WHO WE ARE
De’Longhi Group considers the protection of personal data of third parties, in its possession, as very important and is committed to protect the privacy of said third parties included, but not limited to, its customers, website visitors, and other individuals who interact with us (hereinafter "you", "yourself" or "your").
This Privacy Notice relates to the collection of personal data using online methods (including the De'Longhi Group websites) and offline as specified below. It also provides information about your rights with respect to your personal data, and how you can reach us to update it or get answers to questions you may have about our privacy practices.
In accordance with article 13 of EU Regulation 679/2016 (also known as the General Data Protection Regulation or "GDPR"), De’Longhi America, Inc. (hereinafter "De'Longhi America Inc.", the "Company", "we" or "us"), is the data controller of the personal data collected on this website or application. The Company is also the data controller for the personal data which may be collected when you interact with us, for example when you contact us (via email, phone, web chat or other communication method) or participate in a competition.
DATA THAT MAY BE COLLECTED
The information we collect varies depending on which De’Longhi product or service you use. We have collected the following categories of personal data in the past twelve (12) months:
- Identifiers: This includes contact details, like your name, phone number or e-mail address, as well as your User ID, password hints and similar security information required for authentication and access to our platforms. We collect the information you provide when you interact with us in-person, online, or by phone or mail with our helpdesks, online store and customer support channels, our responses to customer surveys or contests or any additional information you may provide us to facilitate the delivery of our products and services or to respond to your inquiries.
- Personal information, as defined in the California customer records law: This includes information such as your name, contact information, employment and payment information.
- Characteristics of protected classifications in certain jurisdictions (e.g. under California or federal law): This includes demographic information, which may include sex (such as gender and gender identity), date of birth / age, race and/or ethnicity.
- Commercial information: This includes transaction information, purchase history, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies, such as example products you find interesting.
- Internet or other network activity information: This includes information such as Internet speed, error rates, app download and usage, firmware and software versions, registration and configuration settings, Wifi settings, Internet speed, voltage information, storage information, services and feature usage, crash diagnostics, and other performance information. Our Cookies Policy available here provides more details on what information is automatically collected.
- Audio, electronic, visual and similar information: This includes images and audio, video or call recordings, which may be created in connection with our business activities, for example when you contact us for customer support purposes via phone or web chat.
- Professional or employment-related information: This includes information such as your business contact details in order to provide services at a business level. We may also collect your contact details and information about your professional situation and qualifications, including your curriculum vitae and references when you apply for a job with us.
If you connect to this website or application using an account with a social networking platform ("Social Log-In"), then your account information related to such platform, as well as other data you may have given to the platform used to login to this website or application, may be disclosed to us according to your privacy preferences on such platform.
HOW WE COLLECT YOUR PERSONAL DATA
De’Longhi collects and processes your personal data in the following circumstances:
- if you register on our website / download our application to use its functionalities;
- if you connect on our website or application through the Social Log-In;
- if you contact us to request pre-sales or after-sales assistance;
- if you respond to our marketing activities, for example when you complete a reply card or submit your data online on one of our websites;
- if you fill out registration forms with us that are collected in various ways (during demonstrations, cooking classes, promotions or events);
- if other De’Longhi Group companies as well as our business partners provide data about you in a manner that is permitted.
If you provide personal data on behalf of someone else, you must first ensure they have read this Privacy Notice.
Kindly help us to keep your personal data up-to-date by informing us of any changes to your information. Any change in address should be promptly communicated to De’Longhi in order to avoid any problems in the use of our services.
FOR WHAT PURPOSES CAN YOUR PERSONAL DATA BE USED
The processing of personal data must be justified by one of the legal basis established by existing data protection laws and regulations, as described below.
a) Establishment and execution of contractual obligation and resulting obligations, including communications regarding services (for example to perform after-sales services).
De’Longhi may process your Contact data in order to establish and execute a contractual relationship, to provide services requested or to respond to reports or complaints.
De’Longhi may also use your contact details, particularly your email address, to provide you with information concerning a product or service.
Legal bases for the processing: performance of a contract.
The provision of data is obligatory to enable us to manage the contractual relationship; in the absence of the data, we will be unable to put the contract into effect.
b) Operational management and strictly-related purposes, for access to the website, particularly secure areas, also through the Social Log-In system - to simplify registration operations using the information already given to your social network platform.
De'Longhi may process the contact details to enable you to complete the registration procedure on our website or application and allow you to access your Personal Area in order to: (i) download from your Personal Area documents relating to the services you have purchased; (ii) process the other requests made through the website.
