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Privacy policy

This privacy policy relates to your use of the website www.brobizz.com, Brobizz A/S products and services and the Brobizz app.

This Privacy Policy explains how Brobizz A/S processes personal data in connection with the Customers and other natural persons’ use of Brobizz’ Products (Bizz transponders and/or Number Plate Payment), use of Brobizz’ digital platforms, including websites and the App, signing up for and sending direct marketing, sending service notifications, surveys and customer satisfaction surveys, Brobizz’ recording of telephone calls, maintaining blocked lists, and participation in competitions.

In this Privacy Policy, the term "Bizz transponder" is used as a common name for all types of actual transponders which can be used for the electronic collection of payment and which are part of Brobizz’ Product Portfolio.

At Brobizz.com, you can find a list of operators and business partners for which Brobizz' Products can be used.

See also our cookie policy

1. Data Controller

The legal entity responsible for processing the Customer's personal data is:

Brobizz A/S
Business registration number: 31 85 48 22

Address:
Vester Søgade 10
1601 Copenhagen V
e-mail: persondata@brobizz.com​

(Hereinafter referred to as "Brobizz")

2. Description of processing

2.1 Customer Agreement with Brobizz on the collection of payment when using Brobizz' Products

Categories of personal data

Brobizz processes the following general personal data about the Customer when the Customer has entered into a Customer Agreement about the collection of payment when using Brobizz' Products:

Contact information (name, address, postcode, town/city, country, e-mail and telephone number), the registration number of the vehicle associated with Number Plate Payment, vehicle type where applicable, weight and environmental class of the vehicle, the Product's identification number, number of Products per Customer, payment card information, name of bank and account number where applicable, as well as information about transactions when using the Product, including location data (when and where).

Depending on the operator or business partner with which the Customer is using the Bizz transponder, the registration number of the vehicle, for which the Customer intends to use the Bizz transponder regularly, will also be processed. You can find a list here of current operators and business partners requiring information about the registration number to be associated with the Bizz transponder.

When the Customer uses Number Plate Payment, Brobizz does not receive photos of the Customer's number plate from the operator or business partner, but only information stating when Number Plate Payment was used.

Additionally, Brobizz processes data on whether a Customer has a Customer Relationship with an operator and/or a business partner.

In relation to Brobizz' business customers, the company name, business registration number and the contact information of a contact person will also be processed.

Purpose

Brobizz processes the Customer’s personal data for the general purpose of administration and maintenance of the Customer Agreement with the Customer for use in the collection of payment for passages and crossings with operators and business partners, and for supplying the agreed Products for use on the collection of payment. The data for this purpose is collected directly from the Customer, and any information about the Product being used for passages and crossings with operators and business partners is received from the operator or business partner in question.

Contact information, the Product's identification number and the personal data appearing from a Customer enquiry will also be processed for the purpose of responding to and administration of the Customer's enquiries to Brobizz’ Customer Service. Data for this use will be collected directly from the Customer.

If the Customer has requested being contacted by Brobizz’ sales team, for instance through an online contact form, the personal data will be processed for this purpose. Data for this use will be collected directly from the Customer.

In cases where Brobizz is processing data on a Brobizz Customer's Customer Relationship with an operator or a business partner, the purpose of said processing is to assist with the fulfilment of, for instance, a local agreement or some other agreement which the Customer has entered into directly with the operator or business partner; for example assistance with the conclusion and administration of a discount agreement with the operator or business partner. The personal data to be used for this administration and assistance has been collected directly from the Customer or the operator or business partner in question.

If the operator or business partner so requires, the Customer's personal data, such as the registration number of the vehicle associated with the Bizz transponder, will be disclosed to the operator or business partner, so that the Customer will be charged the correct payment under the Customer's Agreement with either Brobizz, an operator or a business partner. This may take place if the Bizz transponder cannot be read correctly.

The personal data, such as location data, is used for general analyses, statistical purposes and mapping user patterns in order to support, improve and optimize operations in relation to the collection of payment and for use for the collection of the payment itself.

If the registration number of the vehicle has not been collected directly from the Customer but from the Motor Register of the Danish Tax Agency (SKAT), the vehicle's registration number will be used for administration and to ensure that the registration number of the vehicle associated with a Product is correct and up to date.

In case Brobizz suspects that the Customer's contact information has not been brought up to date, for instance if Brobizz has tried to send a letter or an e-mail and the letter is returned due to an invalid address, Brobizz can collect data from other sources such as the Central Business Register, an operator or a business partner, for the purpose of administration and to ensure that the Customers’ contact information is updated correctly.

