Privacy Notice

Brambles Limited 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.

This notice applies to this website and any mobile applications or other online and/or mobile applications or websites operated by us or that are related to us (collectively, "Website"). It also describes i) how this Website collects information from you, either as customer or as Website visitor; ii) what types of information it collects; iii) what we may do with the information you provide; iv) who may have access to your information; and v) your rights regarding privacy.

By visiting our website, and/or using the services offered on or through our website, you acknowledge you have read and understood the terms of this Privacy Notice. This Privacy Notice is incorporated into, and part of, the Terms and Conditions of our website, which governs your use of our website.

This Privacy Notice addresses the following topics:

Information we collect from you
IP Addresses and Cookies
How we use your personal information
Disclosure of your personal information
Legal basis to collect and process your personal information
Special provisions for our European users
Your Privacy Rights
Data retention
Security
What else should you know?
How to contact us
Privacy Notice updates
Supplemental Privacy Notice for California users

Please note that this Privacy Notice uses the terms personal data and personal information interchangeably and they are defined as mean any information relating to an identified or identifiable natural person. An identified or 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 or social security number, a driver’s license 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 an applicable data protection or privacy law.

1. HOW WE MAY COLLECT INFORMATION FROM YOU

We may collect and process the following information about you through any of the following channels:

i. From Website Contact Forms

If you choose to use the contact function through any of the Website contact forms, we may ask you to provide us with some basic information about you and/or your company -- such as name, surname, job title, business email address, business postal address, business telephone and business mobile number-- which enables us to provide services and information to you, and helps make our contact with you as productive as possible.

ii. From Further Communications

To continually improve the effectiveness of our customer service communications, we may examine e-mail communications with you for its effectiveness. We may also collect other information from you --such as name, surname, job title and business contact details and opinions-- when you provide comments, participate in surveys, communicate an incident, or submit claims or complaints.

iii. From the Provision of Services

We may receive information about you when we set you up as customer, when we provide our services or when we process any incidents, claims or complaints submitted by you. In such cases, we may collect your name, surname, job title, business email address, tax identifier and billing related information.

We may also collect information about you when we set you up as user of any of our customer facing Website applications (including name, surname and business contact details and log in details).

iv. From Browsing

We may collect details of your visits to our website including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for Our own purposes or otherwise and the resources that you access. For further information, please see next section “IP Addresses and Cookies”.

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 website you came from, and the website 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 website, we collect certain technical and routing information about your computer to facilitate your use of the website. 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 website, and to identify users returning to a website. Cookies are either placed by our website (first-party cookies) or other websites whose content appears on our website (third-party cookies).

Cookies may be either "persistent" cookies or "session" cookies. A persistent cookie consists of a text file sent by a web server to a web browser, which will be stored by the browser and will remain valid until its set expiry date (unless deleted by the user before the expiry date). A session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

2.3. How we use cookies

Cookies do not contain any information that personally identifies you, but information that we store about you may be linked, by us, to the information stored in and obtained from cookies.

We use the information we obtain from you for the following purposes:

to recognise your computer when you visit our website
to track you as you navigate our website
to improve our website's usability
to analyse the use of our website

There are different categories of cookies used for different purposes. We or other parties may collect personal information about your online activities over time and across different websites when you use our website.

2.4. Managing cookies

You can control how your browser handles cookies received from our website. You can choose to refuse all cookies, or to be prompted before a cookie is saved to your hard drive, or to only accept cookies from certain websites that you designate. Information on deleting or controlling cookies is available at www.AboutCookies.org. By refusing to accept cookies from us, you may not be able to use some of the features and functionality available on our website.

3. HOW WE USE YOUR PERSONAL INFORMATION

We may use the information we obtain about you to:

Operate our website;
Ensure that the content from our website is presented in the most effective manner for you and for your computer;
Communicate with you about our products, services, offers, events and promotions, and offer you products and services we believe may be of interest to you, such as through email business alerts and newsletters;
Provide customer support, including by responding to requests for information about our products and services (such as material safety information or inquiries about our services);
Meet the requirements of our contractual relationship with you, including providing you with the specific services that you request and managing incidents, claims and complaints;
Provide access to our customer facing website solutions and applications
Facilitate your involvement in our charity programmes and community activities, only when requested;
Operate, evaluate, and improve our business;
Gather your feedback about and improve our products, services, programmes, and internet services;
Analyse and enhance our marketing communications and strategies and trends and statistics regarding use of our internet services;
Protect against and prevent fraud, unauthorised transactions, claims, and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorised users;
Conduct credit checks on customers and/or customers’ businesses; and
Comply with applicable legal requirements and industry standards and with our policies.
We may aggregate and/or de-identify data about customers and website visitors and use it for any purpose, including product and service development and improvement activities.

