Welcome to the Privacy Policy of Berlin Consulting ("we," "us," "our," or "the Company"). We understand the importance of your privacy, and we are committed to protecting your personal information. This Privacy Policy outlines our practices for collecting, using, maintaining, and disclosing your information when you use our services, visit our website, or sign on to our Expert Panel.
Please read this Privacy Policy carefully. By using our website and services, you agree to the collection, use, and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy may be updated and amended from time to time, please regularly check this page to review any changes.
Information We Collect
We may collect your personal information from the following sources:
a. Our communications: If you contact us via letter, telephone, online chat, email, or other electronic means, we may retain records of such communications;
b. Information you provide to us: Personal information you submit to us, such as your name, Pinyin, title, position, contact details, username, or similar identifiers, provided during the registration process required for accessing and using the website or in the course of interacting with us;
c. Your transaction information: Details of transactions you conduct through our website or other channels, as well as information regarding the performance of the services we provide;
d. Your website browsing records and communication devices used: Details of your website visits and information collected through cookies and other tracking technologies, including but not limited to your IP address and domain name, browser version and operating system, traffic data, location data, network logs, other communication data, and the resources you access;
e. Questionnaire information: We may also request you to complete questionnaires for our research purposes. In such cases, we will collect the information provided in the completed questionnaires;
We collect different types of personal information, which may include:
a. Personal Identifiable Information (PII): Information that can be used to identify you, such as your name, email address, phone number, and ID number
b. Non-Personal Identifiable Information (Non-PII): Information that cannot be used to identify you directly, such as your browsing history, website usage, and device information.
c. Personal financial information: including the name of the bank account holder and the bank account number.
d. Expert Panel Member Information: Information that can be used to verify information about you, including but not limited to your personal information, and contact information.
e. Public information: Personal information that are publicly available, including on social media platforms, recruiting platforms, resume platforms, or job seeking platforms.
f. Third party Information: Personal information that is provided by third party agencies.
Please note that sensitive personal information among the above is marked in bold.
How We Use Your Information
We may use your personal information in the following ways. For each use, we will specify the reason for our use to demonstrate that the processing of your personal information is legitimate. Generally, we use your personal information to:
a. For research and development: Analyze information to better understand the service needs of you and our clients, gain deeper insights into our business, and develop our products and services;
b. Record and monitor certain activities: Record and monitor telephone calls and transactions to ensure service quality, compliance with procedures, and combat fraud;
c. Inform you of changes: Notify you of changes to our services and products;d. Ensure the relevance of website content: Ensure that the content of our website is presented to you and your device in the most effective manner;
d. Restructure or change our business: If we (i) are negotiating the sale of all or part of our business to a third party, (ii) have sold to a third party, or (iii) are undergoing restructuring, we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process, or to the restructured entity or third party for the same purposes set out in this Policy or to analyze any proposed sale or restructuring;
e. Regarding legal or regulatory obligations: Law enforcement agencies, regulatory authorities, and court services. We may process your personal information to comply with our regulatory requirements or engage with regulatory authorities where applicable, which may include disclosing your personal information to third parties, court services, and/or regulatory or law enforcement agencies to enable such agencies to conduct inquiries, litigation, or investigations anywhere in the world or as required. Where permitted, we will forward any such request to you or notify you before responding, unless doing so would impede the prevention or detection of a crime.
If you are an expert, we may also conduct background checks on you to comply with our compliance processes, including the prevention of fraud, bribery, corruption, and sanctions violations.
If you are an expert, by registering and agreeing to this Privacy Policy, you consent to Berlin Consulting sharing your work experience and details of your current occupation/role with our clients in connection with our proposed cooperation. If you agree to participate in a consultation with a client, you consent to us sharing your name and contact details (including telephone number, email address, and other electronic contact methods) with that client to enable you to participate in the consultation. If you agree to participate in an interview that will be uploaded to our content portal, you consent to us displaying your name, current occupation/role, and work experience alongside the transcript and recording of the interview. You acknowledge that all our clients with licensed access worldwide may access our content portal. Our clients will be contractually obligated not to share, distribute, or otherwise provide access to such content to any person who is not a licensed user. However, we do not guarantee their performance of this contractual obligation. We may also publicly disclose your name and biographical information in connection with the transcript and recording of the interview with you, but only with your explicit written consent.
Transmission, Storage, and Security of Personal Information
Data security is of great importance to us. To protect your data, we have established appropriate physical, electronic, and administrative procedures to maintain and safeguard the data collected through our website. In addition, access to your personal information is restricted to our employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal information in accordance with our instructions and are obligated to maintain confidentiality.
