PRIVACY POLICY

SCOPE

The Beehive Platform ("Platform") is operated by Ernst & Young LLP ("EY", "our", "us" or "we"), a limited liability partnership incorporated in England and Wales with registration number OC300001. Our registered office is at 1 More London Place, London, SE1 2AF.

The Platform is a web application aimed at assisting users with tax, finance, legal and other corporate processes. The functionality that may be accessible via the Platform is listed below:

  • Digitization of reports
  • Streamlining finance, tax and law/other compliance processes
  • Streamlining the creation of documents/advice from templates
  • Analysis and classification of data
  • Other similar functionality, aimed at helping with tax, finance and legal/other corporate processes

POLICY RECOMMENDATION

Please read this Privacy Policy ("Policy") carefully before using this Platform as it sets out how we use your personal data in connection with the Platform.

We may modify this Policy from time to time and will place any modified versions on the Platform. Regularly reviewing the Policy ensures that you are always aware of what information we collect, how we use it and under what circumstances we will share it with other parties.

In the event EY needs or wishes to use any personal data for a different purpose other than that stated in this Policy, the terms of use and scope of the Engagement letter then EY will only do so having obtained the users consent.

We recommend that you print a copy of this Policy for future reference.

PRIVACY STATEMENT

This statement, set forth below, is our privacy statement for the global organization of EY member firms and other entities within EY. Here we describe the practices we follow to respect the privacy of all visitors to Beehive.

In this statement, personal information means data which relates to an individual and which identifies that individual, either directly or indirectly, such as your name or your contact information.

If you have any questions regarding the processing of your personal information, please contact us or your usual EY representative.

INFORMATION WE MAY COLLECT

We will only collect data supplied by you or your representatives in the use of the Platform.

We may collect, receive, store and process the following data about you:

  • Information that you provide by filling in forms on the Platform (including information provided at the time of registering to use the Platform, for example, full name, business address, company, title, email address, telephone number, username and password if you create an account on the Platform.)
  • NOTE - information on associated 3rd parties such as names, addresses, locations, suppliers you have included within the data you have provided in the use of the Platform.
  • Meta data that is generated in the course of the use of the Platform (including the timing, frequency and pattern of service use); and
  • Information about your computer and any devices used to access the Platform and about your visits to and use of this website (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths); and
  • Information as set out in the Cookies section.

USES MADE OF YOUR PERSONAL DATA

We use information held about you for the following purposes:

  • to register you on the Platform, authenticate you, and to communicate with you in order to give you access to the Platform;
  • to allow you to use the Platform and provide services on the Platform;
  • to manage the access to the Platform and keep a record of the number of users;
  • to carry out our obligations, or exercise our rights, arising from the Terms of Use you enter in to with us or any contracts entered into between us and you;
  • to carry out our obligations, to enforce or apply the terms, or exercise our rights, under the Terms of Use you enter into with us;
  • to allow us to assess, monitor and record your interaction with the Platform and the content you access;
  • to administer the Platform and provide customer services;
  • to communicate with you about the Platform and, to the extent permitted, about our services that may be of interest to you;
  • for our internal record keeping;
  • to improve the Platform and the services offered on the Platform (including by gathering to management information to form statistical and trend analysis);
  • to ensure that content on the Platform is presented in the most effective manner for you and for your computer;
  • to investigate any complaints about the Platform;
  • to meet legal, regulatory and compliance requirements;
  • to monitor and analyse the use of any account to prevent, investigate and/or report compliance with the Terms of Use you enter in to with us, fraud, security incidents or crime; and
  • for any other purpose that we tell you about specifically when you register or provide data about yourself to us.

LEGAL BASIS FOR USE OF PERSONAL DATA

On some occasions, we process your data with your consent (including when you agree that we may place cookies other than those that are strictly necessary). Where we do process data based on consent, your consent is revocable at any time.

On other occasions, we process your data when we are required to do this by law (for example, if required by a governmental authority or a regulator).

When we ask you to supply us with personal data we will make it clear whether the information we are asking for:

  1. Must be supplied so that we can provide services to you under the Terms of Use you enter into with us
  2. or because it is required by law; or
  3. is optional, and the consequences of not providing the information.