As an alternative method of registration to this website or application, you may instead choose to use the Social Log-In mechanism to connect on our website or application using your account with a social networking platform. If you decide to connect with us this way, you will not have to enter the data necessary for registration (such as contact details), since these will instead be communicated by the social networking platform used to carry out the Social Log-In. In this case, De'Longhi will process your account information related to such social networking platform, and may process other data which you may have provided the social networking platform and which could be visible to us depending on your privacy preferences on such platform. We invite you, therefore, to read the privacy statement of your social networking platform to find out more about their data practices and about available privacy settings.
Legal bases for the processing: performance of a contract.
To allow you to register on the site, or otherwise to use the Social Log-In mechanism, to complete the registration.
With reference to the registration, the Company has implemented a Single Sign-On system under which the registration made on a Company website will be valid for all websites managed by the Company under the "De'Longhi", "Braun" and "Kenwood" brands, including our websites www.delonghi.com, www.braunhousehold.com, www.kenwoodworld.com. With a Single Sign-On, it is not necessary for website users to provide again their contact details if they are already registered with us on one of the above-mentioned websites.
However, in order to safeguard the choices made by the user, any consent provided for marketing communications and activities provided to one of our brands (for example, on the website www.kenwoodworld.com/it) will be used only for advertising material related to that specific brand.
c) Customer Satisfaction and other surveys.
De’Longhi may use your contact details to carry out surveys aimed at measuring customer satisfaction in relation to the service provided.
Legal bases for the processing: legitimate interest of the Company to verify and improve the quality of their services.
d) Marketing to fulfill your needs or to inform you of promotions, also based on your preferences (we have also included profiled marketing).
De’Longhi may process your contact details for marketing and advertising purposes, to inform you of promotional sales initiatives via automated means of contact (email, SMS and other mass communication tools, etc.) and traditional contact methods (e.g. by telephone), such as for market research and statistical surveys, if you give us your consent and within the limits of the consent declaration.
De’Longhi may also processes your contact details, interests and other personal data, in order to send you advertising communication, based on a specific customer profile designed on your personal preferences and interests, if you give us a specific consent and within the limits of the consent.
Legal bases for the processing: consent, a failure to give consent in no way affects the contractual relationship.
Your consent may be revoked at any time by visiting My Account > My Marketing Preferences.
e) Communication to other De’Longhi Group companies for marketing purposes too.
De’Longhi may communicate your contact details to other De’Longhi Group companies (which includes the "De'Longhi", "Braun" and "Kenwood" brands) for activities strictly connected to the activities mentioned in points a), b) and c) above.
Legal bases for the processing: reference is made to the assumptions of the mentioned points.
De’Longhi may communicate your contact details to other De’Longhi Group companies for marketing and advertising purposes, to inform you of promotional sales initiatives via automated means of contact (email, SMS and other mass communication tools, etc.) and traditional contact methods (e.g. by telephone), such as for market research and statistical surveys, if you give us your consent and within the limits of the consent declaration.
Legal bases for the processing: consent, a failure to give consent in no way affects the contractual relationship.
Your consent may be revoked at any time by visiting My Account > My Marketing Preferences.
f) Compliance with legally-binding requests by the legal authorities to discharge obligations of law, regulations or provisions.
De’Longhi collects your personal data to comply with its legal obligations.
Legal bases for the processing: legal obligations with which the Company must comply.
g) To maintain, improve and develop our website, products and services.
We use the information to ensure our website, products and services are working as intended and to make improvements to our website, products and services. We will also use the information we collect in existing services to help us develop new ones or to customize Services for you.
h) For internal data analyses.
We use Personal Information for internal analytics to understand how our applications and services are used.
HOW WE KEEP YOUR PERSONAL DATA SAFE
The Company maintains various administrative, technical and physical safeguards to protect the personal data it holds against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal data that we hold. In addition, the Company requires that its suppliers protect such information from unauthorized access, use, and disclosure.
The security measures we have adopted include:
- severe restrictions on access to your personal data, based on necessity and solely for the purposes communicated;
- perimeter security systems to prevent unauthorized external access;
- permanent monitoring of access to IT systems to identify and stop the misuse of personal data;
- tracking of access to your personal data by our personnel and verification of the related purpose;
- using encrypted means via Secure Socket Layer (SSL) technology for transactions on our website that require the entering of personal data.
