Declaration on the protection of personal data Brink Home Communication Service
I. Introduction
This privacy statement describes the types of personal data that Brink Climate Systems B.V. and its group companies (collectively 'Brink' or 'we') collect and store in connection with the use of the Brink Home Communication Service for the purpose of your Brink products and how these data are used. Brink takes your privacy seriously and will protect your personal data properly. Brink Climate Systems B.V. is the 'controller' of your data.
In this privacy statement we explain how we collect and use your personal data.
When does this privacy statement apply?
Who is responsible for your data?
What data do we collect and how do we do that?
How do we use your data?
Which third parties have access to your data?
How do we ensure that your data are safe and how long do we keep your data?
How can you exercise your legal rights?
II. When does this privacy statement apply?
This privacy statement applies to all your personal data that we collect, use, share and store when you use using the Brink Home Communication Service and the corresponding App and Portal for controlling your Brink products, or when you contact us about these products and services.
Brink Products and the Brink Home Communication Service
In this privacy statement, Brink products is defined as the Brink products in your possession produced by Brink Climate Systems B.V. that can be controlled from the Brink Home Communication Service. This privacy statement applies to all personal data that we collect, use, share and store in connection with the operation of the Brink Home Communication Service with corresponding App and Portal.
Please see the privacy statement on our website for more information on how we collect information on our website and how we use it.
This privacy statement was most recently updated on 1.10.2019, and supersedes earlier versions. We may update this privacy statement from time to time. We will notify you of any changes by posting the revised version of the statement on this website and by informing you about that by email or via the Brink Home Communication Service.
III. Who is responsible for your data?
Brink Climate Systems B.V. is responsible for collecting and using your personal data as described in this privacy statement. If you have any questions, comments or complaints regarding the processing of your personal data, you can contact us by sending an email to: privacy@brinkclimatesystems.nl.
IV. What data do we collect and how do we do that?
Brink Home Communication Service
When you use the Brink Home Communication Service to control your Brink products, we collect the following information about you:
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Personal data for registration at the Portal.
- Email address, password and language.
- To apply for installer rights we ask for a: company name, telephone number, VAT number and customer number (optional)
- Time stamp and version of the consent in the terms of use and the privacy statement.
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Dates of the Brink products and Brink Home Communication Service for the purpose of
ensuring the operation of the system.
- Data and statuses of the Brink products including current and historic installation data, fault messages, trend records, available releases for other users and receiver email addresses entered by the user for fault messages and trend records.
- Connection data of the user and the installation for safeguarding and optimising the optical use: IP address, browser used, time of setting up and terminating the connection, number of attempts to connect.
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Information we collect when you contact us.
- When you mail us or chat with us, we will register the communication. When you telephone us, our support desk will register your questions or complaints in our database.
We collect these data categories in the following ways: (1) we collect information that you yourself provide to us (when setting up your Brink products, when you create an account, when you log in to your communication module or when you contact our customer service department); and (2) we automatically collect information from your Brink products and the Brink Home Communication Service as described above.
V. How do we use your data?
We use your data for the following purposes: (1) to enable us to provide our services and to communicate with you, (2) for research purposes, so we can improve our products and services (3) for the purpose of direct marketing, and (4) for keeping our records and to comply with our legal obligations.
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To enable us to deliver our services and to communicate with you.
To provide our services for your Brink Products and the Brink Home Communication Service, we need most of the information described in section IV.
We use your account information and contact information to personalise your Brink Products and the Brink Home Communication Service and to send you service messages, such as news about security updates or new functionalities. We use your contact information to answer your questions when you contact us.
The settings information and the information about your use of your Brink Products and the Brink Home Communication Service are used to monitor whether your Brink Products and the Brink Home Communication Service perform adequately and to improve your user experience.
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Research to improve our products and services
We are conducting research into general trends and the manner in which our customers use our products and services. We do this to gain a better understanding of the behaviour and the preferences of our customers, so we can develop new products and services and improve our existing products and services even further.
We can merge and analyse the information described in section IV for research purposes. We only use aggregated data and we will not use your email address or other information that can directly traced to you personally.
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Direct marketing
We can use your account and contact information to send you information about your updated products and services of our brands that might be of interest to you. You may always choose to no longer receive these messages by following the instructions in the relevant marketing communication.
