Privacy Statement

1. Collection and use of personal information

1.1 What information we collect

We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you will have previously provided your personal information to us (if, for example, you are a former employee). If you choose to register or login to a B S R web site using a third party single sign-in service that authenticates your identity and connects your social media login information (e.g., LinkedIn, Google, or Twitter) with B S R, we will collect any information or content needed for the registration or log-in that you have permitted the social media provider to share with us, such as your name and email address. Other information we collect will depend on the privacy settings you have set with your social media provider, so please review the privacy statement or policy of the applicable service.

When you register or submit personal information to B S R we will use this information in the manner outlined in this privacy statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards.

For example, if you register to a B S R web site and provide information about your preferences, we will use this information to personalize your user experience. Where you register or login using a third-party single user sign-in we may also recognize you as the same user across any different devices you use and personalize your user experience across other B S R sites you visit. If you send us a resume or curriculum vitae (CV) to apply online for a position with B S R, we will use the information that you provide to match you with available B S R job opportunities.

In some cases where you have registered for certain services, we will store your email address temporarily until we receive confirmation of the information you provided via an email (i.e. where we send an email to the email address provided as part of your registration to confirm a subscription request).

1.2 What legal grounds do we have to use your personal information?

B S R generally collects only the personal information necessary to fulfill your request. Where additional, optional information is sought, you will be notified of this at the point of collection.

We can process personal information, so long as we have a ground under the law to do so. It also requires us to tell you what those grounds are. As a result, when we process your personal information, we will rely on one of the following processing conditions:

• Performance of a contract: this is when the processing of your personal information is necessary in order to perform our obligations under a contract;
• Legal obligation: this is when we are required to process your personal information in order to comply with a legal obligation, such as keeping records for tax purposes or providing information to a public body or law enforcement agency;
• Legitimate interests: we will process information about you where it is in our legitimate interest in running a lawful business to do so in order to further that business, so long as it doesn’t outweigh your interests; or
• Your consent: in some cases, we will ask you for specific permission to process some of your personal information, and we will only process your personal information in this way if you agree to us doing so. You may withdraw and/or modify your consent at any time by contacting in-fmprivacy@bsraffiliates.com.
• Public interest: we may process personal information in order to perform a specific task in the public interest or in the exercise of official authority vested in us.

Examples of the ‘legitimate interests’ referred to above are:

• To offer information and/or services to individuals who visit our website or offer information about employment opportunities.
• To prevent fraud or criminal activity and to safeguard our IT systems.
• To customize individuals’ online experience and improve the performance usability and effectiveness of B S R's online presence.
• To conduct, and to analyze, our marketing activities.
• To meet our corporate and social responsibility obligations.

In some cases, the personal information that we collect will also include special categories of data, such as diversity related information (including data about racial and ethnic origin, political opinions, religious beliefs and other beliefs of a similar nature, trade union membership and data about sexual life and sexual orientation), or health data and data about alleged or proven criminal offences in each case where permitted by law.

1.3 Personal information related to children

B S R understands the importance of protecting children's privacy, especially in an online environment. Our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.

2. Sharing and transfer of personal information

2.1 Transfer to fellow sub-licensees

We may share information about you to our sub-licensees as part of different engagements where required or desirable to meet our legal, contractual and regulatory obligations in which case personal data would be appropriately protected as per applicable laws.

2.2 Transfers to third parties

We do not share personal information with third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards.

B S R may store personal information outside India. If we do this your personal information will continue to be protected.

B S R will not transfer the personal information you provide to any third parties for their own direct marketing use.

3. Choices

In general, you are not required to submit any personal information to us, but we will require you to provide certain personal information for you to receive additional information about our services and events. B S R will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

4. Automatic collection of personal information

In some instances, B S R use cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of B S R's online presence, and to measure the effectiveness of our marketing activities.

5. IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate will be recorded for IT security and system diagnostic purposes. This information will also typically be used in aggregate form to conduct web site trend and performance analysis.

