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BCG PRIVACY STATEMENT AND POLICY

Privacy policy in German


INTRODUCTION



This is the Privacy Statement and Policy (“Privacy Statement”) for Boston
Consulting Group, Inc. and its affiliates ("BCG"). This Privacy Statement was
last updated in December 2022. For more detail on BCG's international operations
please see https://www.bcg.com/offices/default.

BCG understands that your privacy is important. BCG is committed to protecting
your privacy and personal information you provide or as you access and use
materials on BCG.com or other BCG websites (the "Site"), including the Site
subscription pages or other websites or apps that post a link to this Privacy
Statement. In addition, information that you submit to BCG in response to an
email request for information or other outreach from BCG, will be treated in
accordance with this Privacy Statement. If you are a California resident, please
see the California Addendum at the end of this Privacy Statement for further
details on how we handle your information and how to exercise your rights.

BCG may, in its discretion, amend this Privacy Statement from time to time. To
ensure you are able to remain informed about the information we collect and how
we use it, material changes to our statement will be reflected here. This Site
may contain links to external sites which are not governed by this Privacy
Statement. BCG does not take responsibility for the privacy practices of any
third-party sites to which we link. We encourage you to review the privacy
policies of any such sites before you submit information there.


YOUR ACCEPTANCE OF THIS PRIVACY STATEMENT



Please read this Privacy Statement carefully. By browsing the Site or expressly
consenting, where required under applicable privacy laws, you agree to be bound
by this Privacy Statement.


INFORMATION THAT WE COLLECT, AND HOW WE USE IT



What information do we collect?

 Account and Subscription

BCG collects information from you when you create your account for the Site,
request copies of publications, subscribe for email newsletters and press
releases, seek additional information regarding our services, and for marketing
communications (via emails, social media platforms) from BCG based on your
consent, where required under applicable privacy laws.

Personal information that we collect includes names, addresses, e-mail
addresses, phone numbers, IP, geo location, subject areas of interest and/or
demographic information.

If you do not provide such information, you may not be able to create an account
for the Site, request copies of publications, subscribe for email newsletters
and press releases, seek additional information regarding our services or
employment opportunities.

Surveys and events

BCG collects information if you register for conferences and other BCG-sponsored
events, and/or take part in surveys run by BCG.

Personal information that we collect includes names, e-mail addresses, IP,
unique personal identifiers, subject areas of interest and/or demographic
information.

In addition, we sometimes aggregate demographic information, and the types of
systems and browsers of users BCG also may conduct user surveys on the Web or
use technologies to provide BCG with information on a number of areas, such as
user identity, user viewing habits, whether or not users found what they were
searching for, whether the Site content is relevant to user needs, and the like.

How do we use personal information?

The purposes and uses of your personal information will depend on the use of the
Site and the personal information provided. We process your personal
information:


 * For the purposes of safeguarding the legitimate business interests pursued by
   BCG. This includes:
   
   * Communicate with you and manage your requests in relation to your account,
     subscriptions to BCG newsletters, publications, events and survey
     participations
   * Tailoring your experience at the Site with relevant BCG materials
   * Understanding the Site’s user population, identifying subject areas of
     interest, and determining whether the Site is designed to work with the
     computer settings of a majority of our visitors
   * Measuring and improving the effectiveness of BCG marketing programs across
     different channels
   * Improving our web content and navigation
   * Informing you about updates to the service and notifying you about other
     products and services offered by BCG that may be of interest to you,
     including information regarding publications and events and track email
     engagement activity for internal use only.1
 * On the basis of your consent where required under applicable privacy laws.
   Insofar as you have granted us consent to the processing of personal
   information for specific purposes, the lawfulness of such processing is based
   on your consent. You may withdraw your consent at any time.
 * For compliance with a legal obligation. This includes anti-fraud and
   anti-money laundering measures as well as tax and social security
   requirements.


AUTHENTICATION THROUGH OKTA



In order to use the Site, where applicable, you may need to authenticate with
the third-party provider Okta Inc. (301 Brannan St Ste 300, San Francisco, CA
94107) with your personal username and a personal password. To do this, you will
need to download the Okta Verify app and perform the authentication process. The
regulations and data protection declaration of Okta, Inc. apply. We have no
influence on and are not responsible for the data collection by Okta Inc. Your
data will be processed exclusively for the purpose of authentication. After
successful authentication you will receive personal access to our app.