Legal basis

The legal basis of the processing is Article 6.1.b (necessary for the performance of a contract to which the Customer is a party) of the EU General Data Protection Regulation ("GDPR") and GDPR Article 6.1.f (legitimate interests), Brobizz’ legitimate interest being the administration of the electronic collection of payment in relation to the operator and the business partner, to respond to the Customers’ enquiries to Brobizz’ Customer Service, to support and improve operations, and to ensure that the personal data is correct and up to date.

Storage

Brobizz will store the personal data as long as it is necessary for the purposes mentioned above.

Personal data in relation to the Customer's Customer Relationship is stored as long as there is a Customer Relationship and for a maximum of 3 years after the termination of the Contractual Relationship.

Enquiries that Customer Service receives and responds to will be stored for 6 months, and where these enquiries are subject to bookkeeping requirements, they will be stored for 5 years plus the current year.

Personal data relating to a lawsuit will be stored for as long as the case is pending and for up to 10 years after the lawsuit has been terminated.

Information about the Customers' transactions is stored for a period of 5 years plus the current year in accordance with the requirements of the Danish Bookkeeping Act.

2.2 Brobizz' digital platforms (Brobizz’ websites and App)

Categories of personal data

Brobizz can process the following general personal data about the Customer or other natural persons when they use Brobizz’ digital platforms:

Personal data as mentioned in section 2.1, the IP address of the unit used, information about the download of the Brobizz App and whether it is associated with a Customer Agreement or Product, the settings activated in the Brobizz App, the type of unit using Brobizz’ digital platforms (for example computer, tablet or mobile phone), as well as the general digital visitor behaviour collected via cookies or other tracing technology on Brobizz’ websites, in the Brobizz App and at Brobizz’ pages on social media.

Purpose

Brobizz processes the Customers' personal data on the digital platforms for necessary, statistical, functional and marketing purposes, including to be able to optimize the user experience on Brobizz’ digital platforms, for instance 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 be able to target the marketing, for instance when sending out newsletters as mentioned in section 2.3, and to optimize Brobizz’ Products. Some parts of the processing is based on the collection of cookies by Brobizz itself or through third party cookies. You can read more about this in Brobizz’ cookie policy.

For use in the targeting of the marketing, Brobizz may compile personal data or segment/profile this data for the purpose of making the marketing content relevant for the Customer or other natural persons on Brobizz’ digital platforms.

If the Customer or other natural persons has activated and allowed the App to use the unit's location via Brobizz’ App and/or in the settings of the unit used to download the App, and has also consented to receive direct marketing from Brobizz, this information can be used to send marketing based on the location; for instance about operators and business partners nearby.

The sources from which the present personal data has been collected for the above-mentioned purposes are the Customer or Brobizz’ websites, the Brobizz App and other online sources/websites using third party cookies; see more details in Brobizz’ cookie policy.

Legal basis

The legal basis of the processing is GDPR Article 6.1.f (legitimate interests), Brobizz’ legitimate interest being to optimize and maintain its digital platforms and Products as well as to target its marketing. 

In cases where location data is used for the sending of direct marketing, the legal basis of the processing is GDPR Article 6.1.a (consent). The Customer can always withdraw its consent to the processing.

Storage

Brobizz will store the Customers' personal data as long as it is necessary for the purposes mentioned above.

Personal data in relation to the Customer's Customer Relationship and digital behaviour in this regard, which is not based on the collection of cookies, will be stored as long as the Customer Relationship exists and for a maximum of 3 years after the termination of said Customer Relationship with the Customer.

The personal data collected from cookies is deleted according to Brobizz’ cookie policy. See our cookie policy

2.3 Direct marketing, such as newsletters

Categories of personal data

In connection with the signing up for and sending of direct marketing, Brobizz can process general personal data, such as contact information, the Customer's digital behaviour as mentioned in section 2.2 and the open rate for newsletters, among other things. Additionally, Brobizz processes data on whether a Customer has a Contractual Relationship with an operator or a business partner.

Purpose

Brobizz processes the Customers’ personal data when they sign up for receiving direct marketing, such as newsletters or push notifications, for the purpose of administration of the Customers’ consent or to send the Customer the requested marketing material. Brobizz also processes information on the Customer's open rate for the newsletters sent out for statistical purposes, including so Brobizz will be able to make the contents of the newsletter more relevant and targeted and to organise the consent database. This personal data is collected directly from the Customer and from the newsletter sent to the Customer.

The Customer's address, town/city, the digital behaviour as mentioned in section 2.2, providing an insight into interests and focus areas, and the information on whether a Customer has a Customer Relationship with an operator or a business partner, can be used for targeting the content of the marketing itself and the communication with the recipient. To this end, Brobizz may compile or segment/profile personal data. The personal data used for the above-mentioned purposes is collected from the Customer, via cookies or from an operator or business partner.

