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Information note regarding the processing of personal data

This Information note pertains to the personal data processing conducted by BRINK’S CASH SOLUTIONS (RO) SRL, located at 42 Pipera Road, 12th floor, Bucharest, Sector 2, Romania, in its capacity as a personal data controller (hereinafter referred to as BRINK’S (RO)).

The document applies to the following data subjects:
1. Representatives or employees of our business partners (clients or suppliers);
2. Representatives of potential suppliers or clients;
3. Visitors of BRINK’S (RO) premises, work sites, facilities;
4. Visitors of the BRINK’S (RO) website and social media pages;
5. Individuals who send us requests, complaints, notifications etc.;
6. Training participants.

1. For representatives or employees of clients or suppliers, we may process the following personal data:

   - first and last name,
   - position,
   - employer name,
   - work email address,
   - office postal address,
   - work phone number,
   - signature;
   - user data, IP, location when using our company's applications,
for the following purposes:
   - concluding/executing the contract with the clients/suppliers they represent;
   - maintaining and improving the contractual relationship (including responding to potential queries, requests, complaints);
   - business-to-business marketing (e.g., communications and offers about our products, services, and promotions, marketing analysis, feedback requests, etc.).

The basis of these processes is either contractual or the legitimate interest of our company, as applicable.

2. For individuals representing potential clients or suppliers, we may process the following personal data:

   - first and last name,
   - position,
   - employer name,
   - work email address,
   - office postal address,
   - work phone number,
   - signature;

for the following purposes:

   - business-to-business marketing (e.g., communications and offers about our products, services, and promotions, marketing analysis, feedback requests, etc.);
   - initiating collaboration and concluding commercial contracts.

The basis of these processes is either the legitimate interest of our company or the consent of the data subjects, as applicable.

3. For visitors of BRINK’S (RO) premises, work sites, facilities, we may process the following personal data:

   - identity document details, information regarding the purpose, date, and duration of the visit;
   - images (video recordings - CCTV).

The purpose of the processing is to ensure the security of people and property at BRINK’S (RO) locations.

The legal basis for processing is, as applicable, the legitimate interest of our company or compliance with legal obligations incumbent upon BRINK’S (RO) under Law 333/2003 (revised) on the protection of objectives, goods, values, and people, and its implementing rules.

4. For visitors of the BRINK’S (RO) website and social media pages:

When using social media platforms, we take responsibility for the content of the materials published, but the responsibility regarding the use and administration of cookies belongs to these platforms.

For the BRINK’S (RO) website, the use of cookies is based on the explicit consent of the visitors.

5. In our interactions with individuals who send us requests, complaints, notifications, etc., we may process the following personal data provided by them:

   - first and last name,
   - email address,
   - postal address,
   - phone number,
   - signature,
   - location at a certain date,
   - data collected by applications used to ensure IT security.

The basis of these processes is either the legitimate interest of our company or the implicit consent of the data subjects, as applicable.

6. For individuals attending courses organized by BRINK’S (RO) on their own, the processed personal data may include:

   - identity document details,
   - email address,
   - postal address,
   - phone number,
   - signature,
   - employer name.

The basis of these processes is the conclusion/execution of the contract with the concerned data subjects.

Personal data is stored in accordance with our personal data storage policy, which assigns a storage period based on the purpose of processing and the category of data processed. These periods are based on legal provisions (especially in the field of personal data protection), considering also the obligations to store certain data, applicable statute of limitations, recommended practices, and the purposes of our activity.

Normally, we do not transfer data subjects' data to other companies, organizations, or individuals in third countries or to international organizations. In the exceptional case of transfers to third countries, we ensure that all necessary guarantees are taken.

We limit access to personal data to what is strictly necessary, but in certain situations, we may disclose data subjects' data to authorized persons, institutions, authorities, for example:

   - for legitimate reasons related to our activity,
   - to ascertain, defend, and exercise the rights or interests of our company or another person,
   - because we have a legal obligation to disclose data to public authorities or other physical or legal persons.

Your rights as a data subject

As a data subject, you have the following rights:

- to access – you can obtain information about the processing of your personal data, as well as a copy of them;
- to rectification – you can request the completion or updating of your personal data if they are incomplete or inaccurate;
- to be forgotten – in certain situations, you can request the deletion of your personal data;
- to restriction of processing – in certain situations, you can request conditional processing of your personal data until certain operations regarding your data are resolved;
- to object – in the case of processing based on the realization of legitimate interests, you can reasonably oppose such processing;
- to data portability – you can request the transfer of your personal data provided by you and processed by automated means in a structured format, which can be automatically read.

If the legal basis for processing these data is your consent, you have the right to refuse the processing of these data, but in this case, we will no longer be able to include you in the processes for which the respective processing was necessary.

You also have the right to withdraw your consent at any time, without affecting the legality of processing carried out until that moment or processing based on other legal grounds.

Each of the above rights can be exercised by sending a written, signed, and dated request to:

- the operator's headquarters: 42 Pipera Road, 12th floor, Bucharest, Sector 2, Romania,
 or 
- the email address dpo.ro@brinks.com

If you believe that your rights are not respected, you can contact the data protection officer at the above address or file a complaint with the National Authority for Supervision and Processing of Personal Data (ANSPDCP).

Effective date: 2021

The document is subject to periodic reviews. To stay informed, or for any additional details, please write to us at dpo.ro@brinks.com.