This privacy policy describes how Brobizz A/S processes personal data in connection with the use of Brobizz products (Bizz transponders and/or number plate payment) by customers and other natural persons’ use of Brobizz digital platforms, including websites and app, registering and sending direct marketing, sending service notifications, surveys and satisfaction surveys, recording by Brobizz of phone calls, blocklisting and competition participation.
In this Privacy Policy, the term "Bizz transponder" is a common term for all types of physical transponders that can be used for electronic payment collection and which are part of the Brobizz product portfolio.
An overview of operators and partners for which Brobizz products can be used can be found at Brobizz.com.
The legal entity responsible for processing personal customer data is:
Brobizz A/S
CVR number: 31 85 48 22
Address:
Vester Søgade 10
1601 Copenhagen
Email: persondata@brobizz.com
(Hereinafter referred to as “Brobizz")
2.1 Customer agreement with Brobizz regarding payment collection when using Brobizz Products
Personal data categories
Brobizz may process the following general personal data about the Customer upon the Customer entering into a Customer Agreement on payment collection when using Brobizz Products: Contact information (name, address, postal code, city, country, e-mail and telephone number), the registration number of the associated vehicle, customer number, Bizz identification number, motor vehicle type, weight and environmental class of the vehicle if applicable, number of Products per Customer, payment card information, bank and account number if applicable, and information about driving transactions related to using the Product, including location data (driving time and driving location).
Depending on the operators or business partners with which the Customer’s Bizz transponder is used, the registration number of the vehicle with which the Customer intends to use the Bizz transponder is processed regularly.
When the Customer pays by number plate payment, Brobizz receives no image of the Customer's registration number from the operator or business partner but is simply notified that Number Plate Payment was used.
Brobizz also processes information about a Brobizz Customer’s customer relationship with an operator and/or business partner and the customer entering into a special agreement with the operator and/or business partner.
For Brobizz business customers, company name, CVR number and contact details of a contact person are also processed.
Purpose
Brobizz processes all of the above personal data for the overall purpose of being able to administer and maintain the Customer Agreement with the Customer for use in payment collection for passages and crossings with operators and business partners and to deliver agreed Products to facilitate payment collection. The data is collected directly from the Customer while information that the Product has been used for passages and crossings with operators and business partners is received from the respective operator or business partner.
Contact information, bizz Product identification number and personal data that may be generated from an enquiry by the Customer or other natural person are also processed for the purpose of answering and processing the enquiry. This information is collected directly from the customer or other natural person contacting Brobizz.
If the Customer expresses the wish to be contacted by the Brobizz sales function, e.g. via an online contact form, the personal data is processed for this purpose. Information for this purpose is collected directly from the Customer.
Brobizz processing information about a Brobizz Customer’s customer relationship with an operator or business partner is always done with the aim of assisting in the fulfillment of, e.g. a local agreement or other special agreement entered into directly between the Customer and the operator or business partner, e.g. in relation to assistance for concluding and administering a discount agreement with the operator or business partner. The personal data used for this administration and assistance is collected directly from the Customer or the relevant operator or business partner.
Where required by the operator or partner, the Customer's personal data, such as the registration number of the vehicle associated with the Bizz transponder, may be disclosed to the operator or partner for the purpose of charging the Customer correctly pursuant to the Customer's Agreement with either Brobizz, an operator or partner. As an example, this might be in the event that the Bizz transponder cannot be read.
Personal data, such as location data, is used to prepare general analyses and statistics with a view to supporting, improving and optimising operations in relation to payment collection and for use in the payment collection itself.
A vehicle registration number not collected directly from the Customer, but from SKAT's Central Register for Motor Vehicles, is used for the purpose of administration and recording a correct and up-to-date registration number of the vehicle associated with a Product.
If, as an example, Brobizz has reason to question if a Customers' contact information is up to date, e.g. if Brobizz has tried to send out physical or electronic mail and the mail was returned with a message about an invalid address, Brobizz can collect information from other sources, such as CVR, an operator or a business partner with the aim of managing and ensuring correct updating of the Customer contact information in question.
Legal basis
The legal basis for the processing is Article 6(1)(b) of the EU Data Protection Regulation (as necessary for the fulfillment of a contract to which the Customer is a party).