HOW WE MIGHT SHARE YOUR INFORMATION



The third parties with whom we may need to share personal information to help us
provide services and products to you and to run our Site include:


 * Our subsidiaries or affiliates
 * Our advisors
 * Our third-party service providers who process information on our behalf to
   help run some of our internal business operations including email
   distribution, IT services, the Site security and marketing and events
   services
 * Our business partners for publications and events co-organized by BCG and
   them
 * Law enforcement bodies in order to comply with any legal obligation or court
   order
 * BCG may disclose your contact information in response to inquiries by
   bona-fide rights owners in connection with allegations of infringement of
   copyright or other proprietary rights arising from information that you have
   posted on the Site or otherwise provided to BCG

Because BCG is a global organization, we may need to transfer personal
information which is collected on the Site or through other means as described
under this Privacy Statement across the BCG group of companies
(http://www.bcg.com/about/offices/default) to help operate our business
efficiently. This also includes third parties located in different countries
around the world, including outside of the EEA, Switzerland, and the UK. These
arrangements may involve your personal information located in various countries
around the world BCG maintains and stores personal information in systems and
applications located in Europe as well as USA where privacy laws differ. The
personal information is only accessible by authorized persons or vendors who are
bound by privacy requirements, and we only make these arrangements or transfers
where we are satisfied that adequate levels of protection are in place to
protect information held in that country. In addition, the Site may be viewed
and accessed anywhere in the world including countries that may not have laws
regulating the use and transfer of personally identifiable information.


RETENTION OF YOUR PERSONAL INFORMATION

 
BCG retains your personal information for so long as is necessary to fulfil the
purpose for which it was collected. The criteria used to determine our retention
periods include:


 * The length of time we have an ongoing relationship with you and provide
   services to you (for example, for as long as you have an account with us or
   keep using our services) and the length of time thereafter during which we
   may have a legitimate need to reference your personal information to address
   issues that may arise
 * Whether there is a legal obligation to which we are subject (for example,
   certain laws require us to keep records of your transactions for a certain
   period of time before we can delete them); or
 * Whether retention is advisable in light of our legal position (such as in
   regard to applicable statutes of limitations, litigation or regulatory
   investigations)


MARKETING



In our marketing communications with you we monitor and comply with applicable
data privacy laws and if, at any time, you prefer not to receive further
communications from us in any or all forms you will have the ability to
unsubscribe from such communications by means of a link provided in every e-mail
that is sent to you by us. When subscribing to BCG e-mail newsletters, you are
given the opportunity to select which promotions, news, and information you
would like to receive at the time of sign up, and you will have the opportunity
to unsubscribe from such communications.


COOKIES AND OTHER TRACKING TECHNOLOGIES



BCG may use cookies on this Site and in our communications with you to keep
track of your visit to our Site and our communications with you. A “cookie” is a
small amount of data sent from a Web server to your browser and stored on your
computer’s hard drive. Other tracking technologies work similarly to cookies and
place a small amount of data on your devices to monitor your website activity to
allow us to collect information about how you use our Site and our services.
With most internet browsers, you can erase cookies from your computer hard
drive, block all cookies, or receive a warning before a cookie is stored on your
computer. Please refer to your browser instructions or you can visit
https://www.aboutcookies.org/ which will give you more information. Once you
have given your consent to use cookies, we shall store a cookie on your computer
or device to remember this for next time. If you wish to withdraw consent at any
time you will need to delete our cookies using your web browsers settings.
Please be advised that certain sections or functionalities of the Site may be
inaccessible to you if your browser does not accept cookies. We do not currently
respond to browser do-not-track signals.

To view a detailed list of cookies used on BCG.com, click here and for
connect.bcg.com click here.


SECURITY PROCESSES



BCG has in place appropriate technological and operational security processes
designed to protect personally identifiable information from loss, misuse,
alteration, or destruction. Only authorized employees and contractors will have
access to any data provided by you, and that access is limited by need. Each
employee or contractor having access to any personally identifiable information
is obligated to maintain its confidentiality. Although we take steps that are
generally accepted as industry standard to protect your personally identifiable
information, BCG cannot guarantee that your personally identifiable information
will not become accessible to unauthorized persons and BCG cannot be responsible
for any actions resulting from a breach of security when information is supplied
over the internet or any public computer network. To view security commitments
specific to BCG GAMMA products, click here.


LINKS TO OTHER WEB SITES



This Site contains links to other Web sites that are not operated by BCG.

