Privacy policy

BROTHER INTERNATIONAL EUROPE LIMITED (NETHERLANDS BRANCH)
PRIVACY NOTICE

1. INTRODUCTION

This is the Privacy Notice for Brother International Europe Limited (Netherlands Branch) (“Brother”, “we”, “us”, or “our”). This Privacy Notice sets out the personal data we collect, how we use it and your rights in relation to this data. 

2. WHO WE ARE

We are a branch of Brother International Europe Limited operating in the Netherlands. Our branch office address is Zanderij 00025, Amstelveen, Netherlands, 1185ZM. Brother International Europe Limited is a company registered in England and Wales, with registered office at Brother House, 1 Tame Street, Audenshaw, Manchester, M34 5JE. Its company registration number is 00664172. 
Brother International Europe Limited is the controller and is responsible for your personal data.

3. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where identifiers have been removed (anonymous data). We can collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

• Identity Data includes name, username or similar identifiers (e.g., title, date of birth and gender), and any other information you provide us.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you, and other details of products and services that you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website. 

• Profile Data includes your username and password, purchases or orders made by you, product reviews made by you, feedback and survey responses.  

• Usage Data includes information about how you use our website, products and services. 

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose.
Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we can aggregate your Usage Data to calculate the percentage of users accessing a specific website feature, or collect statistics on the products we sell via our website. When we collect aggregated data we do not process any personal data of you from which you could directly or indirectly be identified.  

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data                                                                                                                                                                    

 Identity Data, Contact Data, and Financial Data are necessary to complete transactions and deliver the products to your address. Without this information we might not be able to perform the contract we have or are trying to enter into with you (complete the sale and ship to products). In this case, we may have to cancel a product order or service you have with us but we will notify you if this is the case at the time. 

4. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you:

• You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: 

a) purchase our products;

b) create an account on our website;

c) request marketing to be sent to you;

d) enter a competition, promotion or survey; or

e) give us feedback or contact us. 

• As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.

• We can obtain Technical Data: 

a) By analysing your activity on our website via the use of cookies and other similar technologies;
b) From other companies in our group, including Brother Industries Limited, who collect data on your usage of Brother devices. For further information please see [http://www.brother.com/privacy/device/en/index.htm]. 


5. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data in a lawful and transparent manner. We may process your personal data for the purposes and on the legal bases set out in the table below:

 Purpose/ Activity

  Type of data  L Lawful basis for processing including basis of legitimate interest
New customer registrations Identity; Contact
  • Performance of a contract with you
Purchase and delivery of products, including taking and handling orders, delivering products to you and communication with you about your order.   Identity; Contact; Financial; Transaction; Marketing and Communication
  • Performance of a contract with you 
To manage our relationship with you, including notifying you about changes to our terms or privacy notice Identity; Contact; Profile; Marketing and Communications
  • Performance of a contract with you
  • Necessary to comply with a legal obligation
  • Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To provide you with product and warranty support, or customer service Identity; Contact; Transaction; Technical; Profile; Usage
  • Performance of a contract with you
To administer and protect our business and website, including record keeping, complaint resolution and management of our business relationships and opportunities Identity; Contact; Technical
  • Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
  • Necessary to comply with a legal obligation
To display relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Identity; Contact; Profile; Usage; Marketing and Communications; Technical
  • Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
  • Your consent to use cookies on our website
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences  Technical; Usage  
  • Your consent, where required
  • Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you, promotional sales, or special offers by sending marketing communications and asking you to leave a review or participate in a survey. Identity; Contact; Technical; Usage; Profile; Marketing and Communications
  • Where you opt-in to receive marketing communications, we will send these to you based on your consent. 
  • Where consent is not required (because you are an existing customer who previously purchased a similar product from us), we may send you marketing communications based on our legitimate interest (promoting our business and to provide you with offers of similar services and products

Please note that we will include an unsubscribe link in all our email communications, which removes you from receiving further communications. You can also do this by logging into our website and checking or uncheck relevant boxes to adjust your marketing preferences, or by contacting us at any time.

