Effective December 9, 2008
The CFOdirect Network (CFOdirect) site is a service offering of PricewaterhouseCoopers LLP (PwC US), the US member firm of the PricewaterhouseCoopers global network of member firms. Each PricewaterhouseCoopers member firm is a separate and independent legal entity. CFOdirect is part of the PricewaterhouseCoopers Portal (the PwC Portal), a collection of web sites offered by various member firms of the PricewaterhouseCoopers network (PwC).
Personal data that you provide when you register for CFOdirect will be controlled by PricewaterhouseCoopers LLP, a registered limited liability partnership formed under the laws of the State of Delaware. Other web sites found on the PwC Portal may be offered and controlled by other entities. If you provide personal data in connection with other sites found on the PwC Portal -- e.g., during registration for a particular site, or if you use any subscription or "contact us" features found on the PwC Portal -- your personal data will be controlled by the entity to which you send your personal data. In addition, other entities may also control your personal data as described below. Certain services and web sites offered on the PwC Portal may be subject to different privacy policies. In such instances, a separate privacy policy will be posted.
"We" or "us" in this Privacy Statement means, in relation to your personal data, the PricewaterhouseCoopers entity (i.e., PwC US for the CFOdirect web site) that is the controller of that personal data.
"You" in this Privacy Statement means you as an individual, rather than any legal entity (such as your employer) that you may represent when you register for CFOdirect.
1. What information is collected?
2. How will personal data be used?
3. Are cookies used on CFOdirect?
4. How can I access, change my personal data or withdraw my consent?
5. Are personal data transferred to another country?
6. Are personal data disclosed to other entities?
7. How long are personal data retained?
8. How are personal data secured?
1. What information is collected?
"Personal data" means information about you and/or third parties (where required by law, a third party could be a legal entity represented by you, for example, where you submit data to us about your employer or a client company). Members of CFOdirect must provide personal information in order to register for the site. Information collected includes: name, address, email address, phone, company name, industry, etc.
When you visit CFOdirect, we may collect personal data either:
(i) directly where you are asked to provide data (such as when you register), use any "Contact Us" features of CFOdirect, or subscribe for newsletters
(ii) indirectly to customize CFOdirect to your preferences, such as by using cookies (as described in section 3 below)
(iii) indirectly to monitor usage of CFOdirect, such as tracking the most active organizations using CFOdirect, which is monitored through the corporate IP address and does not identify individual usage
(iv) indirectly from other individuals or third-parties who provide us with information about you, such as a PwC engagement partner who pre-registers you for CFOdirect
If you decide to license CFOdirect, you may be asked to fill in certain boxes with information about yourself or others. You do not have to fill in the "optional" boxes - if you don't, we will still process your registration or question but it is always helpful for us to receive this optional data as it may help us to understand your business needs. You must fill in the "mandatory" boxes marked * as otherwise we may not be able to register you or process your inquiry. We will only ever collect, hold, process, use, communicate and/or disclose such personal data, whether optional or not, in accordance with this Privacy Statement.
If you are acting as an intermediary or otherwise on behalf of a third party or supply us with information regarding a third party (such as your employer or a client company), you undertake that you are an authorized representative or agent of such third party and that you have obtained all necessary consents from such third party to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party's data from you, you undertake to make the third party aware of all matters listed in this Privacy Statement, preferably by distributing a copy of this statement to them or by referring them to our website.
We do not generally seek to collect sensitive data through CFOdirect. If we do seek to collect such data we will ask you to consent to the uses we propose to make of the data. By providing us with unsolicited sensitive data you consent to our using those data, subject to applicable law, for the purposes set out below.
2. How will personal data be used?
We may process and use personal data collected via CFOdirect or otherwise in relation to this site for the following purposes:
- to administer CFOdirect
- to identify the demographics of our membership
- to contact a member for customer service
- to respond to member inquiries
- to allow you access to other sites within the PwC Portal
- to develop reports about CFOdirect usage and membership trends
This information is not used in any way by CFOdirect or PwC to directly solicit purchases of products or services from individual CFOdirect members. CFOdirect and PwC reserve the right to provide PwC engagement teams certain personal information about CFOdirect members that are employed by or otherwise affiliated with PwC clients for the purpose of determining who among their clients is a registered member of CFOdirect. In this case, only the member’s name, job title, and company name are provided and will only be used for assisting engagement teams in the process of introducing CFOdirect to their client base either by demonstrating the site or completing a pre-registration for their client on the client's behalf.
