Personal Data Protection Policy

Delta Grant Thornton is concerned about your privacy and the protection of your personal data. In the interests of transparency, Delta Grant Thornton has adopted a "Personal Data Protection Policy" relating to the personal data collected by Delta Grant Thornton in order to describe the personal data that we may collect from our prospects and clients, the processing that we carry out on this data, the persons or entities to whom we communicate it and the rights enjoyed by the natural persons whose data we process.

 

Our firm may act, as the case may be, as data controller, as joint data controller with its clients, or as a subcontractor of its clients.

Delta Grant Thornton has implemented a Personal Data Protection Policy in accordance with the regulations applicable in the Gabonese Republic and in particular law n°001/2011 of 25 September 2011 relating to the protection of personal data.

1 - Définitions

Supervisory Authority: the National Commission for the Protection of Personal Data;

Consent of the Data Subject: any express, unequivocal, free, specific and informed expression of will by which the data subject or his/her legal, judicial or conventional representative agrees to the manual or electronic processing of his/her personal data;

Recipient: the natural or legal person, public authority, service or any other body that receives communication of personal data, whether or not it is a third party;

Personal Data: any information relating to an identified or directly or indirectly identifiable natural person (hereinafter referred to as "data subject"); "identifiable natural person" means a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location data, an on-line identifier, or to one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity;

Purpose: objective pursued by the processing operation (e.g. recruitment, file management, invoicing);

Limitation of Processing: the marking of personal data stored, with a view to limiting their future processing;

Person Responsible for the Processing: the natural, legal, public or private person, any other authorized body or association which, alone or jointly with others, takes the decision to collect and process data and determines the purposes and means of processing;

Subcontractor: the natural, legal, public or private person, any other authorized body or association which processes data on behalf of the controller;

Third Parties: the natural, legal, public or private person, any other body or association other than the data subject, the controller, the processor and the persons who, under the direct authority of the controller or the processor, are authorized to process personal data

Processing: any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automatic means, such as collection, use, recording, organization, storage, adaptation or alteration, retrieval, storage, copying, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, encryption, erasure or destruction of personal data, and interconnection of networks;

Delta Grant Thornton: includes all legal audit, accounting and advisory activities carried out by the legal entity Delta Grant Thornton. Delta Grant Thornton is a member firm of Grant Thornton International Ltd.

2 - What data is collected ?

Delta Grant Thornton may collect and process the following personal data on its prospects and clients, in particular on its clients' directors/officers, partners/shareholders, members of staff, clients, suppliers and other business partners, both for the purpose of carrying out the assignments entrusted to it by its clients, to comply with its legal and regulatory obligations or for the purposes of its legitimate interests:

- identification data: surname, first names, gender, identity card and passport numbers, nationality, place and date of birth, social security and health insurance number, photo, IP address, etc.;

- contact data: postal and e-mail address, telephone number, etc. ;

- family situation: marital status, number of children, marital status, etc. ;

- tax data: statistical/tax identification number (TIN), tax status, etc.;

- information on education, occupation/working life and employment: level of education, employment, quality or function (including the existence of a political function), name of employer, etc.;

- economic and financial information: income, remuneration arrangements, taxation, benefits in kind, etc.;

- data relating to interactions between the client and the firm: contact reports, telephone interviews, e-mails, interviews, telephone conversations, our website, our social network pages, etc.;

- data relating to the processing of e-mails and communications addressed to you, such as the date and time of receipt of e-mails, the time they are opened, as well as information concerning your interactions with the content transmitted.

3 - On what legal basis this data processed ?

Delta Grant Thornton collects and/or processes personal data, as the case may be:

- for the purpose of executing the contract concluded with our clients or for pre-contractual measures taken at the request of our clients ;

- for the purposes of the legitimate interests pursued by our firm, such as the prevention of fraud, the management of the relationship with its clients and prospects, prospecting and animation, organisation, registration, invitation to the firm's events and more generally the improvement of its service;

- in order to comply with its legal and regulatory obligations, in particular with regard to the fight against money laundering and the financing of terrorism;

- on the basis of the consent of the natural persons concerned, when required by law.

In the event that the natural person whose personal data is processed by our firm has objected to such processing, our firm may nevertheless be authorized to carry out or continue such processing on one of the other legal bases mentioned above.

4 - For what purposes is this data processed ?

