WHO WE ARE

De’Longhi Group considers the protection of personal data of third parties, in its possession, as very important and is committed to protect the privacy of said third parties included, but not limited to, its customers, when carrying on its business, and it pays particular attention to the security and confidentiality of its customers’ personal data.

This Privacy Notice relates to the collection of personal data using online (including the De'Longhi Group websites and mobile apps) and offline methods as specified below.

Kenwood Appliances (S) Pte Ltd (hereinafter "De'Longhi" or the "Company"), with its registered office in 300 Beach Road #18-01/02, The Concourse, Singapore 199555, also in accordance with Regulation EU 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, as Data Controller of the personal data collected provides you with the following information.

DATA THAT MAY BE COLLECTED

The following categories of personal data (hereinafter “Personal Data”) relating to you may be collected:

• Contact data – information on your name, address, telephone number, mobile telephone number, email address. We also collect your personal data when you create an account, including account ID or name and passwords
• Interests – information you have provided regarding areas that interest you, for example products you find interesting;
• Other personal data – information you have provided regarding your date of birth, education, professional situation and household details;
• Social Media data – Any information that you share publicly on a third party social network or information that is part of your profile on a third party social network (such as Facebook) and that you allow the third party social network to share with De’Longhi. Examples include your basic account information (e.g. name, email address, gender, birthday, current city, profile picture, user ID, list of friends, etc.) and any other additional information or activities that you permit the third party social network to share. We receive your third party social network profile information (or parts of it) every time you interact with De’Longhi through a third party social network or if you login in our websites or app through your Social Media accounts. To learn more about how your information from a third party social network is obtained by De’Longhi, or to opt-out of sharing such social network information, please visit the website of the relevant third party social network. We also may collect data you communicate about your experience in using our products and services, including feedback, comments and questions in online evaluations.
• Device Technical Data – Technical information relating to the devices that you use to access our websites, such as the Internet Protocol (IP) address and the type the version of your browser. When you choose to pair the App with your Device, we collect mobile device-specific information including the unique user device number, country of your selection, time zone and session. 
• Mobile Permissions for Personal Data access - Mobile apps may also request your permission to access your mobile device’s storage capabilities, sensors or other features (e.g. Wi-Fi, geo-location or Bluetooth). We require access when strictly necessary to provide the services offered through the app, as detailed in the paragraph FOR WHAT PURPOSES CAN YOUR PERSONAL DATA BE USED.
• Use of the websites and Cookies – information on how you use the websites, how you open or forward our communications, including information acquired via cookies (click here to see our Cookie Policy which regulates the details). Please, read our Cookies Policy to find out how you can set your cookie preferences and to get information about the cookies we use and why we use them. If cookies are used on mobile devices, the necessary information will be communicated as required by the applicable legislation. 
• Sensitive Personal Data. We do not seek to collect or otherwise process sensitive personal data in the ordinary course of our business. Where it becomes necessary to process your sensitive personal data for any reason, we rely on your prior express consent for any processing which is voluntary (e.g. for marketing purposes) or to comply with applicable law.

HOW WE COLLECT YOUR PERSONAL DATA

De’Longhi collects and processes your personal data in the following circumstances:

• if you browse or register on our websites / Apps to use its functionalities; 
• if you purchase the De'Longhi Group products or services on our online shop;
• if you contact us to request pre-sales or after-sales assistance;
• if you respond to our marketing activities, for example when you complete a reply card or submit your data online on one of our websites;
• if you fill out paper forms of registration that are collected in various ways (during demonstrations, cooking classes, promotions or events);
• if other Group companies as well as our business partners provide data about you in a manner that is permitted.
• If you provide personal data on behalf of someone else, you must first ensure they have read this Privacy Policy.

Kindly help us to keep your personal data up-to-date by informing us of any changes. Any change in address should be promptly communicated to De’Longhi in order to avoid problems in the use of our services.

FOR WHAT PURPOSES CAN YOUR PERSONAL DATA BE USED

The processing of personal data must be justified by one of the legal basis established by existing data protection regulations, as described below.

a)   Establishment and execution of contractual obligation and resulting obligations, including communications regarding services (for example to perform after-sales services including complaints and product repair or shop online related activities).

De’Longhi may process your Contact data, Device Technical Data, Mobile Permissions and Cookies in order to establish and execute a contractual relationship (e.g. online purchase of products or services, order fulfillment management), to provide services requested or to respond to and process reports or complaints.

De’Longhi may use your contact details, particularly your email address, to provide you with information concerning the services and your purchase orders as well as after-sales services.

Legal bases for the processing: performance of a contract or legal requirements, which the Company is required to fulfill.

The provision of data is obligatory to enable us to manage the contractual relationship; in the absence of the data, we will be unable to put the contract into effect.

In case you make use of mobile apps, depending on your specific mobile device, the mobile app may request certain permissions that allow it to access personal data stored on your device. We require access when strictly necessary for purposes directly related to providing the services and features of the mobile app. Such permissions may include – where permitted - the location, the Bluetooth/WiFi connection and similar other permissions.

