Privaatsuspoliitika - Brink's Estonia
Brink’s Privacy Statement
Effective Date: 22th October 2021
- Personal Information We Obtain and How We Obtain It
- How We Use Personal Information
- How We Share Personal Information
- Data Transfers
- How We Protect Your Personal Information
- Retention of Your Personal Information
- Your Rights and Choices
- Children’s Personal Information
- Links to Other Sites
- Updates to this Privacy Statement
- How to Contact Us
- California Consumer Privacy Statement
Brink’s Incorporated and its affiliates and subsidiaries (collectively, “Brink’s,” “we,” “our,” “us,” or “the Company”) respect your concerns about privacy and recognize the importance of being transparent about our privacy practices. This Privacy Statement describes the types of personal information we obtain, how we may use and retain that personal information, with whom we may share it, and the rights and choices available to you with respect to our use of that information. This Privacy Statement also describes the measures we take to safeguard the personal information we obtain and how you may contact us about our privacy practices or to exercise your rights.
The entity that is responsible for the processing of your personal information (i.e., the data controller) is the Brink’s affiliate or subsidiary that operates the relevant website or mobile application or provides Brink’s services (“Services”) to you. You can find the contact details of our affiliates and subsidiaries on our website by clicking on a country name at the top of the home page.
This Privacy Statement applies to personal information we obtain, including:
- through our websites, social media pages, mobile applications and other digital platforms we operate or control, whether directly or indirectly via third parties, that reference this Privacy Statement (collectively, the “Online Channels”);
- when you use our Services or purchase our products, and through other offline interactions (“Offline Channels”);
- through third-party sources, including business partners, advertising and social media companies, and vendors; and
- through other data collection points that reference this Privacy Statement (collectively, the “Channels”).
This Privacy Statement is meant to apply globally but does not override applicable data privacy laws and regulations in countries where the Company operates. Certain Brink’s entities may also use localized variances of this Privacy Statement, which will be displayed on the relevant Channels and available upon request to the local Data Protection Officer.
We collect personal information about you in different ways and from various sources. This section describes the type of personal information we collect from you or about you.
Personal Information You Provide
Depending on the nature of your interactions with us, you may provide us with personal information about you in different ways, including:
When You Contact Us
When you send us an email, fill in a contact form, give us a call or contact us in other ways, we will collect your contact information such as your name, email address, postal address, telephone number, and a record of our correspondence or conversation with you. Depending on the subject of your request, we may collect additional information such as the product you are interested in to get a quote, or, if you are an existing customer and request support, your location, customer code or any other relevant information that helps us identify you as a customer).
When You Sign Up for Our Newsletters
You may sign up to receive Brink’s updates, blog post notifications and Brink’s news, in which case we will collect information such as your name, company name, email address, job title and phone number.
When You Write a Testimonial or Review
We may collect personal testimonials of satisfied customers in addition to other endorsements. By submitting such information, you grant Brink’s the right to post and publish such information at our sole discretion.
When You Participate in Surveys
We and our partners may invite you to participate in surveys about our Services. If you choose to participate in the surveys, we may ask you for information such as your name, email address, postal address, telephone number and opinion on our Services.
When You Register for or Use Our Services
When you create an account with us or register for our Services, we will ask for your personal information to create your account or complete your registration.
The types of personal information we may collect include:
- Contact information such as name, email address, postal address, and telephone number;
- Login credentials such as username and password;
- Government-issued ID information to the extent permitted under applicable law, such as copy of an ID document, customer information file number (CIF), Taxpayer Identification Number (TIN), other “doing business as” (DBA) number(s), and other government-issued identification number(s);
- Billing and financial information such as bank, credit or debit card number, account type, routing number, bank institution name, account balance, credit history, investment activity, income or source of funds, and payment/transaction history;
- Business or commercial information such as company name, primary business address, secondary business address, ownership information, products or Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; and
- Any other personal information you provide to us.
We also may ask for and collect personal information about other people when you use our Services, such as your organization’s authorized signatory, main contact and beneficial owners. If you choose to submit any personal information relating to other people, you represent that you have the authority to do so and permit us to use the information in accordance with this Privacy Statement. The information we request is necessary for the purposes described in the “How We Use Personal Information” section of this Privacy Statement. Without this information, we may not be able to provide you with the requested Service.
Personal Information We Obtain by Automated Means
Personal Information Obtained from Other Sources
In addition to the personal information you provide to us directly or that we collect by automated means, we may obtain additional personal information about you from other sources, including from government agencies or public records (such as business profiles from public databases), and data from third-party sources (such as personal information we obtain from our third-party service providers and business partners (including background check providers, credit check providers, data aggregators and data cleansing companies), and marketing partners).
