Introduction
“Citrin Cooperman” is the brand under which Citrin Cooperman & Company, LLP, a licensed independent CPA firm, and Citrin Cooperman Advisors LLC serve clients’ business needs. The two firms operate as separate legal entities in an alternative practice structure. Citrin Cooperman is an independent member of Moore North America, which is itself a regional member of Moore Global Network Limited (MGNL).
This Privacy Notice describes how Citrin Cooperman and more specifically Citrin Cooperman India LLP, collects, uses, shares, sells, discloses, retains, disposes of, and protects Personal Data when you interact with us as a job applicant, employee, contractor, event attendee, office visitor, third party (Data Fiduciary/Data Processor), or any other relevant individual, and describes the choices you have relating to your Personal Data and how to exercise such rights.
Applicability
This Privacy Notice applies to any Personal Data you provide to Citrin Cooperman and any Personal Data we collect during your employment, when you apply to a job posting, contact us, visit, or use our website, “www.citrincooperman.com” and all websites linked to this website, when you visit a Citrin Cooperman office, attend a Citrin Cooperman event or seminar. To use this site, you do not need to send us any Personal Data.
For purposes of this Privacy Notice, “Personal Data,” means any data about an individual who is identifiable by or in relation to such data as defined in, and governed by The Digital Personal Data Protection Act, 2023.
At Citrin Cooperman, we value your privacy and are committed to safeguarding your Personal Data as part of our ongoing dedication to providing a secure and transparent experience for our users. As a result, we are committed to keeping our Privacy Notice up to date, reflecting any changes in our Personal Data practices or the adoption of new privacy policies. Should you have any questions or concerns about our Privacy Notice or how we process your Personal Data, please do not hesitate to reach out to us.
Your Personal Data
We collect and use your Personal Data when you apply for a job to assess your suitability for job opportunities and provide you with personalized experiences. Additionally, we collect and use your Personal Data as an employee to manage the employment relationship including the distribution of benefits, communicate with you, improve the workplace, and protect the health and safety of our employees, and comply with legal and regulatory requirements.
We process your Personal Data for the following purposes:
- To comply with legal/regulatory requirements
- To operate and improve our business
- To manage our workforce and provide them with employment, training, compensation, or benefits
- To improve the security and performance of our website, network, systems, and services
- To protect against fraud and abuse
- To protect the safety and security of our employees and clients
- To operate and understand your use of our website
Type of Personal Data We Collect
We may collect and process the following types of Personal Data:
DATA CATEGORY (EMPLOYEES) |
EXAMPLE PERSONAL IDENTIFIERS |
PURPOSES FOR COLLECTION/USE |
| Authenticating Information |
Passwords, PIN, mother’s maiden name |
We collect and process your Authenticating Information for the following purposes:
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| Beneficiary Contact Information | Name of beneficiary contact, telephone number of beneficiary contact, address of beneficiary contact, relationship to individual |
We collect and process your Beneficiary Contact Information for the following purposes:
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| Background Check Information | Criminal history, criminal records, driving citations |
We collect and process your Background Check Information for the following purposes:
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| Children Information | Names of children, age or gender of children, birth date, address of children, activities associated with children |
We collect and process Clients’ Children Information only with the consent of a parent or guardian for the following purposes:
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| Contact Information | Name, postal address, phone number, mailing address, email address, physical location |
We collect and process your Contact Information for the following purposes:
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| Device Information | Device type and operating system, device unique identifier, IP address, audio, video, device fingerprints |
We collect and process your Device Information for the following purposes:
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| Education and Skills Information | Academic transcripts, educational degrees, education training and history, languages, letters of recommendation |
We collect and process your Education and Skills Information for the following purposes:
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| Employment Information | Benefits and entitlements data, company/entity, contract type, hours of work, job title, salary/wage, workers compensation claims, start date, end date, reason for termination, employee performance results, record of absence, time tracking, annual leave, office location, previous work history, grievances and complaints, health and safety-related information and reporting, job application details, disciplinary action, exit interview |
We collect and process your Employment Information for the following purposes:
|
