Data Protection Policy
Data controller of your personal data are companies:
- A company ConnectLife, data technologies, LLC Partizanska cesta 12, 3320 Velenje, Slovenia, (hereinafter: Company), is acting as core data controller of companies producing and/or trading appliances of the brands within companies of Hisense Europe Group (Hisense, Gorenje, Asko, ATAG, Pelgrim, Etna, Körting, Mora, Upo).
- Hisense USA Corporation, 7310 McGinnis Ferry Road, Suwanee GA 30024
- we adopted an internal procedure regarding the protection of personal data, in which the obligations of the Company and employees regarding the protection of personal data are determined,
- we adopted the Cookie Policy https://ca.asko.com/cookies, which regulates the protection of personal data of website users,
- we have created a dedicated e-mail box where you can contact us regarding all questions about your personal data,
- we regularly educate employees about the handling of personal data.
- we regularly check personal data handling systems and propose improvements.
- Customer ID,
- Title (Mr / Mrs),
- First name and last surname,
- Language of communication,
- invoicing address and delivery address (if the delivery option is selected),
- e-mail address,
- phone number,
- order (number, value)
- method of payment,
- bank account number and/or credit card number,
- product number
- serial number of the product
- purchase invoice
- purchase history
- name and surname,
- e-mail address,
- phone number,
- order number,
- details of purchased products,
- date of purchase,
- address,
- language of communication,
- date of claim,
- service history,
- duration of warranty and extended warranty,
- type of warranty,
- warranty related only to specific parts of the product,
- e-mail communication
- chat transcript
- video conference recording (in case of video conference)
- pictures (in case user sends us pictures of the product)
- in the case of a call to the call centre, a recording of the telephone call.
- e-mail address.
- user ID
- e-mail address
- name and surname,
- phone number,
- address,
- language of communication,
- password,
- food preferences,
- service ticket and service history,
- social network login (in case of establishing user account with social media account: e-mail address, first name, last name, language of communication, photo URL, provider, provider ID)
- account information (login enabled, log, profile update, login location, account created, account access log)
- password (last login, disable login).
- product number,
- serial number of the product,
- date of purchase,
- copy of the purchase invoice,
- IBAN number (only for the purpose of partial refund of the purchase price).
- name or chosen name or review as a guest,
- e-mail address,
- details of purchased products or service performed,
- copy of the purchase invoice
- rating or comment
- review language
- our response
- sentiment analytics of user product reviews.
- name and surname,
- e-mail address,
- phone number,
- data related to prize games (model, serial number, purchase date, invoice)
- location data of the user obtained from the user's mobile device (anonymously),
- the individual's interests regarding viewing products on websites (anonymously),
- contact information via instant messaging applications,
- purchase history,
- postal code,
- data related to delivery, opening, clicking and unsubscriptions of our messages, (anonymously)
- sentiment analytics of user product reviews.
- user account designation,
- purchase history,
- device operating system,
- used browser,
- web address (URL address) of the initial page that you use to access to our website.
- if you like, share a post, mark the Company's profile or comment, we receive access to your public profile and the content of your post,
- if you send us a private message on a social network or through an instant messaging application, we obtain information about your public profile, or your contact information and information about the content of the sent message.
- the public profile of the individual on the social network and the content of the publication,
- contact information of the individual in the instant messaging application,
- other data that you will provide to us during the communication.
- title (mr, mrs),
- name and surname,
- language of communication,
- address,
- phone number,
- e-mail address.
During the usage of the device, we will perform data analysis related to the usage, where those data will be processed in anonymous way and without any link to an identified or identifiable natural person. For this purpose, we will anonymously process following data:
- appliance’s data (brand, model, serial number),
- installation date of the device,
- data on pairing the device with our cloud (appliance paired, pairing type and timestamp)
- operation of the appliance (commands sent to appliance, appliance settings, status and statistics, notifications, appliance alarms and errors, service ticket requests, timer and automation)
- data detected by the device's sensors and which are important for the operation of the device (e.g. data regarding technical performance, data related to possible error messages, temperature, humidity, air quality, etc.),
- booking log (for public laundry)
- food images from appliance and time-lapse videos
- user behaviour analytics,
- device booking,
- resource (water, electricity) consumption,
- food and drink storage and preferences.
