- Introduction
- Personal Information Collected
- Cookies, Google Analytics and Other Tracking Technologies
- Interest Based Advertising
- How We Use Personal Information
- How We Disclose Personal Information
- Other Online Services
- Your Choices
- Data Retention
- Electronic Communication
- Data Security
- Data Transfer
- Updates to Privacy Policy
- Contacting Us
1. INTRODUCTION
This Privacy Policy provides notice of our information collection, use, and disclosure practices by RSM Canada LLP, RSM Canada Consulting LP, RSM Canada Limited and our affiliates (together, “RSM,” “us,” “our,” or “we”). This Privacy Policy applies to our processing of your Personal Information (defined below) including through bg7u.yaldenfamily.net (the “Website”), through offline means such as at RSM events, 或通过提供您或我们的客户要求的服务, such as professional, tax, or audit services (the “Services”). This Privacy Policy does not apply to other online services that we make available but do not link to this Privacy Policy. We may provide you additional privacy notices at the point of collection of your Personal Information on the Website including particular subdomains of rsmus.com, such as the Website’s careers portal.
对于通过跟踪技术(如.g., cookies) on the Website, see our Cookie Policy.
2. PERSONAL INFORMATION COLLECTED
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you. Personal Information does not include information that is anonymized. For clarity, information has been anonymized when it is reasonable to expect in the circumstances that the information cannot be reverse engineered to identify the person directly or indirectly.
We may obtain your Personal Information from the following sources:
- Directly from you. Such as when you register or maintain a Website account with us, sign up to receive e-newsletters, register for events, or fill out online forms.
- Our clients. Clients of our Services may provide us Personal Information about you. For example, our clients may provide Personal Information related to their employees, customers, or suppliers. Personal Information may be in the form of, or included in, documentation provided to us to perform our Services.
- Our vendors. Our vendors may provide us Personal Information related to you in the process of providing us their services. 例如，供应商可能会向我们披露您的饮食偏好，以适应现场活动.
- Tracking technologies. Such as when you visit the Website, which may have first party and third-party technology integrations (e.g., cookies) that help facilitate and personalize your visit to the Website or to other online services. For more information see our Cookie Policy.
- External sources. Such as data resellers, government publicly available records, from your employer, and from referrals or business professionals in your network. This does not include our vendors.
我们收集的有关您的个人信息可能会因您与我们互动的方式而有所不同, but may include:
- Identifiers. This includes names, contact information, addresses, Internet Protocol address, or other similar identifiers.
- Personal Records. This includes your signature, telephone number, education, and employment.
- Commercial information. This 包括个人财产、购买、获得或考虑购买的服务的记录.
- Characteristics of protected classifications. 这包括年龄、性别、国籍或公民身份、种族或民族出身.
- Internet or Other Electronic Network Activity. This includes Internet Protocol address, device identifiers, mobile network, operating system details, language preferences, referring URLs, length of visits, traffic data, pages viewed, and information regarding interactions with the Website.
- Geolocation Data. This includes global latitude and longitude of your location.
- Audio, electronic, visual, or similar information. This includes audio recordings of customer services calls or video recordings of online webinars.
- Professional or Employment-Related Information. 这包括你的职位、雇主和其他专业背景信息.
- Account and Profile Information. If you register an account, you may provide Personal Information such as your name, age, date of birth, gender, address, email address, telephone number, and username/password.
- Payment Information. You may provide certain payment information, such as credit card, debit card, account number or other payment method information, as well as billing address information.
- Information Necessary to Perform Our Services. This includes any information we obtain from the sources listed above in relation to providing our Services such as payment-related information, information on financial conditions, such as bank account information, salary details and other benefits, insurance data and the license plate number of a company car, information on insurances and occupational pensions, 税务信息和文件，如税收平衡和纳税申报文件, compensation data, travel information, birth certificates, marriage licenses, degrees, working and living arrangements, immigration data, work permits, payroll information, and health information such as treatment history and absence data such as medical certificate and information on sick leave, leave of absence, or parental leave.
- Background Check Information. We may run background checks in relation to our Services before, during or after provision of such Services. Information involved may include reputational and financial checks, conflicts, anti-money laundering, government sanction checks, and politically exposed persons checks.
