HUMAX Privacy Policy

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To improve our products/services. (Transfer the personal data from the EU to the UK or from the UK to the EU) To allow you to use the applications to control the products.	(a) Identity (b) Contact (c) Technical Data (d) Profile (e) Usage	(a) Necessary for our legitimate interests (to develop our products/services and grow our business) (b) Consent
To register you as a new customer	(a) Identity (b) Contact	Performance of a contract with you
To register your product warranty	(a) Identity (b) Contact (c) Technical Data	Performance of a contract with you
To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us	(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
To provide customer technical support	(a) Identity (b) Contact (c) Technical Data	Performance of a contract with you
To provide a repair or exchange a product	(a) Identity (b) Contact (c) Technical Data (d) Profile	Performance of a contract with you
To allow you to use the applications within the products and to link to social media platforms	(a) Identity (b) Contact (c) Technical Data (d) Profile (e) Usage	Consent
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity (b) Contact (c) Profile (d) Marketing and Communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(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
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. When you create an account at our websites, you will be given the option to receive information from Humax by e-mail or otherwise about products, promotions or special offers which we feel may be of interest to you. Should you wish to receive such information, please select the opt-in option. These preferences can be updated at any time through the website.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Humax group of companies for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by replying to a promotional e-mail with the word “unsubscribe” in the subject line or by e-mailing us at privacypolicy@humaxdigital.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranty registration or other transactions.

Cookies

Cookies are tiny text files stored on your computer when you visit certain web pages. At this website, we use cookies to keep track of what you have viewed, and to remember you when you return to our site. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you don’t wish to enable cookies, you can disable cookies and you will still be able to browse the site and use it for research purposes. Most web browsers have cookies enabled, but please see internet browser’s help menu to turn them on/off should you need to. Please bear in mind that if you disable certain cookies for this website, you’ll be unable to access certain types of content on the website, such as videos.

Please note that cookies can’t harm your computer. We don’t store personally identifiable information in cookies we create, but we do use encrypted information gathered from them to help improve your experience of the website. For example, they help us to identify and resolve errors, or to determine relevant related products to show you when you’re browsing. For more information about the cookies we use, please see [Learn more about Analytics cookies and privacy information. Learn more about Zopim cookies and privacy information.].Certain third parties (in particular Google Analytics [Analytics cookies and privacy information]) will also place cookies when you visit our website, which allow us to count visits and traffic sources, so that we can monitor the performance of our site and make improvements. This tells us about how the site is used and the number of visitors but any information provided to us by those third parties is anonymised.

If you wish to learn more about cookies in general and how to manage them, visit aboutcookies.org (opens in a new window). Please note that we are not responsible for the content of external websites.

Change of purpose

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. 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.

5. Disclosures of your personal data
    

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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 policy.

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.

6. International transfers
    

We share your personal data within the Humax Group. This may involve transferring your data outside the  UK to Ireland, Germany, the Netherlands, and South Korea.

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data.
• We may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK, namely the International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

7. Data security
    

Humax takes reasonable steps to protect your personal data and has 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. The ways of securing such personal data include:

• limiting physical access to our premises;
• limiting access 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;
• requiring any third party providers to have acceptable security measures to keep personal data secure; and
• putting in place physical, electronic, and procedural safeguards in line with industry standards.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or our application; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

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.

8. Data retention
    

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to carry out the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

We determine the appropriate retention period for personal data by considering the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised 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, regulatory, tax, accounting or other requirements. The categories of data which we retain and the periods for which we retain it are set out in our Data Handling and Retention Policy, a copy of which can be made available on request from privacypolicy@humaxdigital.com.

In some circumstances you can ask us to delete your data.

If we retain your data for research or statistical purposes, we may anonymise your personal data (so that it can no longer be associated with you) and we may use this information indefinitely without further notice to you.

If Humax no longer requires your personal data and are not legally required to retain it, Humax will take reasonable steps to destroy or permanently de-identify the personal data.

9. Your legal rights
    

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the bullet points below to find out more about these rights:

• You may have the right to access your personal data (known as a “data subject access request”). This allows you to request a copy of the personal data we hold about you and to check that we are processing it lawfully.
• You can ask us to rectify any inaccuracies in the personal information that we hold about you. You may have the right to request the 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, 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.
• You may have the right to object to our processing of your personal data where we are relying on a legitimate interest and you feel that the processing impacts on your fundamental rights and freedoms or where we are processing your personal data for direct marketing purposes. Please note that in some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• You may have the right to restrict our processing of your personal data in certain circumstances.
• You may have the right to request that we transfer 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.
• Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting us. 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.
• You may have the right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.

If you wish to exercise any of the rights set out above, please contact us, by sending an e-mail to privacypolicy@humaxdigital.com.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary
    

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

Internal Third Parties

Other companies in the Humax Group acting as joint controllers or processors and who are based in Korea, Poland, France, Germany and Italy and provide IT and system administration services and undertake leadership reporting.

External Third Parties

• Service providers acting as processors based in the United Kingdom and who provide IT and system administration services, delivery services or installation services on site for our products
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom or the other European countries in which we operate and who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom and the equivalent authorities in the other European countries in which we operate, who require reporting of processing activities in certain circumstances.