| Emergency Contact Information | Name of emergency contact, contact information of emergency contact, relationship to individual, next of kin |
We collect and process your Emergency Contact Information to contact your emergency contact in an emergency. |
| Family Information |
Parent’s name, dependents, and other household information |
We collect and process your Family Information for the following purposes:
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| Financial Detail Information | Bank account information, bank statements, compensation data, and other financial-related details such as income, investments, benefits, tax status |
We collect and process your Financial Detail Information for the following purposes:
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| Government Identifier Information |
Driver’s license, national identification number, passport number, social security number, national identity card details |
We collect and process your Government Identifier Information for the following purposes:
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| Personal Detail Information |
Age, gender, date of birth, marital status, nationality, signature |
We collect and process your Personal Detail Information for the following purposes:
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| Personal Health Information |
Information related to medical payment, medical claims data, medical history, products, or equipment used, health plan beneficiary, medical treatment |
We collect and process your Personal Health Information for the following purposes:
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| Special Categories of Personal Data |
Genetic, biometric and health data, as well as Personal Data revealing racial and ethnic origin, political opinions, religious or ideological convictions or trade union membership. |
We collect and process your Special Categories of Personal Data for the following purposes:
|
| Travel and Expense Information |
Expense details, travel booking details, travel history |
We collect and process your Travel and Expense Information for the following purposes:
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| User Account Information |
Account age, account number, email address or username, account password |
We collect and process your User Account Information for the following purposes:
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| Workplace Welfare Information |
Bullying and harassment details |
We collect and process your Workplace Welfare Information for the following purposes:
|
DATA CATEGORY (CONTRACTORS) |
EXAMPLE PERSONAL IDENTIFIERS |
PURPOSES FOR COLLECTION/USE |
| Authenticating Information |
Passwords, PIN, mother’s maiden name |
We collect and process your Authenticating Information for the following purposes:
|
| Background Check Information | Criminal history, criminal records, driving citations |
We collect and process your Background Check Information for the following purposes:
|
| Contact Information | Name, postal address, phone number, mailing address, email address, physical location |
We collect and process your Contact Information for the following purposes:
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| Device Information | Device type and operating system, device unique identifier, IP address, audio, video, device fingerprints |
We collect and process your Device Information for the following purposes:
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| Emergency Contact Information | Name of emergency contact, contact information of emergency contact, relationship to individual, next of kin |
We collect and process your Emergency Contact Information to contact your emergency contact in an emergency. |
| Family Information |
Parent’s name, dependents, and other household information |
We collect and process your Family Information for the following purposes:
|
| Financial Detail Information | Bank account information, bank statements, compensation data, and other financial-related details such as income, investments, benefits, tax status |
We collect and process your Financial Detail Information for the following purposes:
|
| Government Identifier Information |
Driver’s license, national identification number, passport number, social security number, national identity card details |
We collect and process your Government Identifier Information for the following purposes:
|
| Personal Detail Information |
Age, gender, date of birth, marital status, nationality, signature |
We collect and process your Personal Detail Information for the following purposes:
|
| Personal Health Information |
Information related to medical payment, medical claims data, medical history, products, or equipment used, health plan beneficiary, medical treatment |
We collect and process your Personal Health Information for the following purposes:
|
| Professional Experience and Affiliation Information |
Professional memberships, qualifications, certifications |
We collect and process your Professional Experience and Affiliation Information for the following purposes:
|
| Referral Information | Name of referral, contact information of referral, relationship of referral |
We collect and process your Referral Information for the following purposes:
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| Special Categories of Personal Data |
Genetic, biometric and health data, as well as Personal Data revealing racial and ethnic origin, political opinions, religious or ideological convictions or trade union membership. |
We collect and process your Special Categories of Personal Data for the following purposes:
|
| Travel and Expense Information |
Expense details, travel booking details, travel history |
We collect and process your Travel and Expense Information for the following purposes:
|
| Workplace Welfare Information |
Bullying and harassment details |
We collect and process your Workplace Welfare Information for the following purposes:
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DATA CATEGORY (EVENT ATTENDEES) |
EXAMPLE PERSONAL IDENTIFIERS |
PURPOSES FOR COLLECTION/USE |
| Contact Information | Name, postal address, phone number, mailing address, email address, physical location |
We collect and process your Contact Information for the following purposes:
|
| Device Information | Device type and operating system, device unique identifier, IP address, audio, video, device fingerprints |
We collect and process your Device Information for the following purposes:
|
| Emergency Contact Information | Name of emergency contact, contact information of emergency contact, relationship to individual, next of kin |
We collect and process your Emergency Contact Information to contact your emergency contact in an emergency. |
| Family Information |
Parent’s name, dependents, and other household information |
We collect and process your Family Information for the following purposes:
|
| Government Identifier Information |
Driver’s license, national identification number, passport number, social security number, national identity card details |
We collect and process your Government Identifier Information for the following purposes:
|
| Personal Detail Information |
Age, gender, date of birth, marital status, nationality, signature |
We collect and process your Personal Detail Information for the following purposes:
|
| Personal Health Information |
Information related to medical payment, medical claims data, medical history, products, or equipment used, health plan beneficiary, medical treatment |
We collect and process your Personal Health Information for the following purposes:
|
| Professional Experience and Affiliation Information |
Professional memberships, qualifications, certifications |
We collect and process your Professional Experience and Affiliation Information for the following purposes:
|
| Social Media Information | Social media accounts, social media content, social media history, profile information, posts, connections, likes, shares, comments, interactions, behavioral data, technical data |
We collect and process your Social Media Information for the following purposes:
|
DATA CATEGORY (JOB APPLICANTS) |
EXAMPLE PERSONAL IDENTIFIERS |
PURPOSES FOR COLLECTION/USE |
| Background Check Information | Criminal history, criminal records, driving citations |
We collect and process your Background Check Information for the following purposes:
|
| Contact Information | Name, postal address, phone number, mailing address, email address, physical location |
We collect and process your Contact Information for the following purposes:
|
| Device Information | Device type and operating system, device unique identifier, IP address, audio, video, device fingerprints |
We collect and process your Device Information for the following purposes:
|
| Education and Skills Information | Academic transcripts, educational degrees, education training and history, languages, letters of recommendation |
We collect and process your Education and Skills Information for the following purposes:
|
| Employment Information | Benefits and entitlements data, company/entity, contract type, hours of work, job title, salary/wage, workers compensation claims, start date, end date, reason for termination, employee performance results, record of absence, time tracking, annual leave, office location, previous work history, grievances and complaints, health and safety-related information and reporting, job application details, disciplinary action, exit interview |
We collect and process your Employment Information for the following purposes:
|
| Emergency Contact Information | Name of emergency contact, contact information of emergency contact, relationship to individual, next of kin |
We collect and process your Emergency Contact Information to contact your emergency contact in an emergency. |
| Government Identifier Information |
Driver’s license, national identification number, passport number, social security number, national identity card details |
We collect and process your Government Identifier Information for the following purposes:
|
| Personal Detail Information |
Age, gender, date of birth, marital status, nationality, signature |
We collect and process your Personal Detail Information for the following purposes:
|
| Personal Health Information |
Information related to medical payment, medical claims data, medical history, products, or equipment used, health plan beneficiary, medical treatment |
We collect and process your Personal Health Information for the following purposes:
|
| Professional Experience and Affiliation Information |
Professional memberships, qualifications, certifications |
We collect and process your Professional Experience and Affiliation Information for the following purposes:
|
| Referral Information |
Name of referral, contact information of referral, relationship of referral |
We collect and process your Referral Information for the following purposes:
|
| Special Categories of Personal Data |
Genetic, biometric and health data, as well as Personal Data revealing racial and ethnic origin, political opinions, religious or ideological convictions or trade union membership. |
We collect and process your Special Categories of Personal Data for the following purposes:
|
DATA CATEGORY (OFFICE VISITORS) |
EXAMPLE PERSONAL IDENTIFIERS |
PURPOSES FOR COLLECTION/USE |
| Contact Information | Name, postal address, phone number, mailing address, email address, physical location |
We collect and process your Contact Information for the following purposes:
|
| Device Information | Device type and operating system, device unique identifier, IP address, audio, video, device fingerprints |
We collect and process your Device Information for the following purposes:
|
| Emergency Contact Information | Name of emergency contact, contact information of emergency contact, relationship to individual, next of kin |
We collect and process your Emergency Contact Information to contact your emergency contact in an emergency. |
| Government Identifier Information |
Driver’s license, national identification number, passport number, social security number, national identity card details |
We collect and process your Government Identifier Information for the following purposes:
|
| Personal Detail Information |
Age, gender, date of birth, marital status, nationality, signature |
We collect and process your Personal Detail Information for the following purposes:
|
| Personal Health Information |
Information related to medical payment, medical claims data, medical history, products, or equipment used, health plan beneficiary, medical treatment |
We collect and process your Personal Health Information for the following purposes:
|
DATA CATEGORY (THIRD PARTIES) |
EXAMPLE PERSONAL IDENTIFIERS |
PURPOSES FOR COLLECTION/USE |
| Contact Information | Name, postal address, phone number, mailing address, email address, physical location |
We collect and process your Contact Information for the following purposes:
|
| Device Information | Device type and operating system, device unique identifier, IP address, audio, video, device fingerprints |
We collect and process your Device Information for the following purposes:
|
| Emergency Contact Information | Name of emergency contact, contact information of emergency contact, relationship to individual, next of kin |
We collect and process your Emergency Contact Information to contact your emergency contact in an emergency. |
| Financial Detail Information | Bank account information, bank statements, compensation data, and other financial-related details such as income, investments, benefits, tax status |
We collect and process your Financial Detail Information for the following purposes:
|
| Government Identifier Information |
Driver’s license, national identification number, passport number, social security number, national identity card details |
We collect and process your Government Identifier Information for the following purposes:
|
| Personal Detail Information |
Age, gender, date of birth, marital status, nationality, signature |
We collect and process your Personal Detail Information for the following purposes:
|
| Personal Health Information |
Information related to medical payment, medical claims data, medical history, products, or equipment used, health plan beneficiary, medical treatment |
We collect and process your Personal Health Information for the following purposes:
|
| Referral Information |
Name of referral, contact information of referral, relationship of referral |
We collect and process your Referral Information for the following purposes:
|
| Special Categories of Personal Data |
Genetic, biometric and health data, as well as Personal Data revealing racial and ethnic origin, political opinions, religious or ideological convictions or trade union membership. |
We collect and process your Special Categories of Personal Data for the following purposes:
|
| Workplace Welfare Information |
Bullying and harassment details |
We collect and process your Workplace Welfare Information for the following purposes:
|
DATA CATEGORY (WEBSITE USERS) |
EXAMPLE PERSONAL IDENTIFIERS |
PURPOSES FOR COLLECTION/USE |
| Browsing Information | Browsing time, cookie information, IP address, web beacons, device fingerprinting, imprecise geolocation information, web browsing history, search history, clickstream data, social media activity, ad tracking data, pixels, device unique identifier, browser type and settings, application usage data |
We collect and process your Browsing Information for the following purposes:
|
| Contact Information | Name, postal address, phone number, mailing address, email address, physical location |
We collect and process your Contact Information for the following purposes:
|
| Device Information | Device type and operating system, device unique identifier, IP address, audio, video, device fingerprints |
We collect and process your Device Information for the following purposes:
|
| Social Media Information | Social media accounts, social media content, social media history, profile information, posts, connections, likes, shares, comments, interactions, behavioral data, technical data |
We collect and process your Social Media Information for the following purposes:
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Categories of Data Fiduciaries and/or Data Processors to Whom Personal Data Is Potentially Disclosed
We may need to disclose your Personal Data in certain circumstances as outlined below to carry out our business. We take your privacy seriously and will only disclose your Personal Data when it is necessary to do so. Furthermore, we have put safeguards in place to protect your Personal Data and will only disclose your Personal Data to Data Fiduciaries and/or Data Processors who have agreed to protect it as well.