- Legal Records and Documentation. 我们可能会处理与您的法律记录相关的信息，以保护我们的利益, protection of our clients and others, as well as to perform our Services. Legal records may include court records, information on pending or completed litigation or other legal actions, and active disputes.
- External Service Information. We may obtain information about you from external services, 例如，您选择使用由外部方提供的网站功能. 我们也可能用外部记录补充我们向您收集的某些信息. External parties may provide us with information about you in connection with a co-marketing agreement or in connection with a tracking technology.
- Inferences. We may process inferences drawn from any other Personal Information we process to create a profile about you reflecting your preferences, intelligence, abilities, and aptitudes.
3. COOKIES, GOOGLE ANALYTICS AND OTHER TRACKING TECHNOLOGIES
In addition to any Personal Information or other information that you choose to submit through the Website or offline, we and our vendors may use a variety of tracking technologies, including cookies, that collect certain information whenever you interact with the Website, such as device identifier, your IP address, location, other unique identifier, all of the areas within the Website that you visit, and the length and time of the visit.
We may combine certain automatically-collected information with other information we obtain about you, which may include data we obtain from external parties. You can set your browser to refuse cookies from the Website, but if you do so, you may not be able to access or use portions of the Website, 或本网站上的某些产品可能无法按预期或正常运行.
Our Website may use Google Analytics and other comparable technology. Google uses cookies to analyze how you use our Website. The information collected by the cookies is sent to a Google server in the United States and stored there. Google will use this information to evaluate your use of our Website. Additionally, Google may transfer this information to a third party when required by law or in accordance with their terms. By using our Website, you consent to the collection, use, 以及谷歌以上述方式披露您的个人信息. You can withdraw your consent at any time by following the instructions found on this page: http://tools.google.com/dlpage/gaoptout?hl=en.
对于通过跟踪技术(如.g., cookies) on the Website, see our Cookie Policy.
4. INTEREST BASED ADVERTISING
We (and our service providers) may use the information we collect, for instance, IP addresses and unique mobile device identifiers, to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content and features and provide you with a seamless experience across devices. 如果您希望退出基于兴趣的广告目的的跨设备跟踪, you may do so through your device settings.
We may tailor ads to your interest based on your browsing of our Website and elsewhere on the internet, 这可能包括在第三方服务(如Facebook应用程序)上向你发送广告.) after you have left the Website using re-targeting technologies. This type of advertising is often called “interest-based” or “personalized” advertising—and when it occurs on mobile apps, “cross-app” advertising (collectively, “Interest-Based Advertising”).
You can reject or disable Interest-Based Advertising, tailored ads, 或者通过管理浏览器设置或Facebook应用程序设置来重新定位广告. However, please note that if you disable cookies and/or meta pixels, you may be unable to access some customized features on the Website.
To disable the use of Interest-Based Advertising, 在浏览器上登录Facebook网站，进入“设置”选项卡下的“广告设置”. If you are using the Facebook app on your mobile device, you can go to “Ad Settings” by clicking on the “Setting & Privacy” tab, then selecting “Settings”, “Ad”, and “Ad Preferences”.
选择退出谷歌分析显示广告或自定义谷歌显示网络广告, you can visit the Google Ads Settings page. You can learn more about Interest-Based Advertising and how to opt-out of receiving tailored advertising by visiting (i) the Network Advertising Initiative’s Consumer Opt-Out link; or (ii) the Digital Advertising Alliance’s Consumer Opt-Out link.
请注意，即使您选择退出，您仍可能收到我们的广告. However, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs.
5. HOW WE USE PERSONAL INFORMATION
We may use the Personal Information we collect or receive about you for the following purposes including the purposes set out below. Unless otherwise noted, 以下描述涵盖了我们在生效日期前12个月的活动, as well as our current practices.
