myExchange Application Privacy Notice

Brambles Ltd and its affiliates including its companies operating under the CHEP brands (collectively, “Brambles” or “we” or “our” or “us”), respect your right to privacy and your right to control the dissemination of your personal information. Please click here for a list of our business locations and contact information.

Brambles’ myEXCHANGE application (“myEXCHANGE”) is our web-based service and application for recording, managing and monitoring of exchanges of CHEP equipment.

This privacy notice applies to myEXCHANGE and describes i) how myEXCHANGE collects information from you, ii) what types of information it collects, iii) what Brambles and its affiliates may do with the information you provide, iv) who may have access to your information, and v) your rights regarding privacy, including your right to access and correct the information you provide through myEXCHANGE.

By using myEXCHANGE, you acknowledge you have read and understood this Privacy Notice, which is incorporated into, and part of, the Terms and Conditions of myEXCHANGE, which governs your use of the application.

Please note that this privacy notice uses the terms personal data and personal information as equivalent terms as any information relating to an identified or identifiable natural person (‘Data Subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; or as may be further specified by Applicable Data Protection Law.

1.      WHAT IS myEXCHANGE AND WHAT PERSONAL INFORMATION WE COLLECT FROM YOU?

myEXCHANGE is a web-based service and mobile application owned by Brambles and locally used by its CHEP Affiliates, their customers, and their drivers for recording, monitoring and managing exchanges of CHEP equipment.

In order to use myEXCHANGE, you must register as a user. To that end, you have to provide basic personal and authentication information such as your name and last name. Additionally for portal access we also require your business email address and phone number.

Upon registration in myEXCHANGE, you will be asked to provide a username and password, which will be used for authentication purposes in the future. In case you provide personal data or information about other individuals or companies, please make sure they are aware of this Privacy Policy.

We may collect and process the following information about you:

• Contact information (such as name, last name, business email address).
• Geo-location information (such as physical location, collection and delivery locations).
• Internet or other Electronic Network Activity information (such as browsing history, IP address, device type, operating system, and duration of user session).
• Signature (to generate the electronic proofs of delivery).

2.      IP ADDRESSES AND COOKIES

2.1.            IP Addresses

Our web servers may collect the name of the domain you used to access the Internet, the Site you came from, and the Site you visit next. This information is aggregated to measure the number of visits to the site, average time spent, page views, and other statistics about visitors to this site. We may also use this aggregated data to monitor site performance and to make the site both easier and more convenient to use.

When you visit our Sites, we collect certain technical and routing information about your computer to facilitate your use of the Sites. For example, we may log environmental variables, such as browser type, operating system and CPU speed, and the Internet Protocol ("IP") address of your originating Internet Service Provider, to try to bring you the best possible service. We may also record search requests and results to try to ensure the accuracy and efficiency of our search engine. We may use your IP address to track your use of the site. This "Click Stream" data may be matched with other information you provide.

2.2.            About Cookies

Cookies are files, often including unique identifiers, that are sent by web servers to web browsers, and which may then be sent back to the server each time the browser requests a page from the server. Cookies can be used by web servers to identity and track users as they navigate different pages on a Site, and to identify users returning to a Site. myEXCHANGE does not use analytical cookies.

3.      HOW WE USE YOUR PERSONAL INFORMATION

We may use the information we obtain about you to:

• Operate myEXCHANGE
• Ensure that the content from myEXCHANGE is presented in the most effective manner for you and for your device
• Keep track of CHEP equipment balances
• Generate electronic proof of pallets delivery
• Facilitate transactions between our customers and their supply chain
• Protect against and prevent fraud, unauthorised transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorised users
• Comply with applicable legal requirements and industry standards and with our policies

We may aggregate and/or de-identify data about customers and Site visitors and use it for any purpose, including product and service development and improvement activities.

 

Where you have provided information through the myEXCHANGE App, to register you as a user of the App, provide you with services through the App and to improve our business processes, including by managing the delivery and collection of our pallets. We may also disclose information about you, including geolocation information, to our customers, for these purposes.

