Brunswick Corporation Privacy Policy

Effective Date: [12 October 2018]

Brunswick respects your concerns about privacy and values its relationship with you.

This Privacy Policy applies to information collected by Brunswick Corporation, any affiliated or subsidiary companies (“Brunswick,” “we” or “us”), offline or online, including, but not limited to all websites or apps that post a link to this Privacy Policy (collectively, “the Sites”).

This Privacy Policy explains the types of information we collect, the purposes of processing that information, the legal basis for processing that information, how we use that information, and with whom we share it. Our Privacy Policy describes the measures we take to protect the security of the information and the rights that you have as a data subject with regard to this information. We also tell you how you can reach us to update your contact information, remove your name from our mailing lists, or get answers to questions you may have about our privacy practices. Please read this Privacy Policy carefully. By continuing to interact with our sites, you are agreeing to the practices described in this Privacy Policy.

UPDATES TO OUR PRIVACY POLICY

This Privacy Policy may be updated periodically. We may modify this Privacy Policy at any time in our sole discretion. If we make material changes to this Privacy Policy that increase our rights to use personal information we have previously collected about you, we will obtain your consent either through an email to your registered email address or by prominent posting on our sites. If we intend to further process your personal data for a purpose other than that for which the personal data were collected, prior to that further processing, Brunswick shall provide you with information about that other purpose and with additional information necessary to ensure fair and transparent processing.

INFORMATION WE COLLECT

We collect personal information including your name, address, telephone number, employer, email address, site password, demographic information, health information, or financial information when you visit the Sites, create an account with us, or register a product or purchase with the Sites. Some of our sites also offer you the option to interact with, capture, or save information through the Sites such as photos or forum posts.

We also automatically collect information about the devices you use to interact with our Sites. The information we automatically collect includes device identifier, web browser, precise geolocation (with your knowledge and consent), browsing information collected through cookies and beacons on our Sites, and IP address. We also automatically collect information about how you use the Sites, such as what you have searched for and viewed with the Sites. The information automatically collected will be associated with any personal information you have provided.

PURPOSES AND LEGAL BASIS FOR PROCESSING INFORMATION

The information we collect is processed for the following purposes:

To serve the functions of the Sites;
To manage everyday business needs, such as administration and improvement of the Sites;
To analyze the Sites’ performance and functioning;
To prevent fraud; to enforce the Sites’ Terms of Use; to comply with all applicable laws and corporate reporting obligations; and to enforce Brunswick’s agreements;
To analyze how you use the Sites and to perform other market research;
To provide and communicate with you about our products and services;
To provide you with advertisements based on your interests;
To provide you with information about financial options for the purchase of our products;
To facilitate your interaction through our Sites with other consumers, including through social networking; and
To send you further notices, promotions, solicitations, brochures, or other marketing materials regarding our Sites, our products, and the services of our businesses, affiliates, business partners, or authorized dealers.

Brunswick processes this information where we have a legal basis to do so. The legal basis that we will rely on will be one of the following:

You have consented to our processing your personal information;
The processing is necessary to perform a contract with you or to fulfill a request you have made;
The processing is necessary to comply with a legal obligation that applies to Brunswick under EU or Member State law; or
The processing is necessary for purposes that are in Brunswick’s legitimate interests as a multinational equipment retailer in order to, for example, protect our business and better understand our customers.

We may use your personal information to develop a personal profile about you. We may use the personal information in your profile to respond to requests for financial options for purchasing products and services from us.

If you notify us that you do not wish to be contacted for marketing purposes, we will not send you marketing information.

Our Sites do not collect personal information about your online activities over time and across third party websites or online services. Therefore, “do not track” signals transmitted from web browsers do not apply to our sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.

Additional ways in which personal information is collected and processed are as follows:

Information You Provide

Precise Geolocation Information. In order to use some of the Sites, you may be required to allow Brunswick to collect your precise geolocation, with your knowledge and consent, to provide you with a product or service. If you choose not to provide us with your precise geolocation information, these products and services will not function properly and we will not be able to provide them to you.

