PRIVACY POLICY
1. INTRODUCTION
How we work
We care about your privacy and the protection of your personal data. This means that we are committed to operate in an open and transparent manner and in compliance with applicable laws and regulations, including providing up-to-date information about our collection and use of personal data for our customers and other individuals that interact with us or who may have a relationship with an organization that we interact with.
Electrolux and You
By way of this Electrolux Privacy Policy we want to give you information about what personal data we process about you, why we do it, and your rights.
Please note that our relationship may also be regulated in separate agreement(s), including by any applicable Terms and Conditions that apply for the respective product(s).
2. WHAT PERSONAL DATA ELECTROLUX PROCESSES
A. Contact information
This may include your name, display name, address, phone number, email address and login information.
B. Information on purchase of products and/or services
Such as product registration information, warranty information, enrolment status in relation to our services.
C. Satisfaction and feedback data
Such as results of customer satisfaction and feedback surveys.
D. Website visitor and mobile application user data
Such as data collected through cookies or that you have entered in contact forms. This includes IP address that is used to connect your device to the Internet, browser type and version, time zone setting, browser plugin types and versions, operating system and platform. It also includes full Uniform Resource Locators (“URL”) clickstream to, through and from our websites (including date and time), products views or searches, pages that you accessed, page response times, download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs), and methods used to browse away from the page.
E. Appliance identification data
Such as PNC number, serial number, software version, MAC address, model, colour.
F. Appliance usage data
Such as information on how, where and when the appliance is being used.
G. Data generated by the appliance itself
Such as operating data, e.g., opening and closing of internal valves, heating circuit use and efficiency, oven temperature, motor power, activities driven by the appliance's software in order to deliver the cycle/function chosen by you; efficiency data, e.g., water consumption, energy consumption; situational data, e.g., regarding conditions surrounding the product such as ambient temperature, air humidity, water hardness.
H. Correspondence data
Such as date, time and contents of messages.
I. Recorded data (pictures and sound)
Such as photographic image data or video recorded, content which could be taken by sensor or camera of your mobile device, home device or on your appliance, including sound and voice.
J. Log data
Such as time for your entrance and exit.
K. Identification data
This may include national identification number and copies of identification documentation.
L. Audio recordings from consumer service calls
How we collect personal data?
The information that we collect from you when you interact with us online depends on the tasks you complete on the Site, the products or services that you obtain from us and/or your interactions with us. From time to time, you may be able to interact with us anonymously or by pseudonym.You have no obligation to provide any of the personal data requested by us. However, if you choose not to provide us with certain personal data, we may not be able to deal with your request, and/or provide you with the products or services that depend on our ability to collect, use, disclose or process, or which require, your personal data. We also may not be able to respond to your inquiry or instructions without your personal data.
3. WHY WE COLLECT PERSONAL DATA
We collect personal data for a number of reasons (collectively “Processing Purposes”). They are:
- Performance of a contract: When it is necessary for Electrolux, or its third-party processor, to process your personal data to (i) comply with its obligations under a contract with you or (ii) verify your information before embarking on a new contract with you.
- Legitimate interest: When Electrolux, or its third-party processor, has an interest in using your personal data in a certain way, which is necessary and justified considering any possible risks to you and our other customers. For example, using data generated by your appliance to improve the appliance’s services to our customers.
- Consent: When Electrolux asks you to actively indicate your agreement to Electrolux’s use of your personal data for specific purposes(s).
- Compliance with legal obligations: When Electrolux must process your personal data to comply with the legal, regulatory or compliance obligations.
4. WHEN WE COLLECT PERSONAL DATA
A. When you order products and/or services from us
We need to process your personal data to provide you with products and services that you have ordered.
The types of personal data may include types A, C, D, E, F and G set out in section 2 above.
Online purchases: Where you have made an online purchase, e.g., when you place an order for renting an appliance, our payment service provider collects payment information data. We do not process any payment details/personal data in this context other than date and time for completed transaction as communicated by our service provider in conjunction with confirming that you have provided payment.