With respect to answering enquiries from individuals who are not customers and regarding support and improving operations, the legal basis is the EU Data Protection Regulation 6(1)(f) (legitimate interest), where the legitimate interest of Brobizz is to manage enquiries and to support, improve and optimise operations in relation to payment collection.
Storage
Brobizz stores the personal data for as long as necessary for the purposes mentioned above.
Personal data related to the customer's customer relationship is stored for as long as a customer relationship exists. If a customer is inactive for more than 18 months (number plate payment) or 36 months (bizz) the customer relationship will end; if the customer uses no product for more than three months, the customer relationship will end; data is stored for a maximum of three years after termination of the Agreement.
Customer Service enquiries and responses are stored for 13 months except for those relating to required bookkeeping information, which are stored for five years plus the current year.
Personal information relating to legal action is stored as long as the case is pending and up to 10 years after the legal action has ended.
Information about customers' driving transactions is stored for five years plus the current year in accordance with the requirements of the Danish Bookkeeping Act.
2.2. Provider of Toll Box for the Toll Scheme
From January 1, 2025, trucks will be required to pay tolls when driving on toll-eligible road segments. This scheme will hereafter be referred to as the “Toll Scheme.” This section per-tains to our “Toll Box,” which is a Brobizz product capable of handling toll payments. You can read more about Brobizz’s Toll Box here.
Purpose
Brobizz processes personal data about you if you or your workplace has entered into an agreement for a Toll Box, which you use in your truck. We process personal data to be able to administer and maintain the agreement for the Toll Box. This includes processing your infor-mation to deliver the Toll Box and collect tolls.
Categories of Personal Data
We may process the following general personal data about you when you, as a truck owner or truck user, drive on the Danish road network with a Toll Box:
• The name of the company you are employed by and represent
• The company's CVR number
• Contact information in the form of your name, email, and phone number
• The registration number of the vehicle associated with the Toll Box
• The company's customer number
• Identification number of the Toll Box
• Motor vehicle type
• Vehicle data, including the vehicle's weight, environmental class, and CO2 class
• Number of products associated with your workplace
• Information about driving transactions using the Toll Box, including location and time of travel
Sources
When you or your workplace enters into an agreement for a Toll Box, we collect your per-sonal data directly from you or from your workplace.
If Brobizz suspects that your contact information is not up-to-date, Brobizz may collect infor-mation from other sources. This can include the CVR, an operator, or a partner. This pro-cessing aims to ensure the correct updating of our customers' contact information.
Legal Basis
If you own a sole proprietorship and purchase a Toll Box from Brobizz, we process your personal data based on GDPR Article 6(1)(b) (necessary for the performance of a contract to which you are a party).
If your workplace purchases a Toll Box, which you use in your truck, we process your personal data based on GDPR Article 6(1)(f) (legitimate interest), where our legitimate interest is to fulfill the agreement we have entered into with your workplace.
Additionally, according to the Danish Road Toll Act § 6, section 3, the EETS provider (here: Brobizz) may process and exchange information with Sund & Bælt Holding A/S when necessary for the calculation, collection, and settlement under this law.
If we are required to store and/or report information about you to public authorities, we process your personal data based on GDPR Article 6(1)(c) (legal obligation). This would be the case, for example, if your information is included in accounting records or must be reported to the tax authorities (SKAT).
If your information is processed in connection with a lawsuit, we may process your information based on GDPR Article 6(1)(f) (legitimate interest). Our legitimate interest is to establish, assert, and/or defend legal claims.
Storage
Brobizz retains personal data related to the customer relationship as long as the customer relationship exists. After the termination of the customer relationship, the information is stored for a maximum of 3 years, with the exceptions mentioned immediately below.
Brobizz retains information about your workplace's driving transactions for 5 years plus the current year in accordance with the rules of the Danish Accounting Act.
Brobizz retains personal data processed in connection with lawsuits as long as the case is ongoing and up to 10 years after the lawsuit is concluded.
Recipients
Brobizz discloses your information to Sund & Bælt Holding A/S, which calculates the toll price that you incur when driving on toll roads. We may disclose personal data to external companies if this is necessary for us to deliver our products to you or to ensure the collection of outstanding payments.
