Privacy Policy

You take your privacy seriously and so does BGRS.  We are committed to keeping the personal information of our relocating customers and, as applicable, their spouses, partners, dependents or other household members (“Transferees”) accurate, secure and private.  We have adopted this General Privacy Policy to ensure that we continue to meet our commitment to your privacy.  Our General Privacy Policy describes what information we gather and how we collect, protect and use that information.  This General Privacy Policy also describes how you can correct or change your information.  BGRS is committed to complying with all applicable data privacy laws where we operate.  For Transferees resident in the European Union, Switzerland, Canada or Australia, please see Section VIII below.

Except as provided in Section VIII below, this General Privacy Policy applies to the entire BGRS family of companies and to the following BGRS web sites: www.bgrs.com and www.reloaccess.com.  These web sites are hosted by servers located in the United States (“U.S.”), and all information submitted by you thus will be transferred to the U.S. regardless of your location.  By using one or more of these sites, you are consenting to this General Privacy Policy and the collection, use and disclosure of your personal information by BGRS as outlined in this General Privacy Policy.  If you do not agree with the terms described in this General Privacy Policy, please do not use these sites or submit any personal information.  Your continued use of the sites and submission of information will be deemed your conclusive acceptance of our General Privacy Policy.

Information Collection and Use

“Personal Information” means information that can be used to identify an individual.  We may collect and use Personal Information including your name, telephone number, address and email address, employment information, as well as other identifying information.  We may also in limited circumstances and as necessary for the relocation collect and use sensitive information such as health or disability data.  We obtain consent from Transferees where required under applicable law for the processing of Personal Information, including sensitive information, in cases where your employer (our client) has not done so on our behalf.  We may collect Personal Information about you when you provide it to us through our web site, over the phone or by mailing it to us.  We also may collect Personal Information about you from your employer or other third parties such as our suppliers who provide services to you.  The Personal Information collected will be used only to communicate with you and to help us provide relocation services to you in accordance with our client agreements.  As necessary for these purposes, we may share your Personal Information among the companies within the BGRS family.  You have the right to opt out of any use of your Personal Information that is incompatible with the purposes for which we originally collected it or that you subsequently authorized.

We often engage and coordinate third party suppliers to provide our relocation services to you.  To facilitate the delivery of our services, we use suppliers in many countries throughout the world.  The location of the suppliers that will assist us in providing services to you will depend on the particulars of your relocation assignment.  These suppliers are given access only to the Personal Information, if any, that is needed to provide the specific service for which we contract them to provide.  They are contractually bound to protect the confidentiality and security of your Personal Information.  They must agree to limit the use of your Personal Information for the purpose intended in providing the service and are prohibited from doing anything with your Personal Information that we have not authorized them to do.  They are required to treat your Personal Information in a manner consistent with this General Privacy Policy.

We also may disclose Personal Information about you as required or permitted by law.  We do not sell Personal Information about you to anyone, nor do we permit any of our suppliers to do so.  We will retain your Personal Information only as long as necessary to provide you with our services or as required by our contractual arrangements, data retention policies, or by legal requirements.

Correcting/Updating Your Information

We are committed to keeping your Personal information accurate and up-to-date. If you are a current customer and have registered for online access through one of our web sites, you may be able to update Personal information such as: your address, telephone number, email address, user name, password and secret question online.  If you are unable to access or make changes to the information you have provided to us online, you may contact us in order to do so.  To request access to your Personal Information and/or to correct or update it, please use the contact information provided in Section V below. We will act in good faith and take reasonable steps to comply with your request.

Transferees resident in the EU and Switzerland should refer to Annex A for information about how to access personal data covered by Privacy Shield that is held by BGRS.

Security

We restrict access to your Personal Information only to those of our employees, agents and suppliers who have a “need to know” and based on the services we or they are providing to you.  We maintain reasonable physical, electronic and procedural safeguards designed to protect Personal Information.  Our external suppliers and others that we do business with are contractually bound to us to provide at least the same level of privacy protection and security as is required by this Privacy Policy.  We regularly review our security standards and procedures as well as those of our suppliers to protect against unauthorized disclosure or use of or access to your Personal Information.

Cookies

Some of our web sites may make use of “cookie” technology to measure site activity and to customize information to your personal tastes. A cookie is an element of data that a web site can send to your browser which may then store the cookie on your hard drive. Subsequently, when you come back to visit us again, we can tailor information to suit your individual preferences. The goal is to save you time and provide you with a more meaningful visit. Cookies may collect information, including a unique identifier, user preferences, profile information, membership information, general use and volume statistical information, individual web site use data, or provide electronic personalization.  Cookies cannot be used to collect sensitive information about your computer or data residing on your computer. Most major web sites use this technology and most browsers are set up to accept them.

