Date: 25 May 2018
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.
This Policy applies to all entities in the Brunswick group of companies globally which includes its creative agency, MerchantCantos, and TheLincoln Centre.
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.
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.
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.
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.
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 recognises that cookie. Cookies are useful because they allow a website to recognise 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: email@example.com.
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 The Lincoln Centre please email: firstname.lastname@example.org
Where you have been engaging with Brunswick please email: email@example.com
Where you have been engaging with MerchantCantos please email: firstname.lastname@example.org
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 organising 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 endeavours to notify you before we do this, unless we are legally restricted from doing so.
If in the future we re-organise 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
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.
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.
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 unauthorised access, improper use or disclosure, unauthorised 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 recognised 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.
We will retain your personal information for as long as is necessary to fulfil 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 honour your request.
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