Privacy Policy

Privacy Policy

Effective Date: March 19, 2024

Introduction

Crowe LLP and its subsidiaries listed below (collectively, "Crowe" or “us” or “our”) provide professional services including, without limitation, assurance, tax, financial advisory, and consulting services to private and publicly traded businesses as well as to individuals. This Privacy Policy outlines our general policy and practices for protecting personal information that we collect through our Web site at www.crowe.com and other Web sites (each, a "Site") that we operate and which post this Privacy Policy. This Privacy Policy explains the types of information we gather through our Sites, how we use that information, and the rights individuals may exercise in relation to that information.

Crowe LLP subsidiaries include the following: (i) Crowe Cayman Ltd., (ii) Crowe Horwath Global Risk Consulting Holdings Ltd., (iii) Crowe Horwath Global Risk Consulting ULC (Canada), and (iv) Crowe Horwath IT Private Services LLP.

Other webpages of applicable Crowe Global member firms or related entities manage their websites independently and such websites are not the responsibility of Crowe. Such websites, as well as other websites that may be linked to this website, are not governed by this Privacy Policy. Crowe is not responsible or liable for any acts or omissions of Crowe Global or any other member firm of Crowe Global and specifically disclaims any and all responsibility or liability for acts or omissions of Crowe Global or any other Crowe Global member firm. We encourage visitors to review each of these other websites' privacy policies before disclosing any personal information.

By submitting personal information to us, you consent to our use of such personal information in accordance with this Privacy Policy.

If you are a California resident, you have a right to opt-out of the “sale” (as defined by the California Consumer Privacy Act of 2018) of your personal information. Exercise your right to opt-out.

Notice of Personal Information Collection and Use

In order to use this Site, you do not need to submit or provide any personal information. You may voluntarily provide us with personal information.

Personal information that you may submit or may otherwise be collected by Crowe includes, without limitation:

  • Personal details, contact details, and other identifiers, such as your name, physical address, email address, telephone and fax number
  • Commercial information such as history and records of the products and services you have obtained from us and applicable terms and conditions, and credit or debit card information
  • Internet or other electronic network activity information, such as unique personal identifies (e.g., IP address), browser or web history and preferences expressed through selection, viewing or purchase of goods, services and content, information regarding your interaction with our Site or advertisements, geolocation data, and other analytics
  • System and application access data
  • Professional, employment or recruitment related information, such as description of current position, job title, employer, and location, national identification number, social security number, driver’s license, financial information, information required under immigration laws (e.g., citizenship related data), information about your race, ethnicity, religion, disability, and gender.

Typically, personal information is used in the following circumstances:

  • Registration for access to certain areas of the Site
  • Subscribing to or ordering newsletters, media alerts and/or publications
  • Submission of resumes or work history information for purposes of recruitment and/or employment
  • Participation in bulletin boards, discussion or message forums
  • Responding to quick surveys, quizzes, or benchmarking surveys
  • Registration for events (e.g., webcasts or seminars) and conferences
  • Registration for online services
  • Contacting us for further information

We do not intend to actively seek sensitive personal information (also known as special category personal data), except for in limited cases in connection with our recruitment or hiring activities. Sensitive personal information includes, without limitation, data related to race or ethnic origin, political opinions, religious or philosophical belief, trade union membership, medical or health information, sex life or sexual orientation or criminal record (including suspected criminal activities). By providing such sensitive personal information, you explicitly consent to Crowe’s use of that information in accordance with this Privacy Policy or as otherwise agreed upon at the time of disclosure.

We may use the personal information you submit through the Site for Crowe’s business purposes, including without limitation, to manage your requests, to improve the Site or services offered, to process payment, send you administrative information or notices, send you information about our services, events, and other relevant information, and any other purpose stated at the point of collection.

We may maintain and share aggregated or deidentified, data and information derived from personal information with other entities for the purpose of performing activities that may help us provide and improve our products and services.  When we deidentify data, we will not attempt to re-identify the data unless required to do so pursuant to a legal obligation.

If you apply for job openings through our Sites, we may use the personal information you submit to process and evaluate your application for employment and to communicate with you about employment opportunities. We may also retain and use this information to identify and communicate with you about future potential employment opportunities with us.

If we do not obtain your personal information directly from you, we may obtain it from the following sources: publicly available sources (public authorities, public websites, and social media), Crowe existing or prospective personnel or their previous employers, educational institutions, contractors, vendors, suppliers, Crowe member firms, subsidiaries, and newly acquired businesses.

Cookies and Similar Technologies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The table below explains the cookies we use and why.

 

 

How Do I Change My Cookie Settings?

You may manage or change your cookie settings here:

 

 

Also, most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit https://www.consumer.ftc.gov/articles/0042-online-tracking or www.allaboutcookies.org.

Find out how to manage cookies on popular browsers:

To find information relating to other browsers, visit the browser developer's website.

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout.

Do Not Track Signals

Some Web browsers incorporate a "do not track" or similar feature that signals to Web sites with which the browser communicates that a visitor does not want to have his or her online activity tracked. As of the Effective Date of this policy, not all browsers offer a "do-not-track" option and "do-not-track" signals are not yet uniform. The Site does not currently respond to "do-not-track" signals or other similar features.