When you visit our site, we may collect and store information about your visit. We use this information to measure site activity and to develop ideas for improving our site. This information may include: time and length of your visit; web pages you look at on our site; the web site you visited just before coming to ours and the name of your Internet service provider.

Visitors may disable cookies by visiting their browser settings and adjusting their browser’s cookie settings; however, disabling cookies may interfere with the ability to access and/or view certain content on this site.

Who to Contact

For questions or complaints regarding this General Privacy Policy or our privacy practices, or to make an access request, please contact:

By email:

By mail:

Richard D. Ballot
General Counsel
150 Harvester Drive, Suite 201
Burr Ridge, IL 60527

By telephone:

1.973.889.6146

Collection of Personal Information from Children

This site is not directed toward children, including those under the age of 13. We do not knowingly collect or post any information, including Personal Information, from children.

Changes to Our General Privacy Policy

Our General Privacy Policy has been updated and is effective as of the date on which the U.S. Department of Commerce has placed the self-certification submission for BGRS on the Privacy Shield List after having determined that the submission is complete, and remains in effect until amended.  BGRS reserves the right to amend this General Privacy Policy at its sole discretion.  Any alterations to this General Privacy Policy will be posted on our web site in a timely manner.

Compliance With The Specific Data Protection Laws

BGRS complies with the EU-U.S. Privacy Shield Framework Principles and Swiss-U.S. Privacy Shield Framework Principles, including the Supplemental Principles, as set forth on the U.S. Department of Commerce web site.  See Annex A for our EU-U.S. and Swiss-U.S. Privacy Shield Policy addendum to our General Privacy Policy, the terms of which shall supersede our General Privacy Policy in the event of any conflicting provisions.

While this General Privacy Policy governs all of the companies within the BGRS family, additional policies may apply to other regions in which the company operates based on local laws and regulations.  The following links will bring you to additional regional privacy policies that may be applicable:

Australia – http://www.au.brookfield.com/general/privacy (please note that BGRS has closed its offices in Australia, but may process data about Australian citizens)

Canada – click here.

Annex A: BGRS EU-U.S. and Swiss-U.S. Privacy Shield Policy (“Privacy Shield Policy”) 

Scope & Application

This Privacy Shield Policy applies to personal data of the residents of European Union member countries (including Iceland, Liechtenstein and Norway) (collectively, the “EU”) and Switzerland, received by BGRS in the United States from the UnionEU and Switzerland, and recorded in any form, and that is subject to the EU-U.S. Privacy Shield Principles [i], and the Swiss-U.S. Privacy Shield Principles (collectively, the “personal data”). For all such personal data.  For all EU Personal Data, this Privacy Shield Policy supplements the General Privacy Policy.  Where the Privacy Shield Policy is inconsistent with the General Privacy Policy with regard to the processing of Datasuch personal data, the Privacy Shield Policy will prevail.

 

Compliance with EU-U.S. and Swiss-U.S. Privacy Shield

BGRS complies with the EU-U.S. Privacy Shield Framework Principles, the Swiss-U.S. Privacy Shield Framework Principles, and the Supplemental Principles (collectively, the “Principles”), which includes compliance with the specific procedures, obligations, and provisions detailed below.  BGRS’s compliance with each of the relevant Principles is confirmed in further detail below.

Notice

BGRS adheres to the Notice Principle.  BGRS applies the Principles to all personal data, and has certified its adherence to the Principles.  To learn about the Principles and to view our Privacy Shield self-certification, please visit: https://www.privacyshield.gov/list.  Please review this Privacy Shield Policy and the General Privacy Policy, including those Sections of each referenced below, for complete information regarding BGRS’s adherence to the Principles.

BGRS’s Collection, Use, and Disclosure

BGRS collects, uses, and discloses personal data relating to Transferees of the types described in Section I of the General Privacy Policy and for the purposes described in Section I of the General Privacy Policy and Section III.5 of this Privacy Shield Policy.  BGRS discloses such personal data to third party suppliers in order to provide relocation services to Transferees; such third party suppliers include real estate, household goods transportation, travel, language, financial, immigration, spousal counseling, and education service providers, among others.