We may also disclose your personal data to public authorities, as we are legally obliged to report certain information. Similarly, we may disclose your personal data to the police and other third parties if necessary.
Brobizz also uses a supplier that provides the Toll Box and may process information on our behalf.
We also use IT suppliers to whom we may entrust your personal data in connection with the operation, development, and hosting of our IT systems, including file management and email services.
Our suppliers are located in Ireland and Sweden.
We have entered into data processing agreements with our IT suppliers, and therefore they may not use the information for purposes other than those specified in the data processing agreements.
2.3. Testing of the Toll Box before January 1, 2025
If you have received our Toll Box, you can choose to use it before January 1, 2025. If you do so, you automatically participate in our pilot test. This means that the box tracks your driving when you drive around with the box in your truck.
As part of the pilot test, you can access information about what the driven route would have cost if the Toll Scheme had come into effect. You can see this price in Brobizz' Self-Service. You will not be charged for your driving on the Danish road network during the pilot test period, i.e., from October 1, 2024, to December 31, 2024.
However, you will be charged if you use the Toll Box and drive over the Great Belt Bridge or the Øresund Bridge, use ferries, or drive on road segments in Norway, as the Toll Box functions in the same way as a Bizz transmitter. You can read more about how we process personal data in connection with payment collection under section 2.1.
You can also read more about the Toll Box under section 2.2., as well as more about Brobizz' Self-Service under section 2.6.
Purpose
If you drive with the Toll Box before January 1, 2025, we process your information to test and train our box. This way, we ensure that our equipment is ready to be used when the Toll Scheme comes into effect.
Categories of Personal Data
We may process the following general personal data about you when you drive on the Danish road network with a Toll Box during the pilot test:
• The name of the company you are employed by and represent
• The company's CVR number
• Contact details in the form of your name, email, and phone number
• The registration number of the vehicle associated with the Toll Box
• The company's customer number
• Identification number for the Toll Box
• Type of motor vehicle
• Vehicle data, including the vehicle's weight, environmental class, and CO2 class
• Number of products associated with your workplace
• Information about driving transactions using the Toll Box, including location and time of travel
Sources
We collect your personal data directly from you via our Toll Box.
Legal Basis
If you use your Toll Box before January 1, 2025, we process personal data about you for test-ing purposes based on GDPR Article 6(1)(f) (legitimate interest). Our legitimate interest here is to ensure that our Toll Box functions effectively before the Toll Scheme comes into effect.
Additionally, it follows from the Danish EETS Regulation § 4, section 4, and § 6, section 1, no. 6, that EETS providers (here: Brobizz) must provide user-friendly vehicle equipment to EETS users (here: customers). To ensure this, we thoroughly test our Toll Box so that it is ready for use on January 1, 2025.
Retention
Brobizz retains personal data related to the customer relationship as long as the customer re-lationship exists. After the termination of the customer relationship, the data is retained for a maximum of 3 years, with the exceptions mentioned immediately below.
The data recorded by the Toll Box during the pilot test will be deleted no later than one year after the test has concluded.
Recipients
Brobizz discloses your information to Sund & Bælt Holding A/S, which calculates the toll fee you would have been charged if the Toll Scheme had been implemented.
Brobizz uses a supplier that provides the Toll Box and can process information on our behalf.
We also use IT suppliers to whom we may entrust your personal data in connection with the operation, development, and hosting of our IT systems, including file management and email services.
Our suppliers are located in Ireland and Sweden.
We have entered into data processing agreements with our IT suppliers, and they are there-fore not allowed to use the information for purposes other than those specified in the data processing agreements.
2.4. Provider of the Toll App for the Toll Scheme
From January 1, 2025, trucks must pay tolls when driving on toll-liable road segments ("Toll Scheme"). This section concerns our "Toll App," which is an app developed by Brobizz to manage the payment of tolls. You can read more about Brobizz's Toll App here.
Purpose
Brobizz processes personal data about you if you install our Toll App on your phone. When the app is ordered through Brobizz's Self-Service, a license plate payment is simultaneously created, enabling the collection of payments for other fees, such as crossing the Storebælt Bridge. You can read more about license plate payment for business customers under section 2.1.
We process personal data to be able to collect tolls and any other fees that may be charged via the app. We may also process your personal data if it is necessary to correct any errors that may occur in the app.