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Keeping our records up-to-date and complying with our legal obligations
We collect, store and use your data for internal purposes, such as for keeping our records up to date and complying with our legal and tax requirements.
We collect, use, share and store your personal data to provide our services to you, to comply with our legal obligations, to protect our legitimate interests as well as your privacy and that of third parties, or based on your consent.
You may revoke your consent at any time by cancelling your account, which will also remove all data. We may not be able to provide the services requested by you or part of those if you withdraw your consent or if you refuse to provide the personal data that we request from you in connection with the performance of the agreement or to comply with a legal obligation. When we process your personal data for our legitimate interests or those of third parties, we will take all reasonable precautions to prevent your interests from being harmed. For example, our legitimate interests may include security and safety measures or the improvement of our product range and our services to you. For more information about these interests, please refer to the above purposes for which we process your personal data.
VI. Which third parties have access to your data?
For the following purposes, your personal information may be transferred to or shared with our group companies, service providers and partners: (1) to be able to provide our services to you, (2) in support of our operating functions and (3) for research purposes and direct marketing.
If you wish, you can allow your installer access to the technical data of your Brink product or products. Your installer may consult these data to inspect the status of your installation and whether any maintenance is necessary.
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To deliver our services to you
In certain cases, we offer you services in cooperation with one of our partners, for example in the field of home automation. In such cases, we may exchange your information with these partners so that you can benefit optimally from our joint services. We only do this if we think that our services will benefit from the contributions of these external parties. Moreover, we will not share your details with these partners until we have informed you of our plans.
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To support our operating functions
In some cases, we may share your personal information with trusted third parties to perform operating functions (e.g. hosting providers) or the provision of services on our behalf (e.g. support services). Such third parties are obliged to adequately protect your data and process such data strictly according to our instructions.
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Research and direct marketing
Brink Climate Systems B.V. is part of Ariston Group Spa., Italien. Within our group we may exchange information for research and direct marketing purposes (see item V.3 above).
If we are legally obliged to do so, we may also share your personal data with regulators and investigative authorities or the tax authorities.
We may share aggregated, non-personally identifiable information with third parties. We will ensure that this information cannot be traced back to specific users of our products and services.
Our group companies, service providers and partners may be established in a country outside the European Economic Area (EEA), that is all EU countries plus Liechtenstein, Norway and Iceland). In such cases, there is an international transfer of personal data. The laws and regulations in these countries do not always provide the same level of protection for your personal data as the laws and regulations in the Netherlands. If necessary, we will ensure that appropriate safety measures are taken to ensure that the regulations with respect to international transfer of personal data will be respected, as laid down in the standard contractual provisions laid down in European connection.
VII. Use of cookies
For authentication purposes, anonymised cookies are used as necessary for the performance of the service. These exclusively exist during the current browser session and are deleted when the browser is closed. No cookies are stored permanently on your pc. At all times, the use of cookies may be deactivated through your browser settings.
How do we ensure that your data are safe and how long do we keep your data?
We take the necessary technical and organisational measures to ensure that your personal data are properly secured and thus protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, unintentional or unlawful destruction and loss.
We store your data in our systems for as long as this is necessary for the purposes described in this privacy statement, or to the extent that this is necessary to comply with all legal obligations and for settling disputes. When you delete your account or if we no longer need your data, we will delete or anonymise the data.
Some information is processed or stored directly in your App. You can delete such information by deleting the App.
IX. How can you exercise your legal rights?
You can contact us to request access to your personal data for updating and amending. You can also exercise all other rights under the applicable data protection laws and regulations, including the right to delete or limit the processing of your personal data. You may also ask us to transfer your data part of those to other organisations. You may also have the right to object to certain forms of processing of your personal data, and -in those cases where we have requested your permission- to withdraw your permission.
Note: In certain cases, we may ask you to supply additional information to enable us to establish your identity. There may be certain limitations to the rights described in this paragraph, for instance if we can demonstrate that we are under a legal obligation to process your data. Because of the way in which we organise certain services, it may take some time before backups have been erased and we may store certain data if we are obliged to do so for legal reasons.
Requests for access, correction, restriction or removal failure may be submitted free of charge by sending an email to privacy@brinkclimatesystems.nl.
You can also contact us in all cases with remarks and/or complaints with regard to this privacy statement by sending an email to privacy@brinkclimatesystems.nl. In the event of unresolved problems, you also have the right to lodge a complaint with the Personal Data Authority.