In2Retail

The protection of personal data is of great importance to In2Retail B.V. In2Retail operates cash machines in various European countries and processes personal data of customers, contact persons and website visitors. Personal data is any information that can be traced directly or indirectly to you as an individual, such as your name, address, email address or telephone number.

This privacy statement provides information about how In2Retail handles personal data that it collects in the course of its business activities. Among other things, you can read about what data we collect, the purposes for which we use such data, and what rights you have.

We generally process personal data because you are a customer of ours. We also process data when you fill in a form or provide us with information directly. In addition, personal data may be processed when you visit our website (www.in2retail.nl).

A. What data do we process?

We process personal data from business customers, their representatives and contact persons, and website visitors. We process the following personal data, among other things:

name and business contact details;
information about customer relations (such as the role of the contact person and relevant communication and contact history);
contract and usage data related to the products purchased from In2Retail (such as product information, contract duration, transaction data);
data about your visit to the website (IP address, click behaviour, and cookie information).

B. For what purposes do we process your data?

We process data for the following purposes:

to provide products and services to you or your company, as our customer;
handling questions, support requests or other communications;
ensuring the security and optimal functioning of our website;
carrying out administrative processes, such as invoicing, customer registration and reporting;
exercising our rights vis-à-vis you or your company, such as debt collection and legal proceedings; and
marketing our products and services.
In addition, we process data for the following purposes under joint responsibility with IC Cash Services GmbH:

analyses to support our market and product development;
optimisation of existing products and services; and
preparation of anonymised and aggregated reports for sales, marketing and product planning.
Further information on the processing under joint responsibility can be found in the appendix to this privacy statement.

C. On what legal basis do we process your personal data?

We process your data when necessary for the performance of our agreement, to comply with legal obligations, based on our legitimate interest in product improvement and security, or with your explicit consent. If we need your consent, you can easily withdraw it at any time.

D. How long do we retain your personal data?

Your personal data is processed for as long as a contractual relationship exists or for as long as it is necessary for the purposes mentioned. After termination of the contract or when the purpose of processing no longer applies, data will be deleted, unless there are legal retention obligations.

E. With whom may we share personal data?

In principle, In2Retail B.V. does not share personal data with other parties. However, in the context of the further development and optimisation of our payment services, In2Retail may share certain data with IC Cash Services GmbH (Mehlbeerenstraße 4, 82024 Taufkirchen, Germany, email: datenschutzbeauftragter@iccash.de). In2Retail and IC Cash are affiliated companies within the same group of companies. Your data will also be shared with our IT suppliers and other service providers.

The sharing of data with IC Cash is based on the legitimate interests of In2Retail and IC Cash within the meaning of article 6(1)(f) of the General Data Protection Regulation (GDPR). We have carefully weighed up the interests involved and concluded that the exchange of data is proportionate and appropriate for the purpose of improving and innovating our services.

F. Cookies

Our website uses cookies, including for Google Analytics. These cookies mainly collect non-personal information to improve the functioning, user-friendliness and security of our website, and to generate statistics on the use of the website. You can refuse the use of cookies or delete existing cookies via your internet browser settings. Please note that disabling cookies may result in (parts of) the website not functioning properly.

G. What are your rights?

When we process personal data relating to you, you have the right to access that data. You can also request us to correct or delete data, restrict its processing, transfer your data to another party or object to certain processing operations. You can exercise these rights by sending a written request using the contact details provided in this privacy statement. You can address your request to In2Retail B.V.; we are your first point of contact. For a complete overview of your rights, please refer to the website of the Autoriteit Persoonsgegevens. You can also contact them with any complaints about our processing of personal data.

H. Questions or comments?

Do you have any questions about this privacy statement, or would you like to exercise your rights? Please feel free to contact us at:

In2Retail B.V.
Keienbergweg 79, 1011 GE Amsterdam
telephone: +31-(0)85 30 34 801
Email: info@in2retail.nl

This privacy statement is updated periodically. The most current version can be found at www.in2retail.nl.

Appendix

Information about data protection: Joint processing of customer data for market research and product development

In2retail BV works closely with its sister company IC Cash Services GmbH in the field of market research and product development. In this context, personal data of business customers may be processed jointly, for example when customers are natural persons or partnerships or when it concerns the contact details of the contact persons working for the customer. For this processing, we have laid down our respective actual functions and relationships, as well as the data protection obligations arising from the joint data processing, in particular with regard to the exercise of the rights of the data subjects and the fulfilment of the information obligations, in an agreement in accordance with Article 26 of the GDPR. Below, we provide information on the joint processing and on the main content of the agreement on joint responsibility between us and IC Cash Services, in addition to our general privacy statement.

1. Who are the joint controllers within the meaning of Article 26 of the GDPR?

For the above-mentioned processing,

IC Cash Services GmbH

Mehlbeerenstraße 4

82024 Taufkirchen

Germany

Email: datenschutzbeauftragter@iccash.de

 
and
In2Retail B.V.

