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  Privacy and Cookie Policy | Brunswick Group
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PRIVACY AND COOKIE POLICY

Brunswick is an advisory firm specializing in business critical issues. We are
committed to safeguarding the privacy all those about whom we process personal
information including our employees, clients, journalists and visitors to our
websites. Please read the following Policy to understand how we will collect and
use your information and the rights you have in relation to your information.

References in this notice to "your information" are also to personal information
that you provide to us.

Applicability

This Policy applies to all entities in the Brunswick group of companies
globally.

Updates

Brunswick may modify this Policy from time to time to reflect our current
privacy practices. When we make changes to this Policy, we will revise its date.
We encourage you to periodically review this Policy to be informed about how
Brunswick is protecting your information.

By providing personal information to us (including through the use of our
websites), you acknowledge you have read this Policy, and, to the extent your
consent is necessary and valid under applicable law, you consent to the
collection, use and disclosure of such personal information by Brunswick and any
third-party recipients in accordance with this Policy.

What is personal information?

Personal information is information about an identifiable individual, as defined
by applicable law. By 'personal information' we mean names, addresses, email
addresses, and any other personal information you voluntarily provide, for
example by completing an online questionnaire, or by joining our alumni network.

We also collect some personal information automatically when you browse our
websites, such as your IP address and details of the pages that you have
visited.

Sensitive personal information

Sensitive personal information includes race or ethnic origin; political
opinions; religious or philosophical beliefs; trade union membership; physical
or mental health; genetic data; biometric data; sexual life or sexual
orientation; and criminal records. We ask that you do not provide sensitive
personal information of this nature when using our websites. 

If you choose to provide sensitive personal information to us for any reason,
the act of doing so constitutes your explicit consent, where such consent is
necessary and valid under your local law, for us to collect and use that
information in the ways described in this Policy or as described at the point
where you choose to disclose this information.

Processing

In this Policy, we collectively refer to handling, collecting, protecting or
storing your personal information as “processing” such personal information.

What personal information do we process

We may collect personal information from you in the course of our business,
including through your use of our websites, when you contact or request
information from us, when you engage our services or as a result of your
relationship with one or more of our staff and clients.

The personal information that we process includes:

 * Basic information, such as your name (including name prefix or title), the
   company you work for, your title or position and your relationship to a
   person;
 * Contact information, such as your postal address, email address and phone
   number(s);
 * Financial information, such as payment-related information;
 * Technical information, such as information from your visits to our websites
   or applications or in relation to materials and communications we send to you
   electronically;
 * Information you provide to us for the purposes of attending meetings and
   events (including dietary and access requirements);
 * Identification and background information provided by you or collected as
   part of our business acceptance processes;
 * Personal information provided to us by or on behalf of our clients or
   generated by us in the course or providing services to them, which may
   include sensitive personal data; or
 * Any other information relating to you which you may provide to us.

How we obtain personal data

Below are some examples of how you may provide to and we may obtain personal
information from you:

 * As part of our business processes including business acceptance, finance,
   administration and marketing processes, including anti-money laundering,
   conflict, reputational and financial checks;
 * Subscribing to or ordering newsletters and/or publications;
 * Subscribing to third party contact databases;
 * Registering for events and conferences;
 * Submitting CVs or resumes or otherwise for the purposes of recruitment;
 * Contacting us for further information;
 * Monitoring email communications sent to and from Brunswick; and/or
 * Providing us with business cards or other contact information.

How we use personal information

We may use your personal information to:

 * conduct administrative or operational processes within our business;
 * process and respond to requests, enquiries or complaints received by you;
 * provide services requested by you (including the performance of our
   contractual obligations to you);
 * identify services you may be interested in;
 * communicate with you about our services;
 * invite you to events;
 * monitor and analyse our business;
 * form a view of you as an individual and to identify, develop or improve our
   services and/or products that may be of interest to you and to carry out
   market research;
 * to conduct quality and risk management reviews;
 * to understand how people use the features and functions of our websites in
   order to improve the user experience; and
 * send you marketing materials.

Journalists

We frequently engage with journalists and other individual who work in the media
sphere on behalf of clients as an integral part of the particular services we
provide. Where we obtain the personal information of journalists and others in
the media sphere, we use this in order to:

 * Send company press releases;
 * Respond to any questions relating to any communications issued by our clients
   or more generally;
 * Share insights with respect to possible areas of interest and topics that we
   think may be relevant;
 * Facilitate access to and arrange interviews with individuals employed by our
   clients which will be of benefit to both parties;
 * Share information with our clients so that we can be transparent with them
   about who we are speaking to on their behalf and understand who they believe
   may be most relevant to speak to in respect of a particular matter; and
 * Send invitations to meetings or events hosted by us or our clients where on
   occasion we may ask whether you would be willing to act as a speaker or
   moderator.

Cookies

By using any of our websites, you agree that we can place cookies on your
device. If you want to restrict or block any of the above cookies, you should do
this through the web browser settings for each browser you use and on each
device you use to access the Internet.

