Last update 2019-02-15
(for the use of Finish365 Platform)
We are committed to protecting your privacy.
This Privacy Notice governs your use of the Finish 365 (F365) web-page (embedded in Beko PLC’s Homewizz app) on your mobile device (“Platform”), and explains how we collect, use, disclose and protect your Personal Information and respect any rights you benefit from under your local law.
1. THE PLATFORM
By using our Platform, you can easily purchase Finish 365 dishwasher products from us to your home appliances.
2. WHO WE ARE
We are Reckitt Benckiser Hygiene Home Commercial Limited incorporated and registered in the England and Wales with registered company number 11284867 with registered office at 103-105 Bath Road, Slough, Berkshire SL1 3UH ("we", "us", "our"). We act as data controller in respect of the processing of your Personal Information obtained through your use of the Platform.
3. THE PERSONAL INFORMATION WE COLLECT
a) By "Personal Information" (in some countries referred to as "personal data" or "personally identifiable information") we mean any information relating to an identified or identifiable individual. This is broader than just information of a personal or private nature. Please ready carefully this section to learn what Personal Information is obtained from you.
b) This Platform should only be used by people over the age of 16 (or such younger or older age as is necessary to be able to validly consent in your country). We do not knowingly solicit data from or market to anyone under the age of 16. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files upon request within a reasonable time.
c) We may obtain your Personal Information from you directly.
a) You will not be able to use the Platform and order Finish 365 dishwasher products unless you register with us. The Platform obtains information that you provide us with when you download, register and use the Platform.
b) For the creating your account for the use of the Platform, when you register you will need to provide us with your full name, email address and password.
c) For ordering a Finish 365 dishwasher product, you will need to provide the ordered amount of the Finish 365 product, your delivery address (street, house number, postcode, city, country) for us and your mobile phone number for contacting you if necessary.
d) For completing your order, you will be requested to provide credit card information (card holder name, card number, date of expiry, security number), which will be securely protected by the PayPal UK system (see below for more information about this). We also process the value of each of your purchase.
e) We will record your order statement information regarding each of your purchase when you buy Finish 365 product by the Platform. We record when your ordered the product, when we confirmed your order and what is the status of the fulfillment of your order.
f) We also process quantity data of your orders. From your orders we can calculate based on our product catalog how much Finish 365 product (tablets/liquid) you have. You may manually amend this information in the Platform.
Cookies and data that we automatically collect.
h) The Platform may collect certain information automatically, such as the:
- information about your (mobile) device (type of mobile device you use, your mobile operating system and its version);
- information about when, how often, for how long, and how you use the Platform;
- information about the way you use our websites, such as details of the web pages you have viewed, the banners and the hyperlinks you have clicked, etc.;
- whether you have opened e-mails sent by us to you;
- the websites you have visited before arriving at one of our websites;
- your IP address;
- the hyperlinks you have clicked;
- your e-mail address (if you provide it), user name, networks and any other information you choose to share when using third party sites; and
- information you share with us by your mobile device about your location.
i) Where we are required to do so by local law, we will only use that information where you have agreed that we can.
4. OUR PURPOSE FOR THE USE OF YOUR PERSONAL INFORMATION
a) We use your Personal Information to complete your purchase of Finish 365 dishwasher products from us, so we process your Personal Information to perform the sale and purchase contract between us, which is the legal basis for us for processing your Personal Information that you gave us.
b) Accordingly, we use your Personal Information for handling and managing your purchase, to communicate to you with respect to your purchase, to process your payments, to deliver the purchased products and services, and to offer you the necessary customer service.
c) In addition, we use your Personal Information for the following business purposes:
· For e-mail marketing purposes (if your consent is given via checkbox);
· to facilitate the creation of and secure your account on our network;
· to identify you as a user in our system;
· to improve the quality of experience when you use our Platform;
· to send you an e-mail if you request to create or reset a password for the Platform;
· allowing you to participate in promotions, contests, surveys and polls;
· better understanding your needs in order to provide you with more relevant information, analyzing and evaluating our corporate activities, testing, developing and evaluating new products and improving our existing products and services, conducting market research and audits, identifying user trends and examining the degree of effectiveness of our marketing campaigns and degree of satisfaction of our customers;
· if necessary, to send you administrative e-mail notifications, such as security, support, maintenance advisories;
· responding to your requests or enquiries (customer services);
· dealing with any product adverse events you report to us; and
· administering record keeping, meeting legal and regulatory requirements in relation to the sale and purchase between us.
d) We may create anonymous data records from Personal Information by excluding information (such as your name) that make the data personally identifiable to you. We may also collect anonymous data directly from the Platform. We use this anonymous data to analyse request and usage patterns so that we may enhance the content of our Platform. We may use this anonymous data for research and analysis purposes to improve our products and services. We reserve the right to use such anonymous data for any purpose and disclose anonymous data to third parties, including but not limited to our research partners, in our sole discretion.
5. DIRECT MARKETING
a) We may also use your Personal Information to contact you from time to time to provide you with information, required notices and marketing promotions We or our Affiliates may periodically send you free newsletters, surveys, offers, and other promotional materials related to our Platform, Finish 365 products and our other products which we believe are useful for you.
b) We will not do so unless you have consented to this when you registered with the Platform or at a later stage.
c) If you do not wish to receive such newsletters or promotional communications, you may choose not to tick the opt-in box upon registration. If you have chosen to receive marketing communications, you will always have the opportunity to "opt out" at a later stage by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Unsubscribe instructions will be included in every email.
d) Even if you “opt-out” from marketing communication, your account in the Platform will remain with us and you can order Finish365 products.
e) Despite your indicated e-mail preferences, we may send you notices of any updates to our Privacy Notice.
