Legal and Privacy

Privacy and Cookie Policy

Brunswick is a global advisory firm. Founded in 1987, Brunswick is a privately held corporation with 27 offices around the world.  This Privacy Policy (“Policy”) applies to the information  Brunswick Group and its affiliates under common ownership and/or control (together, “Brunswick,” “we,” “us,” “our”) collects from and about you when you visit our website located at www.brunswickgroup.com (the “Site”), interact with us through our social media pages, or engage in any related interactions with us. Please read the Policy to understand how we will collect and use your information and the rights you have in relation to your information.

This Policy contains the following sections:

Updates to this Policy

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.

Information Collected

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.

As you navigate through and interact with our Site, we may also automatically collect certain information about the device you use to access the Site, and browsing actions and patterns, including device identifiers, traffic data, referrer headings, error logs, IP address, browser and operating system type, general location data associated with your IP address, and information about the resources that you access and use on our Site.  This device and usage information may be collected through the use of cookies and similar technologies, which are further discussed below.

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.

How we use the information we collect

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 and Site Analytics

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.

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 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).

Your rights and choices

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 privacy@brunswickgroup.com.

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 privacy@brunswickgroup.com. 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 “Opt out of sale of personal data and Targeted Advertising” here or in the footer of our website.

How we disclose your information

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.

Third-party links and features

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.

Information for International Users

Our Site and our related services are provided in the United States, among other places.  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.

Data Security

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[HP1]  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.

Data Retention

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.

Anti-Slavery Statement

This statement is made on behalf of Brunswick Group Partnership Limited and its affiliated entities (together, “Brunswick,” “we,” “us,” “our”)  pursuant to section 54(1) of the Modern Slavery Act 2015 (U.K.) and Section 14 of the Modern Slavery Act (2018) (Australia), as well as any other relevant or similar statutes (together, the “Act”).

Group Structure

 Brunswick is a global advisory firm. Founded in 1987, Brunswick is a privately held corporation with 27 offices around the world.

Our Commitment

Brunswick is committed to ensuring that there is no slavery or forced human labour in any part of our business or its associated supply chain and ensuring that human rights violations do not occur within our business or any elements of our supply chain.

As an equal opportunity employer, Brunswick is committed to ensuring that all colleagues feel safe and respected in the workplace. We want all colleagues to feel confident that they can report any suspected wrongdoing without risk to themselves.

Our policies are dedicated to ensuring that all prospective employees are entitled to work in the relevant jurisdiction, and to safeguarding employees from abuse and coercion.

Brunswick does not work with any organization, anywhere in the world, that we know to support forced labour.

Brunswick’s Supply Chain

Brunswick strongly believes in maintaining effective transparency across all areas of its business. Given the nature of the services we provide, we have a simple supply chain model built around supporting our core business advisory practices and maintaining our global premises, systems and infrastructure.

The service providers that support our business can be broadly grouped as follows:

  1. Physical business services – e.g. services and products we purchase to maintain our global office environments, including cleaning, security, and stationary/ printer providers;
  2. Information services – e.g. physical and digital sources of information used for research;
  3. Data services – e.g. information technology services, infrastructure and software tools we procure in order to facilitate the management and storage of data that the business generates or receives;
  4. Professional services – e.g. external lawyers, accountants, property agents and insurance specialists; and
  5. Travel services – e.g. travel by our employees and consultants for business purposes, travel agents and other booking providers.

Human Trafficking and Modern Slavery

While we do not have any formal organisational procedures in place specifically relating to human trafficking, we do however, review current clients and suppliers and will investigate further where we believe there is any risk of human trafficking.

Compliance and Policies

Brunswick has implemented a number of human resource, compliance and risk policies which all employees must comply with, including:

  • Anti-Harassment and Discrimination (Global Edition)       
  • Ethical Standards (relating to anti-bribery and corruption)
  • Whistleblower Policy
  • Anti-Retaliation Policy

Whistleblowing Policy and Anti-Retaliation

Employees are required to report any suspected wrongdoing or violations of Brunswick policies. Brunswick has implemented a process through which employees may formally raise and escalate any issues of potential concern within the business, including on a confidential basis. This includes, without limitation, issues relating to slavery or forced human labour.

Anyone believing that they may have relevant information to report may do so via one of the following methods:

  • Via the independently administered, third-party provider, EthicsPoint/NAVEX or via its hotline:
CountryPhone Number
Australia1800 306 510
Belgium0800 13 342
Brazil0800 762 0032
China400 120 9389
France0800 90 43 28
Germany0800 181 3014
Hong Kong800 902 148
India022 5097 2951
Italy (includes San Marino, Vatican City)800 819 536
Japan0800-805-0671
Portugal800 815 095
Saudi Arabia800 850 1649
United Arab Emirates800 0120260
United Kingdom & Northern Ireland0800 066 8927
United States1 855 409 9984
Singapore800 492 2774
South Africa080 001 0748
Spain900 751 437
Sweden020 79 62 49

Brunswick prohibits retaliation against anyone who in good faith reports or participates in the investigation of an actual or suspected violation of laws, regulations, or Brunswick’s policies or procedures.  Any allegation of retaliation will be promptly investigated.  Employees found to have engaged in retaliatory conduct will be subject to discipline, up to and including termination of employment. 

Ethics and Anti-Corruption

  • Brunswick requires all of its employees to adhere to its core compliance policies including: Ethical Standards Policy (covering anti-bribery and anti-corruption), Global Anti-Harassment and Discrimination, Whistleblower Policy, Insider Trading, Cybersecurity, Responsible Use of Artificial Intelligence.
  • All employees are required to complete compliance training on at least an annual basis covering the policies listed above.
  • Brunswick thoroughly investigates any internal or external allegations of a breach of our ethical standards or policies, and any such matters will be handled promptly, with corrective action taken if/as needed.

Compliance Measures

  • We take a risk-based approach to the assessment of suppliers in the context of the Act, assessing whether a particular supplier has any risk of slavery or human trafficking issues based on industry, geography, other risk factors.
  • We will use reasonable efforts to include a requirement in our commercial agreements that suppliers (and any sub-contractors they utilize in performance of services for us) comply with the Act.
  • We will use reasonable efforts to reserve for ourselves a right of audit in our commercial agreements with suppliers in the event that we suspect that a supplier is in breach of the
  • We will use reasonable efforts to include a termination right in our commercial agreements with suppliers in the event that we have reasonable evidence to suggest that a supplier is in breach of the Act.
  • Brunswick has a Whistleblower Policy that requires employees to promptly report any concerns they may have of any violation of our ethical standards or policies, including specifically any allegation of slavery, forced labor, or human trafficking within our organisation or supply chain.

Report a Concern

Brunswick Group and its affiliates under common ownership and/or control (together, “Brunswick,” “we,” “us,” “our”) encourages all employees to report actual or suspected violations of laws, regulations, or Brunswick’s policies or procedures.  Employees may report a concern directly to a supervisor, a mentor, or to a member of the Compliance, Legal, or People teams.  In addition, reports can be made anonymously via a third-party provider.  

Brunswick’s reporting channels are available to everyone- including clients, contractors, vendors, business partners, and the general public.

Brunswick prohibits retaliation against anyone who in good faith reports or participates in the investigation of an actual or suspected violation of laws, regulations, or Brunswick’s policies or procedures.  Any allegation of retaliation will be promptly investigated.  Employees found to have engaged in retaliatory conduct will be subject to discipline, up to and including termination of employment. 

If you would like to make a report, you can do so in the following ways: