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NCR Corporation is committed to implementing leading data protection standards to protect the confidentiality and integrity of Personal Data (as defined below) that we Process (as defined below), including Personal Data to which NCR has access in connection with the provision of products and services to our customers . This policy governs NCR Corporation and its global subsidiaries, including Cardtronics PLC and the Cardtronics group of companies (collectively “NCR”) worldwide for all operations where NCR is the Controller of Personal Data.

Definitions

“Contract Data” means any Personal Data about our customers, our customers’ customers, or our customers’ personnel that NCR Processes in connection with providing products or services to a customer under a contract. 

“Controller” means a natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the Processing of Personal Data.

“Personal Data” means information relating to an identified or identifiable natural person to the extent such information is afforded the protection of law. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identification number, location data, an online identifier or to one or more factors specific to the individual’s physical, physiological, mental, economic, cultural, or social identity. In the state of California, Personal Data may also include categories of information that identify or could be linked to a particular consumer or household such as identifiers, bank account and payment card numbers, Protected Class characteristics, commercial information, biometric information, professional, educational or employment-related information, Internet or electronic network activity, and inferences used to create a profile about a consumer in accordance with applicable law.

“Process” means any operation or set of operations that is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, blocking, erasure, or destruction.

“Processor” means a natural or legal person, public authority, agency or other body which Processes Personal Data on behalf of a Controller.

“Special Categories,” “Sensitive Personal Data,” or  “Characteristics of Protected Class(es)” (collectively, “Special Categories”) means, to the extent designated under applicable law, Personal Data revealing racial or ethnic origin, color, national origin; political opinions, religious, or philosophical beliefs; trade union membership; genetic data or biometric data for the purpose of uniquely identifying a natural person; data concerning age, disability, or health; or data concerning a natural person’s sex life or sexual orientation.

“You” means any individual about whom NCR collects, uses, or discloses Personal Data except as described below.

Collection of Personal Data

The categories of Personal Data NCR may collect about you depend on whether you are a customer, user, employee, or visitor and the requirements of applicable law.

You may provide Personal Data to NCR in a variety of ways, such as:

• Creating an Account, Becoming a Channel Partner, or Setting Up a Merchant Account by registering for an online account or event and supplying your name, title, company, business function, physical and email addresses, telephone number, social security number, tax identification number, financial account information, user IDs, and/or password.
• Entering into a Contract or other business relationship with us. We may collect contact information, financial data, and other similar data to manage our relationship with you or your business, take orders, process and deliver products and services to you including complaint and dispute resolution.
• Communicating with Us. When you contact us to join a mailing list, inquire about or purchase a product or service, apply for employment, fill out an information form, or otherwise contact us with a question, comment, or request, and supply your name, title, company, physical and email addresses, telephone number, resume, user IDs, and/or password. 
• Using Our First-Party ATMs or ATM Networks. When you use our first-party ATMs or ATM network, we collect your card and account information for the purposes of completing the transaction.
• Completing Surveys. If you decide to participate, you may be asked to provide certain information, which may include Personal Data.
• Engaging with us on Social Media. We may offer forums, blogs, or social media pages. Any content you provide on these channels will be considered “public” and is not subject to privacy protections.
• Visiting Our Facilities. When you visit our physical facilities, you may provide us with certain information about you for security purposes. We may also employ closed-circuit video recording (i.e., “CCTV”) that may capture your image.
• Registering for Sweepstakes or Contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

We may collect Personal Data about you in the following ways:

• Information from Other Sources. NCR may collect information about you or obtain Personal Data about you from third parties for the purposes of providing you with information about NCR products and services that may be of interest to you, or to take steps to maintain the accuracy of the information we have about you. If you are in an employment or similar arrangement with a third party that provides products or services to NCR, that third party may share your Personal Data with NCR to further that contractual relationship.
• Automatic Data Collection. NCR may also use certain technologies to automatically collect information about you while you are visiting an NCR website, application, product, or service, which as described in more detail below, may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers and related technologies (see below), mobile carrier, mobile advertising and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the services, information about the links you click, and other information about how you use the services. Information we collect may be associated with accounts and other devices. In addition, we may automatically collect data regarding your use of our websites, applications, products and services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your Personal Data with information that others provide when they use our services.
• Contract Data. NCR may collect Personal Data about your based on the direction of its customer(s). In such cases, it is our customers’ responsibility to ensure that their directions to NCR are consistent with the terms of any privacy policies or other guarantees they have made to you.