6. DISCLOSURE OF YOUR PERSONAL INFORMATION
a) We disclose your Personal Information as described in this Privacy Notice.
b) Third Party Service Providers. We may share your Personal Information with third party service providers who work on our behalf. These third party service providers are required not to use your Personal Information other than to provide the services requested by us.
· Our contracted fulfillment service provider in terms of completing your orders in the Platform is Trojan Electronics 2018 Limited (“Trojan”), who acts as a data processor for us and ensures via it subcontractors (including Hermes as carrier and PayPal UK) that the Finish 365 product you ordered and paid is accounted, collected from the warehouse, packed and delivered to your address. Therefore, Trojan may access to all of the Personal Information that you provide us directly in the Platform.
· For paying for the ordered Finish 365 product in the Platform, you will be requested to provide credit card information in PayPal UK Limited (5, New Street Square, London EC4A 3TW) system where the payment details regarding your each orders are captured by PayPal UK, a subprocessor of Trojan.
· We store your Personal Information on cloud servers provided by Amazon Web Services and which are located in Frankfurt.
c) The cloud servers on which your Personal Information is hosted are managed by Amazon Web Services and Salesforce Inc.
d) Affiliates. We may share your Personal Information with our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to respect this Privacy Notice.
e) Acquisitions. If another company acquires our company, business, or our assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Notice. In the unlikely event of an insolvency, bankruptcy or receivership, your and your child(ren)’s Personal Information may also be transferred as a business asset.
f) Other Disclosures. Regardless of any choices you make regarding your Personal Information, we may disclose Personal Information if we believe in good faith that such disclosure is necessary
(a) in connection with any legal investigation;
(b) to comply with relevant laws or to respond to authorities or court orders, subpoenas or warrants served on us;
(c) to protect or defend our rights or property or the rights of users of our Platform; and/or
g) Transfer to third countries. Your Personal Information may be transferred to and processed in other countries where laws governing the processing of Personal Information may be less stringent than the laws in your country (including jurisdictions outside the European Economic Area). In such cases, where required by local law we will ensure that there are adequate safeguards in place to protect your Personal Information. This adequate safeguard might be a data transfer agreement with the recipient based on standard contractual clauses approved by the European Commission. Where we are legally required to do so, further details of these transfers and copies of these agreements are available from us on request. To the extent required and valid under your local law, you consent to your Personal Information being transferred and processed this way.
7. FOR HOW LONG WE RETAIN YOUR PERSONAL INFORMATION
a) We will retain your Personal Information for as long as you use the Platform and for a reasonable time thereafter. Accordingly, we process your Personal Information:
§ for the performance of your purchase of F365 product, we retain your Personal Information for a period of 7 years following completion of a contractual order;
§ for meeting, legal and regulatory requirements, we retain your Personal Information as it is set out by applicable law.
b) Please note that if you do not use your account in the Platform for a continues 12 months period, we may deactivate your account in the Platform; however we may still retain them for the abovementioned period. After the expiration of the above retention period, we delete your Personal Information.
8. YOUR RIGHTS
a) If you would like us to delete any of your or your child(ren)’s Personal Information, please contact us as described below and we will respond within a reasonable time. Please note that some or all of your Personal Information may be required in order for the Platform to function properly, and we may be required to retain certain information by law.
b) You may have various rights in relation to your Personal Information. In particular, you may have the right to:
· request a copy of Personal Information we hold about you;
· ask that we update the Personal Information we hold about you, or correct any Personal Information that you think is incorrect or incomplete;
· ask that we delete personal data that we hold about you, or restrict the way in which we use your Personal Information (the “right to be forgotten”);
· withdraw consent at any time regarding future`s processing of your Personal Information (to the extent such processing is based on consent);
· object to our processing of your Personal Information (including for direct marketing purposes).
c) If you would like to exercise these rights or understand if they Platformly to you, please contact us using the details set out at “how to contact us” below.
d) If you are unhappy with the way we have handled your Personal Information or any privacy query or request that you have raised with us, you have a right to lodge a claim at competent court or complain to your local data protection regulator at the Informational Commissioner’s Office (ICO).
9. SECURITY OF YOUR PERSONAL INFORMATION
a) We are committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your Personal Information from unauthorized access, use, or disclosure. For example, we limit access to your Personal Information to employees and contractors who need to know that information for the purposes we described above, we use pseudo-anonymization technics.
b) Please be aware that, although we endeavour to provide reasonable security for information that we process and maintain, no security system can prevent all potential security breaches. Therefore, while we use reasonable efforts to protect your Personal Information, we cannot guarantee its absolute security.
10. HOW TO CONTACT US
We welcome your feedback. If you have any comments, questions or complaints regarding this Privacy Notice or our processing of your Personal Information, or would like to exercise any of the rights set out at “your rights” above that are Platformlicable in your location, you can contact us by the following channels:
RB UK Hygiene Home Commercial Limited
103-105 Bath Road, Slough, Berkshire, United Kingdom, SL1 3UH
Tel +44 (0) 845 769 7079
Name of Data Protection Officer: Marco Gregorio
E-mail address of Data Protection Officer: Marco.Gregorio@rb.com
Telephone number of Data Protection Officer: +971043139303
Attn. RB Global Privacy Team
103-105 Bath Road
11. CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice was last modified on 14 February 2019.
This document is a notice to you and not a contract between us. We may occasionally modify or amend it from time to time. When we make changes to this Privacy Notice, we will update the revision date at the top of this Privacy Notice. Where those changes are material, we will take steps to let you know. The new modified or amended Privacy Notice will be displayed from that revision date. Please always verify whether you have consulted the latest version of the Privacy Notice.