Privacy Notice

Who we are?

“Allpoint” means the Allpoint Network and its associated entities. This notice sets out the general principles with which Allpoint will collect, process and treat your personal data (subject to the specific data privacy legislation which applies to you). Personal data, or personal information, means: information about an individual from which that person can be identified (but does not include anonymous data), which can be derived from any information that you tell us about yourself and information we learn by having you as a customer.

We will let you know which of the entities you will have a direct relationship with when you engage with us. When we mention Allpoint, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Allpoint group responsible for processing your personal data.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing your personal data so that you are fully aware of how and why we are using your personal data. This privacy notice supplements the other notices and is not intended to override them.

Data Privacy Manager

We have also appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your rights, please contact the data privacy manager here.

If you have any queries about how Allpoint processes your personal data please contact us here.

Contents

General Information

General Data Protection Regulation (GDPR)

California Consumer Privacy Act (CCPA)

General Information

Personal Data We Collect

We collect contact details and supplementary information required for the purposes of fulfilling the relationship Allpoint has with you, which, may in the case of an employment relationship, include special categories of data. We also collect, use, and share statistical or demographic data. This may be derived from your personal data, but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

Data Type Decscription
Contact Details Your name, where you live, how to contact you i.e. email, phone
Financial Bank account and sort code details, account name, account number, financial institution, debit card number, credit card number
Contractual Signed agreements for the services we provide you
KYC Supporting Documents Details about you taken from documents such as passport number, driving license or birth certificate, utility bills
Land Registry Property details and names of freehold/leasehold ownership
Communication What we find out about you from letters, phone calls and emails we received from you.
Consent Any permissions or consent you have provided us (this may not be applicable and/or required in certain jurisdictions)
Corporate Information Business/organisation information such as directors, corporate registered address, etc. obtained from the applicable corporate registry (i.e. Companies House)
Personal Details Signature
Electronic Internet protocol (IP) address, cookies

How We Collect Personal Data

We will collect personal data about you through any of our Allpoint group businesses:

  • When you complete a form on any of our group business websites
  • When you enter into a contract with Allpoint
  • When you provide information in emails or letters
  • When you speak to us on the phone
  • When you apply for any of our services
  • When you use any of our services
  • When you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

We will also collect data about you from third parties we have an association with, including:

  • Fraud prevention agencies
  • Government and law enforcement agencies
  • Public information sources including DVLA, Land Registry and Companies House
  • Vetting and other agents working on our behalf

How We Use Personal Data

Here is a list of all the ways that we will use your personal information and the lawful basis for collecting and processing your data.

Data Type Description
Contact Details Your name, where you live, how to contact you i.e. email, phone
Financial Bank account and sort code details
Contractual Signed agreements for the services we provide you
KYC supporting documents Details about you taken from documents such as passport number, driving license or birth certificate, utility bills.
Land Registry Property details and names of Freehold/Leasehold ownership
Communication What we find out about you from letters, phone calls and emails we received from you.
Consent Any permissions or consent you have provided us.
Companies House Business/organisation companies house information

Where we collect your personal data from:

We will collect personal data about you through any of our Cardtronics group businesses:

  • When you complete a form on any of our group business web-sites
  • When you enter into a contract with Cardtronics
  • When you provide information in emails or letters
  • When you speak to us on the phone
  • When you apply for any of our services
  • When you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

We will also collect data about you from third parties we have an association with, including:

  • Fraud prevention agencies
  • Government and law enforcement agencies
  • Public information sources including DVLA, Land Registry and Companies House
  • Vetting and other agents working on our behalf

How do we use your personal data?

Here is a list of all the ways that we will use your personal information and the lawful basis for collecting and processing your data.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To manage our relationship with you or your business, take orders, process and deliver products and services to you including complaint and dispute resolution. Managing how we work with other companies that provide services to us and our customers Contact and identity data, documentation, financial data, usage and technical data (a) Performance of a contract with you e.g. making payments, service communications
(b) Necessary for our legitimate interests e.g. KYC
(c) legal duty – record retention
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity and contact data, technical and usage data (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
Security and risk management including detection and investigation and reporting of financial crime. Managing risk for us and our customers. Contact and identity data, documentation, financial data, usage and technical data, CCTV images. (a) Performance of a contract
(b) Necessary for our legitimate interests including crime prevention and detection)
(c) legal duty
To develop new ways to meet our customers’ needs and grow our business, develop new products and services. Usage and technical data. (a) Necessary for our legitimate interests

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or if you are notified that your personal data is required for an alternate purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Who We Share Personal Data With?

