China Notice. If you are resident in China, Chinese law requires us to provide you with specific information regarding how we collect, use, and disclose your “personal information” (as defined in the Personal Information Protection Law of the People’s Republic of China (“PIPL”)). 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.
Legal Bases: Brunswick will only process personal information if there is a legal basis as stipulated in Article 13 of PIPL or other applicable laws and regulations. The following bases apply:
- Compliance with a statutory obligation (Art 13.3). Brunswick needs to process personal information because of a number of statutory obligations, such as the obligation to record and manage whistleblowing complaints.
- The fact that the personal information that has been made public by yourself or otherwise legally disclosed and that it is processed within a reasonable scope (Art 13.6)
Transferring Data Outside the Chinese Mainland: In order to facilitate your use of our Site and related interactions with us, we may at times need to share your personal information with other parts of the Group. This data will be stored within our global data centers. Further details of these providers are available on request.
When personal data is transferred outside China, we always ensure that this is done in strict compliance with the Provisions on Regulating and Facilitating Cross-Border Data Flows. We have adopted a standard contract between Beijing Brunswick Consulting Limited and our overseas recipient Brunswick Group Services Limited.
In addition, prior to the transfer of any personal information, we will always obtain your explicit consent in accordance with Article 39 of the Personal Information Protection Law. In general, we will not transfer your personal information to any company, organization, or individual except under the following circumstances:
- Transfer with your explicit consent: after acquiring your explicit consent, we will transfer your personal information to other parties within the Brunswick Group.
- Corporate transactions: when the transfer of personal information is involved in a merger, acquisition, or bankruptcy liquidation, we will require the new company or organization to continue to be bound by this Personal Information Protection Policy; otherwise, we will require the new company or organization to seek your consent again.
Contact Information
If you have any questions in relation to this notice, please contact us at:
Address:
Attn: Data Protection Representative
Beijing Brunswick Consulting Limited
2605 The Exchange Twin Towers (East),
B12 Jianguomenwai Avenue,
Beijing 100022,
People’s Republic of China
Phone: +86 10 5960 8600
Email: privacycn@brunswickgroup.com; Legal@brunswickgroup.com
Date of Last Revision: December 9, 2025