This policy was last updated on November 21, 2016.
Brookline Inc. and all its subsidiaries and affiliates, including but not limited to Brookline Horizon Dev Ltd ("BHDL" and, collectively with Brookline, Inc. and its other affiliates, "Brookline", "we", "our" or "us") expects its employees, including those of its subsidiaries worldwide and third parties with whom Brookline does business, to maintain the highest standards of ethics and compliance with applicable laws and rules. Brookline is committed to the highest standards of privacy and data protection compliance and expects all its employees and management to adhere to these standards.
Brookline operates an online platform that enables merchants and vendors to send and receive funds as payments for goods and services ("Merchants"). Our services comprise all software and services that we offer, including the Brookline Checkout form that may be made available on a Merchant's website, and other services that we offer through our website when you register for a Brookline account (collectively referred to as the "Services").
We understand that privacy is important to our online visitors and users. We respect your privacy and will take all reasonable steps to safeguard and protect your information as if it was our own.
This Privacy Policy will help you understand what Personal Data Brookline collects; how it collects, holds, uses and discloses that information; and the purposes of collection and disclosure.
The term "Personal Data", as used in this Policy, refers to any data (whether by itself or when linked with other information in the possession of, or likely to come into the possession of, Brookline) that can be used to identify a specific living person. Personal Data does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.
This Privacy Policy will help you understand the following:
Please also review, if applicable, your agreement with Brookline, including our Terms of Service that shall govern in the event of any inconsistency with this Privacy Policy.
This Policy applies to the direct2me.ie website, including all subpages and successor pages (collectively referred to as the "Website"), and also applies to all Services that we offer.
This Policy does not apply to any website, product or service of any third-party company even if the website links to (or from) our Website. Please always review the privacy practices of any third-party company before deciding whether to provide any information.
By using our Website or Services, you are accepting the practices described in this Policy. If you do not agree with this Policy, please delete all cookies from your browser cache after visiting our Website and do not visit or use our Website or Services. Your continued use of our Website or Services will signify your acceptance of this Policy.
We collect Personal Data from our Merchants and our Merchant's customers ("Checkout Users") in order to enable us to provide our Services.
Broadly speaking, we collect information in three ways: (1) when you provide it directly to us, (2) when we obtain verification information about you or your company through trusted third parties (e.g. banks, credit bureaus), and (3) passively through technology such as "cookies" (cookie collection is described below in Section 3 ("Cookies and Web Server Logs").
The types of Personal Data that we collect and our use of that Personal Data will depend on whether you are a Checkout User or Merchant.
Checkout enables Merchants to collect payment information from Checkout Users for a number of payment methods. When you use a Merchant's website to make a purchase, the Merchant will collect your Personal Data and provide it to us. This Personal Data includes your payment card information, your email address, your mobile phone number, and billing and shipping address. We will use this Personal Data as part of the payment processing process. When you use Brookline Checkout on a Merchant's website to store your payment credentials, we will use the Personal Data disclosed to us by the Merchant to complete purchases that you choose to make on other websites or applications that also use Brookline Checkout, but only with your permission. Checkout Users can view our Privacy Policy via a hyperlink and are asked to confirm that their Personal Data be remembered.
This Personal Data described above will be shared and disclosed only as described below in Section 4 ("Sharing and Disclosure of Personal Data").
To gain full access to our Website and Services, you must register for a Brookline account. When you register for an account, we collect the Personal Data you provide, such as the following:
If you elect to not provide Personal Data in optional fields it may limit your ability to use our Services. We may retrieve additional Personal Data about you from third parties and other identification/verification services such as credit bureaus. In addition, we may collect Personal Data from you in other ways including emails, surveys, and other forms of communication. Once you begin using our Services through your Brookline account, we will keep records of your transactions and collect information of your other activities related to our Services.
This Personal Data described above will be shared and disclosed only as described below in Section 4 ("Sharing and Disclosure of Personal Data").
To simply browse our Website, you are not required to provide any Personal Data. However, we may gather non-personally-identifiable information, as described directly above, solely for the purposes of monitoring and improving our Website and Services. We will not share this information with third parties or use it to target any advertisements to you.
Our Website and Services are directed to the general public. We do not knowingly collect information from children under 15 years of age or have any reasonable grounds for believing that children under the age of 15 are accessing our Website or using our Services. If we learn that we have inadvertently collected Personal Data from a child under age 15, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 15, please contact us at info@direct2me.ie.
"Cookies" are a feature of web browser software that allows web servers to recognise the computer used to access a website. Cookies can remember what information a computer accessed on one web page to streamline activities on related web pages and to make the online experience easier and more personalised. Log files are used to monitor, measure, analyse, improve, and troubleshoot our Services.
We utilise "cookies" and other technologies to collect non-personally-identifiable information from our Website and from other websites that use our Services. Where you request that your payment credentials be remembered by our checkout system, the cookies will also collect Personal Data about you. Information gathered through cookies and web-server log files may include information such as the date and time of visits, the pages viewed, IP addresses, links to/from any page, and time spent at our site.
We use cookie data to measure web traffic and usage activity on our Website for purposes of monitoring, troubleshooting and improving our Website and Services, to look for possible fraudulent activity, and to better understand the sources of traffic and transactions on our Website and the websites of Merchants that use our Services. Cookies also allow our servers to remember your account information for future visits and to provide personalised and streamlined information across related pages on our Website and also across other websites or applications that use our Services. You can choose to disable cookies for our Website but this may limit your ability to use our Website and Services.
