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Privacy Statement

This page tells you everything you need to know about how Brier & Thorn and its subsidiary companies protects your personal data and what your rights are in relation to your personal data:

You will also find further information on this page about:

  • Your website data
  • Your cookie data (and other tracking technologies)
  • Your marketing data
  • Your online recruitment data
Summary

If you have any questions concerning data privacy or you want to let us know about website/marketing permissions, please see how to contact us below.

Any changes we may make in the future to “How Brier & Thorn protects your personal data” or the statements you see here will be posted on this page.

This privacy statement is effective January 13, 2016

How Brier & Thorn protects your personal data

Brier & Thorn protects your personal data through its “Binding Corporate Rules” or “BCR”. These consist of:

  • Data Privacy Policy – a global data privacy policy that sets out the safeguards that apply across Brier & Thorn regardless of where we process your data
  • Data Privacy Procedures – such as how we should handle access requests or complaints and
  • Intercompany Agreement – an agreement to make Brier & Thorn’s Data Privacy Policy and Data Privacy Procedures binding on all the participating Brier & Thorn group subsidiaries

Together, these ensure that appropriate data privacy safeguards are in place across our organization. Our BCR reflect the standards contained in European data privacy laws and have been approved by data privacy regulators in Europe (the European Economic Area and Switzerland).

Having BCR means that all our group entities that sign up to our BCR have to comply with the same internal rules. It also means that your rights stay the same no matter where your data are processed by Brier & Thorn (see Your Rights below).

If you would like a full copy of our BCR please contact us.

Data Privacy Policy

The following section summarizes Brier & Thorn’s Data Privacy Policy. If you would like a full copy of the policy please contact us.

  • What person data do we collect?
  • Will we share your personal data with outside parties?
  • What about sensitive personal data?
  • What about data security?
  • Where will your personal data be processed?
  • Retention of your data
  • Your rights
  • Questions and Complaints

What personal data do we collect?
We collect personal data of our workers, candidates, suppliers, business contacts and website users.

We will always try to give individuals appropriate notice of what data will be collected and how it will be used. Whatever happens, we will only process that data if we consider it fair and lawful to do so.

Will we share your personal data with outside parties?
We will not sell personal data to third parties. We may transfer personal data to our contracted service providers and advisors who may be located in other countries. Before we do so, we take steps to ensure that your personal data will be given adequate protection as required by relevant data protection laws and Brier & Thorn’s internal policies.

However, there will be other times when we need to share or disclose personal data you provide for a specific purpose, for example:

  • In the case of an event where we need to provide our caterer with meal preference information or we are running a joint event and have informed you that the data will be shared with our partners. But again, we will notify you as to why we are asking for specific information and it is completely up to you whether you want to provide it;
  • We may need to disclose your personal data to third parties in the event that we sell or liquidate any part of our business or assets;
  • We will disclose or share your personal data to comply with any legal obligation, or to enforce or apply our Terms of Use; or to protect the rights, property, or safety of Brier & Thorn, our clients, or others.

What about sensitive personal data?
We do not generally seek to collect sensitive personal data through this site or otherwise. In the limited cases where we do seek to collect such data, we will do this in accordance with local data privacy law requirements. If you choose to provide us with unsolicited sensitive personal data, you consent to our using the data, subject to applicable law as described in this privacy policy. The term “sensitive personal data” refers to the various categories of personal data identified by European and other data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent. These categories may include personal identity numbers, financial account information, racial or ethnic origin, political opinions, religious, philosophical or other similar beliefs, membership of a trade union or profession or trade association, physical or mental health, biometric or genetic data, sexual life, or criminal record (including information about suspected criminal activities).

What about data security?
We take appropriate steps to maintain the security of personal data collected. Regarding your use of our websites you should understand that the open nature of the Internet is such that information and personal data may flow over networks connecting you to our systems without security measures and may be accessed and used by people other than those for whom the data is intended.

Our site may, from time to time, contain links to and from the sites of our partner networks, advertisers and affiliates. If you follow a link to any of these sites, please note that these sites have their own privacy policies and that we do not accept any responsibility or liability for these policies or sites. Please check these policies before you submit any personal data to these sites.

Where will your personal data be processed?
As a global organization with global IT systems, personal data we collect may be routed, stored, or transferred internationally throughout Brier & Thorn’s worldwide organization in accordance with our Binding Corporate Rules.

