Version date: 8/2/21
Crowe LLP and its subsidiaries listed below (collectively, "Crowe" or “us” or “our”) provide communications, surveys and other alumni program services to its former interns, employees and alumni. This Privacy Statement outlines our general policy and practices for protecting personal information that we collect through our Web site at www.alumni.crowe.com ("Site"). The Site is administered by PeoplePath, Inc. (“PeoplePath”) on behalf of Crowe. This Privacy Statement explains the types of information we gather through our Site, how we use that information, and the rights individuals may exercise in relation to that information.
Crowe LLP subsidiaries include the following: (i) Crowe Healthcare Risk Consulting LLC (ii) Crowe Horwath Cayman Ltd., (iii) Crowe Horwath Global Risk Consulting Holdings Ltd., (iv) Crowe Horwath Global Risk Consulting ULC (Canada), (v) Crowe Horwath Global Risk Consulting SAS (France), (vi) Crowe Horwath Global Risk Consulting LLP (United Kingdom), and (vii) Crowe Horwath IT Services Pvt Ltd.
Other webpages of applicable Crowe Global member firms or related entities manage their websites independently and such websites are not the responsibility of Crowe. Such websites, as well as other websites that may be linked to this website, are not governed by this Privacy Statement. Crowe is not responsible or liable for any acts or omissions of Crowe Global or any other member firm of Crowe Global and specifically disclaims any and all responsibility or liability for acts or omissions of Crowe Global or any other Crowe Global member firm. We encourage visitors to review each of these other website’s privacy policies before disclosing any personal information.
By submitting personal information to us, you consent to our use of such personal information in accordance with this Privacy Statement.
Notice, Choice and Use
You may voluntarily provide us with personal information. Personal information that you may submit to Crowe includes, without limitation, your name, job title, address, email address, telephone and, and other personal information.
Typically, personal information is used in the following circumstances:
- Registration for access to certain areas of the Site
- Subscribing to or ordering newsletters, media alerts and/or publications
- Participation in bulletin boards, discussion or message forums
- Responding to quick surveys, quizzes, or benchmarking surveys
- Registration for events (e.g., webcasts or seminars) and conferences
- Contacting Crowe for further information
Please note that whenever you voluntarily disclose personal information through the Site - in the optional fields in your profile, through email, or in other areas of the Site - that information could be accessible to the rest of the members of the Crowe Alumni Network and may be made public. Please do not post or add personal information to your profile or elsewhere on the Site that you would not want to be publicly available. Crowe will not be responsible for any misuse of such personal information by others, including any unsolicited messages you may receive as a result of providing personal Information on the Site.
Crowe does not intend to actively seek sensitive personal information (also known as special category personal data). Sensitive personal information includes, without limitation, data related to race or ethnic origin, political opinions, religious or philosophical belief, trade union membership, medical or health information, sex life or sexual orientation or criminal record (including suspected criminal activities). By providing such sensitive personal information, you explicitly consent to Crowe’s use of that information in accordance with this Privacy Statement or as otherwise agreed upon at the time of disclosure.
We may use the personal information you submit through the Site for Crowe’s business purposes, including without limitation, to manage your requests, to improve the Site, send you administrative information or notices, send you information about our alumni program, events, and other relevant information, and any other purpose stated at the point of collection.
Please do not provide your username or password for the Site to any third party. You are solely responsible for safeguarding your login information. In addition, please respect the privacy of other alumni members and do not disclose their personal information obtained from the Site to any third party.
Cookies and Similar Technologies
As is the case with many commercial Web sites, Crowe automatically logs certain information about user access to the Site, which may include a user's internet protocol address, browser type, internet service provider, referring/ exit pages, operating system, as well as date and time stamps. We also use "cookies" which are small data files stored on a user's computer to enhance your on-line experience when visiting our Site. The use of "cookies" is common practice for most Web sites; however, most Web browsers include settings that allow users to decline cookies.
Most Web browsers will allow you to see what cookies you have and delete them on an individual basis or block cookies from particular or all websites. Be aware that any preference you have set will be lost if you delete all cookies, including preference to opt-out from cookies as this itself requires an opt-out cookie to have been set. If you wish to restrict or block the cookies which are used on the Site, you can do this through your browser settings.
In addition, you can opt-out of having your anonymized browsing activity within sites recorded by analytics cookies. We use Google Analytics and you can learn more about their privacy policies and how to opt-out of their cookies by clicking on the following link: https://policies.google.com/technologies/product-privacy?hl=en-US . For more information on managing cookies see www.allaboutcookies.org/manage-cookies/.
Do Not Track Signals
Some Web browsers incorporate a "do-not track" or similar feature that signals to Web sites with which the browser communicates that a visitor does not want to have his or her online activity tracked. As of the Effective Date of this statement, not all browsers offer a "do-not-track" option and "do-not-track" signals are not yet uniform. The Site does not currently respond to "do-not-track" signals or other similar features.
