We are delighted that you have shown interest in our company and products. Whirlpool Group (as defined below) takes your data protection rights very seriously and we are committed to improving your customer experience in compliance with all applicable data protection laws and regulations. Please find below our Privacy Notice, which explains the way we process your personal data.
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We are Whirlpool EMEA S.r.l., a company incorporated under the laws of Italy, having its registered office in Via Varesina n.204, 20156 Milano (MI), Italy, a part of the Whirlpool Group ("Whirlpool", "us" or "we"). In our capacity as data controller, we intend to provide the users of our websites, our apps and/or our home appliances that connect to the Internet (respectively, “Website”, “App” and “Smart Appliances”) and any other individual interacting with us ("Users", "you" or "your"), with information concerning the methods used for collecting and processing personal data, in accordance, with the European General Data Protection Regulation no. 679/2016 ("Regulation") and any other applicable local laws and regulations.
“Whirlpool Group” means Whirlpool Corporation, a Delaware corporation, having its global headquarters at 2000 M-63, Benton Harbor, MI 49022 together with and its affiliates from time to time.
INFORMATION WE COLLECT
We collect (1) personal data that you have shared with us, (2) data we collected when we conclude sales and services transactions with you, (3) data collected by our call centres, (4) data concerning your activity on the Website, the App or through the Smart Appliances and (5) information provided or collected through other sources.
We do not collect special categories of personal data relating to you (e.g., health or judicial data).
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HOW WE USE YOUR DATA
We use your personal data to provide you with the services requested, including but not limited to, getting in touch with you in case of security issues related to your household appliance, allowing you to surf through the Website, to use the App and/or the Smart Appliances, responding to requests and to interact with our services including the ones offered through call centers.
Only with your consent, we may also process your personal data to send you customized marketing communications including offers and discounts from us and from our trusted partners, as well as record the phone calls made by you to our call center.
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ON WHAT GROUND DO WE USE YOUR DATA
We only use your data in case there is a legitimate legal ground for processing of personal data, such as
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FOR HOW LONG WE RETAIN YOUR DATA
We use your personal data for the period strictly necessary to achieve the intended purposes.
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WHAT WE DO TO PROTECT YOUR DATA
The security of your data is a priority for us. For this purpose, we have implemented adequate administrative, technical and physical measures designed to safeguard your personal data against loss, theft and unauthorized use, disclosure or modification.
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WITH WHOM DO WE SHARE YOUR DATA
We may share your data with (1) service providers, (2) companies of the Whirlpool Group, and (3) public authorities, when allowed by applicable laws.
Upon your consent, we may also share your personal data with our trusted partners for their marketing purposes.
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TRANSFERS OF YOUR DATA OUTSIDE EEA
Your data may be transferred to subjects located outside European Economic Area (EEA). In any case, we always make sure that appropriate and suitable safeguards compliant with the Regulation are implemented.
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You have, among others, the right to access, integrate, update, amend and delete your personal data.
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You can contact us using our contact us form or writing a letter to Whirlpool EMEA S.r.l., Via Varesina n.204, 20156 Milano (MI), Italy.
You can contact our data protection officer by using the contact us form or sending us an e-mail at firstname.lastname@example.org or by post to our address above with the addition “for the attention of the Data Protection Office”.
We may modify or update this Privacy Notice also in order to comply with applicable laws.
1. TYPE OF PERSONAL DATA PROCESSED
Whirlpool will process the following categories of data.
- Data relating to you
Whirlpool processes personal data about you, collected or provided through a number of sources, including but not limited to:
- personal data provided by you directly at the opening of an account and/or registration of the purchased product and/or when you make a request for information, assistance and purchase of the Whirlpool products on the online shop, such as name, surname, address of residence, email, telephone number;
- personal data provided by you directly or inferred during the phone calls you made to our consumers’ call centers that may be recorded only with your consent, including dates/times of calls, caller contact information, and customer order information;
- personal data contained in images, audio and/or video you submit or allow the App or Smart Appliances to capture;
- personal data provided by other parties’ products or services that you connect through the App or Smart Appliances.
