BGRS China Privacy Notice

Last Modified: June 2022

1. Introduction

This Privacy Notice applies to individuals inside the People’s Republic of China (“China” or “PRC”).

As a talent mobility/relocation management business (BGRS), we are entrusted everyday with collecting and managing personal information of client assignees and transferees. In doing so, we observe the appropriate PRC data protection laws.

Additionally, our data protection and privacy obligations extend to each of our service partners (supply chain) and other service providers with whom we share personal information as they work on your behalf. That is one of the reasons why we carefully screen our service partners – the companies and specialists that handle specific relocation and mobility services from household goods management to immigration to compensation support. We not only ensure they are taking good care of your data; we also verify that they have proper systems in place to protect confidential personal information.

In order to ensure that you are reliably informed about how we operate, we have developed this Privacy Notice, which describes the ways in which we collect, manage, process, store and share information about you as a result of you visiting this site and engaging with BGRS. The Privacy Notice also provides you with information about how you can have control over the use of your data.

If you have any comments or queries regarding our use of your data, please contact our Global Data Protection Officer at privacy@bgrs.com

Alternatively, you can write to our Global Data Protection Officer at BGRS, 150 Harvester Drive, Suite 201, Burr Ridge, IL 60527 USA.

2. What information do we collect about you and how do we collect it?

Often in connection with providing services, or otherwise communicating with you, BGRS may need to collect certain information. The information that we need for these purposes is known as your “personal information” (and your family members’ personal information, if applicable). This may include name, home and/or business address, personal and/or business email address, date of birth, country of birth, government issued identification numbers, job title, salary information, employee identification number, bank account details, gender, marital status, number of dependents, telephone and other contact numbers, and financial information.

We collect this in a number of ways; for example, you may provide personal information to us directly online, via email or over the telephone, or when corresponding with us by letter. We also may collect personal information about you from your employer or other third parties, such as our service partners who provide services to you. When you provide your family members’ personal information to us, you hereby guarantee that you have informed the relevant data subject of the purpose of processing his or her personal information, the fact that you will provide his or her personal information to BGRS, and that you have obtained consent from the data subject.

In support of some services, we may also collect sensitive personal information during your engagement with us, including:

  • financial accounts; and
  • personal information of minor family members under the age of 14

We only collect such sensitive personal information for the purposes of delivering our services. Such information will only be used for that purpose, and we will take strict protective measures to safeguard the security of the personal information that you provide to us. We understand that our processing of your sensitive personal information will not have an adverse impact on you. Where appropriate, we may voice record some of the interactions we have with you. Such recordings will automatically be stored for training and monitoring purposes, and any personal information captured will be strictly protected.

Please also be advised that when you visit this website, cookies will be used to collect information about you such as your Internet Protocol (IP) address which connects your computer or mobile device to the Internet, and information about your visit such as the pages you viewed or searched for, page response times, download errors etc. We do this so that we can measure our website’s performance and make improvements in the future. Cookies are also used to enhance this website’s functionality and personalization, which includes sharing data with third party organizations. You can control this by adjusting your cookies settings as described in our Cookie Policy set out in our general Privacy Policy here.

3. How will we use the information?

In general terms, we seek to collect information about you and your family members (if applicable) so that we can:

  • administer our relationship with you, provide services and respond to enquiries;
  • implement the services that the client has authorized in accordance with the client policy;
  • enable business development including sending invitations to meetings and events and sending out newsletters;
  • deliver information to you about our services;
  • ensure the billing of any procured services and obtain payment;
  • process and respond to any complaints;
  • enable us to meet our legal and other regulatory obligations imposed on us; and
  • audit usage of our services.

The personal information collected will be used only to communicate with you and to help us provide services to you and your employer in accordance with our client agreements.

4. With whom will we share your personal information?

Generally speaking, we will not share your personal information with third parties, except for the circumstances we listed in the general Privacy Policy.

Additionally, in the event of a merger, dissolution, reorganization or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, would be transferred to the surviving entity in a merger or the acquiring entity. According to the Personal Information Protection Law of the PRC, we will inform you of the name and contact information of the recipient of your personal information. All such transfers shall be subject to our commitments with respect to the privacy and confidentiality of such personal information as set forth in this Privacy Notice. This policy shall be binding upon BGRS and its legal successors in interest.

5. Your rights

Right to access to personal information

You have the right to access any personal information we hold about you.

You can make a request to access your information by contacting us at:

Global Data Protection Officer
BGRS
150 Harvester Drive, Suite 201,
Burr Ridge, IL 60527 USA

Or by email at privacy@bgrs.com

Upon receipt of your request, we will ask you to provide sufficient information to prove your identity and address before any personal information is released to you.