B. Onboarding and use of our appliances
Certain appliances may be connected to internet, as applicable, and need to be associated with a user account in one of our mobile applications or on one of our websites, or otherwise registered with us. This is needed to enable functionality (including connectivity) in accordance with the specification of the appliance, including for the provision of any applicable services. Processing may include use of voice services, connection of the appliance to your mobile application, to third party devices, apps and services and establishment of your smart home integration. We may also provide you with updates, as applicable.
For this purpose, we need to process your personal data.
The types of personal data may include A, D, E, F, G and I set out in section 2 above.
C. Repair and servicing
When you seek our support, we need to process your personal data for troubleshooting and repairing purposes and to facilitate access to appropriate functionalities.
We may also record calls or otherwise save written messages for training, quality and documentation purposes.
The types of personal data may include A, E, F, G and H set out in section 2 above.
D. Product recalls
In case of product recalls or other issues with our products, we may need to contact you with safety alerts or other product-related information to handle such recalls or issues.
The types of personal data may include A, B, E, F, G, H, I set out in section 2 above.
E. Administrative communication
We may need to provide you with administrative notices such as user guidance/ product safety notices relating to your product, service or account. In order to do so, we need to process your personal data.
The types of personal data may include A, B, E, F, G and H set out in section 2 above.
F. When you provide us your reviews
We are grateful for your feedback about our appliances and services, and when you give that to us, we will process personal data to show interested individuals what feedback our customers have given our products and services and to evaluate it in order to improve our appliances and services.
The types of personal data may include A, C and H set out in section 2 above.
G. Data analytics for product and service development
We always seek to improve our products and services for you. In order to develop, test, enhance and modify our products and services we need to process personal data associated with the use of our products and services.
The types of personal data may include C, D, E, F and G set out in section 2 above.
We will take appropriate measures to process personal data, e.g., by way of pseudonymization. We may anonymize the information we collect (meaning that it can no longer be associated to you and hence no longer constitutes personal data).
We may also combine the personal data you provide to us with other information collected online or offline to the extent permitted by applicable laws, including information provided by third parties, and use or share it for the purposes described in this Data Privacy Statement.
H. Marketing and advertising
We want you to know about our news and offers. In order to send you marketing communications and show online advertising about our products and services, we need to process your personal data.
Marketing correspondence and online advertising may be personalized and provided through different channels, including social media, email, phone, SMS, post.
The types of personal data may include A, B, C and D set out in section 2 above.
If you choose not to receive marketing communications, your personal data may still be used for the other purposes described in this Data Privacy Statement, such as communicating with you for administrative or transaction purposes as part of the contractual relationship we have with you or where required by law.
I. Our websites and apps
To manage and improve our websites and mobile applications, including to ensure that the content is relevant and displayed in a user-friendly way to give you a good user experience, we need to process your personal data.
We also want to provide you with good functionalities to register with us, such as when you use our contact forms to create an account or when you enter into contests/competitions.
Moreover, we strive to keep our websites and mobile applications safe and secure. In order to do so we need to be able to troubleshoot and analyze data (such as traffic data).
The types of personal data may include A, B, C, D, E, F and G set out in section 2 above.
J. Participation in contests
We like to arrange contests/competitions. In order to arrange contests/competitions, including to announce the winners in press releases, on our websites and social media pages, and to deliver prizes, we need to process personal data of the contestants.
Subject to the conditions for each contest/competition, we may use the contact details of the contestants for marketing campaigns, and the entries may be used in our marketing campaigns.
The types of personal data may include A, B, C, D and I set out in section 2 above.
K. Virtual meetings and events
We organize physical and virtual meetings and events. If you participate in a meeting or event that we organize or otherwise support, we may use your personal data, including specific dietary requirements, health information and access assistance, in connection with the running of the event.
The types of personal data may include A, B, H, I, J and K set out in section 2 above, and information relating to your dietary requirements and access assistance.
We will only process personal data relating to health, e.g., dietary requirements data, during the event, so such personal data will be deleted shortly thereafter. Data collected for other purposes, like for marketing purposes will be stored according to principles given in the relevant sections of this statement.