We commit to:
a. No data transmission over the Internet or through a website can be guaranteed to be completely secure from intrusion. However, we implement commercially reasonable physical, electronic, and procedural security measures to protect your personal information as required by data protection laws. In any case, we recommend that you take appropriate precautions when transmitting data to us over the Internet. Despite our best efforts to ensure security, you assume the risk that any transmission of such data may become insecure. By providing us with your personal data, you agree to this arrangement. We will make reasonable efforts to ensure the security of your data. We have adopted industry-standard, commercially reasonable physical, electronic, and administrative security measures to protect the security of your personal information. However, please note that no data transmission over the Internet or through a website can be 100% secure. Therefore, although we will make every effort to protect your personal information, we cannot guarantee the absolute security of Internet transmissions. We recommend that you also take appropriate precautions (such as using complex passwords, ensuring a secure network environment, etc.) when transmitting sensitive information to us via the Internet.
b. All information you provide to us is stored on our secure servers and accessed and used in accordance with our security policies and standards. Where we have provided you with (or you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential and complying with any other security procedures we notify you of. We ask that you do not share your password with anyone.
c. We will transmit the personal information we collect about you to jurisdictions outside the People's Republic of China via the Internet and internal networks connecting our information systems to effectively provide services to our clients, conduct business, and for other purposes specified in this Privacy Policy. We commit that such transmissions will strictly comply with the requirements of the Personal Information Protection Law of the People's Republic of China and other applicable laws and regulations. We will only transmit your personal information (including sensitive personal information) to the extent necessary and will cooperate with overseas data recipients to process your personal information in a secure manner to protect your legitimate interests and avoid causing harm to you. Unless otherwise required by applicable law, we and the overseas data recipients will only retain your personal information for the shortest necessary retention period.
d. We will retain your personal information for as long as necessary for the purposes of collecting and processing the information and any other permitted related purposes (for example, certain transaction details and communications may be retained until the expiration of the statute of limitations for claims related to the transaction or to comply with regulatory requirements regarding the retention of such data). Therefore, if the information is used for both purposes, we will retain the information until the expiration of the latest period relevant to the purposes; however, we will cease using the information for the purposes after the expiration of the shorter period.
e. We will only allow personnel who need the information for relevant purposes to access your personal information. Our retention periods are based solely on business needs.
f. Any payment details you add will be encrypted.
Legal Bases for Processing Personal Information
When processing your personal data for the purposes set out in this Notice, one or more of the following legal bases may apply, depending on the circumstances:
a. Consent: We may process your personal data with your prior explicit consent (this legal basis applies only to fully voluntary situations and not to any mandatory or obligatory processing);
b. Necessary for the performance of a contract: We may process your personal data where it is necessary for the performance of any contract entered into between us (for example, if you are a member of Berlin Consulting's expert panel, have submitted an application to be a member of the expert panel, or are a client of Berlin Consulting);
c. Required by applicable law: We may process your personal data as required by applicable law;
d. Vital interests: We may process your personal data where it is necessary to protect the vital interests of the relevant individual;
e. Legitimate interests: We may process your personal data where we have a legitimate and valid interest in doing so. We conduct the following balancing test for all situations:
f. We ensure that the processing is carried out in a legal and appropriate manner in accordance with the relevant provisions of this Notice;
g. We ensure that our processing is based on reasonable business needs;
h. And we ensure that the processing will not have any adverse impact on your interests, fundamental rights, or freedoms.
When processing your personal data for the purposes set out in this Notice, one or more of the following legal bases may apply, depending on the circumstances:
The applicable legal basis is as follows:
California Consumer Privacy Act (CCPA)
If you are a California resident, you have certain rights under the California Consumer Privacy Act ("CCPA"):
a. Right to Know: You have the right to request that we disclose the categories and specific pieces of personal information we have collected about you, the sources of that information, the purposes for collecting it, and the categories of third parties with whom we share it.
b. Right to Delete: You have the right to request the deletion of your personal information that we have collected, subject to certain exceptions under the CCPA.
c. Right to Opt-Out: You have the right to opt-out of the sale of your personal information. We do not sell your personal information.
d. Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your privacy rights under the CCPA.
To exercise any of these rights, please contact us using the information provided in the "Contact Us" section of this Privacy Policy. We may ask you to verify your identity before processing your request. We will respond to your request within 45 days, unless we need additional time, in which case we will notify you of the extension.
California residents also have the right to appoint an authorized agent to make a request under the CCPA on their behalf. To appoint an authorized agent, you must provide the agent with written permission and may also be required to verify your identity with us. We may deny a request from an agent that does not provide proof of authorization.