Legal basis                                                                             

The legal basis of the processing is GDPR Article 6.1.f (legitimate interests), Brobizz’ legitimate interest being to distribute relevant and targeted marketing to the recipient. 

Storage

The personal data will be stored for as long as the marketing consent is still valid and until 2 years after the Customer or recipient has withdrawn its consent to receive marketing, or if the Customer or recipient has not opened its newsletters over an extended period of time.

2.4 Service notifications, surveys and customer satisfaction surveys

Categories of personal data

In connection with the sending of service notifications, surveys and customer satisfaction surveys, Brobizz processes general personal data about the Customer, such as name, address, e-mail and telephone number. Brobizz also processes information on the settings activated by the Customer in the Brobizz App.

Purpose

The Customer's contact information is processed for the purpose of contacting the Customer for surveys, which are surveys aimed at investigating certain market conditions, customer satisfaction surveys with the aim of optimizing and supporting operations using input from the Customer's replies, or service notifications serving to provide essential information to the Customer about the Contractual Relationship with Brobizz, an operator or a business partner; for instance letting the Customer know that the contact information should be updated.

As opposed to marketing, the sending of service notifications, surveys and customer satisfaction surveys may take place without the consent of the recipient.

If the Customer has downloaded the Brobizz App and has activated push notifications from Brobizz on the unit, Brobizz may use this digital channel for this purpose of sending such notifications. Similarly, Brobizz may use the Customer's location if this function is activated in Brobizz’ App and/or the settings on the unit having downloaded the App, for the purpose of sending relevant service notifications based on the location.

Legal basis

The legal basis of the processing is GDPR Article 6.1.f (the balancing of interests), Brobizz’ legitimate interest being the administration of and support to operations in connection with the relationship with Brobizz’ Customers, and to inform the Customer about important factors in relation to its Customer Agreement.

The storage period

Personal data relating to service notifications will be stored as long as there is a Customer Relationship, and for a maximum of 3 years after the termination of the Contractual Relationship. Surveys and customer satisfaction surveys will be stored for as long as the relevant concern of the survey is ongoing.

2.5 Recording of telephone calls

Categories of personal data

Brobizz processes general personal data about the person making a telephone call to Brobizz’ Customer Service, such as name, telephone number and other details which the enquiry may concern, if the person has consented to Brobizz recording the telephone call.

Purpose

The processing is done to assure quality and for training purposes.

Legal basis

The legal basis of the processing is GDPR Article 6.1.a (consent). The Customer can always withdraw its consent to the processing.

Storage

Up to 3 months from the time when the recording of the telephone call was made.

2.6 Maintaining a list of blocked Bizz transponders (blocked list)

Categories of personal data

In connection with maintaining the blocked list, Brobizz processes general personal data, such as the identification number of the Bizz transponder and the registration number of the vehicle where applicable.

Purpose

Pursuant to Section 26(1)(i) of the Danish Data Protection Act, the Danish Data Protection Agency has granted Brobizz permission to maintain the blocked list.

The purpose of maintaining such a blocked list is to avoid abuse of Bizz transponders or a vehicle registration number in the event of a breach of contract on the Customer's part, and to protect against external abuse if a Bizz transponder is lost or a vehicle is stolen. The data for this use has been collected from the Customer, from an operator or a business partner or other third parties.

Brobizz will register a Bizz transponder, and vehicle registration number where applicable, on the blocked list in the following instances and will then notify the Customer hereof:

  • When the Bizz transponder or perhaps a vehicle is reported stolen, or if the Customer has lost the Bizz transponder when the Customer Relationship is terminated and the Bizz transponder is to be returned.
  • In the event of payment by payment card, the Bizz transponder and the registration number where applicable will be entered on the blocked list, if no valid payment card is linked to the Bizz transponder and the registration number at the time of use.
  • When the Customer's payment card linked to the Bizz transponder has expired.
  • When paying by invoice, the Bizz transponder and the registration number where applicable will be entered on the blocked list when the agreed payment conditions are not fulfilled.
  • If there is no response from the Customer, including for example by updating a payment card or a registration number, Brobizz can register this on the blocked list.
  • If the Customer has provided wrong or incorrect personal data or has not updated said personal data for use in the collection of payment.
  • When it is necessary for other reasons beyond the control of Brobizz, and in case of suspicions of abuse.