Categories of Personal Data
We may process the following general personal data about you when you, as a truck owner or truck user, drive on the Danish road network while you have initiated a trip in our Toll App:
• The name of the company you are employed by and represent
• Your workplace's CVR number
• Contact details in the form of your name, email, and phone number
• The registration number of the vehicle associated with the Toll App
• The company's customer number
• Your app's identification number
• Motor vehicle type
• Weight and environmental class of the vehicle
• Number of products associated with your workplace
• Information about driving transactions using the Toll App, including location and time of travel
Please note that you must choose to always share location data in your phone's settings to use our Toll App. This is because this setting is necessary for you to use the app without hav-ing it displayed on the screen. Although you have set your phone to always share location da-ta, the app does not collect data until you have actively started a trip in the app. Similarly, the app stops all collection of location data when a trip is ended.
If you have selected "automatic tracking" in your phone's settings, the app will start data col-lection when the app is connected to the truck via Bluetooth, and the vehicle starts moving.
Data collection ends when the app is no longer connected to the vehicle.
The above means that the app will not collect location data if you do not have an active trip in progress.
Sources
When you install our Toll App, we collect your personal data directly from you.
Legal Basis
If you own a sole proprietorship and install our Toll App, we process your personal data based on GDPR Article 6(1)(b) (necessary for the performance of a contract to which you are a par-ty).
If you use the Toll App on behalf of your workplace, we process your personal data based on GDPR Article 6(1)(f) (legitimate interest), where our legitimate interest is to fulfill the agree-ment, we have entered into with your workplace.
Additionally, according to the Danish Road Toll Act § 6, section (3), the EETS provider (here: Brobizz) can process information when it is necessary for the calculation, collection, and set-tlement under this law.
We may also process your personal data based on GDPR Article 6(1)(f) (legitimate interest) when this is done to correct errors in the app. Our legitimate interest here is to offer you an app that functions optimally.
If we are obliged to store and/or report information about you to public authorities, we pro-cess your personal data based on GDPR Article 6(1)(c) (legal obligation). This would be the case, for example, if your information is included in accounting records or must be reported to the tax authorities.
If your information is processed in connection with a legal dispute, we may process your in-formation based on GDPR Article 6(1)(f) (legitimate interest). Our legitimate interest is to es-tablish, assert, and/or defend legal claims.
Retention
Brobizz stores your user information related to the Toll App as long as you have an active user account. If your user account is deleted in Brobizz’ Self-Service, we store your user information for 180 days after the deletion date.
Additionally, Brobizz stores information related to your driving and use of the app for one and a half years from the driving date, after which the information is deleted. Information related to payment collections is stored as stated under section 2.1. This means that Brobizz stores in-formation about your driving transactions for 5 years plus the current year in accordance with the rules of the Accounting Act.
Brobizz stores personal information processed in connection with a lawsuit as long as the case is ongoing and up to 10 years after the lawsuit is concluded.
Recipients
Brobizz discloses your information to Sund & Bælt Holding A/S, which calculates the toll price you incur when driving on toll roads.
We may also disclose personal data to external companies if this is necessary to ensure the collection of outstanding payments.
We may also disclose your personal data to public authorities, as we are legally obliged to re-port certain information.
Similarly, we may disclose your personal data to the police and other third parties if neces-sary.
Brobizz also uses IT providers to whom we may entrust your personal data in connection with the operation, development, and hosting of our IT systems, including file management and email services.
Our IT providers are located in Ireland and England.
We have entered into data processing agreements with our IT providers, and they are there-fore not allowed to use the data for purposes other than those specified in the data pro-cessing agreements.
2.5. Testing the Toll App before January 1, 2025
If you download our Toll App and start using it before January 1, 2025, you will automatically participate in our pilot test. This means that the app will track your driving if you actively start a trip in the app or if you connect the app to your vehicle via Bluetooth.
As part of the pilot test, you can access information about what the driven route would have cost if the Toll Scheme had come into effect. You can see this price in Brobizz’ Self-Service. You will not be charged for your driving on the Danish Road network during the pilot test period, which runs from November 1, 2024, to December 31, 2024.
However, you will be charged if you use the Toll App and drive over the Storebælt Bridge or the Øresund Bridge. You can read more about how we process personal data in connection with payment collection under section 2.1.
