KPMG Law Advokatfirma P/S Privacy Policy

Last updated May 2024

KPMG is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, KPMG is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, “personally identifiable information” or “PII”) processed by KPMG.

Generally, our intent is to collect only the personal information that is necessary so that we can offer information and/or services to customers and others or offer information about employment opportunities. Please review this privacy statement (“Privacy Statement”) to learn more about how we collect, use, share and protect the personal information that we have obtained.

1. Collection and use of personal information

• 1.1. What information we collect

• 1.2. The legal grounds we have to use your personal information

• 1.3. Automatic collection of personal information

  • 1.3.1. IP addresses

  • 1.3.2. Cookies

• 1.4. Children

2. Sharing and transfer of personal information

• 2.1. Transfer within the network of KPMG firms

• 2.2. Transfers to third parties

• 2.3. Transfer outside EEA

3. Choices

4. Access

5. Data security, integrity and erasure

6. Links to other sites

7. Changes to this statement

8. Policy questions and enforcement

1. Collection and use of personal information

1.1. What information we collect
From our customers, suppliers and other third parties we process data, which are necessary in order for us to provide advice and services within our combined services regarding Tax and Advisory Services. As part of the particular matters and projects, we may process data such as your name, contact details, personal security ID-number (in Danish; “CPR-nummer”) and other relevant, necessary data as further defined and set out in the respective matters.

In individual matters, we may process data relating to the persons’ income including the online tax folder, bank account and pension schemes. If necessary due to e.g. tax deduction, we process special categories of data such as trade union membership. If you visit our website, we obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to KPMG (if, for example, you are a former employee).

If you choose to register or log in to a KPMG website using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with KPMG, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

When you register or submit personal information to KPMG, we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you register to a KPMG web site and provide information about your preferences we will use this information to personalize your user experience. Where you register or login using a third party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other KPMG sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with KPMG, we will use the information that you provide to match you with available KPMG job opportunities.

In some cases where you have registered for certain services we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

1.2. The legal grounds we have to use your personal information. The legal basis for KPMG’s processing is Article 6 and Article 9 of GDPR (special categories of data).

KPMG generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

The GDPR and the Danish Data Protection Act allow us to process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;

• Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;

• Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or

• Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw your consent at any time by contacting KPMG at dk-fmkpmgcontactus@kpmg.com.

Examples of the ‘legitimate interests’ referred to above:

• To offer information and/or services to individuals who visit our web site or offer information about employment opportunities.

• To prevent fraud or criminal activity and to safeguard our IT systems.

• To customize individuals’ online experience and improve the performance, usability and effectiveness of KPMG’s online presence.

• To conduct, and to analyse, our marketing activities.

• To meet our corporate and social responsibility obligations.

• To exercise our fundamental rights in the EU under Articles 16 and 17 of the Charter of Fundamental Rights, including our freedom to conduct a business and right to property.

In some cases, the personal data that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.

1.3. Automatic collection of personal information

In some instances, KPMG and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of KPMG’s online presence, and to measure the effectiveness of our marketing activities.

1.3.1. IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.

1.3.2. Cookies

For information about our use of cookies, please see the cookie pop-up on our website.

1.4. Children

KPMG understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

2. Sharing and transfer of personal information

2.1. Transfer within the network of KPMG firms

We share information about you with other member firms of the KPMG network as part of international engagements, and with KPMG International and other member firms where required or desirable to meet our legal and regulatory obligations around the world. Other parts of the KPMG network are also used to provide services to us and you, for example hosting and supporting IT applications, provision of certain forms of insurance for member firms and its clients, performing client conflicts checks and Anti-Money Laundering checks, assisting with client engagement services and otherwise as required in order to continue to run KPMG’s business.

Pursuant to section 126 (1) of the Danish Administration of Justice Act, a lawyer shall conduct himself in a manner consistent with best practice for lawyers, and KPMG Law Advokatfirma ApS lawyers practicing under the title of lawyer shall observe confidentiality according to the Danish professional standards and ethics. Accordingly, sharing and transfer of personal information obtained as part of a client engagement is also subject to the terms as decided from time to time, in individual engagement letters with individual clients.

2.2. Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards. As part of providing our Tax and/or Advisory services and advices, we may transfer personal data to e.g. tax authorities, other public authorities and financial institutions and pension companies or other third parties.

For more information on transfer to third parties, please see this link.

2.3. Transfer outside EEA

In addition, KPMG will transfer certain personal information outside of the EEA to outside companies working with us or on our behalf for the purposes described in this Privacy Statement. KPMG will also typically store personal information outside of the EEA. We typically send personal information to the following countries. If we do this, your personal information will continue to be protected by means of contracts we have in place with those organizations outside the EEA, containing standard data protection clauses which are in a form approved by the European Commission.

KPMG will not transfer the personal information you provide to any third parties for their own direct marketing use.

3. Choices

In general, you are not required to submit any personal information to KPMG, but we will require you to provide certain personal information in order for you to receive additional information about our services and events. KPMG will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request

As described in “Cookies” above, if you wish to prevent cookies from tracking you as you navigate our sites, you can reset your browser to refuse all cookies or to indicate when a cookie is being sent. Note, however, that some portions of our sites may not work properly if you elect to refuse cookies.

4. Your rights

If KPMG processes personal information about you, you have the following rights:

• Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.

• Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it any more.

• Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.

You can make a request or exercise these rights by contacting KPMG at dklaw-privacy@kpmg-law.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

5. Data security, integrity and erasure

KPMG has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite KPMG’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We also make reasonable efforts to retain personal information only for so long i) as the information is necessary to comply with an individual’s request, ii) as necessary to comply with legal, regulatory, internal business or policy requirements, or iii) until that person asks that the information be deleted. The period for which data is retained will depend on the specific nature and circumstances under which the information was collected.

However, personal information collected online will not be retained for more than 2 years.

Personal data collected during a continuous customer relationship will be retained. When the customer relationship ends, we will normally retain your personal data for 5 years until the end of a financial year. Furthermore, we may retain data for up to 10 years from the end of engagements related to tax advice.

6. Links to other sites

Please be aware that KPMG web sites will typically contain links to other sites, including sites maintained by other KPMG member firms that are not governed by this Privacy Statement, but by other privacy statements that will often differ somewhat. We encourage users to review the privacy policy of each web site visited before disclosing any personal information.

By registering on any KPMG web site and then navigating to another KPMG web site while still logged in, you agree to the use of your personal information in accordance with the privacy statement of the KPMG web site you are visiting.

7. Changes to this statement

KPMG may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. Any changes to the processing of personal information as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

8. Policy questions and enforcement

KPMG is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at dklaw-privacy@kpmg-law.com.You may also use this address to communicate any concerns you may have regarding compliance with our Privacy Statement.

If you are not satisfied with the response you receive, you may escalate your concern to our Global Privacy Officer by sending an email to GlobalPrivacyOfficer@kpmg.com. We will acknowledge your email within 14 days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.

In any event, you always have the right to lodge a complaint with Datatilsynet, which is in charge of protecting personal information. You can find further information on www.datatilsynet.dk, or you can write an e-mail to dt@datatilsynet.dk.