The safety and security of your information also depends on you. Where we have provided you with (or you have chosen) a password to allow you to access our website, application or services, you are responsible for keeping this information secret and for complying with any other security procedure we may inform you of. Please do not share your password with anyone. We also encourage you to use caution when using the Internet as it is not 100% secure. Accordingly, we cannot guarantee the security of your personal data transmitted electronically and we cannot promise that your use of our websites, applications and services will be completely safe.
HOW LONG DO WE STORE YOUR INFORMATION FOR
We will keep your personal data only for the length of time necessary to achieve the purposes for which they were collected or for any other related and lawful purpose. Therefore, if your personal data is processed for two different purposes, we will keep the data until the lengthier purpose is achieved. However, we will cease to process the personal data collected for the purpose whose retention period has expired.
We limit access to your personal data to only those individuals who need to use them for the appropriate purposes.
When your personal data are no longer required, or when there is no longer any legal pre-condition for keeping them, they will be irreversibly anonymized (and in such a way may be stored) or securely destroyed.
The retention periods relating to the different purposes described above are as follows:
a) Compliance with contractual obligations: data processed to comply with any contractual obligation are kept for the duration of the contract and in any case, no longer than the subsequent 10 years in order to verify any outstanding issues including accounting documents (e.g. invoices).
b) Operational management and purposes strictly related for the access to the website or application: data processed for these purposes are kept for the duration of the contract and in any case no longer than the subsequent 10 years.
c) Customer satisfaction surveys: data processed for these purposes are kept for 5 years from the date of collection of the personal data (except where you decline to receive further communications).
d) For marketing purposes, including profiled marketing: data processed for marketing purposes are kept for 5 years from the date on which you provided your consent for this purpose (except where you decline to receive further communications); for profiled marketing purposes, data will be kept for 12 months.
e) In the event of disputes: should it be necessary for us to defend ourselves or to take action or bring claims against you or any third parties, we may keep the personal data we deem reasonably necessary for such purposes, for the length of time it takes to pursue the claim.
WHO DO WE SHARE YOUR PERSONAL DATA WITH
Your personal data may be accessed by our duly authorized employees and officers, as well as by external suppliers, appointed, if necessary, as data processors, who support us in providing services.
For the purposes of the performance of their activities and to follow up on the above-mentioned purposes, other De’Longhi Group companies may also access your personal data.
De'Longhi has not disclosed or sold any personal data to third parties for a business or commercial purpose in the preceding 12 months. De'Longhi will also not sell personal data belonging to website visitors, users and other consumers.
HOW WE SHARE YOUR PERSONAL DATA
De'Longhi only shares information when we have legitimate business reasons for doing so. We have shared and may share personal data collected for our business purposes in the following ways, or as otherwise disclosed to you at the time of data collection:
a. Within the De’Longhi Group. We may share the personal data we collect with our headquarters and affiliates.
b. With service providers. We may share personal data with our service providers who support our business and perform services on our behalf based on our instructions and in compliance with appropriate confidentiality and security measures. Examples of such services include the processing of orders and credit card transactions, detecting and preventing fraud, providing customer support, creating marketing content, and assisting us with sales-related efforts or post-sales support.
c. With any successor to all or part of our business. We may sell, transfer or otherwise share some or all of its assets, including personal data, in connection with a merger, acquisition, reorganization, sale of assets, spin-off of assets into a separate business, or similar transaction, or in the event of an insolvency or bankruptcy. Should such an event occur, we will use reasonable efforts to direct the transferee to use personal data you have provided to us in a manner that is consistent with this Privacy Notice.
d. As required by law or regulation. We will share personal data with companies, organizations or individuals outside of De'Longhi if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary in order to:
- meet any applicable law, regulation, legal process or enforceable governmental request,
- enforce any applicable terms of use or service, including investigation of potential violations,
- detect, prevent, or otherwise address fraud, security or technical issues, or
- protect against harm to the rights, property or safety of De'Longhi and its employees, our users or the public as required or permitted by law or regulation.
e. If we otherwise notify you and you consent to the sharing.
INTERNATIONAL DATA TRANSFERS
Our website, application and services are provided from and hosted in the United States. If you are using the website, application or services from outside the United States, your information may be transferred to, stored, and processed by De'Longhi in our facilities and by those third parties with whom we may share your personal information, in the United States, the European Union and other locations where we have offices. These countries may have data protection laws that are different to the laws of your country. Regardless of where your data is located, we:(a) treat all personal data in accordance with applicable law; and (b) take reasonable steps to ensure the security of personal data.