Only in case when we will acquire your explicit consent, we may link data acquired by data analysis to identified natural person. Such data may be forwarded to service providers for the purpose of customer support for troubleshooting and warranty claims. In case of acquiring your additional consent, we may use those data also for personalized offer where we can recommend content through ads and notifications.
In order to connect the appliance to the cloud via local WIFI users have to insert also data about Service Set IDentifier (SSID) and a password. However, those data are used only for pairing the appliance with Wi-Fi module and are not collected, stored or in any other way processed by us.
- Google Marketing Platform for the purpose of obtaining data related to website traffic (e.g. number of visitors, pages visited by visitors, time spent by visitors on the website);
- Google Maps for the purpose of using the mapping service Google Maps via API in order to facilitate the location of places specified by the individual on the website;
- Google Tag Manager for the purpose of managing website tags through the user interface and integration of program codes on our websites;
- Google Ads for the purpose of placing advertisements, remarketing and tracking conversions;
- Google Optimize for the purpose of A/B testing and website testing;
- Site Kit for the purpose of improving and monetizing our content on the web page;
- Youtube for the purpose of establishing a connection with YouTube servers, where the use of plugins from YouTube is required;
- Google Analytics for the purpose of collecting data from websites and apps to create reports that provide business insights;
- Google Search Console in order to show the performance of websites on Google Search and how Google sees our website
- Looker Studio for the purpose of turning data into informative, easy to read, easy to share, and fully customizable dashboards and reports.
- Meta business suite as a social media management tool for Facebook and Instagram for the purpose of creating and scheduling content to responding to engagement to analyzing insights
- Meta pixel for the purpose of placing advertisements, remarketing and tracking conversions.
- Google Ads, provided by Google and you can opt-out of this by visiting the Google Ads Settings page: https://adssettings.google.com/authenticated, and
- Facebook Retargeting, provided by Meta and you can opt-out this by visiting the Facebook site where you have to log in and go to Settings > Ads > Ad Settings. On the app, go to Setting & Privacy > Settings > Ad > Ad Preferences > Ad Settings. Then choose the Not Allowed
- Measures for ensuring ongoing confidentiality, integrity, availability and resilience of processing systems and services
- Measures for ensuring the ability to restore the availability and access to personal data in a timely manner in the event of a physical or technical incident
- Processes for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures in order to ensure the security of the processing
- Measures for user identification and authorisation
- Measures for the protection of data during transmission
- Measures for the protection of data during storage
- Measures for ensuring physical security of locations at which personal data are processed
- Measures for ensuring events logging
- Measures for internal IT and IT security governance and management
- Measures for ensuring data minimisation, data quality and limited data retention
- Measures for allowing data portability and ensuring erasure
- Hisense Gorenje Europe, poslovne storitve, d.o.o., Hrvaška ulica 4, 1000 Ljubljana
- Gorenje, d.o.o., Partizanska cesta 12, 3320 Velenje
- Hisense Home Appliance Group Co., Ltd. Qingdao Branch, F3, Building 3, Section C, Hisense R&D Centre, 399, Songling Road, Qingdao, Shandong, China.
The Company may also transfer personal data to external contractors (mainly for the purpose of ensuring payments, transportation and other matters related to your order etc.). In such a case the Company undertakes to enter into an agreement with the external contractors that ensures adequate security of your personal data, and the external contractors can process your data only for the purpose for which they were obtained.
Your personal data may also be the subject of transfer to external contractors in third countries. In this case the Company will ensure adequate safeguards if the external contractors are seated or provide services relevant to the protection of personal data in a third country that does not offer the same level of data protection as GDPR and undertake other obligations set forth by the GDPR regarding such kind of transfer.
In particular, we may transfer your personal data to other companies in the Hisense group and our distributors that sell our products and services at certain markets or provide other services in relation to business support, complaints of ordered goods or customer support. List of our companies in certain countries and their external contractors that may have access to the personal data of users from certain market is listed in the Appendix.