As described above, NCR websites, applications, and services may employ a variety of tools, including cookies, to help us improve your experience and determine the effectiveness of certain of our marketing initiatives.

• Cookies. A cookie is a small element of data that a website can send to a web browser, which is then stored on the browser user’s computing device. We may use cookies, alone or in combination with other data we may collect from other technologies (such as server logs) to make our websites work or operate more efficiently, to personalize a user’s experience, or to make our websites more useful to our visitors. You can learn more about cookies by visiting https://www.consumer.ftc.gov/articles/0042-online-tracking or www.youronlinechoices.eu.
• Other Technology NCR May Use to Improve Your Experience. NCR, and our service providers, may also use other technology to improve your experience. As described below, these technologies include analysis tools, log file information, web beacons, web links, and local shared objects.
• Analysis Tools. NCR may use analysis tools like Google Analytics or Adobe Analytics to help us analyze how visitors use our websites. Among other things, these tools use cookies to collect data about the number of visitors to the site, the web page that referred visitors to the site, and the pages that visitors view within the site. Both Google Analytics and Adobe Analytics use persistent cookies. To opt out of Google Analytics, visit http://tools.google.com/dlpage/gaoptout. To opt out of Adobe Analytics, visit http://www.adobe.com/privacy/opt-out.html.
• Log File Information. NCR records log file information whenever you access our websites.  Examples of log file information include your IP address, your browser type, the page from which you accessed our website, the pages you viewed while visiting our website, the last page you viewed before you exited our website, and the page you accessed after leaving our website.
• Web Beacons, Pixel Tags, Clear GIFs, and Other Technologies. These technologies involve placing electronic (and usually transparent) images on a website or in an email.  These images place certain information on your device such as cookies, the time and date of a page you viewed and the length of time you viewed the page, the IP address of the device that retrieved the image, the time the web beacon was viewed and for how long, and the type of browser that retrieved the image.  We may use these technologies, for example, to determine whether you have opened or accessed links included in marketing communications from NCR. These technologies often work with cookies; therefore, if you do not want us to associate your cookie information with your visits to our website, you must turn off cookies in your browser.
• Web Links. Emails from NCR may contain links that are designed to take you to a web page after redirection through NCR’s servers (or those of its suppliers). We use the information we obtain during the redirection process to determine whether a particular marketing initiative is effective and may collect information connected to your identity. If you do not want NCR to collect information about the links that you click, you can choose a text-based version of the message (if the option is available).  You may also choose not to click the links we provide in the emails we send to you and search online for the relevant resource independently.
• Local Shared Objects (“Flash Cookies”). NCR may use Adobe Flash Player® to deliver multimedia content, such as a video, to you.  To improve your user experience, NCR may use Flash local shared objects (LSOs) – sometimes called “flash cookies” – to store your flash content information and preferences, similar to other types of cookies NCR employs.  You can manage flash cookies by accessing the following link on Adobe’s website: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
• Notice Regarding APIs and SDKs. We may use third-party APIs and software development kits (“SDKs”) as part of the functionality of our applications. APIs and SDKs may allow third parties including analytics and advertising partners to collect your Personal Data for various purposes including to provide analytics services and content that is more relevant to you.  For more information about our use of APIs and SDKs, please contact us as set forth below.
• Information from Other Sources. We may obtain Personal Data about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you access our website, applications, products and services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made public via your privacy settings. Information we collect through these services may include your name, your user identification number, your user name, location, gender, birth date, email, profile picture, and your contacts stored in that service. This supplemental information allows us to verify information that you have provided to us and to enhance our ability to provide you with information about our business, products, and services.

When we Process Personal Data on behalf of our customers in the performance of a contract, the customer’s privacy policy applies to such Processing. NCR relies on its customers to provide NCR with Processing instructions that comply with those customers’ privacy obligations to you.

Use of Personal Data

NCR is committed to collecting Personal Data for specified and legitimate purposes, to limit its Processing to the stated purpose, and to not Process that data further in a manner incompatible with such purpose without your prior consent.

