This Policy contains the following sections:
- Updates to this Policy
- Information Collected
- How we use the information we collect
- Cookies and Site Analytics
- Legal grounds for processing
- Your rights and choices
- How we disclose your information
- Third-party links and features
- Information for International Users
- Data Security
- Data retention
- Privacy Information for California Residents
- Contact Information
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 processes your information.
By providing information to us, 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 information by Brunswick and any third-party recipients in accordance with this Policy.
As you use our Site and have related interactions with us, the information that we may collect from you, should you choose to provide it to us, includes:
- Basic information, such as your name, the company you work for, and your title or position;
- Contact information, such as your postal address, email address and phone number(s);
- Any other information relating to you which you choose to provide to us.
The Site is not intended to collect sensitive information from and about you, such as financial account numbers or health information. Please do not provide such information as you use the Site.
We may use the information we collect from and about you to:
- provide the Site and related services;
- process and respond to requests, inquiries or complaints received by you;
- identify services you may be interested in and provide you with related marketing materials and event invitations;
- send transactional communications to you about our Site and our services;
- monitor and analyze use of the Site to improve our Site and our business offerings; and
- Develop or improve our Site, services, and/or products and carry out market research.
Aggregate/De-Identified or Anonymized Information. We may aggregate and/or de-identify any information we collect so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use such information for any purpose, including without limitation for research, and may also disclose such data with any third parties.
Cookies. Cookies are text files containing small amounts of information which are added to your device browser when you visit a website. Cookies are useful because they allow a website to recognize a user’s device, preferences and generally help to improve users' online experience. Cookies may be placed by us (first-party cookies) or by third-party partners and service providers (third-party cookies).
We use the following types of cookies on our Site:
- Strictly necessary cookies which are essential to enable you to use the Site -- such as cookies that load Site content;
- Performance cookies which collect aggregated information about how visitors use our Site;
- 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 Site can be auto-completed, saving the user time; and
- Targeted Advertising cookies which allow us or our vendors to collect information about your use of the Site to provide you with relevant ads on other sites you visit. If you interact with certain pages on our website, we may place a cookie on your device to help us understand how you interact with our Site, and if you encounter Brunswick advertising on 3rd party sites, to help us and those third parties understand your interaction with such advertising and determine the effectiveness of our advertising.
Depending on your jurisdictions of residence, you may be asked to consent to our use of certain cookies before they are placed on your browser. Any user of our Site can restrict or block cookies through the web browser settings for each browser and device they use to access the Internet. However, please note that blocking or disabling cookies may affect your use of and experience on our Site.
Analytics. We may use third-party web analytics services on our Site (such as Google Analytics) to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; and provide certain features to you. If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to understand the effectiveness of our communications and marketing campaigns.
We may allow select third parties to place cookies or other tracking technologies on the browser of your device to collect information on your usage of the Site and certain features such as embedded content, etc. as described above as you use the Site. These third parties (e.g., social media platforms, ad networks, etc.) may use this information to serve relevant content and advertising to you as you browse the Internet, and access their own cookies or other tracking technologies on your browser to assist in this activity. If you are interested in more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Digital Advertising Alliance of Canada, Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs.
We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms. Please note that if you use these mechanisms, you may still see advertising on the Internet, but it will not be tailored to you based on your online behavior over time.
Please see the "Your Rights and Choices" section below for additional information on how to effectuate your rights regarding online advertising.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our Services for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. Please note that DNT is a different mechanism than the "global privacy control," which signals that individuals want to exercise certain rights with respect to their data. We do honor global privacy control signals as required by applicable law.
Your local law may require us to set out in this Policy the legal grounds on which we rely in order to process your information. In such cases, we rely on one or more of the following processing conditions:
- to satisfy any legal and regulatory obligations to which we are subject;
- where you have consented to us processing your information for the relevant purpose; or
- 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 interests do not interfere with your rights).
You have certain rights with respect to your information as further described in this section.
General information rights. Your local laws (e.g., if you are a citizen or resident of the European Economic Area or certain U.S. states such as California) may permit you to request that we:
- provide access to and/or a copy of certain information we hold about you
- update information which is out of date or incorrect
- delete certain information that we are holding about you
- restrict the way that we process and disclose certain of your information
- revoke your consent for the processing of your information
We will consider all requests and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request. To submit a request, please contact us at [email protected].