Such data is processed only to the extent that it is necessary to pursue the purposes set out in this Privacy Notice. Whirlpool is required to keep the personal data anonymous and to remove such data where it does not need to process personal data in identifiable form for processing purposes.
- Contract data
Whirlpool processes personal data about the Users when they buy products and services from Whirlpool including name, address, country, contact details such as phone number and e-mail address. Additionally, Whirlpool collects data about the appliances you have bought and or the services you have ordered including requests for warranty services.
- Usage and Browsing data
The Website, the App and the Smart Appliances collect personal data of the Users for technical and functioning reasons. Such data is not collected for the purpose of identifying the User, but it may imply the identification of the same should, for instance, the data be compared to other data held by third parties.
Such category of data includes: (i) the IP address and the domain name of the User’s computer; (ii) the Smart Appliances ID, model and serial number; (iii) the IP address of your home router when you connect a Smart Appliance to our network; (iv) the type of browser and operating system used; (v) the physical location of your device or Smart Appliance (as determined, for example, using satellite, cell phone tower, and WiFi signals); and (vi) other information about your online session such as the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received as reply, the numerical code related to the reply status from the server and other parameters related to the operating system used by the User’s device. After you connect your Smart Appliance to our network, we may automatically collect information from the Smart Appliance on a periodic basis, including status (such as whether the Smart Appliance is off or on, and details about the cycle or function it is performing), instructions that have been entered on the Smart Appliance, fault or error codes and aspects of its environment that may affect how it operates (such as input voltage, signal strength and air temperature). We may track and collect App usage data, such as the date and time the App accesses our servers, what information has been downloaded to the App, and the instructions that are transmitted to the Smart Appliance.
Website data is used only to collect anonymous statistical information on the use of the Website and to control its correct operation and it is retained in accordance with our records retention requirements. Such data may also be used for ascertaining liability in the event of possible computer-related crimes against the Website, the App and/or the Smart Appliances.
If you would prefer to not have Whirlpool collect any data from you Smart Appliances, you will need to de-provision (disconnect) your Smart Appliance from your wireless router and turn off the wireless connection button on your appliance. De-provisioning (disconnecting) your Smart Appliance will also disable your use of the Smart Appliance and App, even if your related account remains active. If you merely deactivate your account but do not de-provision (disconnect) your Smart Appliance, data, which do not include and are not associated with your personal data and does not identify you specifically, will continue to be transmitted to Whirlpool.
We may also collect personal data on our Website by means of different categories of cookies, where applicable after you have provided your active consent. For more information about cookies, please visit our Cookie Notice.
2. PURPOSES OF THE PROCESSING
Where applicable, we will process your personal data we have collected or been provided with for the following purposes:
- allowing you to register on the Website or on the App by opening a personal account, to register a product on the Website and to purchase a product on the Website;
- providing you with the Smart Appliance services, including notifications for purposes of assistance and maintenance and communications functional to using your account or your Smart Appliance, including those related to customer services and the warranty;
- completing the online purchase of the product and providing additional services (after-sale services, extended warranty, the prevention of fraud, the management of returns, contact you in case of a security issue related to your household appliance);
- performing the home delivery of our products and providing you with any requested services;
- arranging for a repair on your product;
- managing the requests for information you send us, including handling complaints and communications received via our interactive chat service;
- entering a prize promotion / competition;
- complying with the statutory provisions and regulations and enforcing our own rights before the courts;
- sending you customized marketing communications related to our products and services electronically (including email, SMS, MMS, social network notifications, mobile applications). Email marketing is based on consent. However, depending on the country in which you are located, certain e-mail marketing activities may be based on Whirlpool’s legitimate interest (soft opt-in);