Personal Information Protection Law of the People's Republic of China (PIPL)
If you are a resident of China, you have certain rights under the Personal Information Protection Law ("PIPL"):
a. Right to Know and Access: You have the right to access and request information about the personal information we have collected about you, the purposes for which it was collected, and the third parties with whom we share it.
b. Right to Correct: You have the right to request corrections or updates to your personal information if it is inaccurate or incomplete.
c. Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions under the PIPL.
d. Right to Limit or Withdraw Consent: You have the right to limit or withdraw your consent for the collection, use, and sharing of your personal information at any time, subject to certain exceptions under the PIPL.
e. Right to Complain: You have the right to file a complaint with the relevant regulatory authority if you believe that our handling of your personal information does not comply with the PIPL.
To exercise any of these rights, please contact us using the information provided in the "Contact Us" section of this Privacy Policy. We may ask you to verify your identity before processing your request. We will respond to your request within a reasonable time, in accordance with the requirements of the PIPL.
Please note that we may be unable to provide certain services to you if you choose to exercise your right to limit or withdraw consent for the collection, use, or sharing of your personal information.
European Union's General Data Protection Regulation (GDPR)
If you are a resident of the European Union (EU), you have certain rights under the General Data Protection Regulation (GDPR):
a. Right to Access: You have the right to request access to the personal data we hold about you, including the purposes for processing, the categories of personal data concerned, and the recipients to whom the data has been disclosed.
b. Right to Rectification: You have the right to request the correction of inaccurate or incomplete personal data we hold about you.
c. Right to Erasure: You have the right to request the deletion of your personal data, subject to certain exceptions under the GDPR.
d. Right to Restrict Processing: You have the right to request the restriction of processing of your personal data in certain circumstances, such as when the accuracy of the data is contested or when the processing is unlawful.
e. Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller without hindrance.
f. Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or when the processing is based on legitimate interests.
g. Right to Withdraw Consent: You have the right to withdraw your consent to the processing of your personal data at any time, where consent is the legal basis for the processing.
h. Right to Lodge a Complaint: You have the right to lodge a complaint with the relevant data protection authority if you believe that our processing of your personal data does not comply with the GDPR.
To exercise any of these rights, please contact us using the information provided in the "Contact Us" section of this Privacy Policy. We may ask you to verify your identity before processing your request. We will respond to your request within one month, unless we need additional time, in which case we will notify you of the extension.
Your Rights & Contact Us
You have the right to request that we do not process your personal information for marketing purposes. You may exercise this right by checking certain boxes on the forms we use to collect your personal information to prevent such processing.
Under data privacy laws, you may have the right to request that we:a. Provide you with more details about how we use your personal information;b. Provide you with a copy of the personal information you have provided to us;c. Update any inaccuracies in the personal information we hold;d. Delete any personal information for which we no longer have a legitimate reason to use;e. Withdraw your consent where the information is processed based on consent, to enable us to stop that specific processing;f. Object to any processing based on legitimate interests, unless our reasons for conducting such processing outweigh any harm to your data protection rights;g. Restrict our use of your information during the investigation of a complaint;h. And deactivate your account.
The exercise of these rights is subject to certain exemptions to protect the public interest (for example, the prevention or investigation of crimes) and our interests (for example, the preservation of legal privilege). If you exercise any of these rights, we will review your eligibility and respond in most cases within one month.
We will make reasonable efforts to ensure that your personal information is accurate. If you are dissatisfied with our use of your personal information, our response to these rights, or have any questions or concerns about this Policy, please contact us at: compliance@berlin-en.cn
Changes to Our Privacy Policy
We may change the content of our website and how we use cookies without prior notice, so our Privacy Policy may change from time to time in the future. Therefore, we recommend that you review the Privacy Policy periodically when browsing the website to stay informed of how we use personal information.
Your Consent
Use of our website constitutes your agreement to our Privacy Policy.
Dispute Resolution
We will make every reasonable effort to negotiate in good faith and resolve any disputes arising out of or in connection with this Privacy Policy or any breach thereof.
No dispute shall affect our continued performance of obligations under this Privacy Policy.
This Privacy Policy and any disputes or claims arising out of or in connection with it (including non-contractual disputes or claims) shall be governed by and construed in accordance with the laws of the People's Republic of China. Any dispute arising out of or in connection with this Privacy Policy shall first be resolved by the parties through friendly negotiation in good faith. If the negotiation fails, either party shall have the right to submit the dispute to the people's court with jurisdiction over Berlin Consulting's place of domicile for resolution through litigation.
Privacy Policy for Berlin Consulting
Last Updated: Nov 1st, 2025