We will also use this precise geolocation information for analytics purposes, and will share your precise geolocation information with third parties, including but not limited to dealers and parties who provide targeted advertising and analytics services.

Information Request. If you request information about our products (e.g., order a brochure, a catalogue, or a magazine), we will ask you to provide personal information and details, such as your name, email address, telephone number, intended use of the relevant product, interests, etc. You may choose to provide additional comments and requests. We, or the authorized dealer in your area, will use your details to send you the information you request and may use this information to communicate with you in the future about our products or services.

Newsletters and Other Communications. We may offer online or offline newsletters and other communications about our products, services and promotions. When you sign up to receive these communications, we ask you for personal information, such as your name, postal address and email address. We, or the authorized dealer in your area, will use the information to send you the communications you request and to communicate with you about our products and services.

Feedback, Surveys, or Contests. We may offer you the opportunity to participate in online surveys, solicitations, or contests. Information we request includes contact information (such as e-mail address) and demographic information (such as number of family members and income ranges). Participation in surveys, solicitations, or contests is completely voluntary. Therefore, you have a choice as to whether to disclose any information. We, our business partners, or the authorized dealer in your area, will use the information provided to notify contest winners and award prizes, to monitor or improve the use of one or more websites or advertising, and to provide aggregated information for marketing analyses. Solicitations may take the form of mailings via U.S. mail; other couriers; or (if provided) email.

Careers. Our Sites may include a link to Brunswick Careers so that you may search for open Brunswick positions and apply for positions by submitting your resume and other personal information, such as your name, contact information, and job history. We use the information you submit to evaluate your interest in employment and to contact you regarding possible employment.

Locate a Dealer. Some of our Sites enable you to locate a dealer near you through the “find dealer” request form. Where this service is available, it is completely voluntary and you will have a choice as to whether to provide your personal information. In order to assist you in locating a dealer, we will ask you for information, such as your first and last name, full postal address and telephone number. We use this information to locate a dealer near you, to evaluate your needs and to give you the best and most relevant service. We, or the authorized dealer in your area, may use the information to communicate with you directly about our products and services.

Online Sales.

Brunswick Sites. Our branded merchandise is offered for sale by Brunswick directly from the Sites. If you transact with Brunswick via our Sites, your information will be collected to process orders. Your information will be collected either by Brunswick or by an authorized third party payment processor.

Third Party Sites. Our branded merchandise also is offered for sale by authorized third party merchandise partners through websites they own and control, which may be linked to the Sites. If you transact with an authorized third-party merchandise partner, your purchase will be conducted on our authorized third-party merchandise partner’s website, subject to the third party’s privacy policies and terms of use. You should review the privacy policy and terms of use that apply to that third party’s website, which will apply to your transaction.

Product Financing and Credit Refinancing. In some instances, we provide links to third-party vendors for product financing or credit refinancing information for some of our products. If such a link is provided, your information is transmitted directly to the third-party vendor and is not received by our companies. You should review the privacy policy and terms of use that apply to the third-party vendor’s website.

Owner’s Programs or Rewards Programs. Some of our Sites offer owner’s programs, reward programs, or coupons and request contact information and information on your product purchases, so that we can enroll you in these programs and communicate with you.

Product Registration. From time to time, some of our Sites may offer online product registration. By registering your product online, you agree that we, our business partners, an authorized dealer/service provider, or third-party advertising agency may contact you related to the product registration for a variety of reasons including, but not limited to, providing product notifications, as required by law, for customer service and/or warranty assistance, to maintain Brunswick’s databases and business processes, and/or to contact you for purposes otherwise stated in this Privacy Policy.