Members may choose to provide certain personal information when using certain areas of the CFOdirect web site. For example, personal information may be provided when:
- Contacting us for help or further information – in which case emails requesting information or assistance with using CFOdirect may be stored or archived in our back-end databases but will not be used for other purposes; or
- Suggesting an event to be included on CFOdirect's Events page – in which case only the name and email address of the event submitter is collected and used to contact the member with questions.
3. Are cookies used on CFOdirect?
A cookie is information sent by a Web server to a user's computer and stored there. The information stored in the cookie can be accessed by that server when the user returns to the web site (in this case CFOdirect). A cookie can hold a variety of information, including the number of times the user has accessed the site, registration information, and the number of times a user has seen a particular advertisement on the site.
We use cookies to help us authenticate your identity as a registered member when you log on to CFOdirect. We also use individual session cookies for each user to track your use of CFOdirect within a single session. Cookies enable us to recognize your browser and to provide certain features to you.
The "Help" function on most browsers will have information on how to (1) prevent your computer from accepting cookies and (2) find out if you have received a cookie and disable them completely, if you so choose.
4. How can I access or change my personal data or withdraw my consent?
You are entitled to request access to and correct all your personal data collected by us via CFOdirect, as well as to require us to delete your personal data if you no longer want us to process it. You may have additional rights provided by applicable laws.
You may access and update some of the data we hold about you (such as your registration data) directly, by editing "Personal Information" in the "My Account" section of CFOdirect. This includes the ability to opt in / opt out of receiving emails. If you consent or have previously consented to the collection, holding, processing, use, communication and or/disclosure of personal data as identified herein, please note that you can withdraw your consent at any time by sending an email to abast.marketing.support@us.pwc.com and we will remove your registration information from CFOdirect.
5. Are personal data transferred to another country?
Because of the international nature of the service provided by CFOdirect and the nature of the PricewaterhouseCoopers global network's activities, personal data may, subject to applicable law, be transferred internationally to other PricewaterhouseCoopers entities around the world for the purposes described above.
This may mean that personal data are transferred to countries, such as the United States where the CFOdirect server is located. Through your use of CFOdirect you are explicitly consenting to the transfer of your personal data to PricewaterhouseCoopers entities located in other countries for the specific purposes described in this Privacy Statement.
6. Are personal data disclosed to other entities?
The data will only be disclosed to certain types of staff within PricewaterhouseCoopers entities (i.e. staff whose job it is to process your registration and enquiries or to otherwise administer CFOdirect), and they will only process the data for the purposes identified in this Privacy Statement. Personal information may also be released to PwC engagement teams for the purpose of determining who among their clients is a registered member of CFOdirect. In this case, only the member’s name, job title, and company name are provided and will only be used for assisting engagement teams in the process of introducing CFOdirect to their client base either by demonstrating the site or completing a pre-registration for their client on the client's behalf.
Personal data will also, subject to applicable law, be disclosed:
· to other entities within the PricewaterhouseCoopers network which may follow the privacy practices in this policy or notify you of their own privacy practices,
· to data processors, suppliers or providers of goods or services (but only for the purposes of processing your request for services or information), and
· where such disclosure is required by law through subpoena, search warrant or other forms of legal process.
Again, this may mean that data are transferred to countries such as the United States as any such third parties mentioned above may be located there.
7. How long are personal data retained?
We will keep your personal data only as long as you are an active member of CFOdirect. Should you become an inactive member (defined by not logging in or receiving our emails for 22 months or more), we will cancel your membership and delete your registration record. For administrative and troubleshooting purposes, we will retain minimal identifying data from your record. This data will only be used to identify your account and will not be shared with anyone within PwC for marketing purposes. It will be stored in an inactive database with restricted access.
8. How are personal data secured?
We have implemented generally accepted standards of technology including Secure Socket Layer (SSL) and operational security in order to protect the personal data collected, but the nature of the Internet is of course such that the data may flow over networks without appropriate security measures and may be accessed and used by unauthorized persons.
Please note that this Privacy Statement only covers CFOdirect, which may or may not regulate the privacy practices of other web sites that may be accessible through or linked to CFOdirect. We encourage visitors to review other PwC Portal sites' privacy statements before disclosing any personal identifying information.