Means for Individuals to Limit Use and Disclosure

BGRS adheres to the Choice Principle and the Sensitive Data and Choice – Timing of Opt Out Supplemental Principles. BGRS or the corporate customer with which BGRS contracts to provide relocation or other services for one or more of its employees (i.e., Transferees) (the “Client”) obtains consent from Transferees to process their personal data, and BGRS offers Transferees choice regarding the processing of their personal data, including where relevant sensitive data is from the EU and/or Switzerland, as described in Section III.2 of this Privacy Shield Policy.

Inquiries, Complaints, and Right of Access

Individuals may contact BGRS to submit inquiries or complaints regarding BGRS’s adherence to the Principles and to request access to their personal data using the contact information listed in Section V of the General Privacy Policy. Please see Section III.6 of this Privacy Shield Policy for more information regarding the right to request access to personal data.

BGRS has designated JAMS to serve as an independent dispute resolution body to address unresolved complaints regarding BGRS’s adherence to the Principles and provide appropriate recourse at no cost to individuals covered by this Privacy Shield Policy. Please see Section III.7 of this Privacy Shield Policy for more information regarding the process for submitting complaints about BGRS’s practices with respect to personal data.

An individual may also invoke binding arbitration pursuant to the conditions and procedures set out in Annex I to the Principles.  Arbitration is available to an individual to determine, for residual claims, whether BGRS has violated its obligations under the Principles as to that individual, and whether any such violation remains fully or partially unremedied.  This option is available only for these purposes.

BGRS Is Subject to the Investigatory and Enforcement Powers of the Federal Trade Commission and Complies With Lawful Data Requests

BGRS is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).  BGRS may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

BGRS’s Liability In Cases of Onward Transfers

In the context of an onward transfer, BGRS is responsible for the processing of personal data that it receives and subsequently transfers to a third party agent acting on its behalf.  BGRS remains liable under the Principles if its agent processes such personal data in a manner inconsistent with the Principles, unless BGRS proves that it is not responsible for the event giving rise to the damage.

Choice

In cases where BGRS acts as a data controller (or co-controller with its Client), BGRS adheres to the Choice Principle and the Sensitive Data and Choice – Timing of Opt Out Supplemental Principles.

Depending on BGRS’s contractual arrangements with each Client, BGRS may obtain consent directly from Transferees to process their personal data in connection with the provision of relocation services. For certain other Transferees, BGRS’s Client may obtain consent from the employee of the Client who is to be relocated and then authorizes BGRS to process relevant personal data, including where relevant sensitive data from the EU and Switzerland, in connection with the provision of relocation services pursuant to a service provider contract.

BGRS offers individuals who are covered by this Privacy Shield Policy the opportunity to choose (“opt out”) whether his or her personal data is to be disclosed to a third party. BGRS also offers individuals who are covered by this Privacy Shield Policy the opportunity to opt out if BGRS provides notice that it intends to use his or her personal data for a purpose that is materially different from the purpose(s) for which it was originally collected or authorized by the Transferee in question. Individuals may opt out by sending an email to: privacy@bgrs.com or by calling:  1.416.380.7564.  If opting out, please provide, at a minimum, your name and identify your employer in order to assist BGRS in verifying your identity, and please identify the uses or disclosures of your personal data by BGRS for which you are choosing to opt out.  Note that opting out may affect BGRS’s ability to provide some of its relocation services.

With regard to sensitive data from the EU and Switzerland, BGRS or its Client will obtain affirmative express consent (opt in) if sensitive data from the EU and Switzerland is to be disclosed to a third party or is to be used for a purpose other than that for which it was originally collected or subsequently authorized by the individuals through the exercise of opt in choice, unless the information in question is subject to an exception contained in the Sensitive Data Supplemental Principle.

In cases where BGRS is acting as a processor, BGRS will assist its Client in complying with the Choice Principle.

Please see Section III.1.b of this Privacy Shield Policy for more information regarding BGRS’s adherence to the Choice Principle and the Sensitive Data and Choice – Timing of Opt Out Supplemental Principles.

Accountability for Onward Transfer

BGRS adheres to the Accountability for Onward Transfer Principle and the Obligatory Contracts for Onward Transfer Supplemental Principle.

Security

BGRS adheres to the Security Principle. BGRS takes reasonable and appropriate measures to protect personal data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the personal data. In cases where BGRS is acting as a processor, BGRS secures personal data in accordance with its contractual obligations to its Clients. For more information on the data security measures employed by BGRS, please see Section III of the General Privacy Policy.