We may also process your personal data as described in the section We need to process data when you visit our premises, as applicable.
L. Manage regulatory, risks and ethics issues
In our business, we need to process personal data to manage risk, compliance and ethics in line with regulatory requirements and our policies. This may, as applicable, involve use of a whistleblowing channel, performance of anti-money laundering checks, sanction screenings, supplier audits and investigations (e.g., in case of a security breach or suspected non-compliance with any of our policies), and in order to comply with company acts, as applicable.
The types of personal data may include […] set out in section 2 above.
M. Comply with bookkeeping rules
To the extent that personal data is needed to comply with bookkeeping rules, we need to process such personal data as required by applicable laws.
The types of personal data may include A, B, D, E, F, H and I set out in section 2 above.
N. Visiting our premises
For security purposes, we need to know who visits our buildings and premises. We also want to make your visit comfortable, including to offer you access to our guest networks.
The types of personal data may include A, B, I and J set out in section 2 above.
O. Changing our organization
In the event of a contemplated or actual reorganization, merger, acquisition, sale, joint venture, assignment or other disposition of all or any portion of our business, assets and stock we may need to share personal data for the purposes of executing the change at hand.
The types of personal data may include all categories set out in section 2 above.
P. Acquiring a business you had a relationship with
Where we have bought all or any portion of assets or stock of a business that you have had a relationship with, we may process your personal data for the purposes set out in this Data Privacy Statement. The actual processing would depend on the nature of your relationship with the business at hand.
The types of personal data may include all categories set out in section 2 above.
Q. Documentation purposes
In addition to retention motivated by the various processing purposes detailed above, we may retain your personal data in order to be able to establish, defend or exercise legal claims during applicable statutory limitation periods.
We may also store personal data as required for product safety purposes, in line with local legal requirements for the various products.
The types of personal data may include all categories set out in section 2 above.
5. WHO DO WE SHARE PERSONAL DATA WITH
Electrolux will disclose your personal data internally within between our group of companies our international third-party service providers and suppliers acting on our behalf, but only in so far as necessary to further provide you with our product or services, or to help with your requests.
We will also disclose your personal data to the following entities, only to the extent that the sharing is necessary:
A. Affiliates
B. Business partners
C. Service providers
D. Other parties when required by law or necessary under applicable procedures
E. Other parties in connection with corporate transactions
6. WHERE DO WE SEND PERSONAL DATA
As a global company, we may store your personal data locally, close to our customers or in other locations where we or our service providers and suppliers are located or have servers.
Your use of our products and services may involve the transfer, storage and processing of your personal data within and outside Thailand in a manner consistent with this Privacy Statement.
Whenever Electrolux transfers personal data to different countries, we will, as far as permissible under applicable laws and regulations, endeavour to:
- make sure the data transfer complies with applicable laws and regulations; and
- ensure that the same level of protection is accorded by the recipient to your personal data.
- contractual clauses to require the recipient to protection your personal data;
- technical solutions such as encryption or pseudonymisation; and/or
- policies and procedures to challenge disproportionate or unlawful requests.
7. HOW LONG DO WE KEEP PERSONAL DATA
Your personal data will be anonymised or deleted from our systems when its uses are no longer required or purposes no longer applicable.
Generally, the following describes how long Electrolux keeps your personal data:
A. As you remain a customer of Electrolux
B. As your products are covered by warranties
C. As you have a contract with Electrolux
D. As required by applicable laws or regulations
E. As long as purpose continue to be applicable
8. HOW WE KEEP PERSONAL DATA SAFE
Electrolux takes reasonable steps to ensure that your personal data is kept confidential and secure.
Reasonable appropriate technical and organizational measures to protect your personal data from unlawful or accidental destruction, accidental loss, unauthorized collection, use, disclosure, access, copying, modification, leakage, damage, alteration or other unlawful forms of processing.
Any information provided to us on the Site is protected using Secure Sockets Layer protocols.
Access to our mainframe computers is protected by firewall security systems where required, relative to the risk of the information stored. In addition, the Site carries an Internet Detection System to monitor potential privacy and security threats.