You may refuse the use of cookies or withdraw your consent at any time by
selecting the appropriate settings on your browser but please note that this may
affect your use and experience of our websites.

Cookies are text files containing small amounts of information which are
downloaded to your device when you visit a website. Cookies are then sent back
to the originating website on each subsequent visit, or to another website that
recognizes that cookie. Cookies are useful because they allow a website to
recognize a user’s device, preferences and generally help to improve your online
experience.

As you navigate through and interact with our websites, we may automatically
collect certain information about your equipment, browsing actions and patterns,
including:

 * Details of your visits to our websites, including traffic data, location data
   and information about the resources that you access and use on our websites;
   and
 * General non-personal statistical data about your operating system and browser
   type.

Collecting this data helps us to improve our websites and to deliver a better
and more personalized service by enabling us to:

 * Estimate our audience size and usage patterns;
 * Store information about your preferences, allowing us to customize our
   websites according to your individual interests;
 * Speed up your searches; and
 * Recognize you when you return to any of our websites.

We use the following types of cookies:

 * Strictly necessary cookies which are essential to enable you to use a
   website;
 * Performance cookies which collect aggregated and anonymous information about
   how visitors a particular website;
 * Functionality cookies which allow us to remember choices a user makes and
   provide enhanced, more personal features, such as storing personal data so
   that in the future forms on the websites can be auto-completed, saving the
   user time; and
 * Cookies supplied by third parties which can be downloaded to your device.
   These third- party cookies are not under our control so you should check the
   websites and cookie policies of any third parties.

We will not keep any cookies placed on the device from which you access any of
our websites longer than is necessary to fulfil the purposes mentioned above. In
any event, such information may not be kept for longer than 1 year.

Legal grounds for processing

Your local law may require us to set out in this Policy the legal grounds on
which we rely in order to process your personal information. In such cases, we
rely on one or more of the following processing conditions:

 * our legitimate interests in the effective delivery of information and
   services to you and in the effective and lawful operation of our businesses
   (provided these do not interfere with your rights);
 * to satisfy any legal and regulatory obligations to which we are subject; or
 * where no other condition for processing is available, if you have agreed to
   us processing your personal information for the relevant purpose.

Rights in respect of your personal information

The European Union’s General Data Protection Regulation and other applicable
data protection laws provide certain rights for data subjects.

You may be entitled to:

 * request a copy of personal information we hold about you and how we process
   it by way of a subject access request;
 * ask that we update the personal information we hold about you, or correct
   such personal information that you think is incorrect or incomplete;
 * ask that we delete personal information that we hold about you, or restrict
   the way in which we use such personal information;
 * object to our processing of your personal information, restrict our
   processing of that information, prevent unauthorised transfers of your
   personal information to a third party and, in some circumstances, require
   personal information relating to you transferred to another organisation;
   and/or
 * withdraw your consent to our processing of your personal information (to the
   extent such processing is based on consent and consent is the only
   permissible basis for processing).

We may require further information from you in order to verify your identity
before disclosing any personal information to you and we may charge for a
request to access your information, if permitted by applicable law.

You may also have the right to lodge a complaint in relation to Brunswick’s
processing of your personal information with a local supervisory authority.

If you would like to exercise these rights, please contact us by sending an
email to: privacyenquiries@brunswickgroup.com.

Marketing Communications

Most of the personal data we collect and use for marketing purposes relates to
individual employees of our clients and other companies with which we have an
existing business relationship. We may also obtain contact information from
public sources, including content made public at social media websites, to make
an initial contact with a relevant individual at a client or other company.

Where we are legally required to obtain your explicit consent to provide you
with marketing materials, we will only provide you with such marketing materials
if you have provided consent for us to do so. We may send you further emails
prompting you to refresh your consent from time to time.

You can exercise your right to prevent marketing communications to you by
checking certain boxes on the forms we use to collect your personal data, or by
utilizing opt-out mechanisms in emails we send to you. If you select any
preferences such as issues, topics, subjects or industries, you may receive
email communications related to those self-selected topics.

You can also exercise the right to discontinue marketing communications to you.
In such cases, we will retain minimum personal data to note that you opted out
in order to avoid contacting you again. If you have agreed to receive marketing
but then later change your mind and no longer wish to receive marketing, please
let us know so we can remove you from our distribution lists.

Our customer relationship management (CRM) databases include personal data
belonging to individuals at our client and other companies with whom we already
have a business relationship or want to develop one. The personal data used for
these purposes includes relevant business information, such as: contact data,
publicly available information (e.g. board membership, published articles, press
releases, your public posts on social media sites if relevant for business
purpose), your responses to targeted email (including web activity following
links from our emails), and other business information included by Brunswick
personnel based on their personal interactions with you.

Please contact us on one of the email addresses below if you do not wish to
receive communications from us or wish to be removed from our internal CRM
databases.

Where you have been engaging with Brunswick please email:
unsubscribe@brunswickgroup.com

Where you have been engaging with Brunswick Campaigns and Content please email:
unsubscribe@brunswickgroup.com

If you decide to unsubscribe from a service or communication, we will try to
remove your information promptly, although we may require additional information
before we can process your request.