Disclosures and Transfers

Crowe may transfer or disclose collected personal information to third-party service providers, subcontractors, Crowe Global member firms, and/or other Crowe affiliated companies for the purpose of managing your request, administration and management of the Site, and/or internal business purposes. Personal information may also be transferred to third-party service providers of identity management, credit card payment processing, website hosting and management, data analysis, data backup, and/or security and storage service. Collected personal information may be transferred to third-parties located in other countries. Crowe will endeavor to take reasonable steps to ensure that such third-parties will provide adequate privacy protection to your personal information. By using the Site, you explicitly consent to the transfer of such data in accordance with this Privacy Policy and as otherwise set forth on the Site.

Additionally, Crowe may disclose personal information to third parties under other circumstances, including, without limitation, the following:

  • As required by applicable law, statute, rule, regulation or professional standard, or through subpoena, search warrant or other legal process
  • When explicitly requested by you
  • When required to deliver publications or reference materials requested by you
  • When required to facilitate conferences or events hosted by third parties
  • As otherwise set forth in this Privacy Policy or on the Site

Third-Party Sites and Social Media Applications

The Site may facilitate certain links to third-party websites that are not operated under Crowe privacy practices. This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any web site or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by Crowe or by our affiliates. Crowe encourages you to carefully review each site’s privacy policy before disclosing any personally identifiable information.

This website may also host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal information or other information that you contribute to any Social Media Applications can be read, collected, and used by other users of that Social Media Application over whom we have little or no control. Crowe is not responsible for any third party’s use, misuse, or misappropriation of any personal information or other information that you contribute to any Social Media Application.

Data Security

The security of your personal information is important to us. We seek to use reasonable physical, technical, and administrative safeguards to protect the information we process. However, no method of transferring data over the Internet or storing electronic data is completely secure. Therefore, while we strive to use reasonable and appropriate means to protect your personal information, we cannot guarantee absolute security. By using the Site, you acknowledge that the transmission of data over the internet is inherently insecure and assume all risks associated with such transmission. Further, you acknowledge and agree that Crowe has no control over the security of data being transmitted over the internet.

Data Integrity

We process personal information only in ways compatible with the purpose for which it was collected, as subsequently authorized by the individual, or as otherwise permitted by applicable law. By using the Site, you acknowledge and agree to be solely responsible for the accuracy and completeness of the information and data that you provide and submit on the Site.

Rights to Your Personal Information

Depending on your jurisdiction or the jurisdiction in which the data was collected, you may be entitled to request details regarding personal information about you that we process and are in possession of. In such instances, we may provide you with the ability to submit a request for access, rectification, erasure, request a copy of your personal information, or to restrict or object to further processing.

You are solely responsible for verifying the ongoing accuracy of the personal information submitted through the Site. If you have an inquiry regarding the accuracy of personal information previously submitted, or have a request to modify such information, please contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. We may limit or deny access to personal information where providing such access would be unreasonably burdensome or inappropriate under the circumstances. All requests to access or change personal information will be handled in accordance with applicable legal requirements.

Visitors who choose to register with this Site may correct and update their user profiles or unsubscribe from certain communications at any time. Visitors who would like to access or change their profiles or would like to request a copy of their personal information should contact us.

You may have the right to request that we disclose to you information about the categories of personal information that we collected, categories of sources from which the personal information is collected, the business or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information and the specific pieces of personal information we have collected. This Privacy Policy provides such information. If you have any questions regarding your personal information please contact us.

Individuals have a right to opt-out of the “sale or sharing” (as defined under the California Consumer Privacy Act of 2018) of your personal information. This right is applicable only to the extent that Crowe is engaged in the sale or sharing of your personal information. Crowe generally does not sell your personal information, however, there are circumstances where we share personal information with our third-party providers or others for which individuals may have the right to opt out. If you choose to exercise your right to opt out of the sale of your personal information, please opt-out.

We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents or service providers, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit to [email protected].

We will not discriminate against you for exercising any of your rights with respect to your personal information. To exercise any rights available to you under applicable data protection law, please contact us at [email protected] or call 1-800-599-6046 (only available in English).

Record Retention

We will retain your personal information only for as long as is necessary for the intended purpose, unless a longer retention period is required or permitted by law, regulation, professional standards or our document retention policies.

Merger and Other Business Transitions

In the event Crowe goes through a business transition, such as a merger, or the acquisition or sale of a portion of its assets, your personal information may be among the assets transferred.

Privacy Policy Changes

Crowe reserves the right to amend or modify this Privacy Policy from time to time, as determined at Crowe’s sole discretion, by publishing an update version on the Site. Crowe encourages you to periodically review this Privacy Policy. You can access the most current version of this Privacy Policy on the Site.

Children Privacy Protection

This Site is not intentionally designed for or directed at children 16 years of age or younger. It is Crowe’s policy to refrain from intentionally and knowingly collecting or maintaining personally identifiable information about children under the age of 16.

Crowe Data Privacy Framework Notice

Crowe complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Crowe has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Crowe has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Unsubscribe

If you no longer wish to receive promotional communications from us, you may at any time request that we discontinue sending you such materials by contacting us using the contact information listed below.

How to Contact Us

To exercise your rights under applicable data protection law or submit requests, questions, comments or concerns about Crowe LLP’s Privacy Policy, EU-US Data Privacy Framework Certification, or data collection and processing practices, you can contact us at [email protected] or call 1-800-599-6046 (only available in English).

Once we receive your request, we may verify it by requesting information sufficient to confirm your identity. If you are a California resident and would like to use an authorized agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We reserve the right to deny requests if we have a reasonable belief that the request is fraudulent.