 
To establish, exercise or defend legal claims in suspected or actual legal proceedings  Identity; Contact; Transaction; Profile
  • Necessary for compliance with applicable laws and regulations.

 

To provide any requested information to the tax, regulatory, anti-money laundering or any other relevant authorities or public bodies, where required to do so, as well as any processing of your personal data in connection to specific legislation, statutory codes of practice and other legal or tax related obligations 

 

 Identity; Contact; Transaction; Profile
  • Necessary for compliance with applicable laws and regulations.


If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

6. WHO DO WE SHARE YOUR PERSONAL DATA WITH?

We can share your personal data for the purposes set out in the table above with the following parties:
• Third-party service providers and suppliers who act on our behalf and who provide services such as website hosting, data analytics, information technology assistance, survey tools, label printing, product shipping (including tracking services) and payment processing;

• Affiliates, subsidiaries or other members of the Brother group;

• Regulatory authorities, as required by applicable laws, for the purposes of including, without limitation to, responding to any governmental or regulatory authority request, cooperating with law enforcement investigations and mutual assistance, or upon receipt of any court order; and

• Parties including prospective or actual buyers or seller in the event of a merger, acquisition, or other reorganization or sale or disposition of all or any portion of our business and/or assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable data protection laws. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. TRANSFERRING YOUR DATA OUTSIDE OF YOUR COUNTRY

We can transfer your personal data to other members of our group or to our suppliers based outside the European Economic Area (EEA). This includes transferring it to Brother Industries Limited in Japan. 
When we do send personal data abroad, we do so using adequate safeguards. This includes standard contract clauses approved for use by the competent authorities in Europe (as applicable), eventually supplemented with additional measures. We can also use other suitable safeguards, such as adequacy decisions, to permit personal data transfers from the European Economic Area (“EEA”) to other countries, in accordance with the applicable laws.

8. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We will store your personal data in accordance with applicable data protection laws and in line with our retention policies. 
In particular, we retain your data for the duration of our customer’s business relationship and for a period of time thereafter to comply with statutory retention periods (for instance, book-keeping purposes), to analyse the data for our own operations, and for historical and archiving purposes associated with the customers’ history of Brother. 
If we process your personal data on the basis of consent, we will delete your personal data following withdrawal of consent (subject to any legal, regulatory or other requirements to retain that data).

10. YOUR LEGAL RIGHTS

In certain circumstances, you have rights under applicable data protection laws in relation to your personal data, which you may use as follows:
• If you wish to access, correct, update or request deletion of your personal data.
• You can object to processing of your personal data when such processing is based on legitimate interests, ask us to restrict processing of your personal data or request portability of your personal data.
• If we have collected and process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
• You have the right to make a complaint at any time to the principal supervisory authorities for Brother International Europe Limited, included in the table below. You can also directly contact your local data protection authority with any complaint regarding how we process or use your data. Links to the websites of the authorities are available here.

Region  

Authority 
UK Information Commissioner’s Office (ICO)
EU Autoriteit Persoonsgegevens


You can exercise your rights at any time by contacting us using the contact details included below in this Privacy Notice. 
We respond to all requests we receive from users in accordance with applicable data protection laws. We may ask you to provide proof of identity before we can answer the above requests. In some cases, we may reject requests for certain reasons (for example, if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another individual). The reason for rejection of the request will be communicated within one month after the request is made.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
We try to respond to all legitimate requests within one calendar month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

11. COOKIES

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

Please see our Cookies Policy for more information on what cookies we use, why we use them and how you can better control their use through your browser and other tools. 

12. CONTACT US

If you have questions regarding your privacy and rights, please contact us:
• Email: privacy@brother.ie
• Post: Brother International Europe Limited, Brother House, 1 Tame Street, Manchester M34 5JE

13. CHANGES TO THIS PRIVACY NOTICE

We may make changes to this Privacy Notice from time to time. If we make any changes we will post our updated Privacy Notice with a note detailing our changes and the dates on which we made them.