Humax is committed to protecting your personal data and respecting your privacy. This policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy policy

This policy sets out the basis on which any personal data we collect from you through your use of our website, or that you otherwise provide to us, will be processed by us, including any data you may provide through our website when you sign up to our newsletter, purchase a product or service or take part in a competition.

Our products, website and services are not intended for children and we do not knowingly collect data relating to children.

It is important that you read this policy together with any other privacy policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This policy supplements the other policies and notices and is not intended to override them.

Controller

For the purposes of the Data Protection Act 1998 and, when it comes into force, the General Data Protection Regulation ((EU) 2016/679) (“GDPR”); all successor legislation to the Data Protection Act 1998 and the GDPR; and the Privacy and Electronic Communications Directive (2002/58/EC) together with all implementing and successor legislation (collectively, the “Data Protection Legislation”), Humax is a data controller and responsible for your personal data.

Humax is made up of different legal entities, details of which can be found here https://au.humaxdigital.com/global-network/. This policy is issued on behalf of the Humax Group so when we mention “Humax”, “we”, “us” or “our” in this policy, we are referring to the relevant company in the Humax Group responsible for processing your data. Humax is the controller and is responsible for this website.

Our Chief Financial Officer (“CFO”) is the senior management person within the business ultimately responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our data privacy team using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Humax Group

Email address: privacypolicy@humaxdigital.com

You have the right to make a complaint at any time to the supervisory authority of the country in which the business that you are dealing with is incorporated:

• In the UK, this is the Information Commissioner’s Office (ICO)who can be contacted through their website (www.ico.org.uk);
• In Germany, this is Die Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (“BFDI”). Responsibility for complaints is split between a number of bodies, the details of which can be found on the BFDI website (www.bfdi.bund.de);
• In France, this is the Commission Nationale de l’Informatique et des Libertés (“CNIL”) who can be contacted through their website (www.cnil.fr); and
• In Italy, it is the Garante per la protezione dei dati personali, whose contact details and other information are located on their website (www.garanteprivacy.it)

We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so please contact us in the first instance on the contact details given above.

Changes to the privacy policy and your duty to inform us of changes

We may from time to time change, alter, adapt, add or remove portions of this privacy policy, but if we do so, we will post any changes on the website.

This version was last updated on 21 May 2018 and historic versions can be obtained by contacting us.

The data protection law in the EU will change on 25 May 2018. Although this policy sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until after 25 May 2018 as we are still working towards getting our systems ready for some of these changes and the Data Protection Legislation itself is still being finalised in some respects.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our site may, from time to time, contain links to third-party websites, plug-ins and applications. If you follow a link to any of these, you may be allowing third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed in a such a way that the person cannot be re-identified (anonymous data).

When you use our website, our products or our services, we will ask you to input and we will collect, use, store and transfer different kinds of personal information about you, such as:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services. This information helps us improve the quality of our service.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data (Special Categories of Personal Data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We will collect data about you through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • purchase our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • register your product warranty;
  • contact us for product information or customer technical support;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us some feedback.
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:
(a) analytics providers such as Google or Microsoft based outside the EU;
(b) advertising networks such as Facebook and other social media platforms based outside the EU; and
(c) search information providers such as Google based outside the EU.

• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay or DPD logistics based inside the EU.
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.
• Identity, Contact, Financial and Transaction Data from our retailers including John Lewis, Currys, Euronics and smaller independent retailers.
• Identity, Technical, Profile and Contact Data from social media platforms such as flickr and twitter.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use information held about you in the following circumstances:

to carry out our obligations arising from a contract we are about to enter into or have entered into with you;

where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and/or

to comply with a legal or regulatory obligations.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message where we do not have a pre-existing relationship with you, or for you to access additional product features. You have the right to withdraw consent at any time by contacting us, but only in relation to the data which we process on that legal basis.

Purposes for which we will use your personal data

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data on more than one lawful basis depending on the specific purpose for which we are using your data in each instance. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
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	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.

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 European Economic Area (“EEA”).

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

Whenever we transfer your personal data out of the EEA, 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 to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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

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, accounting, or reporting requirements.

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 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.
• 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 another data controller. 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. If you withdraw your consent, we may not be able to provide certain products or services to you.
• 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.
• 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.