We have to share your personal data with the parties set out below for the purposes set out in the table above.

  • Internal Third Parties: other companies in the Allpoint group acting as joint controllers or processors and who provide IT, system administration and other services to the group and its customers.
  • External Third Parties: service providers, acting as processors who provide services to Allpoint and its customers.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, fraud and other crime prevention agencies, auditors and insurers.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of certain activities.
  • Agents and advisers who we use to help run your accounts and services, collect what you owe, and explore new ways of doing business
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice
  • Governmental authorities, in response to regulatory requests, subpoenas, court orders, and other similar request

We require all third parties to respect the security of your personal data and to treat it in accordance with the 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. All personal data may be shared within the Allpoint group. This may involve transferring your data outside of your home jurisdiction.

How Long We Keep Personal Data

We will keep your personal information for as long as you are a customer of Allpoint. We will only retain your personal data after that for as long as necessary to fulfil the purposes we collected it for, and for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

After you stop being a customer, we may keep your data for one of these reasons:

  • To respond to any questions or complaints.
  • To show that we treated you fairly.
  • To maintain records according to legal, accounting, reporting, and other rules relating to retention that apply to us.

Protection of Law

Generally, data protection laws prohibit the collection and use of personal information to instances where we have a business or legal reason to do so. Therefore, we will only collect, retain and use your personal data:

  • To fulfil a contract we have with you, for example to make sure that we pay the right amounts to the right person;
  • When it is our legal duty to do so, including for instance retention of records for audit or other purposes;
  • When it is in our legitimate commercial or business interest, including for example for KYC or “know your client” purposes to ensure that we are contracting with the right person or organization; or
  • When you consent to it.

Generally, we do not rely on consent as a legal basis for processing your personal data. In most cases, we will need to collect and process your personal data in relation to a contractual relationship you have with Allpoint or on the grounds of a legitimate business interest. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your personal data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Where we rely on a legitimate business interest to process your personal data, we will carefully assess to what extent processing is necessary and ensure that our business interests do not infringe your own interests and fundamental rights.

Generally we do not rely on consent as a legal basis for processing your personal data. In most cases we will need to collect and process your data in relation to a contractual relationship you have with Cardtronics or on the grounds of a legitimate business interest. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. Where we rely on a legitimate business interest to process your data we will carefully assess to what extent processing is necessary and ensure that our business interests do not infringe your own interests and fundamental rights.

Data and ATMs

When you use one of our ATMs the details from your card/account will be captured and shared with your card issuer or account provider for the purposes of validating the requested transaction. The details from your card/account together with the details of the requested transaction will be used by Allpoint, a number of third party service providers and your card issuer or account provider to authenticate and approve or decline the transaction request. Allpoint does not use any form of automated decision making in this process but other third parties and/or your card issuer or account provider might. The details Allpoint collects from your card/account as part of a transaction have been anonymized by your card issuer or account provider and Allpoint has no means of reconciling your card number or account number (which is further anonymized and encrypted) with a living individual. As such, Allpoint does not consider card/account information or transaction details to be personal data for the purposes of data protection law. This also means that Allpoint cannot identify you in the event of a disputed ATM transaction. If you encounter any issues in using one of our ATMs, you first contact your card issuer or account provider (depending on your jurisdiction, this may be known as a “LINK Discrepancy Form”, a “Regulation E Dispute” or a “Card Trace Request”).

Please note that Allpoint may, as part of the transaction validation process, be asked by the card issuer to retain the card inserted into the ATM. This may be as a result of the card being out of date, the card being abused, where the incorrect PIN number has been attempted a number of times or where an incompatible card has been inserted. Note that under certain network regulations, Allpoint cannot return captured cards to users under any circumstances and any cards collected from the ATM will be securely destroyed on collection. If an ATM has retained your card, in most circumstances this will be at the request of your card issuer and you should contact them first.