You can also read more about the Toll App under section 2.4, as well as more about Brobizz’ Self-Service under section 2.6.
Purpose
If you download the Toll App before January 1, 2025, and start a trip in the app, we will process your information to test and train our app. This ensures that the app is ready for use when the Toll Scheme comes into effect.
Categories of Personal Data
We may process the following general personal data about you if you drive on the Danish Road network while you have started a trip in our Toll App before January 1, 2025:
• The name of the company you are employed by and represent
• Your workplace’s CVR number
• Contact information such as your name, email, and phone number
• The registration number of the vehicle associated with the Toll App
• The company’s customer number
• Your app’s identification number
• Motor vehicle type
• Weight and environmental class of the vehicle
• Number of products associated with your workplace
• Information about driving transactions using the Toll App, including location and time of travel
Note that you must choose to always share location data in your phone’s settings to use our Toll App. This setting is necessary for the app to be used without having it on the screen.
Even if you have set your phone to always share location data, the app does not collect data until you have actively started a trip in the app. Similarly, the app stops all data collection when you end the trip.
If you have selected “automatic tracking” in the app’s settings, the app will start data collection when it connects to the vehicle via Bluetooth, and the vehicle starts moving. Data collection stops when the app is no longer connected to the vehicle.
This means that the app will not collect location data if you do not have an active trip in pro-gress.
Sources
When you install our Toll App, we collect your personal data directly from you.
Legal Basis
If you use the Toll App before January 1, 2025, we process personal data about you for testing purposes based on GDPR article 6, section 1, paragraph f (legitimate interest). Our legitimate interest here is to ensure that our Toll App functions effectively before the Toll Scheme comes into effect.
It also follows from the EETS regulation § 4, section 4, and § 6, section 1, number 6, that EETS providers (here: Brobizz) must provide user-friendly vehicle equipment to EETS users (here: customers). To ensure this, we thoroughly test our Toll App so that it is ready for use on Janu-ary 1, 2025.
Retention
Brobizz stores your user information related to the Toll App as long as you have an active user account. If your user account is deleted in Brobizz’ Self-Service, we store your user information for 180 days after the deletion date.
Information related to your driving during the pilot test is stored for one and a half years from the driving date, after which it is deleted.
If you use the Toll App in connection with crossing the Storebælt Bridge or the Øresund Bridge, we store your personal data related to payment collection as stated above under section 2.1.
Recipients
Brobizz discloses your information to Sund & Bælt Holding A/S, which calculates the price of the toll you could have been charged if the Toll Scheme had come into effect.
Brobizz also uses IT suppliers to whom we may entrust your personal data in connection with the operation, development, and hosting of our IT systems, including file management and email services.
Our IT suppliers are located in Ireland and England.
We have entered into data processing agreements with our IT suppliers, and they may there-fore not use the information for purposes other than those specified in the data processing agreements.
2.6 Brobizz digital platforms (Brobizz websites and app)
Personal data categories
Brobizz may process the following general personal data about the Customer or other individuals when they use Brobizz digital platforms:
Personal data, as mentioned in section 2.1, IP address of the device used, information that the Brobizz app has been downloaded and whether it is associated with a Customer Agreement or Product, settings activated in the Brobizz app, the type of device using Brobizz digital platforms (e.g. PC, tablet or mobile phone) as well as general digital behaviour collected via cookies or other tracking technology on Brobizz websites, in the Brobizz app and on Brobizz pages on social media.
Purpose
Brobizz processes personal customer data on the digital platforms for necessary statistical, functional and marketing purposes, including for optimising the user experience on Brobizz digital platforms, e.g. by providing the Customer with an overview of the Customer's account settings and other available services and features, to maintain Brobizz digital platforms, to target marketing, e.g. in connection with sending out newsletters as mentioned in point 2.6, and to optimise Brobizz Products. Some processing is carried out on the basis of cookie collection by Brobizz itself or via third-party cookies. See more about this in the Brobizz cookie policy.
Brobizz may compile personal data for segmentation/profiling in order to target its marketing, with the aim of making the marketing content relevant to the Customer or other natural persons on Brobizz digital platforms. See also section 2.7 for information on Brobizz processing of information in connection with direct marketing in general.