Delta Grant Thornton collects and/or processes your data for several purposes:

Performing statutory audit, accounting and advisory assignments on behalf of clients commissioning Delta Grant Thornton;

-Communication with you by e-mail or post in the context of the assignments you entrust to us;

-Compliance with professional and ethical regulations (in particular management of obligations in terms of prevention and suppression of money laundering and terrorist financing, management of the obligation of independence, management of conflicts of interest and quality control);

-Management and monitoring of the business relationship between us, including administrative and financial matters, in particular with regard to invoicing and payment management and management of the client file;

-Management of newsletters, legal watch, information relating to training courses, invitations relating to legal or economic news, satisfaction surveys and other communications of the same nature;

-Building up and managing a file of prospects;

-Sending solicitations (commercial prospecting) and communications about our services;

-Managing applications for job, collaboration or internship offers;

-Administration and support for the IT tools that the firm uses in the context of its activity (messaging, business tools, etc.), hosting of these tools, archiving and reprography;

-Compliance with legal and regulatory obligations and the defense of the firm's rights.

In addition, we may be required to process, for the purposes of communicating about our services, the personal data of your employees who are our key contacts for the performance of the assignment, unless they object.

5 - Who are the recipients of these data ?

Our firm communicates or is likely to communicate personal data to the following persons or entities:

- authorized members of staff (collaborators and partners) of the firm,

- authorized staff members (collaborators and associates) belonging to the member entities of our network,

- sub-contractors, external collaborators or possible experts,

- external service providers acting on our behalf, which provide administrative services, IT infrastructure services (including, where appropriate, cloud services) and services in support of our business,

- auditor,

- National Order of Chartered Accountants (ONEC),

- or supervisory authorities (regulators), administrative authorities, courts.

These recipients are subject to strict confidentiality and security obligations and will have access to personal data for strictly professional reasons and limited to the purpose of processing.

6 - In what context are your personal data collected ?

Delta Grant Thornton may collect your personal data:

- via the website http://www.grantthornton.ga: to send an application on the website http://www.grantthornton.ga, or to subscribe to newsletters.

- for alerts, circulars, newsletters: you have the possibility to subscribe to our newsletters. If you no longer wish to receive them, you can unsubscribe by return e-mail.

- via social networks: via the buttons on the pages of these networks, you can follow and/or "like" Delta Grant Thornton's posts. The information suggested by these actions may be used by the social network concerned. We invite you to consult the privacy policy of these networks to know in detail the possible consequences.

- through exchanges with our clients or prospects and the provision of the documentation necessary for the performance of our work, our professional due diligence or the establishment of commercial proposals.

7 - Transfer of personal data

You are informed that we are likely to :

- use, within the framework of our mission or for our internal needs, if necessary, other entities that are members of our networks or external service providers working on our behalf that may be located outside Gabon and expressly authorize us to do so;

- use a service provider for the management and monitoring of the customer journey, for the management of its customer base and expressly authorize us to do so. The information communicated in this case is: surname, first name, e-mail address, company, telephone number, position, title.

- transmit your data to third parties if required by legal or regulatory provisions.

In the event that personal data is transferred outside Gabon to a destination country considered as not providing a sufficient level of protection for personal data, we implement a protection system that complies with the applicable regulations on the protection of personal data. For more information, you can send an email to the Data Protection Officer ("DPO") at dpo@ga.gt.com and/or to the partner signing the engagement letter.

8 - Period of conservation of personal data

Personal data is kept in accordance with the legal provisions for a period not exceeding that necessary for the purposes for which it is collected and processed, without prejudice to the periods of limitation and professional liability.

9 - Your rights

Any natural person whose personal data is processed by our firm has the following rights, recognized by the applicable regulations: a right to rectify inaccurate or incomplete data, a right to erase data, a right to limit data processing, a right to data portability and a right to object to data processing.

Where data processing is based on his consent, the right to withdraw his consent at any time.

Any person concerned may, by proving his or her identity, exercise his or her rights at any time with our firm by sending an e-mail to our Data Protection Officer at dpo@ga.gt.com or by post to: Delta Grant Thornton - Immeuble le Narval - BP 79 - Libreville.

The person concerned also has the right to lodge a complaint with the National Commission for the Protection of Personal Data concerning the processing of his/her personal data.

11 - Cookies

Your browsing on the http://www.grantthornton.ga website may give rise to the use of "cookies", if you continue browsing without changing the settings of your browser.

Cookies consist of information installed by your browser on your hard disk. Cookies allow us to be informed of the characteristics of your visit to our site (type of browser, etc.).

Delta Grant Thornton uses two types of cookies:

- Session or preference cookies, which are essential for browsing and the proper functioning of the site.

- Audience measurement cookies which enable us to monitor your browsing on the site for statistical purposes and to enable Delta Grant Thornton to know its audience better in order to improve its service.

