1. Introduction
Welcome to Briink Intelligence GmbH (“Briink”, “us”, “we”, and “our”). Briink provides software and services via online platforms provided on without limitation www.briink.com, app.briink.com, platform.briink.com and any successor URLs, mobile or localized versions and related domains and subdomains (our “Websites” and the services provided thereon our “Services”).
Our Privacy Policy governs your visits to our Websites, and explains how we collect, safeguard and disclose information that results from your use of our Services.
We use your data to provide and improve our Services. By using our Services, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms of Service (our “Terms”).
Our Terms govern all use of our Services and together with our Privacy Policy constitutes your agreement with us (“agreement”).
2. Definitions
COOKIES are small files stored on your device (computer or mobile device).
DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.
DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
DATA SUBJECT is any living individual who is the subject of Personal Data.
PERSONAL DATA means data about a living individual which can be identified from such data (or from other information either in our possession or likely to come into our possession).
THE USER is the individual using our Services. The User corresponds to the Data Subject, who is the subject of Personal Data.
USAGE DATA is data collected automatically, either generated by the use of our Services or from our Services infrastructure itself (for example, the duration of a page visit).
3. Information Collection, Use and Restriction
Right to Information
We collect several different types of information for various purposes to provide and improve our Services to you.
Every person affected by the processing of Personal Data has the right granted by the European legislator of directives and regulations to receive free information about the Personal Data stored about them and a copy of this information from the person responsible for the processing at any time. Furthermore, the European directives and regulations grant the data subject access to the following information:
Furthermore, the Data Subject has a right to information as to whether Personal Data has been transmitted to a third country or to an international organization. If this is the case, the Data Subject has the right to receive information about the appropriate guarantees in connection with the transmission.
If a Data Subject wishes to exercise this right to information, he or she can contact an employee of the person responsible for processing at any time.
4. Name and Address of the Person Responsible for Data Processing
The person responsible at Briink Intelligence GmbH within the meaning of the GDPR, other data protection laws applicable in the member states of the European Union and other provisions of a data protection nature is:
Briink Intelligence GmbH
Max-Urich-Strasse 3
13355 Berlin
Germany
info@briink.com
5. Name and Address of the Data Protection Officer
The data protection officer of the controller is:
Tomas van der Heijden
Briink Intelligence GmbH
Max-Urich-Strasse 3 13355
Berlin Germany
info@briink.com
Any person concerned can contact our data protection officer directly at any time with any questions or suggestions regarding data protection.
6. Types of Data Collected
Personal Data
While using our Services, we may ask you to provide us with certain Personal Data that can be used to contact or identify you. Personal Data may include, but is not limited to:
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or by emailing at info@briink.com.
Usage Data
We may also collect Usage Data that your browser sends whenever you visit our Services or when you access our Services by or through a mobile device.
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Services that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access our Services with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Tracking Cookies Data
We use cookies and similar tracking technologies to track the activity on our Services and we hold certain information.
Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Services.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies: We use Session Cookies to operate our Services.
Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
Security Cookies: We use Security Cookies for security purposes.
Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
Other Data
While using our Services, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, non-disclosure agreements, information on bonuses and compensation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.
7. Use of Data
Briink uses the collected data for various purposes:
8. Retention of Data
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
9. Transfer of Data
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
Our Services are hosted and operated in Germany and the United States. If you reside outside the United States, your information will be transferred to, processed and stored in the United States under U.S. privacy standards. By using our Websites and providing information to us, you consent to such transfer and processing of your information by us.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Briink will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
10. Disclosure of Data
We may disclose personal information that we collect, or you provide:
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Briink, our customers, or others.
11. Security of Data
The security of your data is important to us but we caution that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
12. Your Data Protection Rights Under the GDPR
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by the GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at info@briink.com.
In certain circumstances, you have the following data protection rights:
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide our Services without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
13. Service Providers
We may employ third party companies and individuals to facilitate our Services (“Service Providers”), provide the Services on our behalf, perform Service-related services or assist us in analysing how our Services are used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
14. Analytics
We may use third-party Service Providers to monitor and analyze the use of our Services.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
Segment.io is a web traffic analysis tool. You can read the Privacy Policy for Segment.io here: https://segment.com/legal/privacy/.
Mixpanel is provided by Mixpanel Inc.
You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of Mixpanel service, please visit this page: https://mixpanel.com/optout/
For more information on what type of information Mixpanel collects, please visit the Terms of Use page of Mixpanel: https://mixpanel.com/terms/
15. CI/CD tools
We may use third-party Service Providers to automate the development process of our Services.
GitHubGitHub is provided by GitHub, Inc.
GitHub is a development platform to host and review code, manage projects, and build software.
For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.
16. Links to Other Sites
Our Services may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
17. Children's Privacy
Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).
We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
18. Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
19. Contact Us
If you have any questions about this Privacy Policy, please contact us:
By email: info@briink.com
Effective date: 04/08/2023