WHO ARE WE?
“Cashzone” is part of the company NCR Atleos, which includes NCR Italia srl and all its subsidiaries. The Group is comprised of a number of business entities, and although those entities operate in different ways and in different jurisdictions, this document sets out the general principles on the basis of which Cashzone will collect, process and process user data. We will list which of the entities of the group you will have a direct relationship with when you participate with us in order to obtain a product or service. When we mention Cashzone, 'we', 'us' or 'our' in this privacy policy, we are referring to the relevant company in the NCR Atleos group responsible for processing your data.
It is important that you read this privacy statement, just like any other privacy policy or fair treatment notice that we may provide on certain occasions when collecting or processing your personal data, so that you are fully aware of how and why we are using your data. This policy complements the other policies and is not intended to replace them.
We offer tailor-made solutions to increase sales, ensuring a greater flow of customers and an increase in the average expenditure per visit.
DATA PRIVACY OFFICER
In addition, we have appointed a data privacy officer who is responsible for overseeing matters related to this policy. If you have any questions about this, including requests to exercise your rights, please contact the Data Privacy Officer using the details provided below.
Privacy Policy
- What personal data are charged?
- Where do we collect your personal data?
- How do we use your personal data?
- Who do we share your data with?
- How long do we keep your information?
- Your rights
- Data and ATM
- Third-party links
- Sending data outside the EEA
- If the user chooses not to provide this information
- Marketing
- CCTV
- Data security
- Your legal rights
- How do I get a copy of your information?
- How to file a complaint?
- Cookies
PRIVACY POLICY
This privacy statement is intended to inform the user about how Cashzone will take care of their personal information. This includes what you tell us about yourself and what we learn from having you as a customer. This policy explains how we do it and explains your privacy rights and how the law protects you. Personal data or personal information means any information about a person from which that person can be identified. The data in which the identity has been deleted (anonymous data) are not included.
We may collect, use, store and transfer different types of personal data about you that we have grouped as follows:
WHAT PERSONAL DATA DO WE COLLECT?
In any case, we collect contact information and therefore the additional information necessary for the purpose of fulfilling the relationship you have with Cashzone, which may include, in the case of an employment relationship, special categories of data.
We also collect, use and share demographic or statistical data. This may be derived from your personal data, but by law it is not considered personal data, since this data does not reveal your identity directly or indirectly. For example, we may aggregate usage data to calculate the percentage of users accessing a specific function of the website. However, if we combine or link aggregated data with your personal data, so that you can directly or indirectly identify you, we treat the combined data as personal data that will be used in accordance with this privacy statement.
FROM WHERE WE COLLECT YOUR PERSONAL DATA FROM:
We will collect your personal data through any of the companies in the NCR Atleos group:
- By filling out a form on any of the websites of our group companies
- When you sign a contract with Cashzone
- When you provide information by email or letter
- When you talk to us on the phone
- When you request any of our services
- When you interact with our website, we may automatically collect technical data about your equipment, actions and browsing patterns. We collect this personal data through the use of cookies, server logs, and other similar technologies. We may also receive your technical information if you visit other websites that use our cookies.
We may also collect data from third parties with whom we have an association relationship, including:
- Fraud prevention agencies
- The government and law enforcement
- Public sources of information, including DVLA, Land Registry and Housing Companies
- Background checks and other agents working on our behalf
HOW TO USE YOUR PERSONAL DATA?
Below is a list of all the ways in which we will use your personal information and the legal basis for collecting and processing the data.
We will only use your personal data for the purposes for which it was collected, unless we reasonably believe that we need to use it for another reason and for a reason compatible with the original purpose. If you would like an explanation of how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for purposes other than the issue, we will inform you and explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or without your consent, in compliance with the above regulations, when this is required or permitted by law.
WHO DO WE SHARE YOUR DATA WITH?
We may share your personal data with the parties listed below for the purposes indicated in the table above.
- Internal third parties: other companies in the group that act jointly as Cashzone or as data processors or data controllers and those that provide system administration and other services for the group and its customers.
- External third parties: suppliers, acting as data controllers who provide services to Cashzone and its customers.
- Professional advisors who act as co-processors or data controllers, including lawyers, bankers, fraud and other crime prevention agencies, auditors and insurers.
- Customs and tax taxes, HMR regulatory authorities and other authorities acting as joint controllers or data controllers that require notification of certain activities.