BCG is not responsible for the privacy practices or the content of any non-BCG
web sites to which we link from the Site. We are not responsible for the
protection and privacy of any information you provide whilst visiting other
websites and sites not governed by our Privacy Statement. We cannot control the
content or security of such websites. We cannot be held responsible for any loss
or damage incurred by a user as a result of visiting such websites. No links are
intended to be, nor should be construed as, an endorsement of any kind by us of
that other website.


COMPLIANCE WITH LAW



BCG complies with all applicable data privacy laws. BCG may be compelled to
surrender personal user or customer information to legal authorities if
presented with a court subpoena or similar legal or administrative order, or as
required or permitted by the laws, rules and regulations of any nation, state or
other applicable jurisdiction. Also, in the event of a violation of the terms
and conditions of use of the Site or a violation of any restrictions on use of
materials provided in or through the Site, we may disclose personal user
information to our affected business partners or legal authorities.


YOUR RIGHTS



In accordance with applicable data privacy laws, including but not limited to
the GDPR and the California Consumer Privacy Act (CCPA), California Privacy
Rights Act (CPRA), you have a right to request a copy of the personal
information we hold about you and details of how we use that information. If any
of the information held about you is incorrect or out of date, you have the
right to amend or rectify it, please follow the process outlined below and we
will amend our records where appropriate. You also have the right to request
that we erase your personal information, stop processing your personal
information, restrict the processing of your personal information, and provide
your personal information in a portable format. Where processing is based on
your consent, you may withdraw your consent to processing. This may not apply if
there are other legal justifications to continue processing. If you think we may
have incorrect personal information, or would like a copy of the personal
information we hold on you, or to exercise any other data protection right,
please contact us. Please note that we need you to prove who you are before we
can provide you with any information.

You also have a right to lodge a complaint with a relevant supervisory
authority.


CHILDREN



BCG understands the importance of protecting children's privacy, particularly in
their online interactions. This Site is not designed for and does not
intentionally target or solicit to children 18 years of age and younger.


USE OF BCG WEB SITES



Your access to and use of the Site are subject to this Privacy Statement and
certain other terms and conditions, contained in our Terms and Conditions of
Use.


CONTACT US



For further questions you may contact the appropriate data protection point of
contact:

Data Protection Office
Boston Consulting Group Inc.
200 Pier Four Boulevard
Boston, MA 02210
Contact Us

Germany
Data Protection Officer (Der Datenschutzbeauftragte)
Boston Consulting Group GmbH
Ludwigstrasse 21
80539 Munich Germany
Contact Us


CALIFORNIA ADDENDUM



This California Addendum applies to California residents and supplements the
information provided above in the Privacy Statement. This Addendum does not
apply to our job applicants, employees, or contractors where the personal
information we collect about those individuals relates to their current, former,
or potential role with us.

Collection, Disclosure, and Sharing of Personal Information
The following list details which categories of personal information we collect
and process both online and offline, as well as which categories of personal
information we disclose to third parties for our operational business purposes,
including within the 12 months preceding the date this Privacy Statement was
last updated. The list also details the categories of personal information that
we “share” for purposes of cross-context behavioral advertising, including
within the preceding 12 months.


 * We may share the following information with ad networks for cross-context
   behavioral advertising:
   
   * Identifiers, such as IP address, and online identifiers
   * Geolocation data, such as approximate location derived from IP address
   * Internet or network activity information, such as browsing history of BCG
     sites, assets or prior visits, and interactions with our online properties
   * Inferences drawn from any of the personal information listed above to
     create a profile about, for example, an individual’s preferences or
     characteristics
 * We may share the following information with our affiliates and subsidiaries;
   third-party service providers; ad networks; external legal, financial, and
   other professional advisors; legal authorities for operational business
   purposes:
   
   * Identifiers, such as name IP address, and online identifiers, contact
     information, unique personal identifiers,
   * Internet or network activity information, such as browsing history of BCG
     sites, assets or prior visits, search history and interactions with our
     online properties
   * Geolocation Data, such as approximate location derived from IP address
   * Inferences drawn from any of the personal information listed above to
     create a profile about, for example, an individual’s preferences or
     characteristics or for statistics and visitor tracking
   * Browser fingerprint and IP address
   * Audio/Video Data. Audio, electronic, visual, and similar information
 * We may share your following information with our joint business partners for
   publications and co-organized events:
   
   * Identifiers such as name and contact information

We may also disclose your personal information to a third party in the event of
any reorganization, financing transaction, merger, sale, joint venture,
partnership, assignment, transfer, or other disposition of all or any portion of
our business, assets, or stock (including in connection with any bankruptcy or
similar proceedings).