Although there is no fee for meeting your request, we reserve the right to charge a reasonable fee if, in our reasonable judgement the request is manifestly unfounded, excessive or repetitive.

Any fee charged will be based upon the administrative cost of providing the information.

We have fifteen working days from the date of receipt of your request to comply. This may be extended if the request to access is complex.

If you request large amounts of information, we may ask you to specify in more detail the information you require.

Right to rectification

You have the right to request that we rectify personal information which is inaccurate or incomplete. In the first instance contact your Relocation Consultant in writing, specifying the inaccurate or incomplete personal information. Provide them with the correct personal information and ask them to rectify it.

We are required to rectify the information within fifteen working days. This may be extended if the request for rectification is complex.

If you feel that your request for rectification is not being dealt with, you can escalate your request to the Global Data Protection Officer at the address given above.

Right to delete

You have a right to have personal information deleted and to prevent further processing in the following circumstances:

  • Where the personal information is no longer necessary in relation to the purpose for which was originally collected of processed, such purpose cannot be realized or has already been realized;
  • Where we stop providing the products or services or the retention period has expired;
  • When you withdraw your consent for your personal information to be processed;
  • Personal information has been processed in violation of this Notice;
  • Personal information has unlawfully been processed;
  • Where there are any other circumstances stipulated by laws and administrative regulations.

We may refuse to comply with your request for deletion if we are required to comply with a legal or statutory obligation, or if the personal information will be required for the purpose of resolving a claim, complaint or in the defense of a claim or complaint.

Right to restrict processing

You have the right to restrict the processing of your personal information in the following circumstances:

  • Where you contest the accuracy of the personal information which is being processed. You can ask for the restriction to be put in place until you are satisfied that the inaccuracies have been rectified;
  • The processing of the information is deemed to be unlawful but you do not want your personal information to be deleted;
  • The personal information is no longer required by BGRS but you would like us to retain it to establish, exercise or defend a legal claim.

Right to object

  • You have the right to object to the processing of your personal information related to direct marketing even if you have previously consented to your personal information being processed for that purpose.

If you object, we will cease processing your personal information for marketing purposes as soon as we receive your written objection.

You can raise your objection at any time by contacting the Global Data Protection Officer at the above address.

Right to ask for explanation

You have the right to ask BGRS to explain our rules on personal information processing. You may contact the Global Data Protection Officer at the above address for exercising such right.

6. How long will we retain information for?

We will retain your personal information for no longer than is necessary for the maintenance of our contract with the client (your employer) and while we are providing on-going services to you. We will also retain your personal information to meet legal or regulatory requirements. We will not typically retain your personal information for longer than seven years.

7. Overseas transfers

Our websites are hosted by servers located in the United States (“U.S.”), and all information submitted by you will thus be transferred to the U.S. regardless of your location. Information that we collect about you is shared within the BGRS family globally as appropriate, and with approved third party service and business partners.

8. Data privacy and security

At BGRS, we maintain a comprehensive data privacy and security work program, which includes processes for ensuring that data protection is a key consideration of all new and existing IT systems that hold personal information. Where any concerns, risks or issues are identified, we conduct relevant impact assessments in order to determine any actions that are necessary to ensure optimum privacy.

We also maintain an active information security work program which seeks to protect the availability, confidentiality and integrity of all physical and information assets. Specifically, this helps us to:

  • Protect against potential breaches of confidentiality;
  • Ensure all IT facilities are protected against damage, loss or misuse;
  • Increase awareness and understanding of the requirements of information security, and the responsibility of our colleagues to protect the confidentiality and integrity of the information that we handle, and
  • Ensure the optimum security of this website.

9. Changes to our Privacy Notice

This Privacy Notice has been updated and is effective as of the date indicated at the beginning of this Privacy Notice, and remains in effect until amended. BGRS reserves the right to amend this Privacy Notice at its sole discretion. Any alterations to this Privacy Notice will be posted on our websites in a timely manner. By accessing these websites or using the services after we make any such changes to this Privacy Notice, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of your personal information is governed by the Privacy Notice in effect at the time we collect such information. Please refer back to this Privacy Notice on a regular basis.

10. General

Questions and comments regarding this Privacy Notice are welcomed, and should be sent to our Global Data Protection Officer at privacy@brgs.com

Alternatively, you can write to our Global Data Protection Officer at BGRS, 150 Harvester Drive, Suite 201, Burr Ridge, IL 60527 USA.

You can also contact our Global Data Protection Officer if you have any concerns or complaints about the way in which your personal information has been handled as a result of you using our website.