- Agents and advisors we use to help you manage your accounts and services, collect what you owe, and explore new ways of doing business
- The third parties to whom we may choose to sell, transfer, or combine parts of our business or assets. Alternatively, we may seek to acquire other companies or to combine them. If there is a change in our business, the new owners will be able to use your personal data in the same way as indicated in this privacy policy
We require that all third parties respect the security of your personal data and treat it in accordance with the law. We cannot allow our third-party service providers to use your personal data for their own purposes, and we are authorized to process your personal data only for specific purposes and in accordance with our instructions.
HOW LONG DO WE KEEP YOUR INFORMATION?
We will keep the user's personal information for as long as the user is a Cashzone customer. We will keep your personal data only later, for as long as necessary to fulfill the purposes for which we are engaged, including for the purpose of satisfying any legal, accounting or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of personal data, the potential risk of harm caused by unauthorized use or disclosure of personal data, the purposes for which we process personal data and whether we can achieve those purposes by other means, and the applicable legal requirements.
After you stop being a customer, we may keep your data for one of the following reasons:
- To respond to any questions or complaints.
- To show that we treated him fairly.
- To keep records in accordance with the rules that apply to us.
Your rights
Protecting data privacy is not only a legal obligation for Cashzone, but it's also important to us.
Data protection law states that we are only allowed to collect and use personal information if we have a good reason to do so. Therefore, we can only collect, store and use your data:
- To fulfill the contract we must, for example, ensure that the right amounts are paid to the right person
- When it is our legal duty to do so, for example, including keeping control records or other purposes, or
- When it is in our legitimate business or business interest, including for example KYC or 'know your customer', to ensure we hire the right person or appropriate organisation, or
- When you give your consent.
In general, we do not rely on consent as a legal basis for processing your personal data. In most cases, we will need to collect and process user data in accordance with a contractual relationship that the user has with Cashzone or based on a legitimate business interest. Please note that we may process your personal data for more than one legal test, depending on the specific purposes for which we are using the data. Please contact us if you need more details about the specific legal basis on which we rely to process your personal data when more than one piece of evidence has been submitted in the table below. If we rely on a legitimate interest in processing user data, we will carefully evaluate the extent to which the processing is necessary and we will ensure that our business interests do not violate your interests and fundamental rights.
DATA AND ATM (ATM)
When you use one of our automated tellers, you should know that your card details can be acquired and shared with the card issuer, in order to validate the requested transaction. Your card details together with the details of the requested transaction will be used by Cashzone, a number of third-party service providers, and your card issuer to authenticate and authorize or decline the transaction request; Cashzone does not use any form of automated decision-making in this process, but other third parties and/or the card issuer may do so. The details that Cashzone collects from your card as part of a transaction have been anonymized by your card issuer, and Cashzone has no means of reconciling your card number (which is also anonymous and encrypted) with a natural person. Therefore, Cashzone does not consider the card and transaction details to be personal data for the purposes of data protection law, but this also means that it cannot identify Cashzone in the event of a dispute over an ATM transaction - If you have problems using one of our automated tellers, you must first contact the card issuer to submit a 'LINK Discrepancy Form'.
Please note that Cashzone, as part of the transaction validation process, may be invited by the card issuer to keep the card inserted in the ATM. This may occur as a result of the card having expired, the card being misused, the fact that the wrong PIN number has been tried an incompatible number of times, or the insertion of an incompatible card. Please note that, in accordance with brand rules and regulations, Cashzone cannot return captured ATM cards or ATM cards securely destroyed upon pickup to users. If an ATM has held your card, in most cases this will be at the request of your card issuer and you should contact them in the first instance.
THIRD-PARTY LINKS
Our websites may contain links to third-party websites, plug-ins and applications. By clicking on those links or activating the connections, the user can authorize third parties to obtain or share information about the user. We do not control these third-party websites nor are we responsible for their privacy policies. When you leave our website, we invite you to read the privacy policy of each website you visit.
SENDING DATA OUTSIDE THE EEA
We may share your personal data within the NCR Atleos group. This may involve the transfer of user data outside the European Economic Area (EEA). In addition, some of our third-party service providers are located outside the EEA or use cloud-based services that run on servers located outside the EEA. We will only send your data outside the EEA:
- Follow their instructions.
- Comply with a legal obligation.
- Work with our agents and advisors that we use to manage your business accounts and services.
If we transfer information to our agents or advisors outside the EEA, we will ensure that it is protected in the same way as if it were used in the EEA.
Please contact us if you would like more information on the specific mechanism used to transfer your personal data outside the EEA.