Any information stored in documents or on Electrolux systems is protected from unauthorized access by the use of a number of security procedures including user passwords.
The transmission of data over the internet is never completely secure, and while we aim to use our best efforts to secure and protect the information, we cannot guarantee the security of any information that is provided or transmitted to us by you. Any such provision of information is at your own risk.
We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any legal or business purposes.
9. YOUR PERSONAL DATA RIGHTS AND HOW TO EXERCISE THEM
You may ask us to provide information about what we collected, and you may ask us to correct any inaccuracies. If permitted by law, we may charge a minimal fee for providing these services. We may also decline requests which are unreasonable, such as repetitive, require disproportionate technical effort, impact or harm the privacy of third parties, impractical or where access is not granted under applicable laws or regulations.
Generally, you may exercise the different rights in the following way:
A. Request access to your personal data
You can request confirmation of whether or not your personal data is being processed and, if it is being processed, request access to your personal data and additional information such as the purpose of the processing. You also have the right to receive a copy of the personal data that is processed. If the request is submitted electronically, the information will also be obtained in a commonly used electronic form unless you request otherwise.
B. Rectification of your personal data
If you notice that personal data about you is inaccurate or incomplete, you have the right to have your personal data rectified.
C. Request the erasure of your personal data
You can have your personal data erased under certain circumstances, e.g., when the personal data is no longer needed to fulfill the purpose for which the personal data was collected.
D. Restrict the processing of your personal data
Under certain circumstances, you may have the right to obtain from us restriction of processing your personal data. In this case, the data at hand will be marked and may only be processed by us for certain purposes.
E. Request your personal data to be provided in a format that can be transferred to you or another organization (portability)
You have the right to request a machine-readable copy of the personal data processed based on your consent or when the processing is necessary to fulfil an agreement with you as well as when personal data has been obtained from you (data portability), and to request that the information be transferred to another data controller (if possible).
F. Object to the processing of your personal data
You can object to processing of your personal data if it is based on a legitimate interest, on grounds relating to your particular situation or if the processing takes place for direct marketing purposes. If we are unable to demonstrate compelling legitimate grounds to continue processing, that override your interests, or if the processing is not necessary to establish, exercise and defend legal claims, we are obliged to cease the processing.
G. Lodge a complaint with the competent supervisory authority
Please contact us with questions or complaints regarding the processing of your personal data at customercarethai@electrolux.com.
You also have the right to lodge a complaint regarding the processing of your personal data with the data protection authority of the country in which you reside or work or where the alleged breach has occurred.
If you have any questions regarding these rights, or if you would like to exercise any of these rights, you may do so in writing, by phone or via email. Please note that exercising these rights may impact our ability to provide you with certain products, functionality or services.
10. SPECIAL CATEGORIES OF PERSONAL DATA
Electrolux does not usually process special categories of personal data. For example:
A. Electrolux does not process personal data pertaining to children
Our products and services are not directed to children, as defined under applicable laws and regulations, and we do not knowingly collect personal data from children. It is our policy to comply with applicable laws and regulations when it requires parent or guardian permission before collecting, using or disclosing personal data of children. We are committed to protecting the privacy needs of children, and we strongly encourage parents and guardians to take an active role in their children’s online activities and interests.
If a parent or guardian becomes aware that his or her child has provided us with his or her personal data without their consent, please contact us. If we become aware that a child has provided us with personal data, we will delete his/her data from our files.
11. COOKIES AND OTHER TECHNOLOGIES
Electrolux may collect personal data through the use of cookies and other technologies when you visit our websites. This may include the following:
A. Cookies
Do you know what cookies are?
Other information, such as browser type, is included in a "cookie".
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device.
Cookies are pieces of information that a website can transfer to an individual’s computer hard drive for record keeping. Cookies make using our Site easier by storing information about your choices on a particular website. This will enable you to take full advantage of the services offered to you.
If you would prefer not to receive cookies you are able to adjust your Internet browser to disable cookies or to warn you when cookies are being used.
Why do we use cookies?