We may transfer your personal data acquired based on your consent according to this data protection policy to advertising and social networks, in particular to:
- Google Ireland Limited (registered number: 368047), with registered office at Gordon House, Barrow Street, Dublin 4, Ireland; the company's privacy policy is available here: LINK
- Facebook Ireland Limited, with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, D02 X525, Ireland; the company's privacy policy is available here: LINK
- Pinterest, Inc., with registered office at 505 Brannan Street San Francisco, CA 94107 United States, the company's privacy policy is available here: LINK
- LinkedIn as a tool provided by Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052, USA, LinkedIn's privacy policy is available here: LINK
To process personal data, we also use the services of other external contractors. External contractors include:
- cloud computing service providers and other technology support providers such as:
- Microsoft Azure, provided by Microsoft Corporation, One Microsoft Way, Redmond, Washington 98052, USA, the company's privacy policy is available here: LINK
- SAP Hybris provided by SAP SE, Dietmar-Hopp-Allee 16, 69190 Walldorf/Germany, the company's privacy policy is available here: LINK SAP America, Inc., 3999 West Chester Pike, Newtown Square, PA 19073, USA.
- Salesforce Marketing Cloud and Salesforce Service Cloud provided by Salesforce, Inc. Salesforce Tower, 415 Mission Street, 3rd Floor, San Francisco, CA 94105, United States, the company's privacy policy is available here: LINK
- Cloudera provided by Cloudera, Inc., 5470 Great America Parkway, Santa Clara, CA 95054, USA, the company's privacy policy is available here: LINK
- Tuya IoT platform provided by Tuya Global Inc., 3979 Freedom Circle, Suite 340, Santa Clara, CA 95054, the company's privacy policy is available here: LINK
- DigitalOcean, 101 6th Ave New York, NY 10013, the company's privacy policy is available here: LINK
- Cloudflare France SAS, 6 place de la Madeleine, 75008 Paris, the company's privacy policy is available here: LINK
- Amazon Web Services, Inc., 410 Terry Avenue North Seattle, WA 98109 United States, the company's privacy policy is available here: LINK
- marketing tools providers that help us optimize the web and personalize content and offers for you, such as:
- AV STUDIO d.o.o., Koroška cesta 55, 3320 Velenje, the company's privacy policy is available here: LINK
- Agilcon, d.o.o., Letališka cesta 32, 1000 Ljubljana, the company's privacy policy is available here: LINK
- ZenLab d.o.o., Polule 77C, 3000 Celje.
- Columbus Global Lautrupvang 6, Ballerup, Denmark 2750.
- Sprinklr, Inc. 29 West 35th Street, New York, NY 10001, USA, the company's privacy policy is available here: LINK
- Freshworks Technologies B.V. Stationsplein 32, 3511 ED Utrecht, the company's privacy policy is available here: LINK
- "eXpoint" SIA, rīvības street 76-34, Riga, LV-1001.
- Mailchimp as a tool provided by Intuit Inc., 2700 Coast Avenue, Mountain View, CA 94043, the company's privacy policy is available here: LINK
- 24TTL B.V., Amsterdam, Noord-Holland, The Netherlands, the company's privacy policy is available here: LINK
- eStoreMedia sp. z o.o., Aleja Komisji Edukacji Narodowej 18, 02-722 Warszawa, Poland, the company's privacy policy is available here: LINK
- SiteOne Landscape Supply, Inc, 300 Colonial Center Parkway Suite 600 Roswell, GA 30076 United States, the company's privacy policy is available here: LINK
- Campaign Monitor Holdings Pty Ltd, 5 STAPLETON AVE SUTHERLAND NSW C3 2232, the company's privacy policy is available here: LINK
- Splunk Inc., 270 BRANNAN STREET SAN FRANCISCO CA 94107, the company's privacy policy is available here: LINK
- Twilio Inc., 101 Spear Street, Ste 500, San Francisco, CA 94105, the company's privacy policy is available here: LINK
- call centres and providers of tools for managing and recording telephone calls, especially:
- Hisense Europe Customer Care Centar, Strahinjića bana 9, 11000 Beograd, Serbia;
- 3CX, 4010 Boy Scout Boulevard, Suite 325, 33607, Tampa, Florida, USA, the company's privacy policy is available here: LINK
- Diabolocom SAS, 20, rue de Paix - 75002 Paris, France, the company's privacy policy is available here: LINK
- Cisco Systems, Inc., 170 West Tasman, Dr.San Jose, CA 95134 USA, the company's privacy policy is available here: LINK.
- external service providers for the maintenance and repair of our devices.
