This policy is for residents of the European Union (EU), United Kingdom (UK), and Cayman Islands and supplements the information contained in our Privacy Policy and Client Data Privacy Notice (“Privacy Notice”) (together, “Privacy Statements”). This policy is adopted to comply with the European General Data Protection Regulation (GDPR), the United Kingdom General Data Protection Regulation (UK GDPR), as well as the Data Protection Law, 2017 (2021 revision) of the Cayman Islands (DPL). Capitalized terms shall have the same meaning as those designated in the Privacy Statements. For purposes of this policy, “Personal Information” shall include the GDPR’s definition of “Personal Data.” This policy explains how CohnReznick, and certain of its affiliates as applicable (“CohnReznick,” “we,” “us,” or “our”) collect, use, disclose and retain Personal Information and how consumers may exercise their rights under the GDPR, UK GDPR, and DPL. Note CohnReznick LLP and its affiliates are separate legal entities, and each entity is solely responsible for its own acts and/or omissions.

WHAT INFORMATION IS COLLECTED

CohnReznick’s data collection practices include the collection and use of Personal Information as described in the Privacy Statements and as set forth below. This policy applies to our data practices both online and offline.

Generally, CohnReznick collects the following categories of Personal Data: 

• Identifiers, including contact information and biographic information;
• Commercial information;
• Financial information; 
• Internet or other similar network, browsing, or search activity;
• Non-precise geolocation data;
• Professional or employment-related information; and 
• Special Category Data.

OUR PURPOSES FOR THE COLLECTION AND USE OF PERSONAL INFORMATION

We may collect Personal Information directly from Clients, users of our website, certain affiliates, business partners, agents, etc. Our collection and use of Personal Information is limited to the purposes of performing and improving services, supporting business operations and maintaining Client relationships, which may include the following: 

1. For execution of a Contract, to execute our rights or the rights of our service providers under a Contract, or enforce the terms and conditions arising under a Contract (e.g., performing services, maintaining the client relationship, keeping the client informed, invoicing and bill collection) or other agreement between the parties;
2. To perform client acceptance procedures, including verifying identities and addresses and performing other due diligence to protect our business interests and to determine eligibility for services; 
3. To comply with legal, tax, accounting, or regulatory obligations to which CohnReznick or a third party is subject, including complying with auditing standards;
4. To manage risk and operations, legal obligations, including ensuring internal compliance with our policies and procedures, to respond to regulatory and government oversight applicable to CohnReznick, and to investigation complaints or pursue and defend claims, proceedings, or disputes;
5. To protect the security and integrity of CohnReznick’s information technology systems;
6. To provide information about relevant services offered by CohnReznick, opportunities and experiences offered by CohnReznick;
7. To evaluate, develop and improve the quality of CohnReznick’s professionals and services or our website and for other related internal business purposes;
8. To seek professional advice, such as from professional advisors (including, but not limited to, legal counsel);
9. For recruitment and evaluation of qualifications for employment or internships;
10. For website related services, like analytics, insights, or customer support, quality and safety maintenance, or to develop new technological improvements; 
11. To evaluate or facilitate the sale or potential sale of all or part of CohnReznick or CohnReznick’s potential acquisition of other entities; 
12. For other purposes that are compatible with this Privacy Policy or where permitted by applicable law; and
13. As otherwise disclosed upon collection, or to the extent Client or a data subject provides other consent or authorization to the collection, use, disclosure and storage of Personal Information.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

To process your Personal Information, we must have a legal basis for doing so. We may process your Personal Information under the following conditions:

• Consent: You have given your consent for processing Personal Information for one or more specific purposes.
• Performance of a contract: The Personal Information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
• Legal obligations: Processing Personal Information is necessary for compliance with a legal obligation to which the CohnReznick is subject.
• Vital interests: Processing Personal Information is necessary in order to protect your vital interests or of another natural person.
• Public interests: Processing Personal Information is related to a task that is carried out in the public interest or in the exercise of official authority vested in CohnReznick.
• Legitimate interests: Processing Personal Information is necessary for the purposes of the legitimate interests pursued by CohnReznick.

DISCLOSURE OF PERSONAL INFORMATION

CohnReznick’s data disclosure practices are described in the Privacy Statements (defined above). Such disclosures may include transfers across borders (even in and to countries where the level of data protection may not be commensurate with the high standard of protection adopted by certain countries, such as the standard suggested by the EU General Data Protection Regulation). We will endeavor to ensure that such onward transfers are accomplished in accordance with all applicable laws.  

CohnReznick may also disclose your Personal Information to third parties, including, but not limited to: 

• our employees, certain affiliates, contractors, agents and third-party vendors to perform services related to your account, to offer our products and services, and for business operations;
• professional service providers for business operations; 
• information technology, software, and cloud providers, security providers, and similar services in connection with providing services and in the support of daily operations;
• service providers to support business operations, develop, operate, and maintain our website, and for marketing purposes;
• government agencies and regulators to fulfill legal obligations;
• a buyer or successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred or third parties in connection with CohnReznick’s acquisition of other entities; 
• to third parties for the purposes of fraud prevention and credit risk reduction (e.g., if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CohnReznick, our clients, or others);
• To enforce or apply any agreements, contracts between us, including for billing and collection purposes;
• law enforcement or government officials; or 
• any other entity disclosed by CohnReznick when you provide the information, or for which you provide consent.

