Effective Date: May 2017

Introduction Grant Thornton LLP (“Grant Thornton”) is a national professional services firm which provides assurance, tax, financial advisory, and consulting services to private and publicly-traded businesses as well as to individuals. This Privacy Statement outlines our general policy and practices for protecting personal information that we collect through our Web site at www.grantthornton.com and other Web sites (each, a “Site”) that we operate and which post this Privacy Statement. This Privacy Statement explains the types of information we gather through our Sites, 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 in accordance with this Privacy Statement.

Grant Thornton participates in the EU- U.S. Privacy Shield and Swiss-U.S. Privacy Shield programs administered by the U.S. Department of Commerce regarding our collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Grant Thornton’s participation in the Privacy Shield programs applies to our collection, use, and retention of any personal information transferred from the European Union, European Economic Area and Switzerland whether through our Sites or in connection with providing our services or operating and administering our business.  To learn more, please visit www.grantthornton.com/privacy-shield-notice.aspx.

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 on the “Log In” page or by submitting requests through our “Contact Us” mailboxes. 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 Sites, or through the registration processes on some of our Sites. If you choose to apply for job openings through our Sites, we may collect additional information such as name, address and other contact information, work and educational experience, licenses and certifications and other personal information.

We do not seek sensitive personal information on our Sites except where we are required to do so as part of the recruitment process. Your decision to submit such information is entirely voluntary.

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.

If you apply for job openings through our Sites, 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 our document retention policies.

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.

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 address, browser type, internet service provider, 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.

In addition, we use the services of Google Analytics, a web analytics service provided by Google, Inc. (“Google”). This analytical tool uses cookies and similar technologies to help analyze how users use the Sites. For more information about the collection and use of data through Google Analytics, please refer to https://www.google.com/policies/privacy/partners. Google offers the ability to opt out from tracking through Google Analytics cookies; for more information, visit http://tools.google.com/dlpage/gaoptout.

Do Not Track Signals Some Web browsers incorporate a "do-not-track" or similar feature that signals to Web sites with which the browser communicates that a visitor does not want to have his or her online activity tracked. As of the Effective Date of this policy, not all browsers offer a “do-not-track” option and “do-not-track” signals are not yet uniform. For this reason, Grant Thornton does not currently respond to “do-not-track” signals.

Disclosures and Transfers Grant Thornton will not disclose an individual's personal information to third parties, except as set forth in this Privacy Statement, 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 legal process or professional standards, (c) to protect our rights, privacy, safety or property and/or those of our affiliates or clients; or (d) in a merger, acquisition or asset sale.

Grant Thornton may use third-party service providers to provide administrative or operational support to Grant Thornton, or to provide engagement team resource services. Such entities may be located within or outside the United States. We require all such service providers to protect the information we entrust to them and to use such information only as necessary to provide services to us.

Additionally, Grant Thornton may disclose and transfer personal information to service providers and to other member firms of Grant Thornton International Ltd., 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. 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.

Third-Party Sites This Privacy Statement 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 webrequests@us.gt.com.

Enforcement 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 Statement. 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.

Privacy Statement Changes Grant Thornton reserves the right to amend or modify this Privacy Statement from time to time. We will post any revised Privacy Statement on this Site, or a similar Web site that replaces this Site.

Minors This Site is not designed for or directed at persons 18 years of age or younger, and we do not intentionally collect information from anyone under the age of 18 through this Site.

How to Contact Us Questions, comments or complaints about Grant Thornton LLP's Privacy Statement, Privacy Shield certification, or data collection and processing practices can be e-mailed to privacy.questions@us.gt.com.