We do not sell and have not sold personal information, including your sensitive
personal information, in the preceding 12 months. Without limiting the
foregoing, we do not sell the personal information, including the sensitive
personal information, of minors under 16 years of age.

Sources of Personal Information

We collect this personal information directly from you and from third-party
sources, such as public databases, joint marketing partners, and social media
platforms, where permitted under applicable local laws.

Purposes for the Collection, Use, or Sharing of Personal Information

We collect, use, or share personal information to operate, manage, and maintain
our business, to provide our products and services, and to accomplish our
business purposes and objectives, including to:


 * Develop, improve, operate repair, and maintain our products and services
 * Provide support and respond to requests for information
 * Advertise and market our products and services, and personalize user
   experiences
 * Conduct research, analytics, and data analysis
 * Operate and maintain our facilities and infrastructure
 * Undertake quality and safety assurance measures, and conduct security control
   and monitoring
 * Detect and prevent fraud and perform identity verification
 * Facilitate and implement any reorganization, financing transaction, merger,
   sale, joint venture, partnership, assignment, transfer, or other disposition
   of all or any portion of our business, assets, or stock (including in
   connection with any bankruptcy or similar proceedings)
 * Maintain records, comply with law, legal process, and internal policies, and
   exercise and defend legal claims.

Purposes for the Collection and Use of Sensitive Personal Information2

We may use sensitive personal information of account log-in, password, or
credentials allowing access to an account which qualify as sensitive personal
information for purposes of performing services for our business, providing
goods or services as requested by you, ensuring security and integrity, short
term transient use such as displaying first party, non-personalized advertising,
order processing and fulfilment, servicing accounts, providing service,
verifying client information, and activities relating to quality and safety
control or product improvement.

Individual Requests

You may, subject to applicable law, make the following requests:


 * You may request that we disclose to you the following information:
   
   * The categories of Personal Information we collected about you and the
     categories of sources from which we collected such personal information
   * The business or commercial purpose for collecting or sharing personal
     information about you
   * The categories of personal information about you that we shared (as defined
     under the applicable privacy law) and the categories of third parties to
     whom we shared such personal information; and
   * The categories of personal information about you that we otherwise
     disclosed, and the categories of third parties to whom we disclosed such
     personal information (where applicable)
 * You may request to correct inaccuracies in your personal information
 * You may request to have your personal information deleted
 * You may request to receive the specific pieces of your personal information,
   including a copy of the personal information you provided to us in a portable
   format
 * You may request to opt out of the “sharing” of your personal information for
   purposes of cross-context behavioral advertising

We will not unlawfully discriminate against you for exercising your rights under
applicable privacy law. To make a privacy request, contact us via
datasubjectrights@bcg.com or call 1-866-I-OPT-OUT (1-866-467-8688) and enter
service code 837# to leave us a message. We will verify and respond to your
request consistent with applicable law, taking into account the type and
sensitivity of the personal information subject to the request. We may need to
request additional personal information from you, such as copy of your driver’s
license, utility bill in order to verify your identity and protect against
fraudulent requests. If you make a request to delete, we may ask you to confirm
your request before we delete your Personal Information.

To request to opt out of any future sharing of your personal information for
purposes of cross-context behavioral advertising, click here.

Authorized Agents

If an agent would like to make a request on your behalf as permitted under
applicable law, the agent may use the submission methods noted in the section
entitled “Individual Requests.” As part of our verification process, we may
request that the agent provide, as applicable, proof concerning their status as
an authorized agent. In addition, we may require that you verify your identity
as described in the section entitled “Individual Requests” or confirm that you
provided the agent permission to submit the request.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain
and use the de-identified information only in a de-identified fashion and will
not attempt to re-identify the information.

1. Unless it is subject to your consent where required under applicable privacy
laws.

2. CPRA defines sensitive personal information as personal information that
reveals an individual’s social security , driver’s license, state identification
card, or passport number; account log-in, financial account, debit card, or
credit card number in combination with any required security or access code,
password, or credentials allowing access to an account; precise geolocation;
racial or ethnic origin, religious or philosophical beliefs, citizenship,
immigration status, or union membership; the contents of mail, email, and text
messages unless BCG is the intended recipient of the communication; genetic
data; The processing of biometric information for the purpose of uniquely
identifying an individual; Personal information collected and analyzed
concerning an individual’s health; and Personal information collected and
analyzed concerning an individual’s sex life or sexual orientation.





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