Independence Data Request Privacy Statement
Last updated: June 2024
Introduction
Independence Data Request is an offering of PricewaterhouseCoopers LLP (“PwC”), a member of the PricewaterhouseCoopers global network of firms.
This privacy statement explains how we collect, use, disclose, transfer, and store personal information in connection with Independence Data Request (the “Solution”). This privacy statement applies solely to the Solution and does not apply to other PwC websites or applications.
PwC processes personal information collected by and in connection with this Solution under the direction of your employer or other company, institution, or organization with which you are affiliated in relation to this Solution and/or which has licensed the Solution for your use (your “Organization”), and has no ownership of such information. PwC is not responsible for how your Organization uses such information. Your Organization is responsible for complying with any laws and regulations that require providing notice and/or obtaining consent prior to the collection and processing of such information.
Information Collection
When you access or use our Solution, we will collect personal information about you and how you interact with our Solution. We collect personal information about you through: (1) information you provide; (2) your device; and (3) third parties, namely your Organization.
Information You Provide
When you access the Solution, you may be asked or choose to provide personal information about yourself, such as: identifiers and contact information including your name, business email address, job title, employee start or end date, office desk or location, and Organization name.
We do not intend to collect sensitive personal information about you through the Solution. “Sensitive personal information” includes information that reveals: social security, driver’s license, government identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data for identification; health information; sexual orientation/ preferences; citizenship or immigration status; personal information of a known child.
Please do not submit sensitive personal information through the Solution.
PwC does not use or disclose sensitive personal information it collects in connection with the Solution for purposes other than those specified in section 7027, subsection (m) of Title 11, Division 6, Chapter 1 of the California Code of Regulations.
Automatically Collected Information
We may use online identification technologies, such as cookies, web beacons, pixels, tags, local storage, or similar technologies (“Cookies”) on our Solution. For more information about the Cookies used on the Application, please review the Microsoft Power Pages Cookies Disclosure.
Information from Third Parties
We may collect the following information about you in connection with the Solution from your Organization: name and business email address.
Information Use
We use the information we collect for the following business purposes:
- To access the Solution
- Operating, maintaining, customizing, analyzing, and improving the Solution;
- Preventing and enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks;
- Complying with laws and regulations as well as professional and industry standards;
- Carrying out our contractual obligations, enforcing our rights, and as otherwise permitted by the contract between PwC and your Organization; and
- Sending Solution-related notifications to you and/or your Organization.
We may also use the information we collect to create aggregate or anonymized information, which we may use to build upon and improve the Solution and our other products and services as well as for other lawful business purposes.
Information Disclosure
As we are administering this Solution to you on behalf of your Organization, we provide the information we collect through the Solution to your Organization. Your Organization using the Solution is responsible for its handling of information collected by the Solution in accordance with its internal policies and applicable law.
PwC is part of a global network of firms. In common with other professional service providers, PwC may transfer or disclose the information we collect, including your information, to third party contractors, subcontractors, subsidiaries, and/or other PwC firms for the purposes for which you have submitted the information and for the administration of the Solution, our systems, and/or other internal, administrative purposes. For example, we may transfer your information to third party service providers of identity management, website hosting and management, data analysis, data backup, security, and storage services.
PwC may also disclose personal information to third parties under the following circumstances:
- When explicitly requested by a user;
- As necessary to comply with law, rules, regulations, legal obligations, professional and industry standards, as well as respond to and comply with subpoena, search warrant or other legal process, including establishing, exercising, or defending our legal rights;
- As necessary in connection with a corporate reorganization, merger, sale, joint venture or other disposition of all or any portion of our business, assets or capital.
We may also provide aggregate information to third parties for any lawful business purpose. We do not sell or share (as such terms are defined by applicable law) personal information collected in connection with the Solution.
Information Transfer
Your information may be transferred outside of your country of residence. This includes to countries outside the European Economic Area, Switzerland, and the United Kingdom. In accordance with applicable legal requirements, we take appropriate measures to facilitate adequate protection for any information so transferred.
When we transfer personal information from the EEA, Switzerland, or the UK to a country or framework not subject to an adequacy decision of the applicable regulatory authority, the transfers will be under a legal mechanism designed to ensure adequate protection of such personal information, such as approved standard contractual clauses.
PwC also adheres to the privacy principles in the EU - U.S. Data Privacy Framework and the Swiss - U.S. Data Privacy Framework as set forth by the U.S. Department of Commerce. To learn more, see our Data Privacy Framework.
Information Retention
We will retain the personal information collected by us through the Solution for as long as is necessary for the purpose(s) for which it was collected in accordance with PwC policies, provided that personal information may be held for longer periods where extended retention periods are required by law, regulation or professional standards, and in order to establish, exercise or defend our legal rights.
Your Choices
Access
You may review and update your personal information by logging into the Solution and selecting the edit button for the question that you wish to review and update.
Managing Cookies
For information on how to manage your cookie preferences, please review our Cookie Notice. Do Not Track (“DNT”) is a privacy preference that you can set in your web browser to send a message to the website operator requesting not to be tracked. Currently, we do not respond to these signals. For more information about DNT, visit https://allaboutdnt.com/.
Requests and Inquiries
Depending on the jurisdiction in which you are located, you may have certain rights with respect to your personal information. Subject to applicable law, these rights may include the right to access and obtain a copy of your personal information (including in a portable format if requested); to have your personal information corrected/rectified or deleted/erased; to restrict or object to the processing of your personal information; to withdraw your consent for processing (where processing is based on your consent); and to not receive discriminatory treatment for exercising your privacy rights. Applicable laws may also give you the right to lodge a complaint with the data protection authority in your country.
If you have any questions about your Organization’s or this Solution’s privacy practices or to exercise any of your rights regarding your personal information, please direct your inquiry to the appropriate contact within your Organization. If we receive a request or inquiry on behalf of your Organization, we will forward your request to your Organization (if we can identify them from the details provided) unless prohibited by law. If your Organization directs us to take action on your request, we will cooperate with your Organization to effectuate the request in accordance with applicable law.
Security
PwC has implemented generally accepted standards of technology and operational security designed to protect personal information from unauthorized access, loss, misuse, alteration, or destruction. Only authorized PwC personnel and the third parties described in this privacy statement are provided access to personal information and these personnel and third parties have agreed to maintain the security of this information.
Third Party Sites
This Solution may link to other websites which do not operate under PwC's privacy practices. When you link to other websites, PwC's privacy practices no longer apply. We encourage you to review the privacy statement of each website you visit before disclosing any personal information.
Children
PwC understands the importance of protecting children's privacy, especially in an online environment. The Solution is not designed for or directed at children under the age of 18 years. PwC does not knowingly sell or share personal information about children under the age of 18 in connection with the Solution.
In addition, upon request and where required by law, PwC will remove content or information posted to the Solution by users who are under the age of 18. Please contact your Organization to request such removal.
Modifications
PwC may update this privacy statement at any time by publishing an updated version. You can access the most current version of this privacy statement at any time on this Solution.