Privacy Notice
Dear user, thank you for choosing our application (hereinafter " App"), which you can consult and use to interact with our connected appliances (hereinafter also " connected appliances"). Depending on its technical characteristics, once connected to the Internet, your appliance is able to transmit information to Candy Hoover Group S.r.l., to provide you with specific services and to send you notifications and communications. To verify the specific functions of your appliance, please consult the appliance's technical data sheet.
Here below you will find all information concerning the processing procedures for your personal data, not only to comply with legal obligations regarding the protection of personal data under Regulation (EU) 2016/679 (hereinafter "Regulation"), and all applicable national legislation (including all procedures by the control authority), but also because we believe that the protection of personal data is a fundamental value of our business and we want to provide you with any information that may help you to protect your privacy and to monitor the use that is made of your data.
Below you will find information on the personal data we collect, the purposes for which we process your personal data, the methods and tools with which we process them, the subjects with whom we may share your data, how long we keep them and what your rights are under the Regulation. We therefore invite you to read the following information; you will find more details in the relevant sections.
1. ABOUT US
The App and the services connected are offered by Candy Hoover Group S.r.l., which will process your data in accordance with current legislation on the protection of personal data. Below you will find our contacts.
1.1 THE DATA CONTROLLER
The Data Controller, i.e. the organisation which makes the decisions regarding the methods and purposes of the processing, is Candy Hoover Group S.r.l. with registered office in Via Comolli, 16 - 20861 Brugherio (MB) and administrative office in Via Privata Eden Fumagalli 20861 Brugherio (MB), Italy, IR code/company register of Monza and Brianza 04666310158 - VAT number 00786860965 (hereinafter " CHG").
You can contact CHG by writing to the above postal address or by e-mail to data.protection@candy-group.com.
1.2 THE DATA PROTECTION OFFICER ("DPO")
The Data Protection Officer (or also the "DPO") is responsible for monitoring compliance with the Regulation in relation to the processing of personal data by CHG.
You can contact the DPO at the following e-mail address data.protection@candy-group.com or by post by writing to:
Candy Hoover Group S.r.l.
Via Privata Eden Fumagalli
20861 Brugherio (MB), Italy
For the attention of Data Protection Officer .
2. DATA AND INFORMATION COLLECTED THROUGH THE APP
When you register with the App, take advantage of the services offered, ask for assistance and support or connect your appliance (for appliances with connectivity), CHG processes some Personal Data concerning you, your appliance and the use you make of it.
Information you provide directly:
When you register, we collect the following personal data that you directly provide: personal and contact information (name, surname, e-mail address, country, password) and, in addition if provided, additional contact information (city, address, mobile phone) and image.
In addition, if you couple your connected appliances, we will ask you to also provide information about the connected appliance (type, brand, specific model, ID number and serial number).
Information acquired indirectly by CHG through registration with the App:
When you register, the App also acquires data about your smartphone and/or tablet used to install the App, and data related to the use of the App itself (such as, for example, errors, crashes), as well as the IP address of origin. Computer processing systems and all software procedures used to operate the App - during normal use - acquire some data whose transmission is implied in the use of communication protocols. This information is not collected to be traced back to a natural person but by its very nature can be traced back to the data subjects. This category of data includes, for example, IP addresses, model of device you use to access, installed OS, URI (Uniform Resource Identifier). In order to allow the correct functioning of the App, information available on the device such as device ID, position and information on your connection to the Wi-Fi network can also be processed.
Information acquired through third parties:
You can decide to register via social networks:
when you do this for example through social networks (for example, Facebook) we automatically collect some data, such as personal data (name, surname) and other data that you import from the relevant social network (country, phone number, city, e-mail address, profile photo if any). This data is imported for the sole purpose of facilitating registration to the App. To find out more about how your data is being processed by the social network used, please refer to the privacy policy of the social network.
Information acquired through the connection and use of the connected appliance:
In the case of appliances equipped with connection technology (e.g. Wi-Fi), when you connect the device to the App and you are connected to the Wi-Fi network, or to other communication technology (such as NFC and/or Bluetooth), CHG receives some data regarding the operation and status of the connected appliance (e.g. on/off, presence of an error). This data is periodically sent to the CHG server.
CHG also collects and uses data about your use of the connected appliance (e.g. frequency of washing, use of the appliance, programme used, etc.), and the services of the App. To do this we use Yahoo's Flurry Analytics system and Google's Crashlytics.
We could also have access to the camera and/or the library of the smarthphone and/or tablet containing images and videos if you use the App for operations that involve its use, for example: scanning the code of the appliance connected during the first connection of the appliance, the display of the appliance during assistance if the display of some elements is useful to identify the problem and its resolution and the selection of the image for the creation of the profile, if you wish to add one. In any case, please note that such access will only take place under your direct supervision and will be limited to what is strictly necessary for that specific operation.