Referral Service. We offer a referral service that allows you to inform your friends and other acquaintances about products and/or information contained on (or through) Brunswick’s websites. If you elect to use such a referral service, the following will apply: email addresses) will be collected for the purpose of sending a one-time email for which you will be noted as the sender of such email. Brunswick will be a service provider facilitating such delivery.

Electronic Delivery for Shareholders. If you are a Brunswick shareholder and would like to receive shareholder materials by email, we ask you to register for this service on the Brunswick.com website. Registering will also allow you to vote your shares online. To register, if you are a shareholder in the United States or Canada, you must provide your Social Security number or tax ID number, your email address and a 4-digit PIN. If you are a shareholder in a country other than the United States or Canada, you must provide your Brunswick shareholder account number, your email address and a 4-digit PIN. We use the information you provide to verify that you are a Brunswick shareholder, to register you for the electronic delivery service, and to provide you with the electronic delivery and voting services you requested. You may also update or cancel your registration on the site by providing the same information.

Information We Automatically Collect

We collect certain information by automated means when you visit our Sites, such as how many users visited our Sites and the pages accessed. By collecting this information, we learn how to best tailor our Sites to our visitors. We collect this information through various means such as “cookies” and “web beacons.” In addition, we may collect IP addresses, as explained below. For more information regarding our use of cookies, please refer to our separate Cookie Policy [LINK].

Cookies. As described in our separate Cookie Policy [LINK], like many companies, we use “cookies” on some of our Sites. Cookies are pieces of code placed on your devices when you visit certain websites. We use cookies to tell us, for example, whether you have visited us before or if you are a new visitor and to help us identify features of the Sites in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website.

Most web browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all the features and functionality of the Sites.

Web Beacons. As described in our separate Cookie Policy [LINK], certain pages on our website contain “web beacons” (also known as Internet tags, pixel tags and clear GIFs). These web beacons allow third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears; the URL of the page on which the beacon appears; the time the page containing the beacon was viewed; the type of browser used to view the page; and the information in cookies set by the third party.

IP Addresses. An IP address is a unique identifier that certain electronic devices used to identify and communicate with each other on the Internet. When you visit our website and/or app, we view the IP address of the device you use to connect to the Internet. We then use this information to determine the general physical location of the device and understand the general locations of our website visitors. We also use this information to enhance our website and/or app.

BUSINESS STRUCTURE CHANGES

We reserve the right to disclose and transfer all information related to our Sites, including personal data:

to a subsequent owner, co-owner or operator of one or more of the Sites; or
in connection with a corporate merger, consolidation, or restructuring, the sale of substantially all of our stock and/or assets, or other corporate change, including, without limitation, during the course of any due diligence process.

CHILDREN’S PRIVACY

Our Sites are general audience Sites not directed at children under the age of 13. If we obtain actual knowledge that any information we collect has been provided by a child under the age of 13, we will promptly delete that information.

LINKING SOCIAL NETWORK ACCOUNTS

Some of the Sites allow you sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, YouTube, Instagram, and Pinterest with Brunswick.

By using this functionality you give Brunswick permission to access all of the elements of your social network profile information that you have made available to be shared and to use it in accordance with the social network’s terms of use and this Privacy Policy. Please refer to the privacy settings in your social network account for information about what data is shared with us and other connected applications and to manage the data that is shared through your account, including information about your activities using our sites.

If you would like to disconnect a social media account from Brunswick, refer to the settings of that social media account and its provider.

INFORMATION WE SHARE

We share the information you provide with affiliates, business partners, or authorized dealers to communicate with you about their products and services, and to send you further notices, promotions, solicitations, or brochures, and other marketing materials regarding our website, our products, and the services they provide. With your knowledge and consent, we will also share your precise geolocation with third parties, including but not limited to dealers and parties who provide targeted advertising and analytics services.

We also share your information with third parties who perform services and functions on our behalf to support our interactions with you including, for example, providing our products and services, administering surveys or contests, hosting product reviews, or communicating with you. These third parties are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. These third parties have no independent rights to the data.