Legal bases for the processing: by default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. The exact procedure for controlling app permissions may be dependent on the User's device and software.

b)   Operational management and strictly-related purposes, for access to the website, particularly secure areas, also through the Social Login system - to simplify registration operations using the information already given to your Social Network.

De'Longhi may process the Contact details to enable you to complete the registration procedure on the site and allow you to access your Personal Area in order to: (i) download from your Personal Area documents relating to the services you have purchased; (ii) process the other requests made through the website, or to allow you to make purchases online.

Registration to the site may take place, where you voluntarily decide to use it, even with the Social Media Log-In mechanism. In this way you will not have to enter the data necessary for registration (such as contact details), which will instead be communicated by the Social Network through which the Log-In is carried out. Please note that in this case De'Longhi may process the data of the Social Log-In, that is not only those related to your Social account but also any other personal data that could be made visible according to the preferences you have set or according to the policy on the privacy of the same Social Network. We invite you, therefore, to read the privacy statement of your Social Network, also for further information on these preferences.

Legal bases for the processing: performance of a contract in the absence of such data, we will be unable to register on the website and shopping in the online store.

To allow you to register on the site, provided that you are not obliged to use the Social Log-In to complete the registration.

With reference to the registration, the Company also specifies that it has implemented a Single Sign-On system, under which the registration made on the site will be valid for all sites managed by the Company, with reference to the brands "De'Longhi", "Braun", “Kenwood" and “Nutribullet” or www.delonghi.com, www.braunhousehold.com, www.kenwoodworld.com, www.nutribullet.com.

In this way it will not be necessary to provide the Contact Data again if you register with one of the aforementioned sites. However, to safeguard the choices made by the user, any consent to treatment for marketing and marketing profiled issues released within a brand (for example on the site www.kenwoodworld.com/it) will be used only for advertising material related to this specific brand.

c)    Customer Satisfaction and other surveys.

De’Longhi may use your Personal data to carry out surveys aimed at measuring customer satisfaction in relation to the service provided. 

Legal bases for the processing: legitimate interest of the Company to verify and improve the quality of the services provided.

d)   Marketing to meet your needs or to inform you of promotions, also based on your preferences (we have also included profiled marketing).

De’Longhi may processes the personal data about you that we collect for marketing and advertising purposes, to inform you of promotional sales initiatives via automated means of contact (email, SMS and other mass communication tools, etc.) ,such as for market research and statistical surveys, if you give us your consent and within the limits of the consent declaration.

De’Longhi may also processes such data in order to send you advertising communication based on your personal preferences and interests, if you give us a specific consent and within the limits of the consent.

Legal bases for the processing: consent, a failure to give consent in no way affects the contractual relationship 

The provision of these data is voluntary, in the absence of consent your personal data will not be processed for the purpose referred to above.

Your consent may be revoked at any time by visiting My Account > My Marketing Preferences. You may also revoke your consent, see paragraph CONTACTS for more details. Revocation of consent will not affect the lawfulness of the processing of your personal data based on consent before its revocation.

e)  Communication to other De’Longhi Group companies for marketing purposes too (included profiled marketing).

De’Longhi may communicate  personal data about you that we collect to other De’Longhi Group companies for activities strictly connected to the treatments referred to in purposes a) b) c) f).

Legal bases for the processing: legitimate interest which arises from internal administrative purposes and needs to manage services and users’ requests within De’Longhi Group. 

De’Longhi may communicate your personal data to other De’Longhi Group companies for marketing and advertising purposes, to inform you of promotional sales initiatives, also based on a specific customer profile designed on your personal preferences and interests,  via automated means of contact (email, SMS and other mass communication tools, etc.) and traditional contact methods (e.g. by telephone), such as for market research and statistical surveys, if you give us your consent and within the limits of the consent declaration.

Legal bases for the processing: consent, a failure to give consent in no way affects the contractual relationship 

Your consent may be revoked at any time by visiting My Account > My Marketing Preferences.  You may also revoke your consent, see paragraph CONTACTS for more details. Revocation of consent will not affect the lawfulness of the processing of your personal data based on consent before its revocation.

f) Compliance with legally-binding requests by the legal authorities to discharge obligations of law, regulations or provisions or investigation or defense against claims.

De’Longhi collects your personal data to comply with legal obligations or determine / assert claims or defend against them

Legal bases for the processing: legal obligations with which the Company must comply or a legitimate interest of the Company consisting in the protection of its rights 

HOW WE KEEP YOUR PERSONAL DATA SAFE

The Company uses a wide range of security measures to improve protection and maintain the security, integrity and accessibility of your personal data.

All your personal data are stored on our secure servers (or on secure paper copies) or on those of our suppliers or commercial partners, and may be accessed and used based on our standards and our security policies (or equivalent standards for our suppliers or commercial partners).

The security measures we have adopted include:

• severe restrictions on access to your personal data, based on necessity and solely for the purposes communicated;
• perimeter security systems to prevent unauthorized external access;
• permanent monitoring of access to IT systems to identify and stop the misuse of personal data;
• tracking of access to your personal data by internal personnel and verification of the related purpose;
• using encrypted means via TLS technology for transactions on our websites and mobile apps that require the entering of personal data.