We use the personal information you provide directly to us as described above to take pre-contractual steps at your request or to fulfill our contractual obligations with you, including to:
- Perform our Services, including to fulfill orders, manage contracts, process payments, and provide the Services you request;
- Respond to you and provide customer support, including to address your inquiries and feedback, requests, and other communications you send us, and provide you with support services;
- Manage your Brink’s account, including to create, administer, and update your Brink’s account; and
- Manage our administrative communications, including to send you information regarding our Services, such as changes to our terms, conditions, and policies and/or other administrative information.
We also may use the information we obtain directly or indirectly from you as described above if we have a legitimate interest to do so, including to support the following functions and activities:
- Marketing, including to present or send you updates, news, and other types of information about offers, promotions, and events that may be of interest to you, and to plan and execute our marketing campaigns and promotions. Where required by applicable law, we will send these communications with your consent;
- Market research and analysis, including to administer our surveys;
- Credit and other financial dealings, including to analyze your eligibility for credit, collect debt, and other financial dealings;
- Prevention and Protection, including to protect the security and integrity of our Online Channels and Services, our users, and others, to identify and prevent fraud and other unlawful activity, and to protect and defend the Company against legal claims and other liabilities;
- Operating, evaluating, and improving our business, including to perform accounting, auditing, record keeping, credit risk management, and other internal functions, such as data analysis, developing new offerings, and monitoring and improving the use of (and satisfaction with) our Services;
- Posting your testimonials and reviews on our Online Channels in addition to other endorsements; and
- Legal and Compliance, including to comply with and enforce applicable laws and regulations, industry standards, and contractual obligations, as well as our policies and terms and conditions, and to cooperate with law enforcement.
In addition, we may use your personal information to comply with our legal obligations, including to keep accounting records.
We may combine data collected from you with other sources to help us improve our products, Services, marketing, and communications, as well as to help expand and tailor our interactions with you. This includes combining personal information we obtain through our Online Channels with information we obtain through offline sources, as well as other sources for the purposes described above. We may anonymize, de-identify, or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. To the extent required by applicable law, we will obtain your consent to do so.
We also may use the personal information we obtain in other ways for which we provide specific notice at the time of collection and obtain your consent if required by applicable law.
We will share your personal information with Brink’s personnel on a need-to-know basis, including internal legal, compliance and security experts. In addition, we may share your personal information with third parties, including as indicated below.
- Our Affiliates and Subsidiaries. We may share your personal information with our parent or affiliates and subsidiaries for the purposes set out in this Privacy Statement.
- Service Providers. We use service providers to help us provide our products and Services and to perform services on our behalf (such as providing security and IT services and support, performing data analysis and analytics, conducting audits, processing payments, assisting with our online advertising activities, fulfilling orders, providing customer service, and performing credit checks). We do not authorize these entities to use or disclose such information except as necessary to perform services on our behalf or to comply with legal requirements.
- Business Partners. We may share personal information with unaffiliated third parties who partner with us to deliver our Services or engage in other commercial activities. Depending on the choices you have made and the nature of the joint activity, these third parties may contact you regarding products or services of interest. However, we do not sell personal information to unaffiliated third parties for their own marketing purposes.
We also may disclose personal information about you (1) if we are required or permitted to do so by applicable law, regulation, or legal process (such as a court order or subpoena); (2) to public and government authorities to comply with a legitimate legal request; (3) when we believe disclosure is necessary to prevent physical harm or financial loss to the Company, our employees, our customers, the public, or others as required or permitted by law; (4) to establish, exercise, or defend our legal rights; (5) in connection with an investigation of suspected or actual fraud, illegal activity, security, or technical issues; (6) in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, or liquidation), or other business transaction; and (7) in other ways for which we provide specific notice at the time of collection and obtain your consent to the extent required by applicable law.
We may transfer the personal information we collect about you to countries outside of the country in which the information originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will implement appropriate safeguards to help ensure that we protect that information as described in this Privacy Statement and in accordance with applicable law.
If you are located in the European Economic Area (“EEA”), United Kingdom (“UK”), or Switzerland, we may transfer your personal information to other affiliates and our service providers or partners, including in the United States. U.S. laws have not been recognized as providing an adequate level of data protection by the European Commission. Accordingly, we will comply with legal requirements with respect to providing adequate protection for the transfer of personal information to those recipients, including, as appropriate, by executing data transfer agreements based on the European Commission’s Standard Contractual Clauses or selecting service providers or partners who implemented Binding Corporate Rules under Article 46 of the EU General Data Protection Regulation (“GDPR”), or relying on a derogation for specific situations under Article 49 of the GDPR (such as international payments for the performance of a contract with you or in your interest). Subject to applicable law, you may obtain a copy of these safeguards by contacting us as indicated in the “How to Contact Us” section of this Privacy Statement.