IF THE USER CHOOSES NOT TO PROVIDE US WITH THIS INFORMATION
We may need to collect personal information by law or based on the terms of a contract we have entered into with you. If you choose not to provide this personal information, this may delay or prevent us from fulfilling our obligations. It could also mean that we are unable to provide the services necessary to manage your accounts or business services. This may mean that we may have to cancel a product or service that you have with us.
Any optional data collection will be clarified at the time of collection.
Marketing
We may use your personal information to inform you about relevant products and offers. This is what we mean when we talk about 'marketing'. The personal information we hold consists of what you tell us and the data we collect when you use our services or from third parties with whom we work. We can use your personal information to send you marketing messages only if we have your consent or a 'legitimate interest', such as a business or business reason. The user can ask us to stop sending marketing messages, by contacting us at any time. If you change your mind, you can update your options at any time by contacting us.
CCTV
Cashzone operates closed circuit television (CCTV) in and around Cashzone facilities and resources to provide a safe environment for staff, visitors, and the general public and also to protect the resources and resources of NCR Atleos. We operate with CCTV for:
- Dissuade those with criminal intent.
- Assist in the prevention and detection of crimes;
- Facilitate the identification, arrest, and prosecution of offenders
- Monitor the security of Cashzone buildings and vehicles;
- Identify problems with the movement of the Cashzone vehicle around buildings.
DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized, altered or disclosed manner. In addition, we may limit access to your personal data to those employees, agents, contractors and other third parties who need to know them. They will only process your personal data in accordance with our instructions and you are subject to a confidentiality obligation.
We have procedures in place to address any suspected personal data breach, and you and any applicable regulatory authority will be notified of a breach where we are legally required to do so.
YOUR LEGAL RIGHTS
The user has the right to:
Request a copy of your personal data
Request access to your personal data (commonly known as a 'data access request'). This allows us to receive a copy of the personal data we hold about you and to verify that we are processing it lawfully. The contact details are set out below.
Request the correction of your personal data.
This allows the user to correct any incomplete or inaccurate data, although it may be necessary to verify the accuracy of the new data provided. The contact details are described below.
Request the cancellation of your personal data.
This allows the user to ask us to delete or remove personal data where there are no valid reasons to continue processing it. You also have the right to ask us to delete or delete your personal data where you have exercised the right to object to the processing (see below), where we may have processed your information illegally or where we are required to delete your personal data to comply with local law. Please note, however, that it is not always possible to satisfy the cancellation request for specific legal reasons and that we will be notified, if any, at the time of the request.
Oppose the processing of your personal data where we are based on a legitimate interest (or those of a third party) and there is something in your particular situation that makes you want to object to the processing, as you believe it has an impact on your fundamental rights and freedoms. The user also has the right to object to the processing of their personal data for direct marketing purposes. In some cases, we may be able to demonstrate that we have legitimate reasons for processing user information that override the user's rights and freedoms. The contact details are described below.
Request the restriction of the processing of your personal data.
This allows you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to indicate the accuracy of the data; (b) where our use of the data is illegal, but the user does not want us to delete it; (c) where it is necessary to keep the data, even if it is no longer necessary to indicate, exercise or defend a right in court; or (d) the user has opposed the use of your information, but we must verify if we have legitimate reasons to use it. The contact details are described below.
Request the transfer of your personal data to yourself or to a third party.
We will provide you, or a third party you choose, with your personal data in a structured format, generally in a machine-readable format. Please note that this right only applies to automated information that the user initially provided through consent to use or where we use that information to perform a contract with the user. The contact details are described below.
Revocation of consent
The user can withdraw their consent at any time where we rely on consent for the processing of their personal data. However, this will not affect the lawfulness of any processing carried out before the consent was revoked. If you withdraw your consent, we may not provide you with certain products or services. We will let you know if this is the case when you withdraw your consent. The contact details are described below.
HOW TO GET A COPY OF YOUR INFORMATION
You can access your personal data by filling out the form here or by writing to us at the following address:
NCR Atleos Data Protection Team, Via Cusago 150/4, 20153, Milan, Italy
We will respond to requests for access from individuals within 30 days.
HOW TO FILE A COMPLAINT
The user also has the right to file a complaint with the Information Commissioner's Office. Full details on how to do this are available on the Information Commissioner's website. However, we'd like to appreciate the opportunity to address your concerns before you approach the ICO, so please contact us in the first instance.
Cookies
To learn more about how we use cookies, see our Cookie Policy.
This Privacy Policy is effective as of April 2018.