Seamless experience
Track your movements
Flash Cookies
We may use cookies to identify you from other users on the Site. As mentioned above, a cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. You can block or deactivate cookies in your browser settings. We use log-in cookies in order to remember you when you have logged in for a seamless experience. We use session cookies to track your movements from page to page and in order to store your selected inputs so you are not constantly asked for the same information. The Site uses Google Analytics which is one of the most widespread and trusted analytics solutions on the web for helping us to understand how you use the Site and ways that we can improve your experience. These cookies may track things such as how long you spend on the Site and the pages that you visit so we can continue to produce engaging content. By continuing to use the Site, you are agreeing to the use of cookies on the Site as outlined above. However, please note that we have no control over the cookies used by third parties. For further information on types of cookies and how they work visit www.allaboutcookies.org.
We may also use flash cookies. "Flash Cookies" (also called Local Shared Objects or "LSOs") are data files similar to cookies, except that they can store more complex data. Flash Cookies are used to remember settings, preferences, and usage, particularly for video, interactive gaming, and other similar services. We may use web beacons. Web beacons are small graphic images on a web page or in an e-mail that can be used for such things as recording the pages and advertisements clicked on by users, or tracking the performance of e-mail marketing campaigns. We may use analytics tags. If so, we use analytical tags to analyse what our customers like to do and the effectiveness of our features and advertising. They can also help us customize your browsing and shopping experience. We may use information collected through analytical tags or tracked links in combination with your personal data for the Purposes. We may also combine personal data you provide to us with other of your personal data (such as purchase history and demographic information) for the Purposes.
B. Social media advertising
Facebook Custom Audience
For these purposes, we provide Facebook with a customer list that includes your email address and other personal data that you provided to us when you registered your consent. When using the Custom Audience feature, your data is locally hashed on our system before we upload and pass it to Facebook ("Hashed Data"). Facebook is producing a Facebook User IDs out of this Hashed Data which is then matched to your Facebook data to be used by Facebook to create the Audience (see Facebook’s data protection guidelines for more details). We basically use this feature to display interest-based advertisements to you when you visit the social network "Facebook" or other websites also using this tool.
Google Marketing Services
For this purpose, we provide Google with a customer list that includes your email address and other personal data that you provided to us when you registered. This allows Google to create a profile about your usage patterns on our website in order to display advertisements in a more targeted manner in order to present our advertisements of interest to users on other apps and websites within the Google Network.
This information is collected by Google and may be transferred to and stored by Google where it has its servers. This means for instance, that Google Ireland Limited may transfer European Data to Google Inc., Amphitheatre Parkway, Mountain View, CA 94043, USA. As a guarantee pursuant of Chapter V GDPR, Google has signed the EU standard contractual clauses that form part of Google’s Google Ads Data Processing Terms.
Please find more information about the Google Personalized Advertising Service here. For more information about Google’s use of data for marketing purposes, please see the summary page, Google’s privacy policy is available here.
C. Hyperlinks to other websites
12. HOW TO CONTACT US ABOUT YOUR PERSONAL DATA
If you have any concerns about our handling or treatment of your personal data, please contact us by writing to our Data Protection Officer at the address below setting out the nature of your complaint.
We will investigate your feedback and endeavor to provide you with our response within a reasonable time of receiving your feedback.
If you have any queries relating to our Privacy Policy, or if you wish to request for access, correction or deletion of your personal data or to withdraw your consent, please contact or send your request to us at:
13. GENERAL
Your consent that is given pursuant to this Electrolux Privacy Policy is additional to and does not supersede any other consents that you provided to Electrolux with regard to processing of your personal data. For the avoidance of doubt, in the event that applicable laws or regulations permit an organization such as us to collect, use or disclose your personal data without your consent, such permission granted by the applicable laws or regulations shall continue to apply.
We may also occasionally make changes to this Electrolux Privacy Policy. When we make material changes to this Electrolux Privacy Policy, we will provide you with prominent notice as appropriate under the circumstances. For example, we may display a prominent notice within the relevant service, or send you an email or device notification.
Please click here to read and download Electrolux's Data Protection Policy.
Last updated: 16 October 2023