Retention of your data
We will retain your personal data only for as long as is necessary. If you have an account with us, we will only keep the data whilst your account is active or for as long as needed to provide services to you and, as further needed for us to comply with our global legal and contractual obligations.

Your rights
You are entitled to know whether we hold personal data about you and, if we do, to have access to that personal data and require it to be corrected if it is inaccurate. We generally do not make decisions by purely automatic means, but if we do, you have the right to object.

You can Contact Us to exercise any of your rights or obtain a copy of Brier & Thorn’s BCR.

If your data was originally collected in Europe (the European Economic Area (EEA) and Switzerland) and it is transferred from a Brier & Thorn entity within Europe to a Brier & Thorn entity outside Europe you have the following additional rights under the BCR:

  • to make complaints to, obtain appropriate redress and, where appropriate, receive compensation from the Brier & Thorn entity within Europe that originally obtained and processed your personal data, in respect of any damage suffered by you as a result of a breach of the Privacy Policy by any other Brier & Thorn entity to which the personal information may have been transferred under the BCR;
  • to lodge a complaint with a competent data protection authority and/ or to take action through a court to enforce compliance by Brier & Thorn with the terms of the Privacy Policy;
  • to obtain a copy of the BCR upon request

You have a question or complaint
If you can’t find what you’re looking for here, or have a concern about our use of your personal data, please Contact Us.

Web Site Policy

This web site is administered by Brier & Thorn, Inc. on behalf of itself and each Brier & Thorn local operating company.

  • Your privacy on Brier & Thorn’s web sites
  • What information do we gather?
  • How do we use information that we collect from the web site?

Your privacy on Brier & Thorn’s web sites
The primary purpose of Brier & Thorn’s web site is to be a dynamic resource and business tool to help you learn more about Brier & Thorn, as well as provide access to our publications and other materials as a global thought leader. We want you to feel secure when visiting our web site and are committed to maintaining your privacy when doing so.

What information do we gather?
Brier & Thorn collects information at its websites in two ways: (1) directly (for example, when you provide information to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our web site’s technology).

We may collect and process the following information:

  • Information that you provide by filling in forms on our website. This includes registering to use the website, subscribing to services, newsletters and alerts, registering for a conference or requesting a white paper or further information. Pages that collect this type of information may provide further information as to why your data is needed and how it will be used. It is completely up to you whether you want to provide it.
  • If you contact us, we may keep a record of that correspondence.
  • We may ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
  • Any postings, comments or other content that you upload or post to a Brier & Thorn web site.
  • Our website collects information about your computer, including (where available) your IP address, operating system and browser type, for system administration, to filter traffic, to look up user domains and to report on statistics.
  • Details of your visits to our web site, the pages you view and resources you access or download, including but not limited to, traffic data, location data, weblogs and other communication data. Please see the Cookies section for more information.

When this information relates to or identifies you, we will treat it as “personal data.”

How do we use information that we collect from the site?
We use personal data to provide you with information you request, process online job applications, and for other purposes which we would describe to you at the point where it is collected or which will be obvious to you. For example:

  • To fulfill your requests for white papers, articles, newsletters or other content.
  • For surveys or research questionnaires.
  • To personalize your experience at our web site.
  • To contact you for marketing purposes where you have agreed to this.

We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section for more information.

Cookies Policy

What are cookies?
Cookies are text files containing small amounts of information which are downloaded to your computer or mobile device when you visit a web site. Cookies are then sent back to the originating web site on each subsequent visit, or to another web site that recognizes that cookie. Cookies are useful because they allow a web site to recognize a user’s device. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.

Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. They can also help to ensure that the advertisements and other content you see online are more relevant to you and your interests. They can be set by the web site that you are visiting (known as first party cookies) or by another entity such as an advertising network (known as third party cookies).The cookies used on this web site have been categorized on the basis of the four categories found in the ICC UK Cookie guide. A list of all the cookies used on this web site by category is set out below. Within the four categories, cookies can either be session or persistent. Session cookies are temporary and once you close the browser window they are deleted from your device. Persistent cookies remain on your device for a longer period and are used by the web site to recognize your device when you return.

What other tracking technology do we use?
We may also use web beacons (including conversion pixels) or other technologies for similar purposes and we may include these on our sites, in marketing e-mail messages or our newsletters to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor web site activity and the information on cookies below also applies to web beacons and similar technologies. Conversion pixels are small codes located on a particular web page which are triggered when someone visits a page resulting in an increase in the conversion count.

