Introduction
Origin Compliance is an offering of PwC Product Sales LLC (“PwC”), a member of the PricewaterhouseCoopers global network of firms. Each PricewaterhouseCoopers member firm is a separate legal entity. For further details, please see www.pwc.com/structure.
PwC is committed to protecting your privacy. This privacy statement explains our information collection practices with respect to Origin Compliance (the “Application”) and how we use, share, and protect that information. Note, this Privacy Statement applies solely to the Application and does not apply to other PwC websites or applications.
Information Collection
When you access or otherwise use our Application, we will collect information about you and how you interact with our Application. We collect information about you through: (1) information you provide; (3) third parties, namely identify third party/ies - e.g., your employer or other company, institution, or organization with which you are affiliated.
Information You Provide
When you access the Application, you may choose to provide information about yourself such as: identifiers and contact information including your name, address, email address, telephone number, login credentials, job title, and company name. By way of example, you may choose to provide your information in the following circumstances:
- User access provisioning / deprovisioning;
- Registration for or otherwise accessing the Application
Automatically Collected Information
We may use online identification technologies, such as cookies, web beacons, pixels, tags, localstorage, or similar technologies (“Cookies”) on our Application. The information we collect using these technologies includes identifiers and internet activity information such as: browser type and language and access time. For more information about the Cookies used on the Application, please review our Cookie Disclosure.
PwC also uses third-party analytics providers, which may set Cookies in your browser or device. Application activity information collected by these analytics providers may be combined with personal information held by PwC. For more information about these third-party tools, please review our Cookie Disclosure.
Information from Third Parties
We may collect the following information about you in connection with the Application from identified third party/ies - e.g., your Organization: business email, occupation/title, business address, and business phone number.
Information Use
We use the information we collect as described above for various purposes depending on the context in which we collected such information. For example, it may be necessary for us to process your information in order to process a transaction or provide a service you have requested or otherwise in accordance with a contract between us, or we may process your information in accordance with your prior consent (where you have provided such consent).
We also use the information we collect for the following business purposes:
- User access provisioning / deprovisioning;
- To operate, maintain, customize, analyze and improve the Application;
- To maintain and improve the safety and security of the Application, and to run our internal operations;
- To prevent and enhance protection against fraud, spam, harassment, intellectual property infringement, crime, and security risks;
- To comply with law, rules, regulations, legal obligations, professional and industry standards, as well as respond to and complying with subpoena, search warrant or other legal process, including establishing, exercising, or defending our legal rights;
- To fulfill your orders/requests and respond to your inquiries.
Information Sharing
We are part of a global network of firms. In common with other professional service providers, PwC may transfer or disclose the information it collects, including your information, to third party contractors, subcontractors, subsidiaries, and/or other PwC firms for the purposes for which you have submitted the information and for the administration of our system or Application and/or other internal, administrative purposes. We transfer your information to third party service providers of identity management, website hosting and management, data analysis, data backup, security, and storage services.
PwC may also disclose information to third parties under the following circumstances:
- When explicitly requested by a user;
- As necessary to comply with law, rules, regulations, legal obligations, professional and industry standards, as well as respond to and complying with subpoena, search warrant or other legal process, including establishing, exercising, or defending our legal rights;
- As necessary in connection with a corporate reorganization, merger, sale, joint venture or other disposition of all or any portion of our business, assets or capital.
We may also share aggregate information about Application users with third parties for any lawful business purpose. We do not sell personal information collected in connection with the Application nor do we disseminate personal information collected in connection with the Application to outside parties for consumer marketing purposes or host mailings on behalf of third parties.
Information Transfer
Your information may be transferred outside of the U.S. or your country of residence. This includes to countries outside the European Economic Area (“EEA”) and to countries that do not have laws that provide the same degree of protection for personal information. In accordance with applicable legal requirements, we take appropriate measures to facilitate adequate protection for any information so transferred.
Where we transfer personal information outside of the EEA to a country or framework not determined by the European Commission as providing an adequate level of protection for personal information, the transfers will be under an agreement which covers European Union requirements for such transfers, such as standard contractual clauses. The European Commission approved standard contractual clauses are available here.