- contacting you for marketing purposes by phone (non-automated) and via paper mail. Such processing may be based on your consent or on Whirlpool’s legitimate interest (in such a case you are granted with the right to opt-out);
- for the purpose of sending you customer care communications concerning products registered by you or which you showed interest in and in order to carry out customer satisfaction surveys;
- upon your consent, sharing your personal data for customized marketing communication with our selected trusted partners as set forth in Section 6 below;
- carrying out activities useful for the transfers of business and business branches, takeovers, mergers, demergers or other transformations and for the execution of such transactions;
- for internal training, documentation purposes and quality control / assurance purposes we might listen to the recorded phone calls made to our consumers’ call centers
3. LEGAL BASIS FOR THE PROCESSING
- The provision of the personal data for the purposes under Section 2, para. a), b), c), d), e), f) and g) is necessary for the purpose the data was provided or shared with us, which includes but is not limited to the registration on the Website, the online purchase of products and the use of ancillary specific services, as well as the participation to prize promotions and competitions. The legal basis for such processing of personal data is the performance of a contract of which you are part or the fulfilment of a request made by you;
- The provision of personal data for the purposes under Section 2, para. h) is mandatory since required to comply with the applicable laws. The legal basis for such processing of personal data is the compliance with a legal obligation;
- The provision of the personal data for the purposes under Section 2, para. i), l) and n) is optional. Unless otherwise provided for by the law applicable in the country in which you are located, without your consent Whirlpool, the companies part of the Whirlpool Group and/or trusted partners will not be able to send you customized marketing communications via automated means, nor record the phone calls you made to our consumers’ call center. In any event, upon the withdrawal of the Users' consent we will no longer process the personal data for which we rely on your consent;
- The provision of personal data for the purposes under Section 2, para. j), k) and m) is necessary to pursue the legitimate interests of Whirlpool and the Whirlpool Group, which will be appropriately balanced with your interests. We may also use, in compliance with the applicable data protection laws, your electronic contact details (email) we collected in the context of a sale of a product or service, in order to send you marketing communications related to similar products or services. In such a case, you may object to such use of your electronic contact details by clicking the “unsubscribe” link at the bottom of the email / SMS at each time the customized marketing communication is sent; or in accordance with Section 9 of this Privacy Notice below. Unless otherwise provided for by the law applicable in the country in which you are located, our legitimate interest is the legal basis on which we rely for the processing of your personal data for the purposes described herein.
4. DATA RETENTION
Whirlpool will process the personal data for as long as it is necessary to achieve the intended purposes pursuant to Section 2 above. In any case, the following retention periods shall apply:
- the data collected for the purposes of Section 2, para. a), b), c), d), e), f) and g) will be retained for the period strictly necessary in order to respond to data subjects' requests and comply with applicable laws and regulations;
- the data collected for the purpose of Section 2, para. h) will be retained for the period mandatorily prescribed by the applicable law provisions (e.g., for tax purposes);
- the data collected for the purposes of Section 2, para. i) and l) will be retained for the maximum data retention period set forth by the applicable law provisions; and
- the data collected for the purposes of Section 2, para. j), k) and m) will be retained for the period strictly necessary in order to pursue Whirlpool business interests.
- the data collected for the purposes of Section 2 para. n) will be retained for no longer than the period set forth by the applicable laws.
Please consider that data retention periods may vary, depending on the applicable local laws.
5. DATA PROCESSING PROCEDURES
Your personal data is processed with the support of Information Technology and/or paper means and it is protected by appropriate security devices suitable to ensure the secrecy and safety of the personal data. In particular, Whirlpool adopts the appropriate administrative, technical, personal and physical measures designed to safeguard the personal data held against any loss, theft as well as unauthorised use, disclosure or change in the personal data.
6. COMMUNICATION OF DATA
We will share your personal data with our trusted partners, such as our extended warranty providers, that intend to use it for direct marketing purposes only when we have specifically informed you and you have given us specific consent to do this.