6. How we use Cookies?

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes. On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as "user-input" cookies may still be required for necessary functionality. Such cookies will not be blocked using this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser's cookies. Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser's settings (often found in your browser's Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites' features. Further information about managing cookies can be found in your browser's help file or through sites such as www.allaboutcookies.org

Below is a list of the types of cookies used on our web sites:

Other third-party tools and widgets may be used on our individual web pages to provide additional functionality. Use of these tools or widgets may place a cookie on your device to make their service easier to use, and ensure your interaction is displayed on our webpages properly.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors.

BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

7. Google Analytics

B S R uses Google Analytics. More information about how Google Analytics is used by B S R can be found here: https://www.google.com/analytics/learn/privacy.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

7.1 Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. B S R only uses web beacons in accordance with applicable laws.

B S R may use web beacons to track the effectiveness of third-party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

In some of our newsletters and other communications, we may monitor recipient actions such as email open rates through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.

7.2 Location-based tools

B S R may collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

7.3 Social media widgets and applications

B S R web sites may include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications may collect and use information regarding your use of B S R web sites (see details on 'Social Sharing' cookies above). Any personal information that you provide via such social media applications may be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

In addition, B S R web sites may host blogs, forums, crowd-sourcing and other applications or services (collectively "social media features"). The purpose of social media features is to facilitate the sharing of knowledge and content. Any personal information that you provide on any B S R social media feature may be shared with other users of that social media feature (unless otherwise stated at the point of collection), over whom we may have limited or no control.

8. Your Rights

If B S R processes personal information about you, you have the following rights:

• Access and correction: you have the right to access to that data. This is sometimes called a ‘Subject Access Request’. If we agree that we are obliged to provide personal information to you, we will provide it to you free of charge. Before providing personal information to you, we may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. If the information we hold about you is incorrect, you are entitled to ask us to correct any inaccuracies in the personal information.
• Object to processing: you have the right to object to us processing your personal information if we are not entitled to use it anymore.
• Other Rights: in addition, you may have rights to have your information deleted if we are keeping it too long, have its processing restricted in certain circumstances and/or to obtain copies of information we hold about you in electronic form.
• Right to Withdraw Consent: You can withdraw your consent that you have previously given to one or more specified purposes to process your personal data. This will not affect the lawfulness of any processing carried out before you withdraw your consent. It may mean we are not able to provide certain products or services to you and we will advise you if this is the case. If you would like to exercise your Data Subject Rights, you can email to in-fmprivacy@bsraffiliates.com.
  We may need to request specific information from you to help us confirm your identity and ensure your right to access the information or to exercise any of your other rights. This helps us to ensure that personal data is not disclosed to any person who has no right to receive it. No fee is required to make a request unless your request is clearly unfounded or excessive. Depending on the circumstances, we may be unable to comply with your request based on other lawful grounds.

You can make a request or exercise these rights by contacting us at in-fmprivacy@bsraffiliates.com and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.

9. Data security and integrity

B S R has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite B S R's best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

We retain personal data for as long as it is needed to provide our services, stay in contact with you and to comply with applicable laws, regulations, and professional obligations that we are subject to and for other legitimate business reasons.

10. Changes to this statement

B S R may modify this privacy statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. Any changes to the processing of personal information as described in this privacy statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

11. Policy questions and enforcement

B S R is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personal information, please contact us at in-fmprivacy@bsraffiliates.com. You may also communicate any concerns that you may have regarding compliance with our privacy statement.

We will acknowledge your email within [14] days and seek to resolve your concern within one month of receipt. Where the concern is complex or we have a large volume of concerns, we will notify you that the concern will take longer than one month to resolve, and we will seek to resolve your concern within three months of the concern being first raised. We may accept your concern (and in that case implement one of the measures set out in the ‘Your Rights’ section above), or we may reject your concern on legitimate grounds.