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Legal

Privacy Policy

This Privacy Policy describes how BEKO PLC (hereinafter referred to as “the Company” or “We“) collects, processes, shares and protects your personal information (as further defined below) that you give when you download and use the HomeWhiz application and the functions provided by the HomeWhiz application (collectively, hereinafter referred to as “the Services“). The Company processes your personal information in accordance with this Privacy Policy. This Privacy Policy has been drafted in light of the General Data Protection Regulation (“GDPR“). We are committed to follow the GDPR in all data processing operations in the EU and where it otherwise applies.

This Privacy Policy is an integral part of the HomeWhiz Terms of Service https://www.homewhiz.com/gb-en/terms/ For further information, please consider that all terms used in this Privacy Policy that are not otherwise defined shall be construed as defined in the HomeWhiz Terms of Service. Any matter not contained in this Privacy Policy shall be subject to the HomeWhiz Terms of Service as provided to and accepted by you.

Any personal information collected and processed by the devices (such as smart TV, smartphone or tablet) on which the HomeWhiz application is running or by the software owned by third parties, which is installed on such device, shall not be subject to this Privacy Policy. Such device and software may process your personal information in accordance with their own privacy policies, and the Company shall not be held liable for any personal information processed in this manner.

What Personal Information We Collect
When you use the HomeWhiz application and the Services, we may – as detailed further below in this Privacy Policy and only to the extent permitted by applicable law – collect your name, surname, e-mail address, user account, phone number, user name, the country where you live and your location, your products supporting the HomeWhiz application, the software used together with the HomeWhiz application, the operating data about the equipment such as when and how long they are used, the equipment sensor data such as water hardness levels, power mains data, equipment temperature levels, the operating data about the components of the equipment, any equipment error information such as errors and alerts displayed, when such errors and alerts are displayed, information about the devices such as smart TV, smartphone or tablet on which you run the HomeWhiz application and the identification details of such devices like MAC number and serial number, and updates of the HomeWhiz application and other software.

We refer all personal information we collect about you as “Personal Data“. Personal Data refers to the data that may be used for determining your identity.

How We Use Personal Information
To the extent permitted by law, we use your Personal Data for the following purposes. We have added the specific legal basis for the processing in brackets: Article 6 para. 1 a GDPR stands for consent, Article 6 para 1 b GDPR for fulfilment of the contract and Article 6 para. 1 f GDPR for processing for legitimate interests:

To register you and to enable you to use our Services (Article 6 para. 1 b GDPR);
To inform you of any new product or service of the Company by sending notices, advertisement or pictures through e-mail, SMS and other similar electronic communication means or via the Services on the HomeWhiz application, but only where you have given us your consent to do so (Article 6 para. 1 a GDPR);
To enable us to improve our products, Services, contents and advertisements provided that we will use anonymised data for this purpose ;
To give you advice on the contents, channels and your purchase of other products of our Company, but only where you have given us your consent to do so (Article 6 para. 1 a GDPR);
To combine the information collected under this Privacy Policy with the data we obtain from other resources, and combine your data obtained via our sales teams, technical service units with your other devices for making analyses, improving our Services, products, contents and advertisements and providing you with better and well-directed after-sale services but only where you have given us your consent to do so (Article 6 para. 1 a GDPR);
To send you important notices such as correspondence on changes in our HomeWhiz Terms of Service and this Privacy Policy (Article 6 para. 1 b GDPR);
To keep internal records on software updates, technical services and other transactions to the extent necessary for the provision of the Services (Article 6 para. 1 b GDPR);
To meet the requirements of any government request which is lawful according to the applicable law (Article 6 para. 1 c GDPR),
To enforce the HomeWhiz Terms of Service and this Privacy Policy, including investigating potential violations (Article 6 para. 1 f GDPR);
To detect, deter or otherwise address any fraud or security issues (Article 6 para. 1 f GDPR);
Processing operations carried out for the purposes as defined in items (ix) and (x) above shall, in particular, ensure the proper and regular functioning of our systems and Services, and therefore safeguard our business interests and the interests of the users using the Services.

To the extent permitted by the applicable laws, we may combine the Personal Data we collect about you with our Services, website or other channels with the information you provided us via other ways, and retain all such information in a combined database or separate databases.

The Company shall not retain your Personal Data for longer than necessary for the purposes for which it was intended or initially collected. Data will be stored for 10 years under normal conditions to provide personalized and healthy service. Unless and to the extent we are required to retain your Personal Data for justified legal reasons (e.g. for compliance with a legal obligation or for the establishment, exercise or defence of legal claims), we will delete or anonymise your Personal Data once you inform us that you will no longer be using our Services. If a deletion of your Personal Data would only be possible with unreasonable efforts, we will anonymise them instead of a deletion. We will not collect Personal Data about you that is not necessary to the purposes it was collected for.

Direct Marketing
Subject to the following paragraph, we may use your Personal Data for marketing purposes, in particular to display to you or present you with advertisements and promotion materials, to inform you about our new products or to conduct free prize draws and prize competitions and other such information which we believe may be of interest to you based on your use of and your interests in our Services, always provided that such use complies with applicable laws.