Identifiers
Sources:
- Directly from you
- Our clients
- Our vendors
- Tracking technologies
- External sources
Purposes:
- To provide you with access to the Website features
- To enable external party features
- 履行必要和适当的内部职能，如记录维护 and developing or improving the Website
- To communicate with you
- To respond to your requests for technical support, online services, or to any other communication you initiate
- To prevent and detect fraud, verify identity, comply with a legal obligation, defend legal claims, assist with legal processes such as investigations, regulatory requests, litigation, and arbitration, and as required by applicable law, court order, or governmental regulations
Personal Records
Sources:
- Directly from you
- Our clients
- Our vendors
- External sources
Purposes:
- 履行必要和适当的内部职能，如记录维护
- To prevent and detect fraud, verify identity, comply with a legal obligation, defend legal claims, assist with legal processes such as investigations, regulatory requests, litigation, and arbitration, and as required by applicable law, court order, or governmental regulations
Commercial Information
Sources:
- Directly from you
- Our clients
- Our vendors
Purposes:
- 履行必要和适当的内部职能，如记录维护 or administration of services
Characteristics of Protected Classifications
Sources:
- Directly from you
- Our clients
- Our vendors
- External sources
Purposes:
- 履行必要和适当的内部职能，如记录维护 or administration of services
Internet or Other Electronic Network Activity
Sources:
- Tracking technologies
Purposes:
- To provide you with access to the Website features
- To enable external party features
- To perform necessary and appropriate internal functions, such as developing or improving the Website
- To prevent and detect fraud, verify identity, comply with a legal obligation, defend legal claims, assist with legal processes such as investigations, regulatory requests, litigation, and arbitration, and as required by applicable law, court order, or governmental regulations
Geolocation
Sources:
- Tracking technologies
Purposes:
- To provide you with access to the Website features
- To enable external party features
- To perform necessary and appropriate internal functions, such as developing or improving the Website
- To prevent and detect fraud, verify identity, comply with a legal obligation, defend legal claims, assist with legal processes such as investigations, regulatory requests, litigation, and arbitration, and as required by applicable law, court order, or governmental regulations
Audio, electronic, visual, thermal, or similar information
Sources:
- Directly from you
- Our clients
- Our vendors
- External sources
Purposes:
- 履行必要和适当的内部职能，如记录维护
- To prevent and detect fraud, verify identity, comply with a legal obligation, defend legal claims, assist with legal processes such as investigations, regulatory requests, litigation, and arbitration, and as required by applicable law, court order, or governmental regulations
- To comply with health and safety obligations
Professional or Employment-Related Information
Sources:
- Directly from you
- Our clients
- Our vendors
- External sources
Purposes:
- 履行必要和适当的内部职能，如记录维护
- To prevent and detect fraud, verify identity, comply with a legal obligation, defend legal claims, assist with legal processes such as investigations, regulatory requests, litigation, and arbitration, and as required by applicable law, court order, or governmental regulations
Inferences drawn from any of the information identified in this section to create a profile about you reflecting your preferences, intelligence, abilities, and aptitudes
Sources:
- Directly from you
- Our clients
- Our vendors
- External sources
- Tracking technologies
Purposes:
- 履行必要和适当的内部职能，如记录维护 and developing or improving the Website
6. HOW WE DISCLOSE PERSONAL INFORMATION
未经您的许可，我们不会向第三方披露您的个人信息, except as described below.
Service Providers. We may disclose your Personal Information to our service providers for certain business purposes as set out below. Personal Information is provided in order for them to provide us services such as payment processing, advertising services, marketing partners, web analytics, data processing, IT services, customer support and other services. These service providers have access to your Personal Information only for the purpose of performing services on our behalf and are expressly obligated not to disclose or use your Personal Information for any other purpose.
个人资料类别及向服务提供者披露的目的
Identifiers
- Helping to ensure security and integrity
- Debugging to identify and repair errors in functionality
- Short-term, transient use
- Performing services needed to operate our business
- Internal research for technological development and demonstration
- 开展活动以验证或维护我们的系统和服务的质量或安全, and to improve, upgrade, or enhance our systems and Website
Personal Records
- Performing services needed to operate our business
Commercial Information
- Performing services needed to operate our business
Characteristics of Protected Classifications
- Performing services needed to operate our business
Internet or Other Electronic Network Activity
- Helping to ensure security and integrity
- Debugging to identify and repair errors in functionality
- Short-term, transient use
- Performing services needed to operate our business
- Internal research for technological development and demonstration
- 开展活动以验证或维护我们的系统和服务的质量或安全, and to improve, upgrade, or enhance our systems and Website
Geolocation
- Helping to ensure security and integrity
- Debugging to identify and repair errors in functionality
- Short-term, transient use
- Performing services needed to operate our business
- Internal research for technological development and demonstration
- 开展活动以验证或维护我们的系统和服务的质量或安全, and to improve, upgrade, or enhance our systems and Website
Audio, electronic, visual, thermal, or similar information
- Helping to ensure security and integrity
- Performing services needed to operate our business
- 开展活动，以验证或维护我们的系统和场所的质量或安全, and to improve, upgrade, or enhance our systems and Website
Professional or Employment-Related Information
- Performing services needed to operate our business
Inferences drawn from any of the information identified in this section to create a profile about you reflecting your preferences, intelligence, abilities, and aptitudes
- Performing services needed to operate our business
Background Check Information
- Performing services needed to operate our business
Legal Records and Documentation
- Performing services needed to operate our business
In addition, we may collect and disclose Account and Profile Information, Payment Information, Information Necessary to Perform Our Services, and External Service Information for the following purposes:
- Provide Services. To provide our Services, including creating and activating accounts, facilitate and manage purchases, processing payments, process transactions, and servicing accounts.
