This privacy policy of July 7, 2023 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.
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 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 2.3, 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 2.3 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 2.4 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.
2.3 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 2.2 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 2.2, 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.
2.4. 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.
2.5. 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.
2.6 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.
2.7. 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 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 7 July 2023