Moodys Private Client LLP has developed their website at moodystax.com (the “Website”) and the Moodys Tax Law App (together referred to as the “Web Services”) as electronic resources with information about our services and the services of our affiliated entities, Moodys US and Moodys LLP, and other information, resources and tools in the field of tax.
What Information We Collect From You
In General. We receive and store any information you enter into our Web Services or give us in any other way. This includes information that can identify you or that can be identified as being about you (“Personal Information”) including your name, phone number, and postal and email addresses.
Information Automatically Collected. Like many other organizations’ web services, ours automatically collects certain non-identifying information regarding website users, such as the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access web pages in our Web Services, the Internet address of the website from which you linked directly to our Web Services, the operating system you are using, and pages of our Web Services you visit. This non-identifying information is used for our Web Services and system administration purposes and to improve the Web Services. Your non-identifying information may be used and permanently archived for future use in order to facilitate your online experience and to gather broad demographic information.
We make no attempt to link this information with the identity of individuals using our Web Services. We may, however, review server logs for security purposes, for example to detect intrusions into our network. The possibility therefore exists that server log data, which contains visitors’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, raw data logs would be shared with appropriate investigative bodies authorized to investigate such breaches of security.
Cookies. Our Web Services use “cookies”, a technology that installs information on a website user’s computer to permit the website to recognize future visits using that computer. Cookies enhance the convenience and use of a website. You may choose to decline cookies if your browser permits but doing so may affect your use of our Web Services and your ability to access certain features of our Web Services.
How We Use Your Information
When you contact us through our Web Services, we collect and use the Personal Information you voluntarily provide to us for the following purposes:
- to respond to your requests for information and services
- to deliver requested services and answer your enquiries
- to process and deliver products that you have ordered from us
- to register you for events and conferences
- to develop and maintain our relationship with you and communicate with you
- to invoice and collect payment for professional services and products provided by us to you
- to contact you regarding your submissions
- to provide a subscription to our newsletter when requested
- to meet any legal or regulatory requirements
- analysis for management purposes
With your consent, your contact information may also be used to provide you further information about our products and services, and otherwise as required or permitted by law. At any time you may ask us to stop sending you newsletters, literature and other information by contacting us at firstname.lastname@example.org.
With Whom We Share Your Personal Information
As a general rule the personal information we collect from those who use our Web Services is held in strict confidence and, except in limited circumstances as permitted or required by law, is not disclosed to third parties without your consent, express or implied.
We may share your personal information with third party vendors who provide services or functions on our behalf. We may also authorize third party vendors to collect information on our behalf, including as necessary to operate features of our Web Services. Third party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purposes.
With your consent your personal information may be shared between Moodys Private Client LLP, Moodys Tax for the purposes set out above.
Your Choices With Respect to the Collection and Use of Your Personal Information
As discussed above, you can choose not to provide us with any information, although it may be needed to take advantage of certain features offered on our Web Services.
You may choose not to accept automatic location tracking in the App at any time by selecting Manual Mode in the Day Counter feature in the App. In any event, this location information is not communicated by the App to us.
If you provide your consent to receive electronic or other communications, you may withdraw your consent at any time.
Please keep in mind that if you directly disclose personally identifying information through the Web Services’ forums, blogs, message boards and other public communication services, this information may be collected and used by others and we are not responsible for those uses.
Third Party Sites and Services
Our Web Services may contain optional links to partners and third-party Internet sites and services that may collect data from you or your computer. Please be aware that if you choose to leave our site via a link, we assume no responsibility for the privacy practices or the content of other websites or services.
Handling Enquiries and Complaints
If you have any comments or questions about our privacy practices at our Web Services, please contact our Privacy Officer at:
Moodys Private Client LLP
Suite 210‑2020 4th Street SW
Calgary, AB T2S 1W3
Client Data Privacy Notice
This is an overview of how Moodys Private Client LLP (2020 4 St SW #210, Calgary, AB T2S 1W3 | (587) 393-1166 (also “we”, “us”, “our”) processes personal information of our clients (“you”, “your”) and their rights in this regard. We take data protection very seriously as in today’s information society, the compliant collection, handling and disclosure of personal information is crucial to business success. With this Client Data Privacy Notice (“Privacy Notice”) we inform you on our principles of handling your personal information.
- What Personal Information We Collect From You
We may collect and process the following categories of personal information about you, whether such personal information is provided by you or by a third party, as set out in Section 3 below.