We may share your personal data with:
- companies of the Whirlpool Group located in the EEA and outside the EEA, acting as autonomous controllers;
- our carefully chosen third party suppliers located in the EEA and outside the EEA, such as call centre operators, content rating service providers, shippers, suppliers of services or technicians assigned to assistance and other suppliers working on our behalf in the role of duly appointed data processors for the purposes described in this notice; other third parties as part of a corporate transaction such as a merger or sale of assets;
- our extended warranty provider Domestic & General (“D&G”) [Domestic & General Insurance PLC]. D&G will act as joint controller (along with Whirlpool) for the purpose of promoting and sale of extended warranties, as well as handling repair requests pursuant to such extended warranties. In particular, D&G will process the personal data for the following purposes: (i) register and manage your account / profile, as well as manufacturers’ warranties; (ii) promotion, sale and administration of service contracts and products / services; (iii) in certain countries, handle and respond to inbound customer service calls and update such data with information from such consumers; (iv) take and receive personal data from consumers to make sales of service contracts, and update such data with information from consumers; (v) handle and respond to inbound consumer complaints (including any litigation); (vi) to manage bookings and provision of repair services and supply replacement products to consumers and correct and update such data with information from consumers in connection with such repair services and/or the provision of replacement products and/or to update such personal data; (vii) carry out surveys on the quality of the products and services performed.
- Third parties providing e-payment services, for the purpose of managing the payments related to your orders. For the sake of clarity, Whirlpool does not process any banking / financial data (including credit card information) of the Users, save for those strictly necessary for the purposes of Section 2, para. c) (e.g. to provide consumers with extended warranty). In connection with such processing, third parties providing e-payment services will process your personal data as autonomous controllers, in accordance with the Regulation (and any other applicable local laws and regulations) and their own respective privacy policies. Whirlpool shall not be liable for any damage (including those arising from the violation of the Regulation and any other applicable data protection law) arising from the processing of Users’ banking / financial data (including credit card information) by said third party providing e-payment services.
- For the distribution, repair and maintenance service of our products we share our Users’ address and contact data with our partners only when strictly necessary;
- We may also be required to disclose personal information in response to lawful requests by government authorities, including requests from national security agencies or law enforcement.
Such third parties will process your personal data on our behalf in the role of duly appointed data processors (with the exception of what is detailed at letter d)) for the purposes described in this notice in accordance with our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.
7. DATA TRANSFER OUTSIDE OF THE EEA
Any transfer of your personal data outside the EEA (both within and outside Whirlpool Group) is carried out based on the following suitable safeguards in accordance with the Regulation:
- When the European Commission has issued an adequacy decision; or
- appropriate safeguards have been provided by or to the Whirlpool group company exporting your personal data including but not limited to standard data protection clauses. Without prejudice to the foregoing, transfer based on standard data protection clauses is featured by additional organizational and technical measures, designed to ensure an adequate level of protection of your personal data.
8. MINORS UNDER THE AGE OF 18
The Website, our Apps, and our Smart Appliances do not address subjects under the age of 18, nor is Whirlpool knowingly collecting personal data from people under the age of 18.
9. RIGHTS OF DATA SUBJECTS
You, at any time and at no charge, can have and/or exercise the following rights:
- the right to be informed on the purposes and methods of the processing of your personal data;
- the right of access to your personal data (commonly known as “data subject access request”). This enables you to receive a copy of the personal data we hold about you;
- the right to ask for updating or rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- the right to request erasure of your personal data. This enables you to ask us to delete or remove your 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 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;
- the right to restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- the right to object to the processing, wholly or partly, of your personal data where we are relying on legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- where we are relying on consent to process your personal data, the right to revoke the consent to the processing of your personal data freely and at any time, also by clicking on the unsubscribe option at the bottom of our marketing communications;
- the right to data portability of your personal data to you or to a different provider. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format;
- the right to contact us by sending us an email at email@example.com or using our contact us form and
- the right to lodge a complaint in front of the competent national data protection or judicial authority.
If you wish to exercise the rights mentioned above, or raise any questions about the personal data we hold about you, please send us an email at firstname.lastname@example.org or write to us at: Whirlpool EMEA S.r.l., Via Varesina n.204, 20156 Milano (MI), Italy, with the addition “for the attention of the Data Protection Office”. Where available, you can also use our contact us form.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you have the right to contact the competent national data protection or judicial authority as described above in Section 9 on the Rights of Data Subjects. You also may contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
10. AMENDMENTS AND UPDATES
We keep this Privacy Notice under regular review. We may update this Privacy Notice to reflect changes to our privacy practices. If we make any material change, we will inform you by updating this Privacy Notice prior to its effective date. We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices. This Privacy Notice was last updated on 02/02/2021.