- Citrin Cooperman: Citrin Cooperman may disclose Personal Data from its original location in India to the United States, our Corporate Headquarters, for processing activities, such as for payroll management, employee benefits administration, and personnel record-keeping.
- Third-party suppliers, service providers, affiliates, and business partners: Citrin Cooperman may disclose Personal Data to third-party suppliers, service providers, affiliates, and business partners to assist us in meeting business operation needs and to deliver our services and functions.
- Vendors: Citrin Cooperman may disclose Personal Data to vendors who provide services to the firm, such as information technology services, cloud computing services, and data storage services. This is done to allow these vendors to perform their services effectively and efficiently.
- Investors: Citrin Cooperman may disclose Personal Data to investors to provide them with information about the firm's financial performance and operations. This disclosure is necessary for investors to make informed investment decisions.
- Regulators: Citrin Cooperman may disclose Personal Data to regulators to comply with legal and regulatory requirements. For example, Citrin Cooperman may be required to disclose Personal Data to the Securities and Exchange Commission in connection with an audit of a public company.
- Law enforcement: Citrin Cooperman may disclose Personal Data to law enforcement agencies if required to do so by law. For example, Citrin Cooperman may be required to disclose Personal Data to the Federal Bureau of Investigation in connection with an investigation of a financial crime.
Mergers and Acquisitions
In the event Citrin Cooperman goes through a business transition, such as a merger, or the acquisition or sale of all or a portion of its assets, your Personal Data may be among the assets transferred.
How We Protect and Store Your Personal Data
Citrin Cooperman takes the protection of Personal Data very seriously and has in place several safeguards to protect the confidentiality and security of Personal Data. These technical and organizational measures include:
- System-level restrictions for access to programs and data, such as appropriate password safeguards and secure sign-on mechanisms, such as dual authentication, are in place.
- Restricted access to programs and data safeguards, such as user provisioning, deprovisioning, and recertification controls, are in place.
- Role-based access to programs and data safeguards, including Privileged User Access controls, are in place.
- Data minimization safeguards, including restricting access to Personal Data to authorized individuals, are in place.
- Data quality safeguards are in place to ensure the integrity of data, prevent errors, and improve the efficiency of data processing.
- Encryption safeguards are in place to protect data in transit and at rest.
- Logging and monitoring controls are in place to protect the integrity of Personal Data.
Citrin Cooperman also has several policies and procedures in place to govern the collection, use, share, sale, disclose, retention and disposal processing of Personal Data. These policies and procedures are designed to ensure that Personal Data is processed, collected, used, and disclosed in a lawfully, fair, and transparent manner. How long we retain your Personal Data depends on the purposes for which it was obtained and its nature. We will keep your Personal Data for the period necessary to fulfill the purposes described in this Notice unless a longer retention period is permitted or required by law and in accordance with the Citrin Cooperman Record Retention Policy.