 

4.      DISCLOSURE AND SALES OF YOUR PERSONAL INFORMATION

When you provide information to our Sites, we may share that information as follows:

• Within Brambles and its affiliate entities. Please click here for a list of our business locations and contact information. Brambles employees will have access on a need-to-know basis and are also bound by obligations of confidentiality. Sharing your information within Brambles group is subject to an Intragroup Data Transfer Agreement.

 

• In order to carry out your requests, to make various features, services and materials available to you, to respond to your inquiries, perform the contractual relationship, and for other purposes described in the "How We Use Your Personal Information" section of this Privacy Notice, we may share your personal information or usage information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals that: provide IT services; host our data; host or operate our systems and sites; analyse data; provide asset collection services; administer awards programs or other third parties that participate in or administer the Application. To the extent we grant these parties access to your personal information, they are expected to follow privacy practices no less protective that our practices to the extent allowed by applicable law.

 

• We may share non-personal information, such as aggregate user statistics, demographic information, and usage information with third parties for in order to improve our services and products; our sites and our communication with you.

 

• We may disclose your personal information, usage information, and other information about you to parties acquiring part or all of our assets, as well as to attorneys and consultants. If we transfer your information to an acquirer, we will use reasonable efforts to direct the acquirer to use your information in a manner that is consistent with this Privacy Notice.

 

• If any bankruptcy or reorganisation proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

 

• We may disclose information about you to others if we have a good faith belief that we are required to do so by law or legal process, to respond to claims, or to protect the rights, property or safety of Brambles or others.

5.      LEGAL BASIS TO COLLECT AND PROCESS YOUR INFORMATION

We will only collect and process personal information about you where we have a legal basis to do so, including i) performance of a contract (where processing is necessary for entering into or the performance of a contract with you), ii) your consent (e.g. when you communicate with us through website contact forms or you log into myEXCHANGE); and iii) the fulfillment of a legitimate interest.

 

We may process your personal information for the purposes of our legitimate interests, provided that such processing does not outweigh your rights and freedoms. Where we rely on legitimate interests, you have the right to object. Please keep in mind that if you object this may affect our ability to perform certain services for your benefit.

 

We process your personal information based on legitimate interests in order to:

• Protect you, us, or others from security threats;
• Comply with laws that apply to us;
• Improve our Site performance;
• Enable or administer our business, such as for invoicing, processing payments and platform maintenance; and
• Understand and improve our business or customer relationships generally.

 

6.      YOUR PRIVACY RIGHTS

Depending on the applicable data protection regulations, you may: (i) request information on and access to the personal information we hold about you (Right of Access); (ii) request that any inaccurate personal information we hold be corrected (Right to Rectification); (iii) to object to certain types of processing of your personal information we carry out (including the right to opt-out of any direct marketing) (Right to Object); (iv) request that We delete the personal information We hold about you (Right to Erasure or Right to Be Forgotten); (v) request that we restrict our processing of your personal information in certain circumstances, such as when you contest the accuracy of that personal information (Right to Restriction of Processing); (vi) request a copy of your personal information in a machine readable, commonly used format (or to request we transfer your personal information in such a format to a third party service provider) (Right to Data Portability); (vii) request not be subject to an automated decision-making or profiling; and/or (viii) withdraw your consent at any time when we process your personal information based on your consent.

Whilst some of these rights can be exercised by you directly through the Site, many of the rights, such as those relating to requests to delete your personal data, will need to be submitted to Us. You may exercise any of the applicable rights by clicking here to complete the Privacy Rights Intake Form.

We will consider such requests and respond to you. If we deny an access request, we will notify you of the reasons for the denial. We may charge you a small fee and may require verification of your identity before providing a copy of your information as permitted by law.

7.      DATA RETENTION

We retain the personal data that we collect from you no longer than is necessary except where we have an ongoing legitimate business need to do so (for example, to provide you with the services you requested or to comply with an applicable legal requirement). In any event, your personal data will be retained consistent with Brambles Global Record Retention Policy and Schedule. For instance, transactional data is archived after 13 months and browsing information is deleted within 12 - 24 months.