Lawful Bases for NCR’s Processing. NCR will use Personal Data where reasonably necessary to fulfill NCR’s business needs (as described below), including to:

• Perform a contract or other business relationship with you or take steps at your request prior to entering into a contract;
• Comply with a regulatory or legal obligation;
• Protect your vital interests or that of another natural person;
• Perform a task carried out in the public interest;
• Carry out Processing with your consent, which you may withdraw at any time as described below;
• Further a legitimate interest of NCR or a third party including, but not limited to
• Researching and developing products, services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
• Auditing related to transactions, short-term transient use in accordance with applicable law, debugging to identify and repair errors that impair existing intended functionality and undertaking activities to verify or maintain the quality or safety of a service or device;
• Detecting security incidents, protecting NCR personnel, property and assets from malicious, deceptive, fraudulent or illegal activity including threats or harm including to NCR’s information technology infrastructure, Intellectual property, or goodwill or reputation and prosecuting those responsible for that activity;
• Ensuring compliance with relevant corporate policies and terms; or
• Optimizing utilization of global corporate resources including the administration of business transactions, personnel and information technology systems.

Additional Business Purposes. In addition to the foregoing, NCR may Process Personal Data in the following specific purposes and circumstances:

• Sensitive Data. With respect to Special Categories of Personal Data or Characteristics of Protected Classes, NCR may Process such information in a manner that is consistent with applicable law. 
• Contract Data. As described above, NCR will use Contract Data consistent with applicable contractual obligations with its customers and applicable law.  NCR also may use Contract Data to facilitate compliance with regulatory and legal requirements.
• Deidentified Data. For deidentified or aggregated data, which was formerly Personal Data, but which can no longer identify individuals, NCR may conduct research and development, statistical, trend or pattern analysis in order to continuously improve our products, services, processes, and security procedures.
• Sales and Marketing. NCR may use your Personal Data for sales and marketing purposes, including contacting you for feedback in customer satisfaction surveys or for market research purposes, providing you with marketing literature on products and services, notifying you of events, and providing you with information about NCR. You may always change your privacy preferences as set forth below. From time to time, NCR may co-brand an offering or a communication with a third party, which may also collect your Personal Data.  In such cases, the use of your Personal Data by such third parties is covered by their respective privacy policies, and not this Privacy Policy. In cases where you choose to forward a page from this website to another individual (where such option is available), NCR may request certain Personal Data about that individual to complete your request, such as name and email address, but NCR will not make further use of such information. NCR’s use may include, but is not limited to, making sales calls, sending marketing communications, delivering or completing requested services or transactions, and tracking and analyzing a series of transactions.
• Social Networking Tools. If NCR uses social networking widgets or tools to provide information to you, your information will be governed by the terms of use and the privacy policy for the applicable social networking platform.
• Fulfilling Business Transactions. NCR may use your Personal Data to fulfil business transaction requests with you or your organization.  With respect to our customers, such requests may include, but are not limited to, maintaining or servicing accounts, verifying customer information, processing payments, providing advertising and marketing services, providing analytics services, undertaking internal research of technological development and demonstration, providing products or services including delivering notifications of product issues, fixes or updates, or contacting you in response to your questions, comments, or requests. With respect to our suppliers, such requests may include issuing purchase orders, receiving invoices, or providing other information such as forecasts.  If, in providing service or support (including support to assist you with the use of our websites or applications), we engage you telephonically or via electronic communications through tools such as email or online chat, we may monitor or record our interactions for purposes of quality assurance, training, or to document the details of the interaction or transaction.
• Recruitment. If you seek employment with NCR, you may provide us with information about yourself, such as a resume.  We may utilize automated processing techniques for candidate applications for qualitative scoring or ranking to optimize the efficiency of our recruiting practices. In such cases, however, this Processing is overseen by our Human Resources personnel.  We may use this information throughout NCR to consider you for employment purposes and may keep your information on file for future consideration, to support NCR’s compliance with applicable legal requirements, and as otherwise set forth in this Privacy Policy or in a separate notice that may be provided to you.

Transfers

NCR is a global company with global operations, partners and suppliers. Where it is necessary for the efficient and effective performance of a business transaction or the fulfilment of one of the uses of Personal Data outlined above, NCR may need to transfer Personal Data from the country of collection to other countries, which may have data protection laws that are different from the laws where you live. Where such a transfer is made from one country or territory to another that is not deemed by the first exporting country (“Exporting Country”) to offer an adequate level of protection to the rights and freedoms of data subjects, NCR’s policy is to do so on the basis of contractual controls between the relevant group companies, partners, or suppliers designed to ensure that substantially the same level of protection is afforded to the Personal Data as in the Exporting Country.  NCR’s contractual safeguards are based on the ‘standard contractual clauses’ issued by the European Commission and other data protection regulatory authorities of the Exporting Country.