In addition, we will disclose information about you:

If we are required to do so by law or legal process;
To law enforcement authorities or other government officials;
When we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
If this is necessary to protect the vital interests of a person;
To enforce our Terms of Use;
To protect our property, services and legal rights;
To prevent fraud against Brunswick, our affiliates, business partners, or authorized dealers;
To support auditing, compliance, and corporate governance functions; or
To comply with any and all applicable laws.

We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us to third parties for the third parties’ direct marketing purposes within the immediately preceding calendar year. We will provide you with a list of the categories of personal information disclosed and a list of the names and addresses of the third parties. To make such a request, please send an email including evidence of residency in California to [email protected].

Some of the Sites provide the opportunity for you to publicly post content. If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and aobtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to [email protected]. Please include evidence of residency in California, and age of requester. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

YOUR AUSTRALIAN PRIVACY RIGHTS

If you are an Australian resident and have any concerns or wish to make a complaint about a breach of an Australian Privacy Principle you should firstly raise your concerns or make your complaint to us in writing at [email protected] or through one of the methods in the “How to Contact Us” section of the privacy policy. We will investigate your concerns or complaint and respond to you within a reasonable period. You should allow us at least 30 days to respond. If you are unhappy with our response, you may take your complaint to the Office of the Australian Information Commissioner. Information on how you may take this action is available at www.oaic.gov.au.

Please note that Brunswick does not collect health information or other information that is “sensitive information” within the meaning of the Privacy Act 1988 (Commonwealth).

You have the option of dealing with us anonymously, however this only applies where it is practical for us to do so, such as providing a response to a general enquiry. For most other functions and activities, we will need your name and contact information and enough information about the particular matter to enable us to adequately serve you and perform our regular business functions. In these circumstances it will not be practical for you to operate under a pseudonym.

LINKS TO OTHER WEBSITES

Our Sites may provide links to other websites for your convenience and information. These websites may operate independently from our Sites. Linked websites may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites you visit are not part of this website, we are not responsible for their content, any use of the websites, or the privacy practices of any of those websites.

THIRD-PARTY ADVERTISEMENTS

Third parties, including advertisers, will collect information, potentially including personal information, about your activities over time and across different websites when you use the Sites. Those third parties provide Brunswick with data collection, reporting, ad response measurement, analytical information, and assist with delivery of relevant marketing messages and advertisements.

Collection of your personal information by third parties is not governed by this Privacy Policy. Please consult the privacy policies of those third parties to determine how they collect and use your personal information.

Many third-party advertisers and some web browsers and mobile devices allow you to opt out of third-party advertising. Information and resources to opt out of interest-based advertising are available from the Digital Advertising Alliance at http://www.aboutads.info/choices/. You may also opt out of tracking and receiving targeted advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices. Please note opting out through these mechanisms does not opt you out of being served advertising. You will continue to receive generic ads while visiting the Sites and elsewhere online.

INFORMATION WE TRANSFER

The Sites to which this Privacy Policy applies are subject to United States law, unless otherwise provided herein. By using the Sites or providing us with your personal information, you are transferring your personal information to us in the United States. In addition, we transfer the personal information we collect on the Sites to other countries where we do business, which may not have the same data protection laws as the country in which you reside. When we transfer your information to other countries, we will protect that information as described here, even though a given country may not have the same privacy and data protection laws as the country in which you reside. You agree to and acknowledge our collection, transfer, and processing of your personal information in accordance with this Privacy Policy.

HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical, and physical safeguards to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the information you provide when visiting or using the Sites.

YOUR RIGHTS

You have the right to request access to the personal information we have collected about you for the purposes of reviewing, modifying, or requesting erasure of the information. You also have the right to request a copy of the information we have collected about you. In certain situations, you may also request that we restrict or cease processing your information.

If you would like to make a request to access, review, or correct the personal information we have collected about you, please contact us at [email protected] or through one of the methods in the “How to Contact Us” section, below.