The processing of some of your data (e.g. your log-in details) is necessary in order to provide services on the Platform to you pursuant to the Terms of Use you enter in to with us. Without this data, we would not be able to provide the Platform to you.

We also process your data when it is in our legitimate interests to do this and when these interests are not overridden by your data protection rights. For example, we have a legitimate interest in using your personal data:

  • to enforce or apply the terms, and exercise our rights, under the Terms of Use you enter in to with us;
  • to carry out our obligations, or exercise our rights, arising from any contracts entered into between us and you;
  • to allow us to assess, monitor and record your interaction with the Platform and the content you access;
  • to administer the Platform and provide customer services;
  • to communicate with you about the Platform and, to the extent permitted, about our services that may be of interest to you;
  • for our internal record keeping;
  • to improve the Platform and the services offered on the Platform (including by gathering to management information to form statistical and trend analysis);
  • to ensure that content on the Platform is presented in the most effective manner for you and for your computer;
  • to investigate any complaints about the Platform;
  • to monitor and analyse the use of any account to prevent, investigate and/or report compliance with the Terms of Use you enter in to with us, fraud, security incidents or crime;
  • as part of a sale or merger of our business or assets;
  • to protect the rights, property, or safety of EY, EY Firms, our customers or others; and
  • as permitted by law, to cooperate with law enforcement inquiries and to ensure compliance with applicable laws and regulations outside the EU.

WHEN WE MAY DISCLOSE PERSONAL DATA

We may disclose or transfer personal data to other companies or entities as follows:

  • to any EY Firm for the purpose of managing our and their relationship with you, to manage the Platform and other purposes identified above in this Policy;
  • to service providers that provide services in relation to the operation of the Platform;
  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use you enter into with us and other agreements or to protect the rights, property, or safety of EY, EY Firms, our customers or others;
  • to government authorities, and to other third parties when compelled to do so by government and law enforcement authorities or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also may disclose personal data when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Platform, or anyone else that could be harmed by such activities. Additionally, we cooperate with law enforcement inquiries and other third parties to enforce laws, intellectual property rights and other rights;
  • to meet certain legal compliance requirements; and
  • to prospective sellers or buyers as part of a sale or merger of our business or assets.

WHERE WE TRANSFER YOUR PERSONAL DATA

We may transfer your personal data to your local EY Firm overseas, which may involve the transfer of personal data to countries outside the European Economic Area which have different data protection standards to those which apply in the European Economic Area, for the purpose of managing our and their relationship with you and for the purposes outlined in this Policy. For a list of the countries in which we operate, please see http://www.ey.com/uk/en/home/ourlocations.

[We may also transfer your personal data to our service providers identified above overseas, which may involve the transfer of personal data to countries outside the European Economic Area which have different data protection standards to those which apply in the European Economic Area, for the purposes outlined in this Policy. [We have put in place European Commission approved standard contractual clauses to protect this data. You have a right to ask us for a copy of these clauses (by contacting us as set out above).]

CONTROLLING YOUR PERSONAL INFORMATION

EY does not collect or compile personal information obtained by Beehive for dissemination or sale to outside parties for consumer marketing purposes or host mailings on behalf of third parties.

You are legally entitled to request details of the personal information we are holding about you.

EY provides you the ability to keep your personal information accurate and up-to-date.

If at any time you would like EY to rectify, erase or restrict the processing of your personal information, or you would like to obtain confirmation whether or not your personal information is processed by EY, access your personal information, exercise your right to data portability or withdraw your consent to processing, please contact us as per the details provided in the contact section at the end of this document.

SAFEGUARD PROVISIONS

EY has a comprehensive global privacy compliance program that includes EU-approved Binding Corporate Rules as well as certification to the EU-US Privacy Shield and the Swiss-US Privacy Shield Frameworks administered by the U.S. Department of Commerce. EY will only disclose your personal information to third parties that have agreed in writing to provide an adequate level of privacy protection.