3. WHY ARE YOUR DATA PROCESSED
The use of your personal data is necessary to allow you to use the App safely, to manage your appliance by displaying any details or notices, to provide assistance on the product and possible services related to it. We also want to be sure of the identity of the App user, protecting you from misuse by any unauthorized third parties.
It is important for us to know more about how our appliances are used to improve their performance, so as to offer you and other users services that are increasingly safer and in line with your expectations. To do this, we may also analyse the data in aggregate form and, with your consent, use this information to contact you and suggest products or services of the Candy Group, or our business partners (such as warranty extensions on the products).
4. PURPOSES OF THE PROCESSING AND LEGAL BASIS
In this section we indicate the purposes for which we process your personal data and the conditions on which such processing is based.
A) To allow you to use the App, register your connected appliance and take advantage of the services and functions offered by its use, for assistance and maintenance purposes, to manage your profile, and thus provide the services you requested. For these purposes your consent is not required, as the legal basis is identified in the execution of the contract and any pre-contractual measures.
B) To send you notices by regular mail about products or services of the Candy group, or our business partners (such as warranty extensions) related to our products that we think are of interest to you based on your purchase preferences and on the use of the product. We process your data, based on our legitimate interest, because we want to stay in touch with you to offer you products and services that may interest you. You may object to such processing at any time by contacting us at the addresses above and below.
C) To send you commercial and promotional communications for CHG products and possibly other companies in the Candy group, by automated means such as e-mail, text messages, push or in-app notifications, as well as by operator calls, to carry out market research and surveys to detect the degree of customer satisfaction with regard to the products and assistance received, to invite you to initiatives and events organized by CHG. For this purpose, data processing occurs with your consent, which is therefore the legal basis for the processing. You may revoke your consent in the manner set out below.
We want to be sure to send you only communications that are of interest to you and therefore we will contact you only with offers or communications that are suitable to your profile, according to your habits of use of the connected appliance and services offered through the App, e.g. communications relating to accessories, spare parts when we believe they may need to be replaced due to wear, or other products useful for the better functioning of the connected appliance). We believe that this activity is in the mutual interest. If you do not wish to receive these communications, please contact us at the above addresses.
D) With your consent, to measure your user experience and obtain information about your use of the App through Yahoo's Flurry system and Google's Crashlytics. In this way, we can understand how to improve the performance of the connected appliance and the service offered. For more information, please visit the websites of the respective manufacturers. For this purpose, your consent is required, which is therefore the legal basis for the processing.
5. DO I HAVE TO PROVIDE DATA?
For some operations and purposes of processing, we need your data. In other cases, you are free to choose whether or not to let us have your data.
5.1 NATURE OF DATA PROVISION
The provision of data for the purposes referred to in paragraph 4 letter A) (marked as such in the registration form) is necessary, otherwise it will not be possible to create the user profile, register the connected appliance, take full advantage of all the features of the App and the connected appliance and receive assistance for the same.
The provision of data for the purposes referred to in paragraph 4 letters B), C) and D) is optional, failing which, you can still use the assistance services and features of the App referred to in letter A).
6. HOW WE PROCESS YOUR DATA
We will process your data primarily through recording, extraction, analysis and archiving tools protected with systems that offer security guarantees in line with industry standards. We process and store your data only for the time necessary for us to carry out the above activities described in point 4 and we adopt technical-organizational solutions for the cancellation of data once these activities have been completed.
6.1 PROCESSING AND STORAGE METHODS
We will process your data mainly using computer systems and analysis tools by authorised personnel trained by CHG. We take measures to ensure the application of the principles of fairness, loyalty and transparency provided by the applicable legislation on the protection of personal data (including the Regulation), protecting your privacy through technical and organisational security measures that ensure an adequate level of security.
The data will be kept for the period of time strictly necessary for the purposes for which they were collected and subsequently processed, without prejudice to any specific time limits imposed by any commercial or civil law. For the fulfilment of the obligations relating to the producer's responsibility for the safety of the product, your data will be retained a period not exceeding 10 years.
For the purposes of paragraph 4 letters C) andD), the data will be stored in our databases (e.g. customer relationship management - CRM -) until the revocation of consent (or opposition to profiling activities, if applicable) and, in any case, within the maximum time limits possibly provided for by applicable law. Profiling data will be retained for no longer than 2 years. If you deactivate your profile connected to the connected appliance, the data concerning your personal profile will be deleted from our systems. The data relating to the use of the connected appliance, on the other hand, will be anonymised by eliminating links to your profile and will be used by CHG for its own analysis activities and statistics.