We maintain administrative, technical, and physical safeguards designed to protect the personal information you provide us against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.
To the extent permitted by applicable law, we typically retain personal information we obtain about you for as long as it is needed (1) for the purposes for which we obtained it and in accordance with the terms of this Privacy Statement, which generally means that we will keep your personal information for the duration of our relationship; (2) to take into account applicable statute of limitation periods and comply with applicable laws; or (3) for legitimate business purposes to the extent permitted by applicable law. As described in the “Your Rights and Choices” section of this Privacy Statement, to the extent provided by the law of your jurisdiction, you may request that we delete your personal information or restrict the use of such information by contacting us as indicated below.
Subject to applicable law, you may have certain rights and choices in connection with the personal information we obtain about you, such as how we use the information and how we communicate with you.
To update your preferences, limit the communications you receive from us, or submit a request, please contact us as specified in the “How to Contact Us” section of this Privacy Statement. You can also unsubscribe from our mailing lists by following the “Unsubscribe” link in our emails.
To the extent provided by the law applicable to our processing of your personal information, you may request access to the personal information we maintain about you or request that we correct, update, complete, amend, or delete your information, or that we restrict the processing of such information by contacting us as indicated in the “How to Contact Us” section of this Privacy Statement.
To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information or responding to requests related to your personal information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain.
If you are located in the EEA and the UK, you also may object to the use of your personal information in certain situations in which we use the information based on our legitimate interests, as described above, and at any time to the processing of your personal information for direct marketing purposes. In addition, to the extent provided by applicable law, you may (1) receive, in a structured, commonly used and machine-readable format, the personal information you have provided to us based on a contract, and (2) have such information transmitted to another company, where technically feasible. Where provided by law, you may withdraw any consent you previously provided to us, and we will apply your preferences going forward. This will not affect the lawfulness of our use of your information based on your consent before its withdrawal. To exercise these rights, please contact us as specified in “How to Contact Us” section of this Privacy Statement. Depending on your location, you may have the right to file a complaint with a privacy regulator if you are not satisfied with our response.
Our Online Channels are designed for a general audience and are not directed to children under the age of 18. We do not knowingly collect or solicit personal information from children under the age of 18 through our Online Channels.
Our Online Channels may contain links to other sites and apps on the Internet that are owned and operated by third parties. The information practices of those websites and apps linked to our Online Channels are not covered by this Privacy Statement. We are not responsible for the privacy notices of third-party websites or apps to which our Online Channels link. If you provide any information to such third parties, different rules regarding the collection and use of your personal information may apply. We strongly suggest you review such third parties’ privacy notices before providing any data to them.
This Privacy Statement may be updated periodically to reflect changes in our information practices. We will post a notice on our Online Channels to notify you of significant changes to this Privacy Statement and indicate at the top of the Privacy Statement when it was most recently updated. We encourage you to periodically review this Privacy Statement for the latest information on our privacy practices.
If you have any questions about this Privacy Statement or would like to exercise your privacy rights under applicable law, please contact the Brink’s affiliate or subsidiary that operates this site or application or which provides the Services to you. You can find a full list of our affiliates and subsidiaries on our website. If you are located in the EEA and the UK, you may contact our data protection officer by email at: email@example.com.
A “cookie” is a small text file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings in the browser. A “web beacon”, also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We use these automated technologies to collect information about your devices, browsing actions, and usage patterns. We use on our Online Channels both first-party cookies (served directly by our website domain when you visit our Online Channels) and third-party cookies (served by a third-party website when you visit our Online Channels and certain third-party websites with whom we have partnered). Some of these cookies are session cookies (which are automatically deleted when you close your browser) and others are persistent cookies (which remain on your computer or other Internet-connected device for a period of time after you end your browsing session, unless you delete them).
The cookies we use on our Online Channels include functionality cookies (which enable improved website and app performance and an enhanced user experience) and analytics cookies (which help us analyze how you navigate through and use our Online Channels).
With respect to analytics cookies, we use third-party analytics services on our Online Channels, such as those of Woopra and Google Analytics. To learn more about Google Analytics and how to opt out, please visit: https://policies.google.com/technologies/partner-sites.