Retention
How long we retain your Personal Data depends on the purpose for which it was obtained and its nature. This includes complying with applicable legal requirements, including complying with the law, retaining records, resolving disputes, and enforcing our agreements. This storage retention period may extend beyond the term of your relationship with us. We will keep your Personal Data for the period necessary to fulfill the purposes described in this Notice unless a longer retention period is permitted or required by law and in accordance with the Citrin Cooperman Record Retention Policy.
Your Data Protection Rights
You may have certain rights over your Personal Data that enable you to control the use and processing of any of your Personal Data that we collect and use.
- Right to Know What Personal Data Is Being Collected/Right to Access Personal Data. You can ask us what Personal Data we collect about you and how we use it, upon verifiable request.
- Right to Recertification (Correction). You may have the right to request corrections of your Personal Data, upon verifiable request where it is inaccurate or out of date.
- Right to Be Forgotten (Right to Erasure). You may have the right under certain circumstances to have your Personal Data erased. You can request we delete Personal Data where you do not believe there is reason for us continuing to process it, or where you believe we collected or are using it unlawfully, where erasure is required by law or where you have withdrawn your consent, upon verifiable request. In certain cases, we may not be able to comply fully or at all with your correction request for legal reasons, and to the extent we are permitted to, we will notify you of the reasons.
- Right to Object to Direct Marketing. You have the right to object to the use of your Personal Data for direct marketing at any time. If you wish to modify your preferences in respect to marketing updates or notifications, or the mailing lists to which you subscribe, you can modify your preferences using this link. All commercial and marketing communications (e.g., notification emails and newsletters) include instructions for opting out of those communications.
- Right to Withdraw Consent. You have the right under certain circumstances, such as where we rely on your consent to process your Personal Data, to withdraw your consent. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, this may impact our ability to manage our employment relationship with you. We will advise you if this is the case when you withdraw your consent. In certain cases, such as for legal reasons, we may not be able to comply fully or at all with your request, and to the extent we are permitted to, we will notify you of the reasons.
Exercising Your Data Protection Rights
Only you, or someone you have legally nominated to act on your behalf, such as a registered Consent Manager, can make a verifiable consumer request related to your Personal Data. You, as a parent or lawful guardian, can also make a verifiable consumer request on behalf of your minor child. If you are making a request on behalf of someone else, we may ask for additional information to protect their Personal Data, such as proof that you are authorized to make the request. We will only use Personal Data provided in a verifiable request to verify the requestors’ identity or authority to make the request.
We cannot respond to your request or provide you with your Personal Data if we cannot verify your identity or authority to make the request, or if we cannot confirm that the Personal Data relates to you or your minor child. We may also be unable to comply with your request if we have a legal or regulatory obligation to keep your Personal Data, such as when the Personal Data is necessary to fulfill our employment relationship with you or complete a transaction. Other reasons your request may be denied are if it jeopardizes the privacy of others.
Your request must:
- Provide enough information so that we can reasonably verify that you are the person whose Personal Data we collected or received from an authorized representative.
- Describe your request in enough detail so that we can understand, evaluate, and respond to it.
To the extent any of the above rights are applicable and you would like to exercise your rights, please leverage our Data Subject Access Request Form, or contact us by email at privacy@citrincooperman.com, or by phone at (888) 450-2221.
How to Complain
If you have any concerns about our use of your Personal Data, you can make a complaint to us by email at privacy@citrincooperman.com, or by phone at (888) 450-2221.
Changes to This Notice
We may update this Statement occasionally. When we do, we will post the current version on this site, and we will revise the version date located at the top of this page. We encourage you to periodically review this Notice so that you will be aware of our privacy practices.
GET IN TOUCH
Our Contact Details
If you have any questions about our privacy practices, how we use your Personal Data, your choices, and rights, or would like to exercise your rights, please contact us.
|
CITRIN COOPERMAN Attn: Privacy Office 50 Rockefeller Plaza New York, New York 10020, USA |
TOLL FREE TELEPHONE: 888-450-2221 |
EMAIL: privacy@citrincooperman.com |
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