Latest News
12.2.2020EisnerAmper Cayman Affiliate EA Governance Offers Governance Services
The Cayman Islands recently enacted legislative changes (which EisnerAmper previously reported on) to enhance
Last Revised date: 30 September 2019
Scope
EisnerAmper Cayman Ltd. (hereafter referred to as “EAC”) is committed to protecting your privacy and safeguarding your personal business and financial information. As part of EAC’s continuing commitment to data protection we have adopted this Privacy Policy to inform you about the types of Personal Data, as defined below, that EAC collects, uses, maintains and discloses and the choices you have regarding such collection, use, maintenance and disclosure and how you may correct any inaccuracies that may arise from time to time.
This Privacy Policy applies to all visitors to the EAC website located at www.eisneramper.ky and to all information submitted to EAC for use with or in connection with this website. By providing your personal information to us on our website you consent to the collection and use of that information in accordance with this Privacy Policy.
This Privacy Policy details how EAC collects, uses, discloses, retains and secures your Personal Data (defined below) as part of its business practices. The purpose of this policy is to clearly articulate the legal justifications for the processing of any Personal Data received and to inform you of your data subject rights under the Cayman Islands’ Data Protection Law, 2017 (“DPL”), any associated Regulations (as may be amended from time to time).
This Privacy Policy shall apply in the event that you decide to provide any Personal Data to EAC.
This Privacy Policy is current as of the “Last Revised” date which appears at the top of this page. EAC may make amendments from time to time without giving notice. Please be careful to review this Privacy Policy each time you visit our website to remain informed of any amendments.
Overview
EAC respects your fundamental right to privacy and entitlement to have all Personal Data processed in accordance with the DPL. EAC applies the following eight data protection principles enshrined in the DPL whenever any Personal Data is being processed:
What is Personal Data?
“Personal data” comprises any information relating to an identified or identifiable natural person being any person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, address or other location data, any online identifier or any one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (e.g. age, gender, marital status, health information, mailing address, telephone numbers, email address, financial information, credit or debit card information or credit history. Personal information excludes any business titles, business addresses or business telephone numbers in your capacity as an employee.
What Personal Data does EAC collect?
EAC collects various Personal Data which may include the following (this list is not exhaustive):
Such information may be provided on our webpage, in an application form, face to face, by telephone, by email, by engagement letter or otherwise.
How do we collect your Personal Data?
We only obtain Personal Data directly from you, or indirectly from third party sources as permitted by applicable laws. At times you may voluntarily choose to provide EAC with unsolicited Personal Data through EAC’s website. Where such information is provided to us for any reason, in so doing you consent to EAC using that information in any manner described in this Privacy Policy or as may be alternatively specifically described at point of such disclosure being made.
In the event of any unsolicited information being provided to EAC we request that no sensitive Personal Data (e.g. personal details revealing racial or ethnic origin, political opinions, religious or other beliefs of a similar nature, philosophical beliefs, genetic data, health information, trade union membership, legal proceedings or health information) be provided unless you provide us with unambiguous consent to collect this information from you.
With respect to our website. EAC may use cookies (i.e. small text files that are stored in your web browser that allows EAC or a third party to recognize you). Cookies can be used to collect store and share certain information about your activities across websites, including on EAC’s website. Please carefully review our Cookies Policy which can be accessed directly at https://eisneramper.ky/index.php/cookies-policy/, or alternatively through our webpage if for any reason this direct link is not successful.
Use of Personal Data
EAC generally uses Personal Data for the following purposes:
Whenever and however EAC collects, processes or uses Personal Data it takes all reasonable steps to ensure it is treated securely and in accordance with this Privacy Policy (as may be amended from time to time). We identify the purposes for which we use any Personal Data at the time we seek to collect such information, and obtain your informed, freely granted and unambiguous consent prior to each specific use. Whenever you provide us with your consent to use your Personal Data, such consent shall include all processing activities carried out for the same purpose or purposes. In the event that use of your Personal Data has multiple purposes, EAC will seek your consent for each separate purpose for which such Personal Data will be used.
Legal basis for processing your Personal Data
The DPL sets out certain different reasons for which a company may process Personal Data, and EAC does so under the following legal conditions:
Where does EAC store your Personal Data?
Personal Data received by EAC is primarily stored on servers maintained by EAC or its EisnerAmper network of associated firms. However, except as restricted by contractual or legal requirements applicable to specific clients, EAC may also utilize the services of selected third party service providers from time to time. EAC takes appropriate measures for the protection of any Personal Data handled by any retained service providers.
How does EAC secure your Personal Data?
The only employees who are granted access to your Personal Data are those with a business “need-to-know” or whose duties or employment responsibilities reasonably require such information.