For information about our safeguard the link below provides you with the details of the EY Data Protection: Biding Corporate Rules (BCR).

SECURITY

While we have implemented appropriate technical and organisational measures to protect personal data on the Platform, but due to the inherent nature of the internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

EY works to protect the confidentiality and security of information it obtains in the course of its business. Access to such information is limited and policies and procedures are in place, designed to safeguard the information from loss, misuse and improper disclosure.

RETENTION - HOW LONG WE KEEP YOUR PERSONAL DATA

Any personal data held by EY within the Beehive only relates to data that is provided by you for your own purpose of using the Beehive.

EY shall retain your personal data and data kept on cookies / similar technologies for no longer than is necessary for the purposes for which it is being processed non withstanding the mandated requirement to keep all data for at least 6 years.

In context with the above and in compliance with EY’s Auditing obligations and standards EY will therefore keep all data received for a period of 7 Years after its useful purpose.

YOUR CHOICES

Review and edit your personal data: You may review and edit the personal data that is stored in your user account on your profile on the Platform, (e.g. your passwords and other contact information) by visiting the Platform.

You may ask us for a copy of your information, to correct it, erase it or to transfer it to other organisations at your request.

You also have rights to object to some processing and, where we have asked for your consent to process your data, to withdraw this consent.

Where we process your data because we have a legitimate interest in doing so (as explained above), you also have a right to object to this. You also have the right to restrict processing in certain circumstances.

These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement or other legitimate grounds to process your data.

We may ask you to verify your identity and to provide other details to help us to respond to your request.

If you wish to exercise these rights, please contact us via one of the options referenced in the Contact Details section below.

We hope that we can satisfy queries you may have about the way we process your data. However, if you have unresolved concerns you also have the right to complain to data protection authorities.

Choices about cookies: See the Cookies Policy.

SPECIAL CATEGORIES OF PERSONAL DATA

EY does not intentionally collect any special categories of personal data (sensitive personal information) via Beehive unless in a specific country we are legally required to do so, for example, for recruitment purposes. Sensitive personal information includes: information revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade-union membership; the processing of genetic or biometric data for the purpose of uniquely identifying a natural person; information concerning health; information concerning a natural person's sex life or sexual orientation; and in some cases, social security numbers or financial information.

Changes to this privacy statement

EY may change this privacy statement as needed. If changes to the statement are made, please note that it may take up to 30 business days before new privacy practices are implemented. Check this page periodically if you would like to monitor changes.

Unsubscribe

EY gives you choices regarding the collection and usage of your personal information. If you have registered for any EY related updates through ey.com or Beehive, and do not wish to receive future e-mails, please visit our unsubscribe page within the application you registered.

COMPLAINTS

If you are concerned about an alleged breach of privacy law or any other regulation by EY, you can contact us or via your usual local EY representative or EY’s Global Privacy Leader, Office of the General Counsel, 6 More London Place, London, SE1 2DA, United Kingdom. An EY Privacy Leader will be made available to investigate your complaint and give you information about how it will be handled.

  1. If you are concerned about an alleged breach of privacy law or any other regulation, contact EY’s Global Privacy Officer, Office of the General Counsel, 6 More London Place, London, SE1 2DA, United Kingdom or via email at dataprotectionenquiries@uk.ey.com or via your usual EY representative. An EY Privacy Officer will investigate your complaint and provide information about how it will be handled and resolved.
  2. If you are not satisfied with how EY resolved your complaint, you have the right to complain to Information Commissioner’s Office. You can also refer the matter to a court of competent jurisdiction.

If you are not satisfied with the way in which EY has resolved your complaint, you have the right to complain to the data protection authority in your country. You may also refer the matter to a court of competent jurisdiction.

CONTACT DETAILS

If you decide to withdraw your consent to processing your personal information please email beehive@ey.com.

Questions, comments and requests regarding this Policy should be addressed to dataprotectionenquiries@uk.ey.com.

In addition, you can contact our data protection officer at dataprotectionofficer@uk.ey.com.

If you have additional questions or concerns, contact your usual EY representative or email global.data.protection@ey.com.