If the Customer or other natural persons, via the Brobizz app and/or in the settings of the device that has downloaded the app, has activated and allowed the app's use of the device location, and marketing consent has been given to receive direct marketing from Brobizz, this information may be used to send location-based marketing notifications about, e.g. nearby operators and business partners.
Section 2.8 also provides information about the extent to which Brobizz uses the app to send out service notifications.
The sources from which personal data is collected for the above-described purposes are the Customer or the Brobizz websites, the Brobizz app and other online sources/websites to which third-party cookies have been set; see details in the Brobizz cookie policy.
Legal basis
The legal basis for the data processing is the EU Data Protection Regulation 6(1)(f) (legitimate interest), with the legitimate interest of Brobizz being to optimise and maintain its digital platforms and Products and to target marketing.
Storage
Brobizz stores the personal Customer data as long as is necessary for the purposes mentioned.
Personal information related to the Customer's Customer relationship and respective digital usage, which is not based on a cookie collection, is stored for as long as a Customer relationship exists and a maximum of three years after termination of the Contractual relationship with the Customer.
The customer profile on the Brobizz app is stored until the customer relationship ceases.
Personal information collected on the basis of cookies is deleted in accordance with the BroBizz cookie policy. See cookie policy.
2.7 Direct marketing, such as newsletters
Personal data categories
In connection with registration and the sending of direct marketing, Brobizz may process general personal data such as name, e-mail, address and telephone number of the Customer, the Customer's digital behaviour, as mentioned in point 2.5 and the opening rate of newsletters. Brobizz also processes information about whether a Brobizz Customer has a contractual relationship with an operator or business partner.
Purpose
Brobizz processes the Customer's personal data in connection with the registration to receive direct marketing, such as receipt of newsletters or push notifications, with the aim of being able to manage the Customer's consent and send the Customer the desired marketing material.
Furthermore, for statistical purposes, Brobizz processes information about the Customer's opening rate in part to provide more relevant and targeted newsletter content in the future and to be able to clean up the consent database. This personal data is collected directly from the Customer and via the newsletter sent to the Customer.
The customer's address, city and country, the digital preferences as mentioned in section 2.6, which give an insight into areas of interest and focus, the information about whether a customer has a customer relationship with an operator or business partner and about the most recent usage of Bizz or number plate payment are used for the purpose of tailoring the actual content of the marketing and communication to the recipient. For this purpose, Brobizz may compile personal data or segment/profile. The personal information used for the above purposes is obtained from the Customer, via cookies or from an operator or business partner.
Legal basis
The legal basis for this data processing is the EU Data Protection Regulation 6(1)(f), (legitimate interest), with the legitimate interest of Brobizz being the sending of relevant and targeted marketing to the recipient.
With respect to the use of location information for sending direct marketing, the legal basis for the data processing is the EU Data Protection Regulation 6(1)(a), (consent). The customer can withdraw consent to the processing at any time.
Storage
The personal data is stored as long as the marketing consent is still valid and until two years after the Customer or the recipient has withdrawn his/her consent to receive the marketing or following a longer period when the Customer or the recipient has not opened his/her newsletters.
2.8. Service announcements, surveys and customer satisfaction surveys
Personal data categories
In relation to the sending out of service notifications, surveys and customer satisfaction surveys, Brobizz processes general personal data such as name, address, e-mail and telephone number of the Customer. This also includes the processing by Brobizz of information about which settings the customer has activated in the Brobizz app with respect to location data, registration number and type of vehicle the customer has signed up with in his/her agreement.
Purpose
Customer contact information is processed for the purpose of contacting the customer with surveys designed to gauge certain market conditions, satisfaction surveys to assist in optimising and supporting operations with input from customer responses, or service notifications with the aim of providing the customer with essential information about the contractual relationship with Brobizz, an operator or business partner, such as a notification that contact information needs to be updated.
The sending of service notifications, surveys and satisfaction surveys can - in contrast to marketing - take place without the consent of the recipient.
If the Customer has downloaded the Brobizz app and has activated reception of push notifications from BroBizz on the device, Brobizz may use this digital channel for the purpose of the notification transmission. Likewise, Brobizz may use the Customer's location if this function is activated in the Brobizz app and/or in the settings of the device that has downloaded the app for the purpose of sending relevant service notifications based on the location.