Disclosure of Personal Data to Third Parties

We may share your Personal Data (including Contract Data) within NCR. We also may share Personal Data with the following categories of third parties:

Service Providers. We may share Personal Data with third-party suppliers and service providers that help us Process Personal Data. Examples of categories of suppliers include:, IT vendors (including IT and related services, security product providers, email providers, and application providers), customer service providers, contingent workers, consultants, professional advisors, and other vendors to support the provision of our products and services. It is NCR’s practice to enter into contracts with our suppliers and service providers that require them to handle your information in a manner consistent with NCR policy and applicable law. 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.

Business Partners. We may provide Personal Data to business partners with whom we jointly offer products or services. In such cases, our business partner’s name may appear along with ours.

Bank Card Issuers. When you use one of our first-party ATMs, we will share the information captured with your card issuer or account provider for the purposes of validating the requested transaction.

Advertising Partners. Third parties do not advertise on NCR’s websites. NCR, however, may contract with third parties who collect information about your online activities over time and across different devices and websites (including NCR websites).  These third parties use cookies or web beacons across multiple websites, including NCR’s websites, to collect certain information about you (e.g., your IP address, mobile identifiers, page(s) visited, location, time of day) to provide you with targeted ads based on your interests. We engage with these third parties to help us deliver targeted advertisements about NCR on other websites you visit. If we need to facilitate these third parties to place cookies on your device to enable this functionality, we will do so in accordance with this Privacy Policy. However, the third parties’ collection, use, and disclosures of your information is governed by their own privacy policies and statements. You have several choices to control the delivery of targeted ads to you by NCR, as described below.

Disclosure in the Event of Merger, Sale or Other Asset Transfer. From time to time, NCR may contemplate entering into various business development activities which may include the sale, purchase, merger, or reorganization of one or more of its businesses.  These business development activities may require the disclosure of Personal Data to the prospective or actual purchaser(s). When such disclosures are required, NCR will seek appropriate protections of your Personal Data.

Disclosures to Protect Us or Others. In certain circumstances, NCR may use or release Personal Data to third parties when disclosure is required by a legal authority to which we are subject, such as pursuant to a statute, regulation, judicial proceeding, court order, or subpoena. We also reserve our right to use or provide your Personal Data to third parties, including law enforcement, auditors, consultants, and government officials, to protect NCR’s rights, property, or safety, and/or the rights or property of our customers, business partners, suppliers, or other third parties. We may also disclosure Personal Data to enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity

Your Privacy Rights

Your Preferences. You have certain choices about your Personal Data.  Where you have consented to the processing of your Personal Data, you may withdraw that consent at any time and prevent further processing as follows:

• Email and Telephone Communications. From time to time, you may sign up to receive information or access to NCR services, or where law permits, we may provide you with information we believe may be of interest to you. In all cases, we will provide you with mechanisms to control your receipt of such communications or services. In addition, you may indicate to us that you no longer wish to receive emailed marketing communications from us by following the unsubscribe instructions included in the email communications we may provide to you, and you may always contact us directly as set forth in this Privacy Policy.
• Contract Data. With respect to Contract Data, the NCR customer is responsible for your Personal Data, and, where applicable, Processing your privacy rights requests.
• Mobile Devices. If you install an NCR mobile application, NCR may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
• Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that at this time NCR does not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
• Cookies and Interest-Based Advertising. You may stop or restrict the placement of technologies on your device or remove them by adjusting your preferences as your browser or device permits. If you would like to change your browser’s cookie settings, please refer to the online help offered with your browser or to your device manufacturer’s website.  Please note, however, if you decide to turn off cookies, there may be some features of our websites that may not be available to you and some pages may not display properly. To learn more about managing cookies on your device, please visit  http://www.allaboutcookies.org/manage-cookies/. The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy, at http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, www.networkadvertising.org/managing/opt_out.asp, and www.aboutads.info/choices/.  To separately make choices for mobile apps on a mobile device, you can download DAA's AppChoices application from your device's app store. Alternatively, for some devices, you may use your device's platform controls in your settings to exercise choice.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements may also provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes. Furthermore, even if you exercise your choices, you may still receive generic, non-targeted ads from NCR. 