We may occasionally email you with information about offers or new services. If you do not wish to receive this marketing material then please email privacy@direct2me.ie. You can also opt out of these email communications by replying with unsubscribe in the subject line, or via an unsubscribe link included in such communications. However, you will continue to receive certain email communications related to your account and your relationship with Brookline.
If you wish to opt out of having cookies set on your browser, the only way to ensure that this happens is to manage the settings on your web browser to delete all cookies and disallow further acceptance of cookies. Note that disabling cookies on your browser prevents Brookline from tracking your activities in relation to our Website and Services. However, it may also disable many of the features available through our Websites and Services and some aspects of our Services may not work properly if you do so. For more information, refer to your browser's technical information. You may also consider visiting aboutcookies.org, which provides helpful information about cookies.
Appendix 1 lists the types of Cookies we use and their purpose.
Brookline does not sell or rent your Personal Data to marketers or third parties. Brookline may disclose Personal Data it collects about you to trusted third parties who are integral to the operation of our Website and Services for a variety of purposes in connection with providing our Services, operating our Website and special offers to you. These third parties may include our agents, related bodies corporate, contractors, financial institutions, payment processors, verification services and credit bureaus, as well as any third parties that you have directly authorised to receive your Personal Data.
We may share Checkout User's contact information, but not their card information, with Merchants as part of the Checkout User's purchases.
Brookline Connect allows Merchants selling on partner websites, e.g. online marketplaces, to directly accept credit card payments. If you authorise an application to access your Brookline account using Brookline Connect, you acknowledge that we may share payment transaction data and related information with the third party that provides the authorised application. The use of your information by such third party will be subject to their applicable privacy policy, which you should carefully review.
We may store your Personal Data in locations outside the direct control of Brookline, for instance, on servers or databases co-located with hosting providers. Some of our the related bodies corporate or third parties to whom we disclose your Personal Data are located outside of Ireland. These countries may include the United States of America and Ireland.
We may also disclose your Personal Data to law enforcement, government officials, or other third parties if required by law or we believe in good faith that the disclosure is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our Terms of Service.
In addition, in the event of a merger, acquisition, reorganisation, bankruptcy, or other similar events, certain information in our possession may be transferred to our successor or assign.
Any sharing or disclosure of your Personal Data will be in compliance with applicable data protection laws and regulations.
Personal Data that we collect and use for any purpose or purposes shall not be retained for longer than is necessary for that purpose or those purposes. This includes the Personal Data of Checkout Users.
Brookline has a variety of obligations to retain the data that you provide us, both to ensure that transactions can be appropriately processed, settled, refunded or charged back, to identify fraud, and also to comply with laws applicable to us and to our banking providers and credit card processors. Accordingly, even if you close your Brookline account we will retain certain information as necessary to meet our obligations. However, we will identify your account in our database as "inactive" or "closed".
Although no data transmission can be guaranteed to be 100% secure, we take all reasonable steps to ensure that the Personal Data we collect, use or disclose is accurate, complete, up-to-date, relevant and stored securely.
We also take all reasonable steps to ensure that the Personal Data we hold is protected from misuse, interference, loss, unauthorised access, modification or disclosure by the use of various methods including access limitation, and industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files.
Brookline will provide some or all of its Services from systems located outside of Europe. As such, Merchants are required to disclose to Checkout Users that personally identifiable information may be transferred, processed and stored outside of Europe.
Brookline maintains strict administrative, technical and physical procedures to protect information stored in our servers, which are located in the United States. Access to information is limited (through user/password credentials and software systems) to those employees who require it to perform their job functions.
We reserve the right to make changes to this Policy from time to time. Please review this Policy periodically to check for updates. If any changes are material and/or retroactive, we may provide additional notice and/or an opportunity to "opt-in," as appropriate under the circumstances. We may also advise you of changes to this policy by emailing and/or mailing the revised policy to any addresses you provide us.
Merchants can update their account information by signing on to our Website with their Brookline account.
If you have any questions or suggestions about this Privacy Policy or would like to access or seek correction of your Personal Data, or if you have complaints regarding our privacy practices, please contact our Privacy Officer by emailing info@direct2me.ie.
We aim to acknowledge receipt of all complaints within five business days and to resolve all complaints within 40 business days (although this may not be possible in all circumstances, and is dependent on the complexity of the issue). Where we cannot resolve a complaint within 40 business days, we will notify you of the reason for the delay as well as an indication of when we expect to resolve the complaint.
Cookies enable us to identify your device, or you when you have logged in. We use cookies that are strictly necessary to enable you to move around the site or to provide certain basic features. We use cookies to enhance the functionality of the Website by storing your preferences, for example. We also use cookies to help us to improve the performance of our Website to provide you with a better user experience.
Strictly necessary cookies: These cookies are necessary in order for you to move around Brookline.com and use the site:
| Cookie Name | Purpose |
| accounts | A list of Brookline accounts you have access to |
| direct2me.csrf | A random token to prevent cross site request forgery |
| rack.session | A unique session identifier |
| session | A unique session identifier if you're logged into your Brookline dashboard |
| machine_identifier | A random string used to identify your machine |
Functionality: Functionality cookies record information about choices you've made and allow us to tailor the Website to you.
| Cookie Name | Purpose |
| country | The country you're currently viewing the site for |
| lang | The programming language you last viewed docs in |
| cookiesEnabled | A random value we set to determine whether we're able to set cookies for the user |
| logged_in | whether or not you're currently logged in |