The purpose of these cookies is to:

- Measure the number of users of the services, thus making them easier to use and to ensure their ability to respond quickly to requests,

- Analyze the data to enable Delta Grant Thornton to understand how users interact with the services in order to improve them,

If you refuse the use of certain cookies, we remind you that in this case you may not be able to take full advantage of a significant part of the functions of the http://www.granththornton.ga website.

12 - Security measures

Delta Grant Thornton takes all useful precautions, as well as appropriate technical and organizational measures, to preserve the security of your personal data and, in particular, to protect them against accidental or illicit destruction, accidental loss, alteration, unauthorized dissemination or access.

 13 - Link to other websites

The Delta Grant Thornton websites may provide links to third party websites as well as to all websites of members of the Grant Thornton International group.

Delta Grant Thornton has no control over the content of third party sites or the practices of these third parties with regard to the protection of Personal Data that they may collect.

Consequently, Delta Grant Thornton disclaims any responsibility for the processing of your Personal Data by these third parties.

14 - Applicable law

This policy is governed and interpreted according to Gabonese law.

However, you can reset your browser so as to refuse any cookie or to alert you to when a cookie is being sent. Web browsers allow you to control cookies stored on your hard drive through the web browser settings. To find out more about cookies, including what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org.

We only use cookies to monitor the performance of our website and to improve user experience.

If you choose not to accept our cookies, some of the features of our site may not work as well as we intend.

Cookies used by the GTIL website

Cookie type	Cookie Name	Purpose
Google analytics	utma _utmb _utmc _utmz	These cookies are used to monitor the performance of our site. We use the information to help us improve the site. The cookies collect information in an anonymous form, including the number of visits to our site, where visitors have come from to the site and the pages they visited. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Youtube preferences	PREF use_hitbox VISITOR_INFO1_LIVE	We use YouTube to embed a selection of videos in our Thinking and campaign pages. The embedded videos do not set cookies themselves and can be played with no cookies set. However, if the 'Share' button is clicked YouTube will set cookies. The VISITOR_INFO1_LIVE cookie attempts to estimate your bandwidth and the use_hitbox and PREF cookies increment the 'views' counter on the YouTube video and stores session preferences. These cookies don’t gather information that identifies a user.
Twitter	guest_id	We embed a Twitter feed in our Thinking and campaign pages. This cookie is used to identify you to twitter. if you do not have a twitter account or never accessed the twitter.com website directly then twitter will assign you a unique code to track your visit to the Twitter feed.

How do we use your personal data?

We use your personal data to provide information to you or your organisation.

We may also use your personal data to carry out research about our visitors' demographics, interests and behaviour. We do this to better understand our visitors. This research is compiled and analysed on an aggregated and anonymous basis.

When you give us personal data, those data may be sent electronically to servers anywhere in the world and may be used, stored and processed anywhere in the world.

Whenever and wherever we collect, process or use personal data, we take steps to ensure that it is treated securely and in accordance with our privacy policy.

To whom might we disclose your personal data?

We may pass your personal data to anyone who needs the data in order to fulfil your request for our services, or process any payment. Some of these may be located outside the European Economic Area.

We may pass your personal data to Grant Thornton member firms or to our data processors.

Except as set out above, we will not disclose your personal information unless we are obliged to do so or allowed to do so, by law, or where we need to do so in order to run our business (for instance where we outsource services or other people process data for us).

Direct Marketing

You may at any time request us to stop using your personal data for direct marketing purposes. If you wish to do this, please contact us.

Links

Our website contains links to Grant Thornton member and correspondent firm websites, but this privacy policy applies only to personal data collected via websites operated by GTIL which include www.gti.org , www.internationalbusinessreport.com and www.globaldynamismindex.com  and to how GTIL processes personal data. It does not apply to specific member or correspondent firms practising under the Grant Thornton name. We are not responsible for the privacy practices of these or other sites. We encourage our visitors to be aware when they leave our website, and to read the privacy policy of other sites that collect or use personal data.

Security

Unfortunately, no data transmission over the Internet or any other network can be guaranteed as 100% secure, but we take appropriate steps to try to protect the security of your personal data.

Contacts

This is the website of GTIL, a non-practicing, non-trading international umbrella organisation that does not deliver services. GTIL and its member firms are not a worldwide partnership.  GTIL and each member firm of GTIL is a separate legal entity.

If you want to request any information about your personal data, please contact us at our registered office.

Registered office address: Grant Thornton House, Melton Street, Euston Square, London NW1 2EP.

Inaccuracies and Corrections

We would like to keep your personal data accurate and up to date. If you become aware of any errors or inaccuracies please let us know by contacting us at our registered office.