Where we have provided you with (or you have chosen) a password to allow you to access our website, application or services, you are responsible for keeping this password secret and for complying with any other security procedure we inform you of. Please do not share your password with anyone.

DO WE PROFILE YOU ON THE BASIS OF YOUR PERSONAL DATA?

De’Longhi may also process your contact details, information about interests and other personal data in order to send advertising information according to your client profile determined on the basis of your personal preferences and interests, if you give us your explicit consent and to the extent provided for therein. Decisions in this respect can be made automatically. After determining whether the criteria have been met, the IT system automatically sends advertising information according to your client profile.

HOW LONG DO WE STORE YOUR INFORMATION FOR

We will keep your personal data only for the length of time necessary to achieve the purposes for which they were collected or for any other related and lawful purpose. Therefore, if your personal data is processed for two different purposes, we will keep the data until the lengthier purpose is achieved. However, we will cease to process the personal data collected for the purpose whose retention period has expired.

We limit access to your personal data to only those individuals who need to use them for the appropriate purposes.

When your personal data are no longer required, or when there is no longer any legal pre-condition for keeping them, they will be irreversibly anonymized (and in such a way may be stored) or securely destroyed.

The retention periods relating to the different purposes described above are indicated to follow:

a) Compliance with contractual obligations: data processed to comply with any contractual obligation may be kept for the duration of the contract and after the contract for duration of limitation period of claims specified under provisions of law; in order to verify any outstanding issues including accounting documents (e.g. invoices).

b) Operational management and strictly-related purposes for access to the website: data processed for these purposes may be kept for the duration of the contract and after the contract for duration of limitation period of claims specified under provisions of law.

c) Customer Satisfaction and other surveys: data processed for these purposes may be kept for 5 years from the personal data collection date (except where you decline to receive further communications).

d) For marketing purposes, including profiled marketing: data processed for marketing purposes may be kept for 5 years from the date on which you provided your consent for this purpose (except where you decline to receive further communications).

e) Communication of data to other De’Longhi Group companies: data, which are processed by De’Longhi Group companies for activities strictly connected to the purposes referred to points a), b), c) and f) of the section FOR WHAT PURPOSES CAN YOUR PERSONAL DATA BE USED, are kept in line with – respectively - the specifications a), b), c) and f) of the present section. 

Data, which are processed by De’Longhi Group companies for marketing purposes referred to point d) of the section FOR WHAT PURPOSES CAN YOUR PERSONAL DATA BE USED, are kept in line with the specification d) of the present section.

f) To comply with legally binding requests from state authorities and to comply with legal obligations: data processed for this purpose may be stored for the duration of these obligations. In the event of disputes, personal data may be stored for the reasonably period necessary for such purpose.

WHO WE CAN SHARE YOUR PERSONAL DATA WITH

Your personal data may be accessed by duly-authorized employees and by external suppliers, appointed, if necessary, as data processors, who support us in providing services (e.g. payment/billing processing, order fulfillment, information technology and related infrastructure provision, customer service, management of marketing campaigns and anti-fraud checks in ecommerce transactions).

For the purposes of the performance of their activities and to follow up on the above mentioned purposes your personal data may also be accessed by other De’Longhi Group companies and may be transferred outside the European Economic Area (in such case, De’Longhi will adopt appropriate safeguards of data subjects’ rights.

De’Longhi never sells your personal data to other parties.

CONTACTS

The contact details for De’Longhi, in its capacity as Data Controller, may be found at the Data Protection Officer (DPO) address at the end of this policy.

Should you have any questions regarding our processing of your personal data, contact us by email asking for Data Protection Officer (DPO) or local Privacy Manager, respectively, at dpo.privacy@delonghigroup.com. and eshop.sg@delonghigroup.com

YOUR PERSONAL DATA PROTECTION RIGHTS AND YOUR RIGHT TO FILE COMPLAINTS BEFORE THE SUPERVISORY AUTHORITIES

On certain conditions, you are entitled to:

• require information on your personal data processing 
• require a copy of the personal data you have provided to us or to transfer it to a third party;
• require correction and/or completion if the personal data processed concerning you is incorrect or incomplete;
• require the erasure of your data;
• refuse to allow your data to be processed for direct marketing purposes;  
• revoke your consent, in cases where the processing is based on consent;  
• limit the way in which we process your personal data;
• exercise your right of objection.

The exercising of the above rights is subject to certain exceptions that are intended to safeguard the public interest (e.g. the prevention or identification of crimes) and our interests (e.g. maintaining professional secrecy). Should you wish to exercise any of the above rights, we will check that you are entitled to do so and will usually respond within one month.

We endeavor to respond to any complaints or reports concerning the methods used to process your Data. Nevertheless, should you wish, you may forward your complaints or reports to the authority responsible for data protection using the following contact details Infocomm Media Development Authority (https://www.imda.gov.sg/).