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

If You Choose Not To Share Personal Information With Us

We may need to collect your personal information by law, or under the terms of a contract we have with you. If you choose not to give us this personal information, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform services needed to run your accounts or business services. In certain circumstances, failure to provide personal information could cause us to cancel a product or service you have with us. Any personal data collection that is optional will be made clear at the point of collection.

Marketing

We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’. The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from third parties we work with. We can only use your personal information to send you marketing messages if we have either your consent or the legal ability to do so. You can ask us to stop sending you marketing messages by contacting us at any time. If you change your mind you can update your choices at any time by contacting us, or unsubscribing to any electronic messages (if available in your jurisdiction). We do not sell personal data to any party.

CCTV

Allpoint operate closed circuit television (CCTV) systems in and around Allpoint facilities and assets to provide a safe and secure environment for staff, visitors, the general public and also to protect our property and assets. We operate CCTV to:

  • Deter those having criminal intent;
  • Assist in prevention and detection of crime;
  • Facilitate with the identification, apprehension and prosecution of offenders;
  • Monitor security of our buildings and vehicles; and,
  • Identify vehicle movement problems around our buildings.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Cookies

To find out more about how we use cookies please see our cookie notice.

Complaints

Please let us know if you are unhappy with how we have used your personal information. You can contact us here. Depending on where you live, you may also have the right to complain to the Information Commissioner’s Office (ICO). Full details of how to do this are on the Information Commissioners website. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us first.

Possible Future Changes

Our privacy notice is review and updated annually. Last review/update was performed November 2019.


GENERAL DATA PROTECTION REGULATION (GDPR)

This section applies to those whose data is protected by GDPR.

Legal Rights Under GDPR

With respect to those whose personal data is protected by the GDPR you have the right to the following.

Request a Copy of your Personal Data Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Contact us here.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. Contact us here.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data This enables you to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms. Contact us here.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. Contact us here.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. Contact us here.

Withdraw Consent. Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Contact us here.

How to Get a Copy of Your Information

You can access your personal information we hold by contacting us here, or by writing to us at this address:

  • Data Protection Team
  • Allpoint Network
  • 2050 West Sam Houston Parkway South, Suite 1300
  • Houston, TX 77042

We will respond to access requests within 30 days.

Sending Data Outside of the EEA

All personal data may be shared within the Allpoint group. This may involve transferring your data outside of your home jurisdiction.

Your data may be transferred outside the European Economic Area (EEA). In addition, some of our third party service providers are located outside of the EEA or use cloud based services that are operated on servers located outside the EEA. We will only send your data outside of the EEA to:

  • Follow your instructions.
  • Comply with a legal duty.
  • Work with our agents and advisers who we use to help run your business accounts and services.

If we do transfer information to our agents or advisers outside of the EEA, we will make sure that it is protected in the same way as if it was being used in the EEA. We’ll use any of these safeguards:

  • Transfer it to a non-EEA country with privacy laws that give the same protection as the EEA. More information can be found here on the European Commission Justice website.
  • Put in place a contract with the recipient (data processor) that means they must protect it to the same standards as the EEA. Read more about this here on the European Commission Justice website,
  • Transfer it to organisations that are part of Privacy Shield. This is a framework that sets privacy standards for data sent between the US and EU countries. It makes sure those standards are similar to what is used within the EEA. Further information can be found on the European Commission Justice website Please contact us here if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.


CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

This section applies to those whose data is protected by CCPA.

The CCPA is a data privacy law which applies to certain businesses that collect personal information from California residents, which is effective as of January 1, 2020. In October 2019, the California Attorney General published draft regulations to provide further guidance on CCPA which are expected to be finalized in 2020. The information and product updates provided here are subject to change based on updated regulations from the California Attorney General. This section supplements the information contained above and applies solely to all visitors, users, and others who reside in the State of California. We include this section to comply with the CCPA, and any terms defined in the CCPA have the same meaning when used in this section.

Legal Rights Under CCPA

The CCPA provides consumers who are California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at (800) 809-0308.
  • Contacting us here.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent please contact us here.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and,
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Request restriction of processing of your personal data.

Personal Information Sales Opt-Out and Opt-In Rights. We do not sell personal data to any party. Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.