Marketing Communications. If, in accordance with applicable legal requirements, we send you marketing communications regarding our services or the services of third parties that we believe will be interesting to you, you can ask us to stop sending such communications at any time by contacting us at [email protected]. In our marketing email messages, you can also opt out by following the instructions located at the bottom of such emails. Please note that, regardless of your request, we may still use and disclose certain information as permitted by this Policy or as required by applicable law. For example, you may not opt out of certain transactional emails from us, such as those confirming your requests or providing you with updates regarding our legal terms.
Sale/Targeted advertising opt out rights. Under the laws in certain jurisdictions, you have the right to opt out of our processing or sharing of your information for online targeted advertising purposes. Note that certain jurisdictions also allow you to opt out of the “sale” of your information to third parties in exchange for valuable consideration. We may use analytics and online advertising tools that result in the disclosure of your information to our third-party partners and that are subject to this opt out right. You can opt out of both of these activities by clicking "Your Privacy Choices" here or in the footer of our website.
We may transfer or disclose information we collect to other Brunswick affiliates globally and to their third-party contractors, subcontractors, and/or their subsidiaries and affiliates for our legitimate business purposes. Specifically, in accordance with applicable legal requirements, we may disclose your information to the following entities:
- Our professional advisers, auditors and insurers;
- Service providers to whom we outsource certain support services such as word processing, marketing, data storage, translation, photocopying and document review;
- IT service providers to Brunswick (including identity management, Site hosting and management, data analysis, data backup, security and storage services);
- Online advertising and related analytics partners, that help us serve you with more relevant ads about our services as you use the Internet and analyze the effectiveness of such ads;
- Legal or regulatory bodies where we believe in good faith that disclosure of your information is required by law or necessary to protect Brunswick Group, our clients, and the public;
- Other businesses or organizations in the event that we undergo a business transaction that involves the sale or transfer of some or all of our assets to that other entity; and
- Any other entity where we have your consent to do so.
The Site may contain links to third-party websites and features. If you choose to visit these sites and use their services, please note that we are not responsible for their content or privacy practices. The collection, use, and disclosure of your information will be subject to the privacy policies of the third-party websites, and not this Policy. We urge you to read the privacy policies of these third parties.
Our Site and our related services are provided among other places, in the United States. Please note that the level of information privacy protection in the United States may differ from the privacy protections in your jurisdiction of residence. By using the Site, you acknowledge and agree to the processing of your information in the United States.
We use a variety of security, technical and organizational measures to help protect your 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’s ICT function 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 can never be 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 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, best practices, 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.
California Notice. If you are a California resident, California law requires us to provide you with specific information regarding how we collect, use, and disclose your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). Throughout this Policy, we discuss in detail the specific pieces of personal information we collect from and about you. Please see the “Information we Collect” and “How We Use Your Information” sections above for more information.
Your Choices Regarding “Sharing” and “Selling”: You have the right to opt out of our sale/sharing of your personal information for purposes of online advertising and related analytics by clicking "Your Privacy Choices." Your opt out choice will apply only to the particular device and browser on which you are making the choice, so please repeat your opt out choice on other browsers and devices if you would like. Please note that we will also honor browser-based opt out signals (such as the global privacy control) in accordance with our legal obligations.
Other CCPA rights.
Financial incentives. If we offer any financial incentives in exchange for your personal information (e.g., discount coupons in exchange for your email address), we will provide you with appropriate information about such incentives so that you can make an informed decision as to whether to participate.
Right to Limit. The CCPA allows you to limit the use or disclosure of your “sensitive personal information” (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.
Shine the Light. The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we disclose certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not disclose your personal information with third parties for their own direct marketing purposes.
If you have any questions in relation to this Policy please contact us at:
Address: Attn: US Legal, Brunswick Group LLC, 1114 Avenue of the Americas, 24th Floor, New York, NY 10036
Telephone: +1 (212) 333-3810
Email: [email protected]
Date of Last Revision: July 2023