If you have other registrations with Brunswick or have provided your information
to Brunswick through other means (such as subscribing to newsletters), those
registrations will be maintained unless you to take specific action to inform us
to cease contacting you.

When we keep your personal information, we are responsible for keeping an
accurate record of the information that you have submitted to us and verified. 
We do not assume responsibility for verifying the ongoing accuracy of your
personal information. 


Sharing your Personal Information

We may transfer or disclose the personal information we collect to other
Brunswick affiliates globally and to their third party contractors,
subcontractors, and/or their subsidiaries and affiliates.  When we transfer
personal information, we do so for the purposes for which the information has
been submitted, for the purposes listed above, for the administration and
maintenance of our websites and associated systems, and/or other internal or
administrative purposes.

We may for example share personal information with certain trusted third parties
in accordance with contractual arrangements in place with them, including:

 * Our professional advisers, auditors and insurers;
 * Suppliers to whom we outsource certain support services such as word
   processing, translation, photocopying and document review;
 * IT service providers to Brunswick (including identity management, website
   hosting and management, data analysis, data backup, security and storage
   services);
 * Third parties engaged in the course of the services we provide to clients and
   with their prior consent; and
 * Third parties involved in hosting or organizing events or seminars.

The third-party providers may use their own third party subcontractors that have
access to personal data (sub-processors). We only use third party providers that
are bound to maintain appropriate levels of security and confidentiality, to
process personal information and to flow those same obligations down to their
sub-processors.  

We may be required to disclose your information to comply with legal or
regulatory requirements; under those circumstances, we will use reasonable
endeavors to notify you before we do this, unless we are legally restricted from
doing so.


Business reorganization

If in the future we re-organize or transfer all or part of our business, we may
need to transfer your information to new Brunswick entities or to third parties
through which the business of Brunswick will be carried out.


External Websites/Social Media

Please be aware that Brunswick websites may contain links to other sites that
are not governed by this Policy. We encourage users to review the privacy policy
of each website visited before disclosing any personal information.

By registering on any Brunswick website and then navigating to another Brunswick
website while still logged in, you agree to the use of your personal information
in accordance with the Policy.

Brunswick may use social media sites such as Facebook, LinkedIn and Twitter. If
you use these services, you should review their privacy policy for more
information on how they deal with your personal information.


Transfer

In order to provide our services we may need to transfer your personal
information to locations outside the jurisdiction in which you provide it or
where you are viewing this website for the purposes set out in this Policy. 
This may entail a transfer of your information from a location within the
European Economic Area (the “EEA”) to outside the EEA, or from outside the EEA
to a location within the EEA.

The level of information protection in countries outside the EEA may be less
than that offered within the EEA. Where this is the case, we will implement
appropriate measures to ensure that your personal information remains protected
and secure in accordance with applicable data protection laws.

An agreement is in place between all Brunswick entities globally that share and
process personal data containing terms no less stringent than those provided in
the EU standard clauses.

Where our third-party service providers process personal data outside the EEA in
the course of providing services to us, our written agreement with them will
include appropriate measures, satisfying EU requirements for the transfer of
personal data to data processors or data controllers outside the EEA.


Security

We have implemented measures to ensure that all Brunswick offices and affiliated
entities keep your personal information confidential and secure and only use it
for the specified purposes about which we have informed you. To the best of our
ability, access to your personal information is limited to those who have a need
to know. Those individuals who have access to the data are required to maintain
the confidentiality of such information.

We use a variety of security, technical and organisational measures to help
protect your personal information from unauthorized access, improper use or
disclosure, unauthorized modification or unlawful destruction or accidental loss
with applicable data protection laws. Despite Brunswick's best efforts, however,
security cannot be absolutely guaranteed against all threats.

Brunswick holds the internationally recognized security standard BS ISO/IEC
27001:2013 in respect of its document management and email systems and the
supporting infrastructure for Brunswick’s offices globally. This is an
independently verified certification that information security is managed in
line with international best practice.

However, the transmission of information via the internet is not completely
secure. Although we will do our best to try and protect your information, we
cannot guarantee the security of your information transmitted to our websites;
any transmission is at your own risk.


Data Retention

We will retain your personal information for as long as is necessary to fulfill
the purposes outlined in this Policy unless a longer retention period is
required or permitted by law.

Our retention periods are based on the requirements of applicable data
protection laws and the purpose for which the information is collected and used,
taking into account legal and regulatory requirements to retain the information
for a minimum period, limitation periods for taking legal action, good practice
and Brunswick’s business purposes.

We keep contact information (such as mailing list information) until a user
unsubscribes or requests that we delete that information. If you choose to
unsubscribe from a mailing list or newsletter, we may keep certain limited
information about you so that we may honor your request.

Contact information

If you have any questions in relation to this Policy please contact us at:

Address: Attn: Legal Director, Brunswick Group, 16, Lincoln’s Inn Fields,
London, WC2A 3ED

Telephone: +44 20 7404 5959

Email: privacyenquiries@brunswickgroup.com


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