- Identification information ► including your first name, middle names, maiden name, last name, marital status, title, gender, date of birth, passport number, driving licence number, social insurance number;
- Contact information ► including your billing address, telephone number(s) and email address;
- Financialinformation ► including your bank account and payment card details;
- Service information ► including details about client services you receive from us and your feedback.
In limited circumstances, we may also collect sensitive personal information about you, for example, where required to do so for legal or regulatory purposes or where you have provided us with such personal information as it is necessary for a specific service we are providing to you and to the extent permitted by applicable privacy laws.
- Why and For What Purpose We Collect and Process Your Personal Information
We may process your personal information in the following way. For each use, we note the grounds we justify each use of your personal information.
- To provide our tax and other client services to you and to conduct our business► to administer and perform our services, including to carry out our obligations arising from any agreements entered into between you and us. Legal grounds: contract performance, consent (where sensitive personal information is processed).
- For marketing purposes► to provide you with details of new services, legal updates and invites to events where you have chosen to receive these. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out at the beginning of this Privacy Notice or in Section 9 below. Legal grounds:legitimate interests (to promote our client services), consent (where required, e.g. for sending electronic messages).
- For research and business development purposes► analysis in order to better understand your and our clients’ services and marketing requirements and to better understand our business and develop our services and offerings. Legal grounds: legitimate interests (to allow us to improve our client services and to identify ways to grow our business).
- To fulfil our legal or regulatory obligations► to comply with our legal obligations (performing client due diligence, anti-money laundering, anti-bribery, sanctions screening, identifying conflicts of interests) and for the prevention of fraud and/or other relevant background checks as may be required by applicable law. Legal grounds: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities).
- Where We Collect Your Personal Information From
We may obtain your personal information from you or from third parties such as governmental or regulatory bodies or other authorities, sanctions and politically exposed person screening lists and public registers, etc.
- With Whom We Share Your Personal Information
We are bound by professional secrecy obligations and generally do not share your personal information with third parties unless we received your consent.
- Do We Transfer Your Personal Information to Third Countries
We don’t transfer your personal information to third countries that are not deemed to ensure adequate level of protection. Your personal information is stored in a database in Canada.
- Storage Limits
We keep records of your personal information for no longer than is necessary for the purpose for which we obtained them and any other permitted linked purposes. This includes for example the purposes of satisfying any legal, regulatory, accounting, reporting requirements, to carry out legal work, for the establishment or defence of legal claims. If personal information is used for two purposes, we will retain it until the purpose with the latest period expires, but we will stop using it for the purpose with a shorter period one that period expires.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and privacy laws.
- Updating Your Personal Information
We will use reasonable endeavours to ensure that your personal information is accurate. In order to assist us with this, you should notify us of any changes to your personal information that you have provided to us by contacting us using the contact details set out at the beginning of this Privacy Notice or in Section 9 below.
- Your Rights With Respect to the Collection and Use of Your Personal Information
If you are situated in the EU, you have certain rights in relation to your personal information. Please be aware that certain exceptions apply to the exercise of these rights and so you will not be able to exercise these in all situations. In addition, these will vary in different EU member states.
- Subject Access: You have a right to be provided with access to any personal information held about you by us generally within one (1) month of your request.
- Rectification: You can ask us to have inaccurate personal information amended.
- Erasure: You can ask us to erase personal information in certain circumstances and we will take reasonable steps to inform other controllers that are processing the personal information that you have requested the erasure of any links to, copies or replication of it.
- Withdrawal of consent: You can withdraw any consents to processing that you have given us and prevent further processing if there is no other ground under which we can process your personal information.
- Restriction: You can require certain personal information to be marked as restricted whilst complaints are resolved and also restrict processing in certain other circumstances.
- Portability: You can ask us to transmit the personal information that you have provided to us and we still hold about you to a third party electronically.
- Raise a complaint: You can raise a complaint about our processing with the data protection regulator in your jurisdiction.
- Objection against processing of Personal Information: You have a right to object to processing being carried out by us if (a) we are processing personal information based on legitimate interests or for the performance of a task in the public interest (including profiling), (b) if we are using personal information for direct marketing purposes, or (c) if personal information is being processed for scientific or historical research or statistical purposes. You will be informed that you have a right to object at the point of data collection and the right to object will be explicitly brought to your attention and be presented clearly and separately from any other information.
- Handling Enquiries and Complaints
If you have any questions about this Privacy Notice, including any requests to exercise your rights, please contact our Privacy Officer using the contact details set out below:
Moodys Private Client LLP
Suite 210‑2020 4th Street SW
Calgary, AB T2S 1W3