing of data and security. We only share personal information that allows the Service Provider to provide their services.
• If we are reorganised or sold to another organisation: KPMG may also disclose personal information to the relevant entities in connection with the sale, assignment, or other transfer of the business of the site to which the data relates;
• Courts, tribunals, law enforcement or regulatory bodies: KPMG may, to the extent permitted by the local laws or subject to the fulfillment of the regulatory requirements of the applicable laws, disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government regulations.
• Audits: disclosures of personal information may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat.

In addition, KPMG may transfer certain personal information inside and outside of Hong Kong, Macau and/or Chinese Mainland to companies working with us or on our behalf for the purposes described in this Privacy Statement to the extent permitted by law and subject to the fulfilment of the regulatory requirements of the applicable laws.

KPMG may also store personal information inside or outside of Hong Kong, Macau and/or Chinese Mainland. If we do this your personal information will continue to be protected by means of contracts we have in place with those organisations inside and outside Hong Kong, Macau and/or Chinese Mainland, which are in a form approved by the competent authority in the applicable jurisdiction.

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

2.2 Transfer within the global organisation of KPMG firms

To the extent permitted by applicable law, we share information including personal information you provided with other member firms of the KPMG global organisation as part of international engagements, and with KPMG International and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the KPMG organisation are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its 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.

By providing KPMG with personal information via online systems, visitors are explicitly consenting to this transfer and/or storage of their personal information across borders for the purpose of the foregoing Section 2.1 and this Section 2.2. If information you provided includes personal information of other individuals, you agree to obtain express consent, whenever required under the applicable law, from these other individuals prior to the submission of such personal information to KPMG. If information you provided includes personal information of other individuals within Chinese Mainland, you agree and warrant to notify these other individuals of such cross-border transfer and obtain separate consent (if consent legal basis is relied upon) from these individuals, whenever required under the applicable laws, prior to the submission of such personal information to KPMG. By consenting to this Privacy Statement, you confirm that explicit consent has been obtained from the relevant individuals.

3. Choices

In general, you are not required to submit any personal information to KPMG, but we may require you to provide certain personal information in order for you to receive additional information about our services and events.

KPMG may also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as newsletters, publications, invitation, and any marketing materials, you will be able to unsubscribe at any time by following the instructions included in each communication (in some cases, we may present to you additional Personal Information Collection Statements that further applies to a specific subscription, which you shall read through as well before submitting any personal information to opt-in).

If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information or confirmation before we can process your request.

As described in "Cookies" above, if you wish to prevent cookies from tracking you as you navigate our sites, you can manage your consent for targeting cookies using the cookie banner, or by updating your browser’s settings (often found in your browser’s Tools or Preferences menu) to not accept cookies.

4. Your rights

If you have submitted personal information to KPMG, you have the following rights:

• Access: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information.
• Correction: If the information we hold about you is incorrect, you may ask us to correct any inaccuracies in your personal information.
• Object to processing: you may have the right to object to us processing your personal information if we are not entitled to use it any more.
• Withdrawal of consent: where we process your personal information on the legal basis of the consent from you, you have the right to withdraw your consent at any time by contacting KPMG via the email below (note: withdrawal of consent does not affect the validity of our consent-based personal information processing prior to the withdrawal).
• Deletion: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting KPMG at cn-fmdataprivacy@kpmg.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

5. Data security and integrity

KPMG has reasonable security policies and procedures in place to protect personal information from unauthorised loss, misuse, alteration, or destruction. Despite KPMG's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information 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. Note that if you have access to parts of our websites or services via a personal ID and password, you remain responsible for keeping your user ID and password confidential.

We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual's request or until that person asks that the information be deleted and, in any case, no longer than 10 years.

6. Links to other sites

Please be aware that KPMG web sites may contain links to other sites, including sites maintained by other KPMG member firms that are not governed by this Privacy Statement but by other privacy statements that may differ somewhat. We encourage users to review the privacy statement of each Web site visited before disclosing any personal information.

By registering on any KPMG web site and then navigating to another KPMG web site while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the KPMG web site you are visiting.

7. Changes to this Privacy Statement

KPMG may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this Privacy Statement, we will revise the "updated" date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how KPMG is protecting your information.

8. Questions and enforcement on this Privacy Statement

KPMG is committed to protecting the privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at cn-fmdataprivacy@kpmg.com.  You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

If you are not satisfied with the response you receive, you may escalate your concern to the Firm’s Privacy Liaison by sending an email to:

PRC’s Privacy Liaison Officer: PLO.cn@kpmg.com

HK & Macau’s Privacy Liaison Officer: PLO.hk@kpmg.com

We will acknowledge your email within [14] days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.

¹ "KPMG," or "we" or "us" refers to KPMG member firms and their affiliates operating in Chinese Mainland, Hong Kong (SAR) and Macau (SAR), each being a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.