Although not currently relied upon as an authorized mechanism for cross border transfers, PricewaterhouseCoopers LLP and its affiliated U.S. subsidiaries also adhere to the privacy principles in the EU - U.S. Privacy Shield Framework and the Swiss - U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce. To learn more, see our Privacy Shield Policy.
Information Retention
We will retain the personal information collected by us through the Application for as long as is necessary for the purpose(s) for which it was collected as set out in this privacy statement, provided that personal information may be held for longer periods where extended retention periods are required by law, regulation or professional standards, and in order to establish, exercise or defend our legal rights.
Your Choices
Unsubscribe
Should you wish to unsubscribe from our mailing list or any registrations, we will provide instructions in communications to you; or you may contact us at: us_origincompliance@pwc.com.
Managing Cookies
If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, you may refuse or delete one or more cookies and still access the Application, but Application functionality may be impaired. After you finish browsing this Application, you may delete Application cookies from your system if you wish. For more information about how to manage your cookie preferences, please review our Cookie Disclosure.
Do Not Track
Do Not Track (“DNT”) is a privacy preference that you can set in your web browser to send a message to the website operator requesting not to be tracked. Currently, we do not respond to these DNT signals. For more information about DNT, visit https://allaboutdnt.com/.
Access
You may review and change your personal information by logging into the Application and visiting your account profile page. If you would like to update your information or request to have outdated information removed, please contact us at: us_origincompliance@pwc.com.
Rights
Depending on the jurisdiction in which you are located, you may have certain rights with respect to your personal information. Subject to applicable law, these rights may include the right to:
- Know what personal information about you we have collected, disclosed, and/or sold, as applicable;
- Obtain a copy of your personal information;
- Delete your personal information;
- Direct us not to sell your personal information (but as noted above, we do not sell personal information collected about you in connection with the Application);
- Correct or update your personal information;
- Restrict the processing of your personal information;
- Object to the processing of your personal information;
- Withdraw your consent for processing (where processing is based on your consent). Please note that if you withdraw your consent, we may not be able to provide you the services for which it was necessary to process your information based on your consent; and
- Exercise your privacy rights without discriminatory treatment from us.
To exercise any of the rights described above, please submit a verifiable request to us by either using our request form or calling us at 1-888-438-4427.
The verifiable request must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. Further, you must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Please, however, refrain from sending us sensitive personal information. Where permitted by law, you may use an authorized agent to submit a request on your behalf if you have provided the authorized agent signed permission to do so.
We may not be able to fulfill your request if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a verifiable request to verify the requestor’s identity or authority to make the request.
We will respond to your request within a reasonable timeframe in accordance with applicable law. We reserve the right to charge an appropriate fee for complying with a request where permitted by applicable law, and to deny a request where it may be manifestly unfounded, excessive, or unwarranted under applicable law.
We hope that you won’t ever need to, but if you do want to complain about our use of personal information, please send us a message with the details of your complaint using our general contact form. You may also contact our EU Representative, PwC Malta, by completing our EU Representative contact form. Applicable laws may also give you the right to lodge a complaint with the data protection authority in your country.
Security
PwC has implemented generally accepted standards of technology and operational security designed to protect personal information from unauthorized access, loss, misuse, alteration, or destruction. Only authorized PwC personnel and the third parties described in this privacy statement are provided access to personal information and these employees and third parties have agreed to maintain the confidentiality of this information.
Third Party Sites
This Application may link to other websites which do not operate under PwC's privacy practices. When you link to other websites, PwC's privacy practices no longer apply. We encourage you to review the privacy statement of each website you visit before disclosing any personal information.
Children
PwC understands the importance of protecting children's privacy, especially in an online environment. The Application is not intentionally designed for or directed at children under the age of 13 years. It is PwC's policy never to knowingly collect or maintain personal information about children under the age of 13.
Modifications
PwC may update this privacy statement at any time by publishing an updated version here. You can access the most current version of this privacy statement at any time on this Application.
Contact Us
If you have questions about this privacy statement or about our privacy practices, please contact us at us_origincompliance@pwc.com.