Privacy Policy

Introduction

PwC is strongly committed to protecting personal data. This privacy statement describes why and how we collect and use personal data and provides information about individuals’ rights. It applies to personal data provided to us, both by individuals themselves or by others. We may use personal data provided to us for any of the purposes described in this privacy statement or as otherwise stated at the point of collection.

“PwC” (and “we”, “us”, or “our”) refers to any PricewaterhouseCoopers member firm in the Middle East and that: (1) is a contracting party for the purposes of providing or receiving services, (2) posted a position for which you are applying, or (3) you have a role or relationship with. Each member firm in the PwC network is a separate legal entity and a separate controller for personal data. Personal data is any information relating to an identified or identifiable living person. When “you” or “your” are used in this statement, we are referring to the relevant individual who is the subject of the personal data. PwC processes personal data for numerous purposes, and the means of collection, lawful basis of processing, use, disclosure, and retention periods for each purpose may differ.

When collecting and using personal data, our policy is to be transparent about why and how we process personal data. To find out more about our specific processing activities, please go to the relevant sections of this statement.

Security

We take the security of all the data we hold very seriously. The Network Information Security Policy Framework for the PwC network is aligned and compatible with financial services industry recognised security frameworks (e.g. ISO27002:2013) and best practices. An annual review of alignment and these processes is conducted as part of the governance procedure. We have a framework of policies, procedures and training in place covering data protection, confidentiality and security and regularly review the appropriateness of the measures we have in place to keep the data that we hold secure.

Collection of Personal Data

PwC collects personal data as part of the application process, including:

• Basic Card Information
  • First Name
  • Last Name
  • Company Name
  • Job Title
  • Job Function
  • Business Email
  • Phone Number
  • Work Location
• Inquiry Details
  • Information about the services the prospective client is interested in or requesting
• KYC Documentation
  • Commercial Registration
  • Trade License
  • Valid Passport Copy of UBO(s) / Controller(s)
  • National ID Card of UBO(s) / Controller(s)
  • Intermediary Ownership Documentation
  • Ownership Structure Chart with Percentages (signed/stamped)
  • Documents supporting UBO identification
  • Articles of Association (AoA) and Memorandum of Association (MoA)

How Data is Collected

• Through the “Contact Us” form completed by users
• When using OTP functionality to log in to the portal
• Via secure login and document upload processes

Use of Personal Data

Personal data collected from prospective clients through Bookkeeping Connect may be used for the following purposes:

• Responding to Inquiries
  • Information provided via the contact form is used to follow up on service requests and share details about relevant offerings.
• Providing Access to Bookkeeping Connect
  • Personal data is used to set up and manage user accounts, including onboarding and authentication.
• Issuing One-Time Passwords (OTP)
  • Email addresses are used to generate and deliver OTPs for secure, temporary access to the KYC portal.
• Facilitating Identity and Regulatory Compliance
  • KYC documents are processed to comply with applicable legal and regulatory requirements.
• Enabling Single Sign-On (SSO)

Our Legal Grounds for Processing Personal Data

The laws in some jurisdictions require us to set out the legal grounds on which we rely to process your personal information:

• The processing is necessary for compliance with a present or future legal or regulatory obligation to which we are subject (those concerning anti-terrorism, fraud, anti-money laundering and anti-corruption);
• The processing is necessary for performing a task in the public interest; and
• Where the above do not apply, the processing is necessary for the purposes of the legitimate interests of one or more firms of the PwC network (to take on clients, comply with law and carry out risk assessments) and which do not override the interests or fundamental rights and freedoms of the data subject.

When and How We Share Personal Data and Locations of Processing

We will only share personal data with others when we are legally permitted to do so. When we share data with others, we put contractual arrangements and security mechanisms in place as appropriate to protect the data and to comply with our data protection, confidentiality and security standards.

We are part of a global network of firms and in common with other professional service providers, we use third parties located in other countries to help us run our business. As a result, personal data may be transferred outside the countries where we and our clients are located. This includes countries that do not have laws that provide specific protection for personal data. We have taken steps to ensure all personal data is provided with adequate protection and that all transfers of personal data outside a specific jurisdiction are done lawfully. Where we transfer personal data outside a jurisdiction to a country not determined as providing an adequate level of protection for personal data, the transfers will be under an agreement which covers the relevant data protection requirements for the transfer of personal data outside the jurisdiction.

Personal data held by us may be transferred to:

• Other PwC member firms
  • For details of our member firm locations, please click here.
  • We may share personal data with other PwC member firms where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from PwC member firms in different territories).
  • We store personal data on our or other PwC member firm servers around the world such as the EU, Singapore and the USA. IT support and services are provided by PwC member firms in different territories.
• Third party organisations that provide applications/functionality, data processing or IT services to us

We are part of a global network of firms and in common with other professional service providers, we use third parties to help us run our business and these third parties may be located in other countries.

We do not provide third-party organizations with access to personal data in connection with this application.

Further details about other processors (such as IT service providers) used by PwC and locations of processing are captured on the ME Firm’s privacy statement.

Where the locations of processing are outside of a jurisdiction that imposes restrictions over transferring personal data (such as EEA, UK, DIFC, ADGM, Bahrain, Oman, KSA, Qatar and QFC), we have the approved standard contractual clauses in place to provide appropriate safeguards for personal data transferred outside to jurisdictions that do not provide an adequate level of protection for personal data.

• Auditors, insurers and professional advisers
  We may share personal data with our auditors and professional advisors such as lawyers.
• Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation
  Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.

Data Retention

We will retain your personal data for as long as is considered necessary for the purpose(s) for which it was collected (including as required by applicable law or regulation). Our baseline retention period is 2 years after the user completes the contact us form on Bookkeeping Connect.

Personal data may be held for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.

Changes to This Privacy Statement

We recognize that transparency is an ongoing responsibility, so we will keep this privacy statement under regular review. This privacy statement was last updated on 22 September 2025.

Data Controller and Contact Information

We are generally controllers for the personal data we process. If you have any questions about this privacy statement or how and why we process personal data, please contact us at: mer_me_data_protection_management@pwc.com

Individuals’ Rights and How to Exercise Them

Some local laws and regulations in the ME grant Individuals certain rights over their personal data and controllers are responsible for fulfilling these rights.

Individuals’ rights may include the right of access to personal data, to rectification of personal data, to erasure of personal data / right to be forgotten, to restrict processing of personal data, to object to processing of personal data, to data portability, the right to withdraw consent at any time (where processing is based on consent) and the right to lodge a complaint with a supervisory authority.

Contact Us

For any enquiries, or if you wish to exercise a legal right in relation to your personal data, or complain about our use of personal data, please send an email to mer_me_data_protection_management@pwc.com, or submit a request.