Legal basis
The legal basis for this processing is the EU Data Protection Regulation 6(1)(f), (balancing of interests), with the legitimate interest of Brobizz being the ability to manage and support operations regarding the relationship with Brobizz Customers as well as being able to inform the Customer about significant matters in relation to their Customer Agreement.
Retention period
Personal information in relation to service notifications is stored as long as a customer relationship exists and a maximum of three years after the termination of the contractual relationship. Questionnaires and satisfaction surveys are stored for as long as the relevant issue subject to the desire for the investigation is ongoing.
2.9. Recording of telephone conversations
Personal data Categories
Brobizz processes general personal data about individuals who contact the Brobizz Customer Service function by telephone, such as name, telephone number and other personal data the enquiry may relate to, if the individual has consented to Brobizz recording the telephone call.
Purpose
The purpose of this processing is the documentation of possible agreements made between the customer and a customer service employee.
Legal basis
The legal basis for this processing is the EU Data Protection Regulation 6(1)(a),(consent). The customer can withdraw consent to the processing at any time.
Retention period
Up to three months from the time of recording the conversation.
2.10 Keeping a list of blocked Bizz transponders (block list)
Personal data categories
Brobizz may process information about the Customer's bizz identification number and any vehicle registration number for use in maintaining a list of blocked Bizz transponders. The information used for the block list is collected from customers, operators and business partners.
Purpose
The purpose of the block list and the processing of the information is, i) to avoid misuse of Bizz transponders and vehicle registration numbers in the event of breach of agreement by the customer (e.g. non-payment or failure to update necessary payment information, etc.), ii) to avoid misuse of Bizz transponders or vehicle registration numbers in the event of loss of the Bizz transponder and/or vehicle, and iii) enabling Brobizz to identify Bizz transponders that have run out of battery or lack necessary updates (with a view to informing the individual Customer about this).
Brobizz may register a bizz transponder and possibly a vehicle registration number on the block list in the following cases:
The Bizz transponder and/or the vehicle is/are reported stolen
The Bizz transponder is lost by the Customer
The customer relationship has been terminated and an attempt has been made to recall the Bizz transponder
At the time of using the Bizz transponder and the registration number, no valid payment card is associated with it, including if the payment card has expired (applies to customer relationships where payment is normally made by payment card)
The Customer has not complied with the agreed conditions for payment (applies to customer relationships where payment is normally made via invoice)
Brobizz has unsuccessfully requested that the Customer update a payment card or a registration number
The Bizz transponder runs out of battery, or other technical requirements lead to a necessary update of the transponder.
The Customer has provided incorrect, inaccurate or failed to update personal data for use in the payment collection.
Legal basis
The legal basis for processing the above information is § 26, subsection 1 of the Data Protection Act.
Sharing of information
Brobizz passes the block list information on to operators and partners who are part of the EasyGo collaboration. Read more about the EasyGo collaboration of operators here.
Retention period
Brobizz stores the above information only as long as is necessary to fulfill the purposes described above or until the eventual termination of the Bizz transponder or customer agreement.
2.11. Competitions
Personal data categories
Brobizz processes general personal data of competition participants, such as name, address, telephone number, e-mail address and any marketing consent with respect to competition participation.
Purpose
The purpose of this personal data processing is to make it possible to contact the winner of the competition and, in some instances, for statistical purposes.
In certain instances, the processing is done to facilitate the sending of marketing material to the competition participant, if the competition participant has registered for this in the context of the competition. Brobizz may also process the personal data in order to target marketing.
If an existing Customer participates in the competition and provides his/her contact details, these can be used for updating of the Customer's contact details at Brobizz.
Legal basis
The legal basis for this personal data processing is the EU Data Protection Regulation 6(1)(f), with the legitimate interest of Brobizz being the ability to contact the winner, create statistics, send out and target marketing, and ensure that personal data is correct and up to date.
Retention period
Contact information submitted by non-winning competition entrants will be stored until the competition has ended and the winner has received his/her prize.
The winner's contact information is stored for three years, calculated from receipt of the prize. Bookkeeping information in relation to the winner's prize distribution is, however, stored for five years after the end of the financial year in which the prize is distributed.