Keienbergweg 79

1101 GE Amsterdam

The Netherlands

Tel.: +31 - (0)85 30 34 801

Email: info@in2retail.nl
are the joint controllers within the meaning of Article 26 of the GDPR.

2. What personal data do we process for what purposes within the framework of joint responsibility?

Purposes of processing: IC Cash Services GmbH analyses In2retail BV's customer data for market research and product development purposes and makes the analysis results and recommendations for measures available to In2retail BV. This includes, in particular, identifying other products that are suitable for In2retail BV's customers, optimising products that have already been purchased, and developing and implementing sales strategies.

Categories of data and nature of processing: In connection with the provision of this service, the following data relating to customers of In2Retail B.V. is transferred by In2Retail B.V. to IC Cash Services GmbH and stored and further processed by IC Cash Services GmbH for the above-mentioned purposes:

(1)            customer contact details, such as: first and last name, customer business contact details, contract and usage-related data relating to the relevant In2retail BV products, insofar as the customer is a natural person or a partnership/association of persons;

(2)            contact details of the customer's contact persons, such as: first and last name, business contact details of the contact person, connection to the business operations of the relevant customer.

IC Cash Services GmbH evaluates the personal data provided by In2retail BV on the basis of jointly agreed criteria, stores the analysis results and makes them available to In2retail BV, if necessary also in a personalised form. In addition, IC Cash Services GmbH anonymises or aggregates the data received in order to use it in aggregated form for its own market analysis and product development purposes.

3. Legal basis for processing

The transfer and further processing of customers' personal data in this context takes place on the basis of the legitimate interest of IC Cash Services GmbH and In2retail BV, Article 6(1)(f) GDPR. For this processing, we have weighed our interest in market research and product development against the interests of In2retail BV's customers and their contact persons. We have concluded that our above-mentioned interests outweigh the relevant interests of the data subjects, as the personal data processed is business data that is not sensitive or special, is processed within the In2Retail group for specific, clearly defined purposes, and the processing does not cause any inconvenience or other negative consequences for the data subjects. Both parties adhere to the principle of data minimisation and only collect the data necessary for lawful processing.

Although the joint processing for market research and product development is a different purpose than that of the original data collection (according to Article 6(4) of the GDPR), it is compatible with it because of the close connection between the performance of the agreement and product development and market research. This concerns only business-related data of the dealers and contact details of their contact persons. Given the ongoing business relationship, dealers and their contact persons can reasonably expect the additional use of their business-related data for market research and product development. The impact on the data subjects is minimal, as the data for product development purposes is only processed within the group and under protective measures such as encryption and aggregation.

Reference to the right to object in accordance with Art. 21 GDPR: You have the right to object at any time to the processing of your personal data on the basis of Art. 6(1)(f) GDPR (legitimate interest). We will then stop processing your data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms.

4. Recipients and access within joint processing

Within IC Cash Services GmbH, only authorised users have access to personal data. The analysis results are made available to In2Retail B.V., if necessary also in a personalised form. The results of aggregated analyses are made accessible to an extended user group within IC Cash Services GmbH. Processing and analysis take place in accordance with the jointly defined purposes and means. Otherwise, we will only pass on personal data to processors within the meaning of Art. 28 GDPR who provide us with technical support in data processing.

5. Retention period

Personal data is processed and stored for the duration of the contractual relationship between the customer and In2retail BV. If the contractual relationship with In2retail BV is terminated, IC Cash Services GmbH will immediately delete the stored personal data of the customer or their contact persons.

6. What have the joint controllers agreed with regard to the rights of data subjects and the fulfilment of information obligations?

Within the framework of our joint responsibility in the area of data protection, we and IC Cash Services have agreed in a transparent manner which of us fulfils which obligations under the GDPR, in particular with regard to the exercise of the rights of the data subject and which of us fulfils which information obligations.

We have agreed that In2retail BV will act as the central point of contact for receiving and coordinating requests from data subjects (point of contact within the meaning of Article 26(1) of the GDPR). In addition, we have agreed that each of the joint controllers must fulfil the information obligations towards the data subject. The privacy statement of In2retail BV can be consulted at https://in2retail.nl/en/privacy-policy.

Comments:

Notwithstanding the powers described above, you can always assert your rights against both In2retail BV and IC Cash Services GmbH.

In2retail BV and IC Cash Services GmbH have agreed to notify each other immediately if data subjects exercise their rights. They will provide each other with all the information necessary to respond to requests for information.

Data subjects will, in principle, receive the information from the body where they exercised their rights.

In2retail BV carries out other data processing operations for which there is no joint responsibility, but for which In2retail BV is solely responsible. These processes are therefore not covered by the above summary. Detailed information about these processing operations can be found in the privacy statement of In2retail BV.