- Research and Development. 我们可能会开发新功能，创造新产品或改进现有产品, 包括将个人信息用于与某些研究相关的内部目的. This may include when you participate in surveys or research activities.
- Advertising. We may personalize your experience with us by conducting advertising, such as contextual, targeted, or behavioral advertising. 例如，这允许我们推荐您可能喜欢或觉得有用的产品.
- Marketing Messages. To communicate with you about products or services you have purchased or used; provide you with promotional messages and personalized advertising; to notify you of other products; to notify you of contests, challenges, sweepstakes, and other promotions; to notify you of services we think may be of interest to you; and, for other marketing purposes.
- Customer Service. To respond to your requests for technical support, online services, product information or to any other communication you initiate, including requests, inquiries, and complaints.
Co-Branded Services. From time to time, we may enter into an arrangement with another company that is not owned by or affiliated with us to provide additional features on the Website. These arrangements may include business partners, sponsors, and co-branded online services (referred to here as “co-branded services”). Any information, including Personal Information, 您在其中一个联合品牌服务上提供的信息可能会与这些合作伙伴共享. 通过参与活动或提供您在这些联合品牌服务上的信息, you consent to our providing your information to those partners. Separate privacy policies may apply to these partners’ collection, use, and disclosure of your Personal Information.
Business Transactions. In the event of a business transaction, we may disclose Personal Information to prospective or actual purchasers, investors, or successor entities in connection with a contemplated reorganization or an actual reorganization of our business, in connection with financing, a sale, 或涉及处置我们全部或部分业务或资产的其他交易, including for the purpose of permitting the due diligence required to decide whether to proceed with a transaction, 根据充分的数据处理实践和保障措施的保证.
Legal Compliance and Safety. We may also disclose Personal Information for legal compliance, law enforcement, and public safety purposes. For example, to law enforcement, government or regulatory bodies, lawful authorities, or other authorized third parties in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Privacy Policy, or agreements with third parties, or for crime-prevention purposes.
我们可能会将您的个人信息与我们从我们的服务中获得的数据结合起来, other users, or third parties. We reserve the right to convert, or permit others to convert, your Personal Information into deidentified, anonymized, or aggregated data, as permitted by law.
With Your Consent. 我们也可能在您的同意或您的指示下分享或披露您的个人信息.
If we share your Personal Information with service providers, we ensure that the contracts between RSM and the service providers has appropriate controls and protections in place at the service provider level to protect your Personal Information. Our service providers may, from time to time, sub-contract certain administrative services to other service providers that may not reside in Canada and require access to certain Personal Information to perform contracted services. In this case, RSM’s service providers are responsible for ensuring appropriate security measures and controls are in place to protect your Personal Information from unauthorized use, loss, theft, alteration and destruction. Personal Information available to service providers in foreign jurisdictions may be disclosed to local authorities as may be prescribed by law.
7. OTHER ONLINE SERVICES
本网站可能包含指向其他在线服务的链接或由其他在线服务提供的功能. For example, you may be able to share content from the Website to your social media profile on an external online service. 本隐私政策不适用于我们不拥有或控制的公司的做法. 我们提供这些外部链接只是为了您的方便，我们无法控制, do not review, 并且不对外部在线服务或其隐私政策或做法负责. If you provide any Personal Information to any third party or through any such third-party website, we recommend that you familiarize yourself with the privacy policies and practices of that third party.