If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

8.      SECURITY

We maintain certain administrative, technical and physical safeguards to help protect against loss, misuse or unauthorised access, disclosure, alteration, or destruction of your personal information. However, no electronic data transmission or storage of information can be completely secure. We cannot ensure or warrant the security of any information you transmit to us or that we acquire. Accordingly, you must use each of our Sites at your own risk.

If, despite all our efforts, a data breach does occur, we shall do everything reasonably practicable to limit the damage. In case of a data breach, and depending on the circumstances, we will inform you about remedial actions to prevent any further damage.

9.      WHAT ELSE SHOULD YOU KNOW?

User-Generated Content

Some of our services and social networking features enable you to submit your own content for public posting. Personal information you post in this fashion becomes public information and is not subject to this Site Privacy Notice. We cannot control how others may use publicly posted information.

Any personal information that you post or submit to any Brambles’ social media platform or Site (such as Facebook or Twitter) will be subject to social media platforms’ privacy notices. Nevertheless, when such information is processed by Brambles, such processing will be subject to this Privacy Notice. 

10.  OUR EMAIL AND TEXT MESSAGE OPT-OUT POLICY

In order to register for an account, you will need to consent to our Terms of Use and this Privacy Notice. By providing an email address on the Brambles Sites, you agree that we may contact you in the event of a change in this Privacy Notice, to provide you with any service-related notices, or to provide you with information about our events, invitations, or related educational information.

We currently provide the following opt-out opportunities:

• At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us to unsubscribe.
• At any time, you can contact us through Brambles Know Your Privacy Rights channel by clicking here to unsubscribe and opt-out of our right per your consent under the terms of this Privacy Notice to share your Personal Information.

Notwithstanding anything else in this Privacy Notice, please note that we always reserve the right to contact you in the event of a change in this Privacy Notice, or to provide you with any service-related notices.

11.  CHILDREN

Our services are generally not directed to children under 16. We do not knowingly collect personal information from anyone under 16 without parental consent. If you become aware that we have collected personal information from a child under the age of 16 without parental consent, please contact us as indicated below so we can take appropriate action. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

12.  HOW TO CONTACT US

If you have any questions, comments or concerns about this Privacy Notice or if you would like us to update information, we have about you or your preferences, please contact our Global Data Privacy Officer at privacy@brambles.com.

13.  PRIVACY NOTICE UPDATES

We reserve the right to modify or supplement this Privacy Notice at any time. Changes to the policy will be posted at least 30 days prior to the effective date of the changes. The date below indicates when this Privacy Notice was last changed.

This policy was last updated on 12.07.2024, effective 12.07.2024

 

 

 

 

 

 

CHEP – Exchange App Collection Statement

 

 

This privacy collection statement applies to CHEP Australia Limited ABN 11 117 266 323 (“CHEP”, “we”, “us”, “our”).

 

By downloading this App you will be providing personal information to CHEP.

 

We are collecting this information for the purposes of registering and allowing you to use our Exchange App (the App), which will enable us and you to manage the delivery and collection of our pallets. We will use your personal information to register you as a user, set up your account, communicate with you, manage your account and provide you with support. Via the portal, we will capture the user’s personal information (name and last name) to enable App user setup.

 

While using the App and if you approve, we will use your geolocation data to auto populate your nearby delivery/collection locations.

 

App is only collecting data when the app is being used - we cannot see where the driver goes during the day (for example).

 

We may disclose your personal information to third parties for these purposes. This includes disclosures to our customers, particularly of geolocation information, as required for our customers to locate and manage equipment. We may also provide your information to our contractors who provide services to us including IT service providers, our professional advisers, our related companies, and other third parties as required by law. 

 

We may disclose your personal information overseas to overseas providers who perform certain functions for us including e.g. data storage. We will not otherwise disclose your personal information to recipients overseas without your consent or where required or permitted to do so by law.

 

If you do not provide the requested personal information, we may be unable to register you as a user of the App and permit you to use the App.

 

Our privacy policy contains information about how you may seek access to, or correction of, personal information that we hold about you, how you can complain to us if you believe your privacy rights have been breached, and how we will handle your complaint. 

 

If you would like further information please contact CHEP's Global Data Privacy Officer at privacy@brambles.com.