Your Individual Rights. In accordance with applicable law, we provide several mechanisms to allow you to:

• Access Personal Data about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic Personal Data transferred to another party. Where permitted by law, NCR may charge a reasonable fee if we are required to provide information about you. You may have the right to request information about public and private entities with which the NCR has shared data.
• Request rectification correction of your Personal Data where it is inaccurate or incomplete.  In some cases, NCR may provide self-service tools that enable you to update Personal Data about you or refer you to the Controller of your Personal Data who is able to make the correction. 
• Request deletion or erasure of your Personal Data where required by law, subject to certain exceptions prescribed by law.
• Request restriction of or object to Processing of your Personal Data, including the right to opt in or opt out of the sale of your Personal Data to third parties, if applicable, where such requests are permitted by law. You may request restriction of the Processing of your Personal Data while NCR undertakes to verify the accuracy of your data where you have contested its accuracy; where NCR’s Processing is unlawful and you have the right to erasure, but request that we restrict Processing instead; where the data are no longer needed for the purposes of the Processing by us, but they may be required by you for the pursuit or defense of a legal claim, or by NCR where its legitimate interests override your request for restriction.. NCR will notify you before we begin to Process any information about you that was restricted just prior to Processing.

You may log into your account or use the contact mechanisms specified below to make your request, or, if you do not have an account, please visit our access request portal. We will process such requests in accordance with applicable laws. Where necessary to protect your privacy, NCR may take reasonable steps to verify your identity before acting on a request.

Consent Exceptions. Where you have previously provided your consent, you may withdrawal your consent at any time; however, doing so will not affect the lawfulness of NCR’s processing before your withdrawal of consent.  Once you withdraw consent, we will no longer Process your information for the purpose(s) to which you originally consented unless there are compelling legitimate grounds for further Processing which override your interests, rights, and freedoms or if Processing is necessary for the establishment, exercise, or defense of legal claims.

Denying a Request. In certain circumstances applicable law may permit NCR to deny such requests, for example, where an access, rectification, or erasure request is manifestly unfounded or excessive, in particular where it is repetitive, where the burden or expense of providing access would be disproportionate to the risks to your privacy, or where the rights of other persons would be violated. You may appeal a denial by contacting NCR in the manner set forth in the Contact Us section of this Privacy Policy.

Use of Automated Individual Decision Making Including Statistical Analysis and Profiling

NCR may use statistical and analytic techniques to support automated individual decisionmaking including profiling for the purpose of improving the quality, performance or efficiency of our products, services or processes or to screen applicants for employment, to facilitate compliance with law or policy, or to protect our information technology infrastructure.

Protection of Your Personal Data

NCR aims to provide leading data security protections to safeguard Personal Data. We prioritize safety across our business and commit to operating in accordance with the laws applicable to the countries in which we conduct business and with our contractual requirements. Furthermore, NCR takes reasonable and appropriate steps designed to safeguard Personal Data in accordance with these laws and requirements.   

Retention of Personal Data

NCR retains Personal Data only for so long as it is necessary to support the overall purpose(s) for which NCR collected such information. We will retain and use your personal information as necessary to comply with our business and legal obligations, resolve disputes, protect our assets, and enforce our rights and agreements. We take steps to minimize access, use and retention of Personal Data to what is reasonably necessary.   

Children's Information

NCR’s applications and websites are not directed to children under the age of 16.  By your use of our applications and websites, you affirm that you are at least 16 years of age. If you are a parent or a guardian, and you believe your child has provided NCR with Personal Data without your consent, please contact us as described below.

Changes to This Privacy Policy

We reserve the right to update this Privacy Policy at any time, and we will make an updated copy of such privacy Policy available on our website. When we make any revisions that materially change the ways in which we use or share the Personal Data previously collected from you, we will give you the opportunity to consent to or opt-out of such changes before applying them to that Personal Data in accordance with applicable law.

Changing Your Preferences and Contacting Us

You may change your marketing preferences by clicking here.

We want to address any concerns you may have. You may send any comments or questions regarding this Privacy Policy or NCR’s handling of your Personal Data by email to [email protected], or by mail to:

NCR Corporation
Privacy Office
864 Spring Street NW
Atlanta, GA 30308
US Toll-free: 1-800-CALL-NCR

We will respond to your request within 30 days of submission. 

If NCR does not satisfactorily address your concerns, you have the right to lodge a complaint with your any national data protection authority of competent jurisdiction.