The third-party apps, tools, widgets, and plug-ins on our Online Channels also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of these features and is subject to the privacy notices of such providers.
How to Change Your Cookie Settings
You can stop certain types of cookies from being downloaded on your device by selecting the appropriate settings on your web browser. Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie and how to disable existing cookies. The following external links will explain how to manage cookies for the most common browsers:
To find out how to manage cookies for other browsers, please click “help” on your browser’s menu or visit www.allaboutcookies.org. In addition, your mobile device settings may allow you to prohibit mobile app platforms (such as Apple and Google) from sharing certain information obtained by automated means with app developers and operators such as us. Our Online Channels are not designed to respond to “do not track” signals received from browsers. Please note that without cookies or other automated tools we use to collect this type of data, you may not be able to use all the features of our Online Channels.
Effective Date: 22th October 2021
Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
- Identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers, and similar technology; Brink’s account number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, IP address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers;
- Additional Data Subject to Cal. Civ. Code § 1798.80 such as signature, state identification card number, bank account number, credit card number, debit card number, and other financial information;
- Commercial Information such as records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies;
- Online Activity such as Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications, or advertisements;
- Geolocation Data;
- Protected Classifications such as race, color, national origin, age, sex, gender, citizenship status, and military and veteran status, and other characteristics of protected classifications under California or federal law;
- Sensory Information such as audio, electronic, visual, and similar information; and
- Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
- Performing Services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short Term Use, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Detecting security Incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality: Identifiers; Online Activity; and Sensory Information
- Internal R&D for technological development and demonstration
- Safety, including undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
We also may collect additional information or use the information listed above in other ways for which we provide specific notice at the time of collection.
Our Prior Collection, Use, and Disclosure of Personal Information
Sources of Personal Information. We may have obtained personal information about you from various sources, including as described below.
- Directly from you (such as when you purchase and use our products or Services; contact us with requests, feedback, or suggestions; or provide product invitations or referrals);
- Your devices (such as when you visit our websites or apps);
- Our affiliates and subsidiaries;
- Our service providers and business partners;
- Unaffiliated third parties with whom we partner to deliver our Services or engage in other commercial activities;
- Government entities, law enforcement authorities, and third-party subpoenas; and
- Publicly available sources.
Sharing of Personal Information. We may have shared your personal information with certain categories of third parties, as described below, including for the business purposes described above.
- We may have shared the following categories of your personal information with our affiliates and subsidiaries: identifiers, additional data subject to Cal. Civ. Code § 1798.80, commercial information, online activity, geolocation (if true), sensory information and inferences.
- We may have shared the following categories of your personal information with our service providers: identifiers, additional data subject to Cal. Civ. Code § 1798.80, commercial information, online activity, geolocation (if true), sensory information and inferences.
- We may have shared the following categories of your personal information with our business partners: identifiers, additional data subject to Cal. Civ. Code § 1798.80, commercial information, online activity, geolocation (if true), sensory information and inferences.
- We may have shared the following categories of your personal information with professional services organizations (such as auditors and law firms): identifiers, additional data subject to Cal. Civ. Code § 1798.80, commercial information, online activity, geolocation (if true), sensory information and inferences.
- We may have shared the following categories of your personal information with data analytics providers: identifiers, additional data subject to Cal. Civ. Code § 1798.80, commercial information, online activity, geolocation (if true), sensory information and inferences.
- We may have shared the following categories of your personal information with third parties in the event of a corporate transaction, such as an acquisition: identifiers, additional data subject to Cal. Civ. Code § 1798.80, commercial information, online activity, geolocation (if true), sensory information and inferences.
Sale of Personal Information. We do not sell your personal information. We do not have actual knowledge that we sell personal information of minors under 16 years of age.
California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
- Access and Deletion. You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected about you during the past 12 months and details regarding our collection, use, disclosure, and sale of such information. You also have the right to request that we delete certain personal information we have collected from you. To submit an access or deletion request, please contact dpo_CCPA@brinksinc.com or call 1-877-275-4585. To submit a CCPA request as an authorized agent on behalf of another individual, please contact dpo_CCPA@brinksinc.com.
Verifying Requests. To help protect your privacy and maintain security, we will take steps and may require you to provide certain information to verify your identity before granting you access to your personal information or complying with your request. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion, or opt-out of sale request on your behalf, we may require the authorized agent to provide proof that you provided the authorized agent signed permission to do so, and (b) for access and deletion requests, we may require you to (i) verify your own identity directly with us (as described above) or (ii) directly confirm that you provided the authorized agent permission to submit the request.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.