8. YOUR CHOICES
You have the right to access, 更新和纠正我们保管和控制的您的个人信息中的不准确之处, subject to certain exceptions prescribed by law. If you have a registered account, you may be able to change your preferences as well as update your Personal Information through your account settings.
You may exercise your rights to access, update or correct inaccuracies by logging on to your account or contacting us at dataprivacyoffice@rsmus.com. 如果您通过电子邮件或电话与我们联系，我们可能会要求您验证您的身份. 您也可以指定授权代理人提出了解或删除请求. In order to be able to act, 授权代理人必须提交他们被授权代表你行事的证明, or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on their behalf.
对于我们收集的个人信息，不能通过您的帐户访问, you can request, in writing, that we correct an error or omission to your Personal Information or delete your Personal Information. We will respond to written requests within thirty (30) days, or alternatively, the timeframe prescribed by the relevant legislation.
9. DATA RETENTION
We keep the categories of Personal Information described above for as long as is necessary for the purposes described in this Notice or to achieve the purposes for which the information was collected, or as may be permitted under applicable law. 这通常意味着只要符合以下条件之一，就可以保留信息:
- Your Personal Information is reasonably necessary to manage our operations, to manage your relationship with us, or to satisfy another purpose for which we collected the information;
- Your Personal Information is reasonably necessary to carry out a disclosed purpose that is reasonably compatible with the context in which the Personal Information was collected;
- Your Personal Information is reasonably required to protect or defend our rights or property (which will generally relate to applicable laws that limit actions in a particular case); or
- We are otherwise required or permitted to keep your Personal Information by applicable laws or regulations.
To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements. Unless otherwise required by applicable law, at the end of the retention period we will remove Personal Information from our systems and records.
Where your Personal Information is used for more than one purpose, we will retain it until the purpose with the latest period expires.
10. ELECTRONIC COMMUNICATION
When you sign up for an account and create a profile, or otherwise sign-up to receive information regarding our developments or related products and services, we collect your contact information such as your name, phone number, mailing addresses and email address. If you opt in to receiving our communications, we will use this information to send you communications based on your expressed interests by mail or email.
You will always have the opportunity to unsubscribe from receiving any of our e-mail or other communications at any time by contacting us at dataprivacyoffice@rsmus.com and we will ensure that our e-mails include instructions on how to unsubscribe if you no longer wish to receive future e-mails from us.
If you decide to unsubscribe, we will only contact you (i) for the purposes allowed under applicable law; (ii) to send you notices of changes to our Privacy Policy; or (iii) to receive service related messages.
11. DATA SECURITY
We implement reasonable physical, technological, and organizational safeguards to protect against unauthorized or unlawful processing of Personal Information and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Information. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Information. RSM limits access to internal systems that hold Personal Information to individuals who need access for a legitimate business purpose.
12. DATA TRANSFER
Your Personal Information may be collected, used, processed, transferred, and retained in multiple countries including, Canada and the United States, which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. Additionally, and as discussed above, we may also engage service providers to perform certain services on our behalf and to otherwise provide the Services. These service providers may store, process and transfer Personal Information on servers located outside of Canada in jurisdictions whose data protection laws may differ from those of Canada, such as the United States. As a result, Personal Information may be subject to access requests from governments, courts, 或者根据这些司法管辖区的法律在这些司法管辖区执法. For example, 为了响应政府当局的有效要求或请求，可以共享信息, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our service providers to maintain protections on Personal Information that are equivalent to those that apply in Canada.
13. UPDATES TO PRIVACY POLICY
We may change this Privacy Policy from time to time. 如有变更，我们将以修改本隐私政策顶部日期的方式通知您. We may provide more specific reasonable notice at our discretion (e.g.(横幅、弹出窗口或发送给您的电子邮件)，如果我们实质性地更改本隐私政策. Any changes to this Privacy Policy will be effective as of the “Last Updated” date at the top of this page, unless otherwise expressly indicate.
14. CONTACTING US
You may contact us dataprivacyoffice@rsmus.com, 1-800-274-3978, or:
- Attn: Data Privacy Office
- 200 S. Wacker Drive
- Suite 3900
- Chicago, IL 60606