4. DISCLOSURE OF YOUR PERSONAL INFORMATION

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

Within Brambles and affiliated entities. Please click here for a list of our business locations and contact information. Brambles’ employees will have access on need-to-know basis and have committed themselves to confidentiality.
Sharing your information within the Brambles Group is subject to an Intragroup Data Transfer Agreement. Additionally, as some Brambles Group entities are located outside the European Union (EU), the European Economic Area (EEA) and the United Kingdom (UK), International Data Transfers will take place consistent with the safeguards set out in Standard Contractual Clauses and/or Standard Data Protection Clauses adopted or approved by the European Commission or an equivalent supervisory authority.
In order to carry out your requests, to make various features, services and materials available to you, to respond to your inquiries, perform our 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 other entities with which We do business), such as companies or individuals that: provide IT services; host our data; host or operate our systems and sites; analyse data; provide customer service; mail product samples or manage payments; credit rating agencies; advertisers; sponsors or other third parties that participate in or administer our promotions or provide marketing or promotional assistance. Our services offering may present you with the opportunity to opt in to receive information or marketing offers from third parties or to otherwise consent to the sharing of your information with third parties. If you agree to have your personal information shared, your personal information will be disclosed to the third party subject to the privacy notice and business practices of that third party.
We may share non-personal information, such as aggregate user statistics, demographic information, and usage information with third parties for data analysis 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 PERSONAL 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); and iii) the fulfilment 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 to our processing, 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 website performance;
Enable or administer our business, such as for invoicing and platform maintenance; and
Understand and improve our business or customer relationships generally.

6. SPECIAL PROVISIONS FOR OUR EUROPEAN AND UK USERS

By providing us with information and data, you understand and acknowledge that we may collect, use and disclose personal data for commercial and marketing purposes, and may provide such information (consistent with the terms of this Privacy Notice) within Brambles, which may be outside your resident jurisdiction.

6.1. Communications

To continually improve the effectiveness of our customer service communications, we may examine e-mail communications with you for effectiveness. Insofar as this communication relates to European Union or European Economic Area (EU/EEA) or United Kingdom (UK) customer services, such analyses are performed on the basis of anonymised e-mails. We anonymise these e-mails in accordance with the requirements of the EU General Data Protection Regulation, the UK General Data Protection Regulation and applicable local laws before transmitting them to a processor / service provider outside of the EU/EEA or the UK for their analysis. In the unlikely event that data are re-identified after transfer, the security of your data will be protected by appropriate safeguards, including but not limited to Model Clauses pursuant to the European Commission’s decision 2021/914 as published in O.J. EU 2021 L 199/31 (and is also available online by clicking here or via URL https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj) or the International Data Transfer Clauses approved by the UK Authorities (“Model Clauses”).

6.2. Where we store your personal information

Please be aware that the personal data you share may be transferred, and stored, outside of the EU/EEA and outside of the UK, and in a database and on servers in the United States and other countries in which the privacy laws may not be as comprehensive as those in your country of residence or citizenship. Such transfers will occur only where appropriate safeguards are in place, including but not limited to Model Clauses.

6.3. European and UK Supervisory Authorities

You have the right to register a complaint with a European data protection or supervisory authority about our collection and use of your personal information. For more information, please contact your local data protection authority (contact details for EU data protection authorities are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm and for UK data protection authority at https://ico.org.uk/)

7. 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); (v) 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 to 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 this website, 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 sending an email to privacy@brambles.com or 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.

8. 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.

9. 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 our website 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.

10. WHAT ELSE SHOULD YOU KNOW?

10.1. User-Generated Content

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

Any information, communications, or material of any type or nature that you post or submit to our website (including, but not limited to any Brambles websites contained on a social media platform or website such as Facebook or Twitter) by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of any social media platform or website, and we are therefore not responsible for any content or Submissions contained on such sites and platforms.

10.2. Privacy Practices of Third Parties

Some of our services and social networking features enable you to submit your own content for public posting. For instance, our website displays the Twitter icon and the LinkedIn icon. When you click on these third party icons, a new window will open for that company’s website. Information you post in this fashion becomes public information and is not subject to this website Privacy Notice. We cannot control how others may use publicly-posted information.

Any information, communications, or material of any type or nature that you post or submit to our website (including, but not limited to any Brambles website contained on a social media platform or website such as Facebook or Twitter) by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”), is done at your own risk and without any expectation of privacy. We cannot control the actions of other users of any social media platform or website, and we are therefore not responsible for any content or submissions contained on such sites and platforms.

10.3. 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.

10.4. Communications

Subject to your marketing preferences, collected at the time you submit a request for more information on our website, we may send you marketing information about goods and services which may be of interest to you by post, telephone, email or other means. You have the right to "opt in” and "opt out” of certain uses of your personal information for these purposes. To that aim, you will modify your preferences through the “unsubscribe” link included on our marketing emails or following the process indicated in “Your Privacy Rights” Section.