What if I don’t want cookies?
By using our web site you agree that we can place cookies and other similar technologies on your device as explained below. If you want to remove existing cookies from your device you can do this using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this. When you review your browser settings or options, you can identify the Brier & Thorn cookies by the fact they include “.brierandthorn” in the name. For more information on managing cookies see www.allaboutcookies.org/manage-cookies. Current “Do Not Track” initiatives are not recognized by our web site.

Please bear in mind that deleting and blocking cookies will have an impact on your user experience as parts of the web site may no longer work. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our web site or click a link in a targeted email we have sent you, even if you have previously deleted our cookies.

You cannot remove or block web beacons or personalized URLs, as they form part of the content of web pages and emails rather than placing information on your device. But, as they work in conjunction with cookies, turning off cookies will also prevent any web beacons from tracking your user activity on our site. The web beacon will still account for an anonymous visit, but your unique information will not be recorded.

What types of cookies are there and which ones does this web site use?

Strictly necessary cookies – These cookies are essential to enable you to move around the site and use its features, such as accessing secure areas of the web site. Without these cookies, services you have asked for cannot be provided.

We categorize the following cookies as strictly necessary:

  1. Registered Visitor Cookie – A unique identifier given to each registered user, used to recognize them through their visit and when they return to the web site. (see also Functionality cookies below).

Performance cookies – These cookies collect information about how visitors use a web site, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is anonymous and is only used to improve how a web site works.

We categorize the following as performance cookies:

  1. Referrer URL (internal page) – Used to store the URL of the previous page visited. Allows us to track how visitors navigate through our web site.
  2. Referrer URL (external page, including if you click on links on Brier & Thornsocial media pages). Used to store the URL which refers a visitor to our web site so we may understand what URLs are referring visitors to our web site.
  3. URL history – Used to store the page visited by a user before that user submits a form. Also, used to display recently viewed articles to each visitor.
  4. Unregistered Visitor Cookie – A unique identifier given to each visitor to allow analysis on how unregistered visitors use our web site.
  5. Session management cookies – These cookies allow us to follow the actions of a user during a browser session. A browser session starts when a user opens the browser window and finishes when they close their browser window. Our session management cookies are created temporarily. Once you close your browser, our session management cookies are deleted.

Functionality cookies – These cookies allow a web site to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a web site may be able to provide you with local information or news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customize.

They may also be used to provide services you have asked for such as watching a video or commenting on a blog. These cookies cannot track your browsing activity on other web sites. They don’t gather any information about you that could be used for advertising or remembering where you’ve been on the internet outside our web site.

We categorize the following as functionality cookies:

  1. Recently viewed pages – Stores pages visited by the user on our web site and displays them in right hand navigation for easy reference.
  2. Search history – Stores searches on our web site conducted by the user and displays them for the user in the right hand navigation for easy reference.
  3. Registered Visitor Cookie – A unique identifier given to each registered user to our web site, used to serve them content and offers based on their profiles. Also used for analysis and marketing purposes (See also: Strictly necessary cookies above and Use of cookies for marketing and analytics below).

Targeting cookies – These cookies are used to: (1) deliver advertisements that are targeted to be relevant to you, (2) limit the number of times you see an advertisement, (3) help measure the effectiveness of the advertising campaign, and (4) understand people’s behaviour after they view an ad. They are usually placed by advertising networks with the web site operator’s permission. They remember that you have visited a web site and this information is shared with other organizations such as advertisers. Quite often they will be linked to web site functionality provided by the other organization.

At Brier & Thorn we do not have third party advertising on our web site but these cookies may be used on third party web sites and third parties may use them on our web site as follows:

  1. Third party social media web sites may log information about you, for example if you click an “Add This” or “Like” button for a social media web site while on our web site. We do not control such web sites or their activities. You may be able to find information about social media web sites on the web sites themselves. We recommend you read the terms of use and privacy policy of such web sites before using them.
  2. If you click on a Brier & Thorn advertisement on a non-Brier & Thorn web site, a cookie may be used to log which web site you are on, to ensure our advertisements are served effectively and to measure whether our advertisements are viewed. Brier & Thorn may use service providers such as Doubleclick, MediaMind, www.DidIt.com and others for these purposes
  3. We partner with ShareThis on our web site. ShareThis is a widget on the web site that enables users to share content from the web site with others through social media web sites such as Facebook and Twitter. ShareThis includes cookies on the web site which collect information on how users use the web site and associate users with topics of interest, based on the content they share. This data will be used for analytics on the web site (creating statistics as to what is most popular and how many people are sharing particular content) and to determine how to target advertising on other external web sites. ShareThis may share its analytical data with Brier & Thorn. ShareThis does not use personal identifiers of users (such as names and e-mail addresses) for these purposes and identification is solely by an anonymous identifier. For further information about ShareThis, the cookies it uses and how to opt out of ShareThis cookies, please refer to their web site [www.sharethis.com/privacy].
  4. We use reputable third parties to gather and provide us with information about our website and advertising audiences and to deliver targeted advertisements on third party sites. These third parties only use anonymous identifiers and have no way of associating these identifiers with identifiable users. Organizations such as Quantcast and Retargeter do this for us and you can find more information on their websites or by clicking the AdChoices icon in our ads.
  5. We also partner with certain social media websites such as Facebook and Twitter to add conversion pixels to certain pages on our website that allow us to re-engage website visitors. A conversion pixel is a small code located on a particular web page which is triggered when someone visits a page resulting in an increase in the conversion count. These pixels enable us to advertise to those website visitors within Facebook and Twitter and continue their experience with Brier & Thorn.

Use of cookies for marketing and analytics – We may use information collected from our cookies to identify user behavior and to serve content and offers based on your profile, and for the other purposes described below.

Some of the cookies we use don’t collect information that identifies a visitor. For example –

  • Performance cookies (see above)
  • Targeting cookies (see above) where you are not a registered user

In other cases we can associate cookie information (including information from cookies placed via our advertisements on third party sites) with an identifiable individual. For example–

  • If a user is a registered user (see RegisteredVisitorCookie above)
  • If we send you a targeted email which includes web beacons, cookies or similar technologies we will know whether you open, read, or delete the message.
  • When you click a link in a marketing e-mail you receive from Brier & Thorn, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Note – For some of our cookies we use Omniture (part of Adobe) to host optimization products and services for us to provide us with web analytics and intelligence about our website. For further information on how Omniture collects and uses information on our behalf, please refer to the Omniture Products and Services Privacy Statement at www.omniture.com/privacy/product.

Non-cookie tracking technologies – Brier & Thorn also employs technologies that perform similar functions to cookies, but that may not respond to browser settings intended for use with cookies. These include personalized URLs (PURLs), web beacons, and other similar technologies.

Marketing Policy

The following describes our use of personal data for marketing purposes:

  • Sources of marketing data
  • Targeted e-mail
  • Customer Relationship Management (CRM) databases
  • Use of Brier & Thorn web sites
  • Combining and analyzing personal data

 

Sources of Marketing Data.
The bulk 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.

 

Targeted E-mail.
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from Brier & Thorn, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.

Targeted e-mails from Brier & Thorn may include additional data privacy information, as required by applicable laws.

 

Customer Relationship Management (CRM) Databases.
Like all large companies, Brier & Thorn uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our 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 e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by Brier & Thorn professionals based on their personal interactions with you. If you wish to be excluded from our CRM databases, please use the contact form.

Combining and Analyzing Personal Data.
As described above, we may combine data from publicly available sources, and from our e-mail, website, and personal interactions with you. We combine this data to better understand your needs and the needs of your company, to assess the suitability of our service offerings for your needs, and to perform the other activities described throughout this privacy statement.

Your Rights
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 e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by using our contact form. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again.

Recruiting Policy

If you use Brier & Thorn’s online career resources, we collect personal data that you submit to the website and use it for recruiting-related purposes. We may also use Cookies and other tracking technology and the same technologies we use for Marketing (including Customer Relationship Management (CRM) Databases, Targeted E-mail & Combining and Analyzing Personal Data) to provide individuals with a personalized online experience, to send relevant information about careers and opportunities at Brier & Thorn, and to analyze the effectiveness of our recruitment efforts and resources. More information about how your data will be used by Brier & Thorn during the recruitment process will be provided as part of the recruitment process.

Brier & Thorn, Inc.

  • Country of Incorporation: United States
  • Registered Address: 1855 1st Avenue, Suite 103, San Diego, CA 92101

Brier & Thorn Mexico, S.A.P.I. de C.V.

  • Country of Incorporation: Mexico
  • Registered Address: Boulevard General Rodolfo Sánchez, Taboada 10488, 22010, Tijuana, Baja California

Brier & Thorn Germany, GmbH

  • Country of Incorporation: Deutschland
  • Registered Address: Königstraße 10C, 70173 Stuttgart, Germany
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