Brobizz may disclose the information on the blocked list for the above-mentioned purposes to operators or business partners for which the Bizz transponder can be used. For example, the information is disclosed to the EasyGo partnership, a consortium of operators. You can find more information about this at https://easygo.com/. 

Legal basis

The legal basis of the processing is GDPR Article 6.1.f (legitimate interests), Brobizz’ legitimate interest being to maintain the blocked list to ensure that Bizz transponders are not abused.

Storage

The personal data on the blocked list will be stored until the circumstances leading to the blocking have been remedied or until the Bizz transponder or Customer Agreement has been closed.

2.7 Competitions

Categories of personal data

Brobizz processes the general personal data of the contestants, such as name, address, telephone number and marketing consent where applicable in connection with their participation in the competition.

Purpose

The purpose of the processing is to be able to contact the winner of the competition and in some cases for statistical purposes.

In some cases, the purpose of the processing is also to send marketing to the contestant if the contestant has signed up for this in connection with the competition. Additionally, Brobizz may process the personal data to target the marketing.

If an existing Customer enters the competition and provides its contact information, this may be used to ensure that the Customer's contact information with Brobizz is up to date.

Legal basis

The legal basis of the processing is GDPR Article 6.1.f, Brobizz’ legitimate interest being to contact the winner, keep statistics, to send and target the marketing and to ensure that the personal data is correct and up to date.

The storage period

Brobizz will store contact information provided by the contestants that did not win until the competition has ended and the winner has received its prize.

The winner's contact information will be stored for 3 years from the receipt of the prize. However, information, subject to bookkeeping requirements, about the winner receiving the prize will be stored for 5 years following the end of the accounting year in which the prize is given.

Contact information provided in order to receive marketing will be stored for as long as the marketing consent is still valid and until 2 years after the Customer or recipient has withdrawn its consent to receive marketing, or if the Customer or recipient has not opened its newsletters over an extended period of time.

For existing Customers, where the contact information has been updated, the contact information will be stored as long as there is a Customer Relationship and for a maximum of 3 years after the termination of the Contractual Relationship.

3. Recipients of personal data

Brobizz does not disclose the Customer’s personal data unless it is required by law, or it is necessary for the fulfilment of an Agreement into which Brobizz has entered with the individual Customer, or to assist in the fulfilment of an Agreement which the Customer has entered into with an operator or a business partner. For example, this may comprise disclosure to:

  • Operators and business partners to ensure the correct administration, validation and updating of personal data for use when collecting payment and for the blocked list as mentioned in section 2.6.
  • External suppliers to ensure collection of outstanding payments; for instance a debt collecting agency.
  • External suppliers and carriers to be able to supply Products as agreed to the Customer; such as for instance PostNord.

Additionally, Brobizz uses suppliers to which the Customer's personal data is disclosed, typically in connection with the operation, development and hosting of, for instance, 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 under the instructions of Brobizz. Brobizz has entered into written data processing agreements with said data processors.

The data processors are subject to confidentiality, and they cannot use the personal data for other purposes than what is designated in the data processing agreement.

4. Transfers to countries outside the EU/EEA

In some cases, Brobizz transfers personal data to data processors established outside the EU/EEA for the specific purposes mentioned in section 2. Brobizz is aware of the rules in this respect and will always make sure to have the necessary guarantees in place when transferring data to a country outside the EU/EEA.

The transfers takes place on the legal basis of the European Commission's standard contractual clauses, published by the European Commission, and will be in accordance with GDPR Article 49.1.b-e.

The Customer can contact Brobizz for a copy of the legal basis

5. The rights of the data subject under Chapter III of the GDPR

The Customer or other natural persons that Brobizz processes personal data about has the right to request access to, rectification and erasure of its personal data, and also has the right to object to the processing of its personal data and to restrictions of the processing of the personal data.

If the processing of the personal data is based on a consent, the Customer or other natural persons, from which the consent was obtained, has the right to withdraw the consent at any time. The withdrawal will not affect the lawfulness of the processing carried out before the consent was withdrawn.

Additionally, the Customer has the right to receive the personal data provided by the Customer itself in a structured, commonly used and machine-readable format (data portability).

There may be conditions or limitations to these rights. Therefore, it is not certain that the Customer has the right to data portability in the specific case, as it depends on the specific circumstances of the processing activity. For example, it may not always be possible to meet a request for erasure if Brobizz has a legitimate reason for keeping the personal data.

The Customer or other natural persons that Brobizz processes personal data about can exercise these rights by contacting persondata@brobizz.com, and can always submit a complaint to a data protection agency; in Denmark this is the Danish Data Protection Agency.

 

Lasted update: 26 November 2020

 

Country: Denmark
Language: English

Country: Denmark
Language: English