11. 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 Privacy Team at privacy@brambles.com

12. 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 8 March 2022, effective 1 April 2022.

Supplemental Privacy Notice for California users

Effective Date: 1 April 2022

This Supplemental Privacy Notice for California Users (“California Notice”) is provided to inform you how we may process personal information of California consumers. This California Notice supplements our other privacy policies and notices, including our main Privacy Notice. In the event of a conflict between any other policy, statement, or notice and this California Notice, this California Notice will prevail as to California consumers and their rights.

1. INFORMATION WE MAY COLLECT FROM CALIFORNIA RESIDENTS

The specific pieces of personal information that Brambles collects, uses, and shares depends on the services you use on our website. We may collect the following categories of personal information:

Contact information (such as name, email address, phone number, unique personal identifier, online identifier, and Internet Protocol address).
Personal identifiers (such as name, signature, address, telephone number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information).
Employment information (such as current or past job history or performance evaluations; disciplinary action, professional memberships, employee reference checks, and trade union membership).
Commercial information (such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies).
Geo-location information (such as physical location or movements).
Internet or other Electronic Network Activity information (such as browsing history, IP address, device type, operating system, and duration of user session).
Inferences drawn from the above categories of personal information reflecting your preferences, characteristics, behaviours, attitudes and abilities.

In addition to the above categories, you may choose to provide us with additional pieces of information when you fill in a form, provide comments, or interact with us in other ways.

2. SOURCES OF PERSONAL INFORMATION AND HOW WE USE IT

We collect information from a variety of sources. The following are categories of source from which information is collected:

Directly from you and other users through your interactions with and use of our services;
Through our website, including online forms;
Through automated technologies and online browser tools, including the use of cookies, pixel tags and other technologies; and
From third party service providers or business partners, including advertising networks and data analytics providers.

We may use personal information collected listed in Item 1 “Information We May Collect from California Residents” from any of the sources listed in Item 2 “Sources of Personal Information and How We Use It” section of this California Notice for our internal business purposes, such as data analysis, audits, developing new products, enhancing our websites and apps, improving our services, identifying usage trends and determining the effectiveness of our promotional campaigns.

3. DISCLOSURES AND SALES OF INFORMATION

We share personal information with our service providers, other vendors (including those that facilitate interest-based and other advertising and marketing), affiliates, and third parties. Generally, we disclose the following categories of personal information for a business purpose:

Identifiers
Personal Records Described in Cal. Civ. Code § 1798.80(e)
Commercial Information
Internet or other electronic network activity information
Geolocation Data
Inferences

Although we do not sell personal information in exchange for money, some of the ways in which we share personal information for advertising or marketing may be considered “sales” under California laws. The categories of personal information we sell are:

Identifiers
Commercial Information
Internet or other electronic network activity information
Geolocation Data

The categories of persons to which we disclosed this personal information include affiliated and related companies, service providers, professional advisors, and external auditors. More information on how we share personal information can be found in our Privacy Notice.

4. CALIFORNIA PRIVACY RIGHTS

4.1 Your Rights

You have the right: (i) to know the categories and/or specific pieces of personal information collected about you, including whether your personal information is sold or disclosed and the purpose, and with whom your personal information was shared in the prior twelve months; (ii) to request deletion of personal information, if permissible by law; (iii) to access a copy of the personal information we retain about you; (iv) to opt-out of the sale of personal information; and (v) to non-discrimination based on the exercise of a consumer’s privacy rights.

4.2 Exercising Your Rights

You may exercise any of the rights described in this California Notice by sending an email to privacy@brambles.com; by clicking here to complete the Privacy Rights Intake Form or calling 1-855-409-0019. We will promptly respond to all applicable requests.

We will verify your identity in connection with any requests you submit to help ensure that we provide the information we maintain to the individuals to whom it pertains, and allow only those individuals or their authorised representatives to exercise rights with respect to that information. If you are an authorised agent making a request on behalf of a consumer, we may require and request additional information to verify that you are authorised to make that request.

We reserve the right to deny your request if we cannot verify your identity. Where we deny your request in whole or in part, we will inform you of the denial, provide an explanation of our actions, and the reason(s) for the denial.

We will not restrict or deny you access to our services because of choices and requests you make in connection with your personal information.

5. CALIFORNIA’S “SHINE THE LIGHT” LAW

If you are a California resident, you are entitled, once a year, free of charge, to request information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. You may exercise your right under California’s “Shine the Light” Law by contacting us as detailed in the “How to Contact Us” section of the California Notice.

6. CALIFORNIA RESIDENTS AND DO-NOT-TRACK DISCLOSURE

Because there is not yet a consensus on how companies should respond to web browser-based or other do-not-track ("DNT") mechanisms, our website does not respond to web browser-based DNT signals.