Disclosures and Transfers
Crowe may transfer or disclose collected personal information to third-party service providers, subcontractors, Crowe Global member firms, and/or other Crowe affiliated companies for the purpose of managing your request, administration and management of the Site, and/or internal business purposes. Crowe may also disclose your personal information to other users and members of the Site with the purpose of enabling other users to search for and locate you via the directory. Personal information may also be transferred to third-party service providers of identity management, website hosting and management, data analysis, data backup, and/or security and storage service. Crowe may transfer or disclose collected personal information to PeoplePath for the purpose of PeoplePath administrating, hosting and managing the Site. Collected personal information may be transferred to third-parties located in other countries. Crowe will endeavor to take reasonable steps to ensure that such third-parties will provide adequate privacy protection to your personal information. By using the Site, you explicitly consent to the transfer of such data in accordance with this Privacy Statement and as otherwise set forth on the Site.
Additionally, Crowe may disclose personal information to third parties under other circumstances, including, without limitation, the following:
- As required by applicable law, statute, rule, regulation or professional standard, or through subpoena, search warrant or other legal process
- When explicitly requested by you
- When required to deliver publications or reference materials requested by you
- When required to facilitate conferences or events hosted by third parties
- As otherwise set forth in this Privacy Statement or on the Site
Third-Party Sites and Social Media Applications
This website may also host various blogs, forums, wikis and other social media applications or services that allow you to share content with other users (collectively “Social Media Applications”). Any personal information or other information that you contribute to any Social Media Applications can be read, collected, and used by other users of that Social Media Application over whom we have little or no control. Crowe is not responsible for any third party’s use, misuse, or misappropriation of any personal information or other information that you contribute to any Social Media Application.
The security of your personal information is important to us. We seek to use reasonable physical, technical, and administrative safeguards to protect the information we process. However, no method of transferring data over the Internet or storing electronic data is completely secure. Therefore, while we strive to use reasonable and appropriate means to protect your personal information, we cannot guarantee absolute security. By using the Site, you acknowledge that the transmission of data over the internet is inherently insecure and assume all risks associated with such transmission. Further, you acknowledge and agree that Crowe has no control over the security of data being transmitted over the internet.
We process personal information only in ways compatible with the purpose for which it was collected, as subsequently authorized by the individual, or as otherwise permitted by applicable law. By using the Site, you acknowledge and agree to be solely responsible for the accuracy and completeness of the information and data that you provide and submit on the Site.
Access and Correction
Depending on your jurisdiction or the jurisdiction in which the data was collected, you may be entitled to request details regarding personal information about you that we are in possession of. In such instances, we may provide you with the ability to submit a request for access, rectification, erasure, request a copy of your personal information, or to restrict or object to further processing.
You are solely responsible for verifying the ongoing accuracy of the personal information submitted through the Site. If you have an inquiry regarding the accuracy of personal information previously submitted, or have a request to modify such information, please contact us using the contact information below. We will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate. We may limit or deny access to personal information where providing such access would be unreasonably burdensome or inappropriate under the circumstances. All requests to access or change personal information will be handled in accordance with applicable legal requirements.
Visitors who choose to register with this Site may correct and update their user profiles or unsubscribe from certain communications at any time. Visitors who would like to access or change their profiles or would like to request a copy of their personal information should contact us at firstname.lastname@example.org.
We will retain your personal information only for as long as is necessary for the intended purpose, unless a longer retention period is required or permitted by law, regulation, professional standards or our document retention policies.
Merger and Other Business Transitions
In the event Crowe goes through a business transition, such as a merger, or the acquisition or sale of a portion of its assets, your personal information may be among the assets transferred.
Privacy Statement Changes
Crowe reserves the right to amend or modify this Privacy Statement from time to time, as determined at Crowe’s sole discretion, by publishing an update version on the Site. Crowe encourages you to periodically review this Privacy Statement. You can access the most current version of this Privacy Statement on the Site.
Children Privacy Protection
This Site is not intentionally designed for or directed at children 13 years of age or younger. It is Crowe’s policy to refrain from intentionally and knowingly collect or maintain personally identifiable information about children under the age of 13.
Data Transfers from the EU/EEA, UK and Switzerland to the US
Crowe LLP complies with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union / European Economic Area, United Kingdom and Switzerland to the United States. Crowe LLP has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. To learn more, please visit Crowe EU-U.S. and Swiss-U.S. Privacy Shield Notice
In compliance with the Privacy Shield Principles, Crowe LLP commits to resolve complaints about the collection or use of your personal information. EU/EEA, UK and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Crowe LLP at: email@example.com. Crowe LLP has further committed to cooperate with the panel established by the EU/EEA and UK data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU/EEA, UK and Switzerland. In the event of a complaint not resolved by any other Privacy Shield mechanisms, an individual has the possibility to invoke binding arbitration for the resolution of this complaint. For additional information, please see https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject will be in line with the General Data Protection Regulation (GDPR) when applicable, and in accordance with the country-specific data protection regulations applicable to Crowe LLP.
As the controller, Crowe LLP has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed.
If you no longer wish to receive promotional communications from us, you may at any time request that we discontinue sending you such materials by contacting us using the contact information listed below.
How to Contact Us
Questions, comments or concerns about Crowe LLP’s Privacy Statement, Privacy Shield Certification, or data collection and processing practices can be emailed to firstname.lastname@example.org.