Privacy Policy

Introduction

GRANT THORNTON Antigua (“Grant Thornton” or “we”) is a professional services firm which provides assurance, tax, financial advisory, outsourcing, and consulting services to private and publicly-traded businesses, government organizations as well as to individuals (the “Services”). This Privacy Policy outlines our general policy and practices for protecting personal information that we collect through our Web site at http://www. grantthornton.ag (the “Site”) that we operate and in connection with the provision of the Services. This Privacy Policy explains the types of information we gather through our Site or through the delivery of our services, how we use that information, and the choices individuals may exercise regarding our use of, and their ability to correct, that information. By submitting personal information to us, you are consenting to use of your personal information (including any disclosures, processing, and transfers of your information to third parties by Grant Thornton) in accordance with this Privacy Policy. Any consent you provide is entirely voluntary. If you do not accept this Privacy Statement, then you should not submit any personal information to Grant Thornton through our Sites or Services.

Notice, Choice and Use

In order to use this Site, you do not need to send us any personal information. You may voluntarily provide us with personal information, such as your name and contact information, by subscribing to publications or by submitting requests through our “Contact Us” link. In addition, you may voluntarily provide us with personal information by registering for some of our events (e.g. webcasts, seminars and conferences) or to receive media alerts through our Site, or through the registration processes on our Site.

We may use the personal information you submit through the Site to respond to your requests (e.g. send you information about Grant Thornton’s services or events), send you administrative information or notices, send you information about our services, and for our internal business purposes.

We do not seek sensitive personal information on our Sites except where we are required to do so as part of the recruitment process. If you apply for job openings, we may use this information to process and evaluate your application for employment and to communicate with you about employment opportunities. We may also retain and use this information to identify and communicate with you about future potential employment opportunities with us. If we elect to make an offer of employment, this information may become part of the employee file and may be used for other employment and work-related purposes.

We retain personal information for only so long as necessary for the intended purpose, unless a longer retention period is required or permitted by law or other professional obligations (e.g. professional regulatory bodies).

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.

In certain cases in the future, as our Site expands, we may require visitors to register in order to obtain a user-id and password for authentication and secure access to a transaction or certain business confidential or proprietary information services on the Site.

Personally identifiable information provided to Grant Thornton through the Site is provided voluntarily by visitors. Should visitors subsequently choose to unsubscribe from mailing lists or any registrations, we will provide instructions on the Site area or in communications to our visitors; or a visitor may contact us at: privacy.questions@ag.gt.com.

Cookies and Similar Technologies

As is the case with many commercial Web sites, Grant Thornton automatically logs certain information about user access to the Site, which may include a user’s internet protocol (IP) address, browser type, internet service provider (ISP), 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.

Disclosures and Transfers

Grant Thornton will not disclose an individual’s personal information to third parties, except as set forth in this Privacy Policy, when we have the individual’s permission to make the disclosure, or as necessary to fulfill the purpose for which the information was submitted. We also may use or disclose personal information as we believe to be necessary or appropriate: (a) under applicable law (including to meet a national security or law enforcement requirement), (b) to comply with a legal process or professional standards, or (c) to protect our rights, privacy, safety or property and/or those of our affiliates or clients.

We may use third party service providers to provide services on our behalf who may have access to personal information. We require all such service providers to protect the information we entrust to them.

Grant Thornton may disclose and transfer personal information to service providers and to other member firms of Grant Thornton International Ltd. (“GTIL”) or within Grant Thornton, and this transfer may result in data passing from one jurisdiction to another, including to and from the United States of America and possibly other countries outside of the European Economic Area, some of which may not have been deemed by the European Commission to ensure an adequate level of protection for personal information. Because privacy laws vary from one jurisdiction to another, personal information may be transferred to a jurisdiction where the laws may differ from the laws in the jurisdiction in which the information originated.

Do not Track (DNT)

Grant Thornton does not track its users to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites may keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. Most popular browsers allow the user to activate a DNT signal to inform third parties (e.g. advertisers) that you do not want to be tracked.

Third-Party Sites

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any Web site or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us or by our affiliates.

Data Security

The security of your personal information is important to us. We seek to use reasonable physical (e.g. key card office entry, locking doors), technical (e.g. password protection, network firewalls, laptop encryption, authentication mechanisms), and administrative safeguards (e.g. confidentiality agreements, training, procedures that limit access to and use of data) 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.

Data Integrity

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. To the extent necessary for such purposes, we take reasonable steps to make sure that personal information is accurate, complete, current, and otherwise reliable with regard to its intended use.

Access and Correction

If an individual becomes aware that information we maintain about that individual is inaccurate, or if an individual would like to update or review his or her information, the individual may 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 privacy.questions@ag.gt.com.

In addition, if you are a resident of the European Union, you may have certain rights under European data protection law with respect to your personal information, including the right to request access to, correct, amend, delete, limit the use of, or withdraw your consent for the processing of your personal information. You also may have the right to receive a copy of your personal information in a commonly used and machine-readable format and to transmit such information to another controller.

To request deletion of, access to or to make changes to information, or to otherwise exercise any of your rights in this paragraph, please send us an email at privacy.questions@ag.gt.com. Grant Thornton will take steps to address your request to the extent consistent with and permitted by laws, regulations and professional standards applicable to Grant Thornton and our own internal policies. If you are a client and request that we delete or limit the use of your personal information required to perform our Services, we may not be able to complete our engagement.

Enforce and Dispute Resolution

We will investigate and attempt to resolve complaints and disputes regarding our use and disclosure of personal information in accordance with this Privacy Policy. We encourage interested persons to raise any concerns with us using the contact information below. Any employee who we determine is in violation of our privacy policies will be subject to disciplinary process.

Merger, Change in Ownership and Other Business Transitions

In the event Grant Thornton goes through a business transition, such as a merger, or the acquisition or sale of all or a portion of its assets, your personal information may be among the assets transferred.

Minors

Grant Thornton understands the importance of protecting children's privacy especially in an online environment. The Site covered by this Privacy Policy is not intentionally designed for or directed at children 13 years of age or younger. It is Grant Thornton’s policy never to knowingly collect or maintain information about anyone under the age of 13 other than when necessary for the processing of family Citizenship by Investment applications and with parental consent.

Privacy Policy Modifications

Grant Thornton reserves the right to modify or amend this Privacy Policy from time to time. We will post any revised Privacy Statement on this Site, or a similar Web site that replaces this Site. By continuing to use our Site, you agree that the terms of this Privacy Policy as of the effective date will apply to information previously collected or collected in the future as permitted by law.

How to Contact Us

Questions, comments or complaints about Grant Thornton’s Privacy Policy or data collection and processing practices can be e-mailed to: privacy.questions@ag.gt.com, or by writing to us using the contact details below:

Corporate Mailing Address:
Grant Thornton
Privacy Matters

P.O. Box 1531

11 Old Parham Road
St. John’s , ANTIGUA