- processors of external communication, especially communication via SMS messages and chat rooms, especially:
- LiveChat, Inc. (101 Arch Street, 8th Floor, Boston MA 02110, United States of America, the company's privacy policy is available here: LINK
- Jivochat as a tool provided by Lucas Loureiro Carvalho Suporte Tecnico ME., the Rua Neves Armond, 140, Sala 301, Praia Do Suá. Vitória, ES/Brazil, the company's privacy policy is available here: LINK
- TargetFirst, 23 rue de la Croix Lormel, 22190 PLERIN, the company's privacy policy is available here: LINK
- companies that prepare surveys for us regarding user satisfaction with our products and services, especially:
- Trustpilot A/S, Pilestraede 58, 5th floor, DK-1112 Copenhagen K, the company's privacy policy is available here: LINK.
- Bazaarvoice, Inc., 10901 Stonelake Blvd, Austin, TX 78759, the company's privacy policy is available here: LINK
- Reevoo, 2nd Floor Walbrook Wharf, 78-83 Upper Thames Street, London EC4R 3TD, the company's privacy policy is available here: LINK
- Momentive Europe UC, 2 Shelbourne Buildings, Second Floor, Shelbourne Rd Ballsbridge, Dublin 4, Ireland, the company's privacy policy is available here: LINK
From time to time, the company organizes prize games and similar promotional campaigns together with third parties, to whom it may also provide individual personal data, whereby you will be informed of this prior to the collection of personal data.
- complete the transaction for which the personal data was collected, provide a good or service requested by the consumer, or reasonably anticipated within the context of our ongoing business relationship with the consumer, or otherwise perform a contract between us and the consumer,
- detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity,
- debug to identify and repair errors that impair existing intended functionality,
- exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law,
- comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code,
- enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with us,
- comply with a legal obligation, or
- otherwise use the consumer’s personal data, internally, in a lawful manner that is compatible with the context in which the consumer provided the personal data.
You may request to receive details about how we collect, use, and share your personal data. Specifically, you may request to receive the specific pieces of information that we have collected about you by contacting our Data Protection Officer (defined in section below). If you do so, we may need to collect additional personal data and other information, including name, email address, zip code, product purchase location, phone number (which you may choose not to provide), product model number and serial number to verify your identity. The same process applies to requests for the deletion of personal data described above.
You may also request to receive:
- the categories of personal data that we have collected about you,
- the categories of personal data that we have disclosed for a business purpose,
- the categories of sources from which we collected the personal data,
- our purposes for collecting that personal data, and
- the categories of parties with whom we share your personal data.
- Full name and email address or address, in order to communicate the response to your request.
- The documents that prove your identity, or if applicable, that of your legal representative.
- A clear description of the personal data with respect to which you seek to exercise any of the ARCO Rights.
- Any other element or document that facilitates the location of personal data.
- Right of access – enables you to obtain the information as to whether your personal data is being processed and regarding the procedures and methods of personal data processing,
- Right to rectification – in case you notice that your data is not accurate, you have the right to complete incomplete or to correct the incorrect data,
- Right to erasure – allows you to request the erasure of your personal data that we process. We will do this in accordance with the GDPR and in the event that there are no other restrictions preventing us from doing so,
- Right to restrict processing - allows you to restrict processing, while you dispute the accuracy of the data, object to deletion, as the purpose of the processing for which the data was collected is no longer relevant, and you want further storage due to legitimate interests, or if you have submitted a request to determine the legal reasons for processing,
- Right to data portability – allows you to receive a copy of the provided personal data in a structured, commonly used hardware format, and to transmit data to another controller, if the requirements set forth by the GDPR are met,
- Right to object - enables objection in case of data collection and processing for the purposes of direct marketing or related profiling,
- Right to review automated decision-making - in the event that a decision that is reflected in our mutual relationship is based on automated decision-making, you can use the right to implement a new, non-automated decision,
- Right to withdraw consent – in the event that the processing is based on the given consent, you have the right to revoke the consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
If you wish to use any of the above rights, you can do so by notifying us at the e-mail address privacy@connectlife.io.
- For company ConnectLife, data technologies, LLC: Information Commissioner of the Republic of Slovenia, by mail to the address: Dunajska 22, 1000 Ljubljana or via e -mail to the address: gp.ip@ip-rs.si
- For company Hisense USA Corporation: The Attorney General or Consumer Protection Division of the State you reside.
15. Data Protection Officer
In all matters related to the processing of your personal data, our data protection officer is at your disposal and can be contacted at the e-mail address: privacy@connectlife.io.