Privacy shield notice

Grant Thornton LLP and its subsidiaries Grant Thornton Public Sector LLC and Grant Thornton Financial Advisors (collectively, “Grant Thornton” for purposes of this Notice) comply with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union, the United Kingdom and Switzerland to the United States. Grant Thornton has certified to the Department of Commerce that it adheres to the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability, and the 16 Supplemental Principles (collectively, “Privacy Shield Principles”). Grant Thornton’s adherence to the Privacy Shield Principles may be limited to the extent necessary to meet national security, public interest, or law enforcement requirements.

Grant Thornton’s participation in the Privacy Shield program applies to all personal information that we receive from the European Union, European Economic Area, the United Kingdom and Switzerland. Grant Thornton collects and receives personal information from the European Union, the United Kingdom and Switzerland in connection with client engagements for audit, tax and advisory services. We also collect and receive personal information related to employees from other member firms of Grant Thornton International Ltd. seeking employment or internship opportunities with us. We may also collect personal information from individuals located in the European Union, the United Kingdom and Switzerland who voluntarily provide such information through Grant Thornton’s Web sites in connection with applying for job openings or subscribing to events or media alerts. Please see the Privacy Statement on our external Web site at https://www.grantthornton.com/privacy-policy for more information.

As described in the Privacy Shield Principles, Grant Thornton also has certain responsibilities related to personal information that it receives under the Privacy Shield and subsequently transfers to a third party. In particular, Grant Thornton remains responsible and liable under the Privacy Shield Principles if third party agents that Grant Thornton engages to process personal information on our behalf do so in a manner inconsistent with the Privacy Shield Principles, unless we prove that Grant Thornton is not responsible for the event giving rise to the damage. The Federal Trade Commission has jurisdiction over Grant Thornton’s compliance with the representations made in this notice and the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield frameworks.

Individuals have the right to access their personal information, and to correct, amend or delete such information where it is inaccurate or processed unlawfully, as described in the Privacy Shield Principles. To exercise these rights, please email us at privacy.questions@us.gt.com.

Grant Thornton is committed to responding to any inquiries and resolving any complaints about your privacy and our collection or use of your personal information. Individuals with inquiries or complaints should first contact Grant Thornton by email at privacy.questions@us.gt.com.

Grant Thornton is further committed to referring unresolved privacy complaints to JAMS, an alternative dispute resolution provider. The services of JAMS are provided at no cost to you. Please visit www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint. With respect to any human resources data collected under the Privacy Shield, Grant Thornton will cooperate with the appropriate EU Data Protection Authorities and the Swiss Federal Data Protection Commissioner, as applicable, during the investigation and resolution of complaints. As further explained in the Privacy Shield Principles, a binding arbitration option will also be made available to you in order to address complaints not resolved by any other means.

This policy may be amended or modified from time to time consistent with the EU-U.S. Privacy Shield and Swiss-U.S. Privacy Shield frameworks. If there is any conflict between the terms in this policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit www.privacyshield.gov. To view Grant Thornton’s certification, please visit www.privacyshield.gov/list.