7. WHO ARE YOUR DATA SHARED WITH
In order to guarantee the functioning of the App and the services connected to it, CHG uses third parties called upon to carry out specific services on behalf of CHG. On the basis of specific contractual obligations imposed by CHG, access by these subjects to the data is limited to the processing operations strictly necessary to allow you to use the App and the services provided by CHG. These persons act as data processors and may be called upon to respond directly in civil and administrative matters if they process the data in a way that does not comply with the instructions received.
7.1 SCOPE OF COMMUNICATION AND DISCLOSURE
Without prejudice to communications made in compliance with legal and contractual obligations, your data may be communicated to personnel authorised by CHG, or by third parties operating on behalf of and on the instructions of CHG itself as data processors, including companies that provide assistance and support for the maintenance, operation and after-sales service of the connected appliance, including the company GIAS S.r.l. of the Candy group that offers technical assistance on registered products and may access information relating to any anomalies or malfunctions reported by the products.
CHG also uses suppliers who offer data hosting services for data collected through the App in their data centres, as well as companies who offer technical support and who take care of the development of the App and who can access the data to provide support services in the event of malfunctions or data migration. Additional providers are used to provide the voice interaction service that allows you to communicate via the App with your connected appliance.
In addition, for specific requirements related to the location of the servers of CHG and/or its suppliers, CHG also uses suppliers located in third countries outside the European Union for the provision of services (including telephone support and hosting services); these suppliers operate on behalf and upon instructions of CHG as data processors. In such case, CHG undertakes to ensure an adequate level of protection and safeguard, including the conclusion of standard contractual clauses. If you wish to obtain a copy of the safeguards used, please contact us on one of the addressed provided above. For the data recorded in the CRM, CHG reports that such supplier has adhered to the Privacy Shield.
In case of consent to the processing of data for marketing purposes, your data may also be processed by marketing agencies, or other companies, such as data processor for CHG, for purposes relating to the management and delivery of business information (via e-mail, phone call through operator), market research or other promotional activities, such as competitions and prize-awarding events.
For more information about those data processers who process your data on behalf of CHG, you can write to CHG to the e-mail address data.protection@candy-group.com .
In addition, in the performance of its normal business activities, your data may be disclosed to professionals, consulting firms, competent authorities (in compliance with legal obligations) or other entities that operate as data controllers, such as individual companies associated with and/or controlled by the Candy Group, located in the European Union, which provide assistance services and maintenance of the connected appliance, or e-commerce service.
In the event that CHG is involved in corporate transactions, including extraordinary transactions, if necessary for the purposes of the relevant assessments, the data may be disclosed to the data subjects involved in such transactions (for example, our counterparties) and to the professionals who support CHG or our counterparties in the conduct of such transactions.
CHG may aggregate the data collected through the use of the App (preventing the association with your personal data and your identification) and share such data with its partners or other third parties (e.g. universities) for research purposes (including to improve the products of CHG). This data may also be used after you have deactivated your profile or stopped using the services of the App.
CHG uses platforms for sending newsletters and promotional communications with reports, directly or through its partners or other third parties. Thanks to the reports, CHG will be able to know, in aggregate, for example: whether the e-mails were delivered and not; who opened an e-mail or clicked on a single link, for statistical purposes only, to evaluate the effectiveness of the promotional campaign.
8. WHICH RIGHTS DOES THE LAW RECOGNISE TO YOU AND HOW CAN YOU EXERCISE THEM
The law gives you the right to control how your data is processed, and to limit, if necessary, the use of your data. You can exercise these rights at any time and free of charge by contacting our company and writing to the addresses indicated at the beginning. CHG will do everything necessary to facilitate the exercise of your rights.
8.1 RIGHTS OF THE DATA SUBJECTS
Pursuant to Articles 15 and following of the Regulation you have the right to:
You can exercise your rights at any time by sending an email to data.protection@candy-group.com or by writing to
Candy Hoover Group S.r.l.
Via Privata Eden Fumagalli
20861 Brugherio (MB), Italy
For the attention of Data Protection Officer .
If you believe that your data has not been processed in accordance with the law or there is a dispute about its use, you can complain to the Supervisory Authority of the member state where you reside, work, or where the alleged breach occurred.
You can also uninstall the App at any time. Please note that even if you do not use the App, uninstall the App or deactivate your profile, the connected appliance will continue to record data and send it to the CHG server.
If you do not want CHG to collect data sent periodically to CHG's servers, contact us at the above addresses for further instructions and support regarding the reset of your connected appliance model.
9. FURTHER USEFUL INFORMATION
The App contains links to third-party sites (for example, Amazon, if you decide to use the dash button). We have no control over the processing of your personal data on these sites. Therefore, we invite you to take a look at the privacy notice available on the sites themselves.
10. UPDATES ON THE PRIVACY NOTICE
This privacy notice may be updated over time. Please visit this section periodically to view any changes. In case of significant changes we will in any case notify you on the site or by email, as deemed most appropriate by CHG.
30/04/2019