If you are located in the European Economic Area, ("EEA"), we comply with applicable legal requirements providing adequate safeguards for the transfer of personal data to countries other than the country where you are located. In particular, we use contractual protections for the transfer of Personal Information to third parties, such as the European Commission’s Standard Contractual Clauses.
By using our website, application and services or by providing us any personal data, where applicable law permits, you agree to the transfers, processing, and storage of your personal data outside of your country of residence.
CHILDREN’S PRIVACY
Our websites, applications and services are designed for adults. We do not knowingly allow individuals under the age of 16 to set up an account with us. If you are under 16, do not use the websites, applications or services. If we learn that we have collected or received personal information from an individual under the age of 16 without parental consent, we will delete that information. If you believe that we may have collected personal data from someone under the age of 16, please let us know by contacting us at the address at the end of this Privacy Notice and we will take appropriate measures to investigate and address the issue as soon as practicable.
NOTICE TO CALIFORNIA RESIDENTS
De’Longhi does not sell personal information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018), nor does De’Longhi share personal information with third parties for their direct marketing purposes (pursuant to California Civil Code Sec. 1798.83).
Financial Incentives: From time to time, we may offer financial incentives, such as coupons, discounts, vouchers or other price reductions, for our products and services in exchange for your enrollment in our emails, newsletter, contests or similar communications. The amount or nature of the coupon, discount, voucher or other price reduction will be specified in each instance before you submit to us your personal data. In order to receive these financial incentives, you will be asked to provide us certain personal data, such as your email address in order to receive a discount coupon or your contact details to participate in a competition. You can opt into the financial incentive by submitting your personal data. You can simply opt out of the financial incentive by not submitting your personal data. You can also opt out of the financial incentive at any time. To do so, please use the contact information provided below to submit a request, or by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
YOUR PERSONAL DATA PROTECTION RIGHTS AND YOUR RIGHT TO FILE COMPLAINTS BEFORE THE SUPERVISORY AUTHORITIES
Depending on your country or state of residence, you have certain rights regarding the personal data we hold about you and certain choices about what personal data we collect from you, how we use it, and how we communicate with you.
These rights include the possibility for you to request:
- access to your personal data, meaning that you have the right to request that we disclose what personal data we have collected, used and disclosed about you,
- a copy of the personal data you have provided to us, and to request the Company to transmit your personal data to another controller,
- the adjustment of data in our possession,
- the deletion of any data for which the legal precondition for processing no longer exists,
- to opt-out of marketing communications we send you at any time,
- to deny processing for direct marketing purposes,
- to revoke your consent, in cases where the processing is based on consent,
- to limit the way in which we process your personal data.
You will not receive any discriminatory treatment when you exercise one of your privacy rights.
You can exercise any of the above rights by contacting us using the contact details provided in the "Contact Us" heading below. You also have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.
The exercising of the above rights is subject to certain exceptions provided by law that are intended to safeguard the public interest (e.g. the prevention or identification of crimes) and our interests (e.g. maintaining professional secrecy). Should you wish to exercise any of the above rights, we will check that you are entitled to do so and will usually respond within one month.
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your personal data, we will verify your identity by using a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your personal data.
UPDATES TO THIS PRIVACY NOTICE
We may update this Privacy Notice from time to time. If we modify our Privacy Notice, we will post the revised version here, with an updated revision date. We recommend that you visit this page periodically to be aware of and to review any such revisions. If we make material changes to our Privacy Notice, we may also notify you by other means prior to the changes taking effect, such as by posting a notice on our websites or by sending you a notification.
CONTACT US
We endeavor to respond to any complaints or reports concerning the methods used to process your Data.
The contact details for De’Longhi, in its capacity as Data Controller, is available below, together with the Data Protection Officer (DPO) address.
Should you have any questions regarding our processing of your personal data, you may contact us by email @ braunmarketing.us@delonghigroup.com, asking for the Data Protection Officer (DPO) or Privacy Manager.
Please use the contact details below, if you would like to:
- Exercise your rights,
- Learn more about your rights or our privacy practices, or
- Designate an authorized agent to make a request on your behalf.
You can contact us using the following contact details:
Data Protection Officer
Braun Household c/o DeLonghi America
2 Park Way, Suite 3A
Upper Saddle River, NJ 07458
Email: braunmarketing.us@delonghigroup.com
Last update on 1/1/2020