Contact information provided for the purpose of receiving marketing is stored as long as the marketing consent remains valid and until two years after the Customer or recipient has withdrawn his/her consent to receive marketing or if the Customer or recipient has not opened his/her newsletters for a long period of time.
For existing Customers whose contact information is updated, the contact information is stored as long as a Customer relationship exists and a maximum of three years after termination of the Contractual relationship with the Customer.
Brobizz continuously focuses on the potential of AI when it comes to efficient and targeted handling of customer inquiries. Consequently, Brobizz develops AI solutions (work processes driven by artificial intelligence) aimed at handling inquiries from customers and other physical persons.
The information is processed with the purpose of developing AI solutions that support efficient handling of inquiries from customers and other physical persons.
If we deem it necessary and appropriate to use personal data for the development and testing of an AI solution, we will typically use specific customer inquiries that we have received via the form on the website or email. These customer inquiries will never be more than one year old.
When developing and testing based on customer inquiries, we generally process the personal data listed above under section 2.1. This section enumerates the categories of information that may be recorded when we respond to customer inquiries – for example, contact information and the content of the respective inquiry.
The information is collected directly from you, as it originates from your customer inquiry.
We process your personal data based on GDPR Article 6, paragraph 1, letter f (legitimate interest), where Brobizz's legitimate interest is to be able to develop a technical solution that makes it possible to respond to inquiries from customers and other physical persons faster and more efficiently.
The personal data involved in the development of AI solutions is retained for 28 days from the time the inquiry has been used for training the AI solution. However, the information is deleted immediately after the test period ends, regardless of whether this is before the 28 days.
In connection with the development and testing of Brobizz's AI solutions, Brobizz transfers personal data to an IT supplier that develops and offers IT solutions, which are used for optimizing operations. This supplier is located in Denmark.
Brobizz also uses an IT supplier to whom your personal data may be transferred in connection with the operation, development, and hosting of IT systems, including file management and email services. This supplier is located in Ireland.
The suppliers are data processors for Brobizz and process personal data solely under instructions from Brobizz. We have entered into written data processing agreements with the suppliers.
Brobizz's data processors are subject to confidentiality and may not use the personal data for purposes other than those specified in the data processing agreements.
Brobizz shares the Customer's personal data only if legally required, if necessary to fulfill an Agreement that Brobizz has entered into with the individual Customer, with business partners and Operators, or if Brobizz has another legitimate interest in this. As examples, data can be passed on to:
Brobizz also uses suppliers to whom the Customer's personal data is entrusted, typically in connection with the operation, development and hosting of, e.g. communication and marketing solutions, preparation of market analyses and IT systems for handling business data. These suppliers are data processors for Brobizz and process personal data as directed by Brobizz. Brobizz has entered into written data processing agreements with these data processors.
The data processors are subject to confidentiality and may not use the personal data for purposes other than those specified in the data processing agreement.
Brobizz transfers personal data to both data processors and sub-data processors established respectively within and outside the EU/EEA. In cases where personal data is transferred to data processors and/or sub-processors outside the EU/EEA, Brobizz ascertains the legal basis for the transfer in accordance with the applicable data protection legislation at all times. You can get further information about the specific transfer conditions by contacting Brobizz.
Customers or other natural persons with personal data subject to processing by Brobizz have the right to request access, correction and deletion of their personal data as well as the right to object to the processing of their personal data and to have the processing of their personal data restricted.
If processing of personal data is based on consent, the Customer or other natural person from whom consent was obtained has the right to revoke the consent at any time. Revocation will not affect the legality of the processing carried out prior to the revocation of consent.
Customers also have the right to receive the personal data that they have submitted themselves in a structured, commonly used and machine-readable format (data portability). Conditions or limitations to these rights may apply. It is therefore not certain that a Customer, e.g. has the right to data portability in a specific case - this depends on the specific circumstances in which the processing is done. Nor is it always possible to comply with a deletion request if Brobizz has a legitimate reason to store the respective personal data.
The customer or natural persons whose personal data is subject to processing by Brobizz may exercise their rights by contacting persondata@brobizz.com and may, at any time, lodge a complaint with a data protection supervisory authority, e.g. The Data Protection Authority in Denmark.
Last updated 1 November 2024