To help protect your privacy and security, we will take reasonable steps to verify your identity, such as requiring a password and user ID, before granting access to your information.

You will be notified of any actions taken on your personal information in response to a request submitted for modification, deletion, or restrictions on the processing of your personal information.

When data processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before such withdrawal. You also have a right to data portability when the data processing is based on a contract between you and Brunswick and the data was processed by automated means. You may exercise these rights by submitting a written request to [email protected]. Brunswick will respond to your request within one month.

You have the right to lodge a complaint with the appropriate privacy or data protection regulator in your jurisdiction. RETENTION OF INFORMATION

Brunswick retains all personal information for the duration of the relevant business relationship or, where required, in accordance with its information management policies and schedules. When deleting personal information based on a request by the data subject, Brunswick will make reasonable attempts to ensure that all instances of the information are deleted in their entirety. For requests for access, corrections, or deletion, please refer to the “Access and Correction” section of this policy.

Brunswick will maintain the necessary documentation to demonstrate compliance with all its obligations and to allow audits, including inspections, to be carried out by Brunswick or another auditor it has mandated, and to participate in such audits.

Brunswick shall keep a written data processing activity register, listing data processing activities by category. Brunswick will maintain the necessary documentation to demonstrate compliance with all its obligations and to allow audits, including inspections, to be carried out by Brunswick or another auditor it has mandated, and to participate in such audits.

PRIVACY SHIELD COMPLIANCE

Brunswick, as well as its U.S. affiliates, divisions, subsidiaries further identified below, comply with the EU-U.S. Privacy Shield Framework and Swiss-U.S. Privacy Shield Framework for Human Resources personal data as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States for Brunswick’s Human Resources operations. Brunswick has certified to the Department of Commerce that it adheres to the Privacy Shield Principles for Human Resources personal data. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

The U.S. Brunswick entities adhering to the Privacy Shield Principles for Human Resources personal data, include: Attwood Corporation; BBG Logistics, Inc.; Blue Water Finance, Inc.; Boston Whaler, Inc.; Brunswick Commercial & Government Products, Inc.; Brunswick Family Boat Co. Inc.; Brunswick Financial Services Corporation; Brunswick Leisure Boat Company, LLC; Brunswick Marine in EMEA, Inc.; Brunswick Marine Sales Corporation; Brunswick Product Protection Corporation; Cybex International, Inc.; Garelick Mfg. Co.; Land 'N' Sea Distributing, Inc.; Life Fitness International Sales, Inc.; Lund Boat Company; Marine Power International Limited; Marine Power International Pty. Limited; Marine Power New Zealand Limited; Sea Ray Boats, Inc.; and Thunder Jet Boats, Inc.

With respect to Human Resources personal data received or transferred pursuant to the Privacy Shield, Brunswick and its related entities listed above are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

In certain circumstances, employees who have submitted personal data to Brunswick for Human Resources purposes may invoke binding arbitration when other dispute resolution methods have been exhausted, as described in Annex 1 to the Privacy Shield.

As described in the Privacy Shield Principles, Brunswick remains responsible for any of your personal information received for Human Resources operations under the Privacy Shield and transferred to a third party acting as an agent on its behalf.

Brunswick commits to cooperate with EU data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred from the EU and Switzerland in the context of the employment relationship.

HOW TO CONTACT US

If you have any questions or comments about this Privacy Policy, please contact:

Brunswick Corporation
Attn: Law Department
1 North Field Court
Lake Forest, IL 60045
Phone: 855-283-1103 or 847-735-4002
Email: [email protected]

If you would like to update your contact information or preferences, have your information removed from our mailing lists, or no longer receive marketing e-mails resulting from information collected via product registration cards or other sources, you may do so by:

Adjusting the settings in an account you created through the Sites;
Unsubscribing via the links contained in emails from us; or

Contacting us at [email protected] or through one of the methods in this section.