Depending on the jurisdiction you reside in and in accordance with applicable laws in your country, we will ask you to expressly consent to receiving marketing material or product information before we send you any marketing or promotional material or before we send you any such material or information.

You can change your mind about your preferences in respect of direct marketing at any time by using the unsubscribe button on every such mailing, by updating your user profile or account data or by contacting us at contact@homewhiz.com. If you do so, we would not remove your Personal Data from our databases to the extent that this Personal Data is still required by us under the terms of this Privacy Policy or otherwise to continue to provide our Services to you.

Location-based Services
The Company may collect the location data of your device, and use, store, transmit or share such location-based data through the HomeWhiz application and the Services for providing location-based services for its products. The location data is collected anonymously in a form based on product, not personally identifying you.

Data Processed by Third Party Applications, Software or Services
When you use the Services, you may also use several applications, software and services provided by various third parties (such as the provider of the device on which the HomeWhiz application runs or the providers of other software running on the same device). Such applications, software or services may process your Personal Data and they are subject to their own terms of use and privacy policies.

Sharing of your Personal Information with Third Parties
In principle, we do not share or disclose your Personal Data to third parties. However, the Company may be required to share your Personal Data as set out in this Section.

Company may share your Personal Data in accordance with applicable laws in the following cases:

where this is necessary in order to provide the Services to you (Article 6 para. 1b GDPR),
if we are required to disclose your Personal Data in order to comply with any legal obligation or the decision of a judicial authority, public authority or a government body, or if disclosure is necessary for national security, law enforcement or other issues of public importance (Article 6 para. 1 c GDPR),
if we are required to disclose your Personal Data to providers of outsourced Services like cloud computing to enable them to provide such Services (Article 6 para. 1b GDPR),
if it is necessary for providing after-sale services and repair services to your devices that are necessary for the use of the Services (Article 6 para. 1b GDPR), or
where we are otherwise permitted to do so by applicable law.
Company uses its affiliate Arçelik A.S. acting as a service provider to process your Personal Data. Arçelik A.S. is located in Turkey, a country outside the European Union that may not offer the same standard of data protection as applies in the European Union.

Before transferring the Personal Data of a resident of an EU/EEA member state we will take steps to ensure that such data will be afforded the same level of protection as under applicable data protection laws within the EU/EEA. For data transfers outside of the EU, Company uses the standard contractual clauses adopted by the European Commission and will make available a copy to you upon request.

We will not make your Personal Data available to third parties for any other purposes as described in this Privacy Policy and we will not sell your Personal Data.

Security Measures Taken for Your Personal Data
The Company takes appropriate administrative, technical and physical measures to protect your Personal Data against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.

We protect the security of your Personal Data by using encryption and password protection where appropriate, and limiting access to your Personal Data.

Whilst we have done all of this, these measures do not release you from taking appropriate steps to keep your password and other user identification safe and secure, in particular by avoiding obvious user ID’s or passwords, by changing your password regularly and by ensuring that you do not disclose your password(s) or grant any other person access to your user account.

Links to External Content Resources
Our Services may contain some services or links that may direct you to other websites, services or external content resources which are outside of our control. We are not responsible for such direction and the privacy of any Personal Data which you provide on other websites.

Changes to this Privacy Policy
The Company may change and update this Privacy Policy from time to time. The Company will notify you of any material changes or additions to this Privacy Policy and will provide you with a copy of the amended Privacy Policy by use of your email address provided to the Company, or by any other suitable means which ensures that you will be notified of any changes to this Privacy Policy.

Access to the Privacy Policy and Withdrawal of Consent
You can display the content of the latest “HomeWhiz Privacy Policy” you have acknowledged to have read on the HomeWhiz application. If you withdraw your separately declared consent to specific processing operations, you may not be able to use all sections of our Services.

Your Rights for Your Personal Data
You have the following rights with respect to your personal data we hold:

to learn whether your Personal Data is processed;
if processed, to request information in connection therewith;
to learn the purpose of the processing and whether such data is used for intended purposes;
to request the correction of any inaccurate or incomplete Personal Data;
to request the erasure or destruction of your Personal Data or the restriction of the processing in accordance with the applicable laws;
to object to any further processing based on Article 6 para. 1 f GDPR (see Section 2 above);
to withdraw any consent you have given;
under certain circumstances to demand data portability;
to request us to notify third parties to whom your Personal Data has been disclosed (if any) of the actions taken according to the subparagraphs (d) and (e) above; and
to lodge a complaint with a supervisory authority.
To exercise your rights, you can use the contact details as indicated in Section 12 below.

How to Contact Us for your Personal Information and Data
Please do not hesitate to contact us to learn more about the Company’s processing operations and our commitment to this Privacy Policy: Beko PLC, 1 Greenhill Crescent, Watford, Hertfordshire, WD18 8QU, 0330 678 0105

You can contact the Company’s data protection officer on the above contact details or by emailing contact@homewhiz.com.

Date of Issue: 25 May 2018

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