EAC employs appropriate physical, technical, organizational and contractual measures to protect your Personal Data against loss, theft, unauthorized processing, destruction, damage, inappropriate copying, use or modification in accordance with its information technology policies.
When does EAC disclose Personal Data?
EAC identifies to whom, and for what purposes it may disclose any Personal Data at the time of collection. EAC may disclose your Personal Data in the following circumstances (this list is not exhaustive):
EAC may also make disclosure of Personal Data to a potential acquirer in connection with a transaction involving the potential sale or acquisition or some or all of EAC or a related EisnerAmper Global affiliate member firm, or as otherwise permitted by law, in which case the use of your Personal Data by the new entity would continue to be limited by applicable laws.
How long does EAC retain your Personal Data?
The retention period for holding of Personal Data will vary and be determined by criteria including the purposes for its use and retention periods prescribed by law and other legal obligations.
Direct Marketing
You may contact us directly at any time to make a request to EAC to stop using your Personal Data for direct marketing purposes.
Inaccuracies and Corrections
EAC endeavors to keep your personal data as accurate and up to date as possible. Should you become aware of any errors or inaccuracies in your Personal Data provided or retained by us please notify us by contacting us directly at our registered office address.
International transfer of Personal Data
Your personal data is stored in the Cayman Islands unless it is transferred to another country for contractual purposes. Any Personal Data transferred to other countries may be subject to laws, regulations and lawful disclosure requirements of the jurisdiction(s) where such information may ultimately be stored. If at any time EAC transfers Personal Data outside the Cayman Islands, it will take all reasonable measures to ensure that, as a minimum there are adequate safeguards in place regarding the rights and freedoms of each relevant data subjects as provided for under the DPL.
What rights do you have in respect to your Personal Data?
Individuals have a right to be informed how your Personal Data is processed and this privacy notice fulfills EAC’s obligation in that respect.
The DPL also gives individuals statutory rights to:
Any questions or concerns not addressed in this notice, you may contact Ben Leung at bleung@eisneramper.ky or if you are not satisfied with any responses provided to any access requests made you may contact the Ombudsman (see contact details further below).
How quickly shall we respond to your written requests?
Unless we advise to the contrary, we shall respond to written requests not later than 30 days after receipt of any written requests. We shall advise if for any reason we are unable to meet your requests within this timeframe (e.g. where a large amount of Personal Data is requested or required to be searched through and meeting the timelines would unreasonably interfere with EAC’s day-to-day business operations; (b) where more time may be required to consult with any relevant third party prior to EAC being able to decide whether or not to provide access to the requested Personal Data; or (c) you provide consent to an extension of the 30 day timeframe. You have the right to make a complaint to the Ombudsman (see contact details below) in respect of this time limit should you choose to do so.
We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Data. Any such identifying confirmation shall be used only for that purpose.
Are there costs to you for requesting access to your Personal Data?
We will in many instances be able to provide you with your requested Personal Data information free of charge except where any request made is determined to be manifestly unfounded or excessive because the request is (a) repetitive; (b) fraudulent in nature; or would divert EAC’s resources unreasonably. In the event of (a) (b) or (c) arising EAC may charge such fee as covers the cost of providing the requested data and information or may refuse to act on the request and provide reasons for so doing.
The Ombudsman Contact Details
Should you wish to exercise any of your data protection rights and entitlements above you may contact Ben Leung at bleung@eisneramper.ky.
Should you feel that your personal data has not been handled correctly, or you are not satisfied with any responses received to any requests you have made regarding the use of your Personal Data, you have a statutory entitlement under section 43 of the DPL to complain to the Cayman Islands’ Ombudsman. The Ombudsman can be contacted by calling: 1-345-946-6283 or by email at info@ombudsman.ky.
Changes to this Privacy Notice
We may occasionally update this Privacy Notice to reflect changes to our practices and service offerings. Whenever we post any changes to this Privacy Notice we will revise the “Last Revised” date at the commencement of this Privacy Notice. Whenever we make any material changes to the manner in which we collect, use, and/or share Personal Data we will notify you by prominently posting notice of any such alterations on the website. We recommend you check this page from time to time to inform yourself of any changes in this Privacy Notice.
195 global partners
advising greater than
200 public companies
Best Audit Service
Institutional Investors'
Alpha Awards 2015
Best Tax Service
Institutional Investors'
Alpha Awards 2015
Best Client Service
Institutional Investors'
Alpha Awards 2015
Hedge Fund Experience
Institutional Investors'
Alpha Awards 2015
Regulatory & Compliance
Institutional Investors'
Alpha Awards 2015
The Cayman Islands recently enacted legislative changes (which EisnerAmper previously reported on) to enhance
ASU 2018-13 significantly reduces disclosure requirements related to level 3 investments held