Data Integrity and Purpose Limitation

BGRS adheres to the Data Integrity and Purpose Limitation Principle. BGRS’s collection and use of personal data is limited to the information that is relevant for the purposes of processing, including, for example, the purposes described in Section I of the General Privacy Policy as well as those that, depending on the circumstances, reasonably serve customer relations, compliance and legal considerations, auditing and due diligence, security and fraud prevention, preserving or defending BGRS’s legal rights, or other purposes consistent with the expectations of a reasonable person given the context of the collection. This may include processing in the manner described in the Performing Due Diligence and Conducting Audits Supplemental Principle.

BGRS will keep personal data of Transferees in accordance with the terms and conditions of the relevant customer agreement in cases where BGRS is acting as a processor or agent. In cases where BGRS is acting as a data controller, BGRS may retain such personal data of a Transferee for the longer of any of the following: (i) the period during which the Transferee remains an active customer of BGRS; (ii) the period specified in the Transferee’s unambiguous consent to the processing of its data by BGRS for relocation purposes; or (iii) as long as necessary for BGRS to meet any applicable legal requirements or to protect its legitimate interests, including with respect to actual or potential legal claims.

Access

BGRS adheres to the Access Principle and Access Supplemental Principle. Individuals from EU and Switzerland may obtain access to personal data about them that BGRS holds. For this purpose, “access” means that individuals have the right to: (i) obtain from BGRS confirmation of whether or not BGRS is processing personal data relating to them; (ii) have communicated to them the personal data relating to them so that they can verify its accuracy and the lawfulness of the processing; and (iii) have their personal data corrected, amended, or deleted where it is inaccurate or processed in violation of the Principles. Individuals from EU and Switzerland may request to access their personal data using the contact information listed in Section V of the General Privacy Policy.

BGRS may limit or deny access as provided in the Principles, including where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated.  If BGRS determines that access should be restricted in any particular instance, BGRS will provide as appropriate to the individual requesting access an explanation of why BGRS has made a determination to restrict access and a contact point for any further inquiries.  BGRS is not required to provide access unless it is supplied with sufficient information to allow it to confirm the identity of the person making the request.  BGRS will respond to all access requests within a reasonable time period, in a reasonable manner, and in a form that is readily intelligible to the individual.

In cases where BGRS is acting as a processor, BGRS will obtain authorization from its Client prior to providing access or refer the requesting individual to the appropriate Client contact.

BGRS may charge a fee for providing access where necessary or appropriate.

Please see Section III.1.c of this Privacy Shield Policy for more information regarding BGRS’s adherence to the Access Principle and Access Supplemental Principle.

Recourse, Enforcement, and Liability

BGRS adheres to the Recourse, Enforcement and Liability Principle and the Verification and Dispute Resolution and Enforcement Supplemental Principles.  BGRS has established in-house procedures for receiving and addressing complaints.  Individuals may contact BGRS to submit inquiries or complaints regarding BGRS’s adherence to the Principles using the contact information listed in Section V of the General Privacy Policy.  BGRS will respond to individuals within 45 days of receiving a complaint.

BGRS utilizes JAMS, an alternative dispute resolution provider based in the United States, to investigate and expeditiously resolve complaints and disputes that cannot be resolved internally, at no cost to the individual, by reference to the Principles. Unresolved complaints may be directed to JAMS using the complaint submission form found here. Individuals are encouraged to raise any complaints they have with BGRS before proceeding to JAMS. The JAMS complaint and recourse mechanism described here is available to individuals from EU and Switzerland whose personal data has been collected or processed by BGRS under the Principles. The JAMS complaint and recourse mechanism is not available to individuals from EU whose personal data has been collected or processed by BGRS under any other EU data transfer adequacy mechanism.

BGRS has implemented a self-assessment procedure to verify that the attestations and assertions that BGRS has made about its Privacy Shield privacy practices are true and that they have been implemented as presented and in accordance with the Principles.  BGRS is obligated to remedy problems arising out of any failure to comply with the Principles.

Please see Section III.1.c of this Privacy Shield Policy for more information regarding BGRS’s adherence to the Recourse, Enforcement and Liability Principle and the Verification and Dispute Resolution and Enforcement Supplemental Principles.

Adherence to the Principles

BGRS adheres to or its data practices with respect to personal data are consistent with the Principles, including those not specifically listed above, such as the Supplemental Principles of:  Self-Certification; Travel Information; Public Record and Publicly Available Information; and Access Requests by Public Authorities.

[i] BGRS’s agreements with its corporate clients determine whether personal data that is transferred to points outside the European Union are to be covered by the EU-U.S. Privacy Shield Principles or another EU-approved adequacy mechanism, including the EU Standard Contractual Clauses.  In the event that the relevant agreement is silent on this point, this Privacy Shield Policy shall apply to the personal data covered by the agreement.