If you wish to receive a list of third parties who process your Personal Information on our behalf, please contact us by any of the below methods for contacting CohnReznick.

Data Transfers outside of the European Economic Area (“EEA”) or United Kingdom (“UK”) 

If you are located in the EEA or UK, we have implemented secured transfer mechanisms, such as the standard contractual clauses, and, where applicable, additional technical, contractual and/or organizational measures to secure the transfer of your Personal Information to jurisdictions that the European Commission or Information Commissioner’s Office (ICO) does not consider to provide the same privacy protections as in the EU and UK. You can learn about these safeguards by contacting us at [email protected]. 

We are based in the United States of America. We may process, store, and transfer the Personal Information we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own. 

By submitting your Personal Information or engaging with our Websites, you consent to this transfer, storing, or processing.

PERSONAL INFORMATION RETENTION AND DELETION

CohnReznick retains Personal information as set forth in the Privacy Statements. (See, Retention of Personal Information). Generally, we retain Personal Information for as long as necessary purposes for which it was collected and for the purposes of satisfying any legal, accounting, contractual or reporting requirements. 

YOUR DATA PROTECTION RIGHTS

In certain circumstances, you have the following data protection rights with respect to the Personal Information that we collect and process:

• The Right to Request Access.  You have the right to access, update, or delete the information we have about you.
• The Right of Rectification.  You have the right to have any incomplete or inaccurate information we hold about you corrected. 
• The Right to Object.  You have the right to object to our processing of your Personal Information.
• The Right to Restrict Processing.  You have the right to request that we restrict the processing of your Personal Information.   
• The Right of Erasure.  In certain circumstances, you have the right to ask us to remove or delete your Personal Information.
• The Right to be Forgotten. You have the right to request that we delete your Personal Information, in certain situations. 
• The Right to Transfer.  Upon request we will provide you (or a third-party you have chosen) the Personal Information we have collected about you. Your Personal Information will be provided in a structured, commonly used, machine-readable format.  Please note that this right only applies to automated information which you initially provided consent for us to use or where we used the Personal Information to perform a contract with you.
• Withdraw Your Consent.  You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information. 

CohnReznick will comply with all such requests, to the extent it is a Controller of the data subject’s Personal Information, provided we do not have a legitimate business interest for processing such Personal Information or are not required to retain any such Personal Information pursuant to applicable law (e.g., if CohnReznick prepares a data subject’s U.S. tax returns, then CohnReznick is required to retain the data subject’s Personal Information and all backup information used to prepare the tax return in accordance with applicable law).

To the extent that CohnReznick is a Processor or if CohnReznick is a joint Controller of Personal Information on behalf of the Client, CohnReznick will provide to Client all information received from data subjects who have contacted CohnReznick to exercise any rights pursuant to the applicable Privacy Laws (including Articles 13 to 23 of the GDPR) and provide all reasonable assistance to Client in responding to data subject requests pursuant to such applicable Privacy Laws.  To the extent that CohnReznick is a sole Controller of Personal Information, CohnReznick will respond to data subject requests under the applicable Privacy Laws (including Chapter 3 of the GDPR).

EXERCISING YOUR RIGHTS 

You may exercise any of the rights enumerated above by contacting us at through any of our Contact methods outlined below.  Please note that we may ask you to verify your identity before responding to such requests.  We may require that you confirm your identity by providing a driver’s license, passport or other form of identification.    
You also have the right to complain to a Data Protection Authority about our collection and use of your Personal Information.  For more information, please contact your local data protection authority in the European Economic Area, United Kingdom, or Cayman Islands. 

CONTACT US

You acknowledge and consent to your Personal Information being collected, processed, stored, analyzed and disclosed as set forth in this privacy policy. If residents of the EU, UK and Cayman Islands have any requests, questions or complaints regarding the privacy of your Personal Information or have requested to exercise their rights under the applicable laws governing their Personal Information, they may submit a request or contact CohnReznick in one of the following ways:

- By email to: [email protected]

- By submission of a Privacy Request Web Form

- By telephone at: 1-8625-245-5031

- By written notice mailed to:

CohnReznick LLP
Attn: Legal Department
14 Sylvan Way
Parsippany, New Jersey 07054

UPDATES TO THIS POLICY

You are advised to review this policy periodically for any changes. We may update this policy from time to time as it may be revised due to legislative changes, changes in technology or our privacy practices or new uses of Personal Information not previously disclosed in this policy. We will notify you of any material changes and update the “Last Updated” date at the top of the policy. Changes to this policy are effective when they are posted on our website.  If you have any comments, concerns or questions about this policy, please contact us.