PRIVACY POLICY

ON WHAT GROUNDS DO WE USE YOUR DATA

We use your data to allow you to use the Website and the relevant services.

Your personal data is also collected to comply with legal obligations or to protect the legitimate interests of Whirlpool.

Without certain data we may be unable to offer you the services or grant you access to the Website, as the case may be.

For further information click here.

FOR HOW LONG WE RETAIN YOUR DATA

We use your personal data for the period strictly necessary to achieve the intended purposes.

For further information click here.

WHAT DO WE DO TO PROTECT YOUR DATA

The security of your data is a priority for us. For this purpose, we have implemented adequate administrative, technical and physical measures designed to safeguard your personal data against loss, theft and unauthorized use, disclosure of modification.

For further information click here.

WITH WHOM DO WE SHARE YOUR DATA

We may share your data with (1) service providers, (2) our affiliated companies, and (3) public authorities, when allowed by applicable laws.

Upon your consent, we may also share your personal data with our trusted partners for their marketing purposes.

For further information click here.

TRANSFERS OF YOUR DATA OUTSIDE EEA

Your data may be transferred to subjects located outside European Economic Area (EEA). In any case, we always make sure that appropriate and suitable safeguards compliant with the Regulation are implemented.

For further information click here.

YOUR RIGHTS

You have among others the right to access, integrate, update, amend and delete your personal data.

For further information click here.

CONTACT US

You can contact us by sending us an email at data_protection_emea@whirlpool.com. We may modify or update this Privacy Notice also in order to comply with applicable laws.

1. TYPE OF PERSONAL DATA PROCESSED

Whirlpool will process the following categories of data:You can contact us using our contact us form. We may modify or update this Privacy Notice also in order to comply with applicable laws.

1. Data relating to you

Whirlpool processes personal data about you, collected or provided through a number of sources, including but not limited to:

1. personal data provided by you directly at the opening of an account and/or registration of the purchased product and/or when you make a request for information, assistance and purchase of the Whirlpool products on the online shop, such as name, surname, address of residence, email, telephone number;
2. personal data provided by you directly or inferred during the phone calls you made to our consumers’ call centers that may be recorded only with your consent, including dates/times of calls, caller contact information, and customer order information;
3. personal data contained in images, audio and/or video you submit or allow the App or Smart Appliances to capture;
4. personal data provided by other parties’ products or services that you connect through the App or Smart Appliances.

Such data is processed only to the extent that it is necessary to pursue the purposes set out in this Privacy Notice. Whirlpool is required to keep the personal data anonymous and to remove such data where it does not need to process personal data in identifiable form for processing purposes.

2. Browsing data

2. PURPOSES OF THE PROCESSING

Where applicable, we will process your personal data we have collected or been provided with for the following purposes:

1. allowing you to register on the Website by opening a personal account, to register a product on the Website and to purchase a product on the Website;
2. completing the online purchase of the product and providing additional services (after-sale services, the prevention of fraud, the management of returns);
3. performing the home delivery of our products and providing you with any requested services;
4. arranging for a repair on your product;
5. managing the requests for information you send us, including handling complaints and communications received via our interactive chat service;
6. entering a prize promotion / competition;
7. complying with the statutory provisions and regulations and enforcing our own rights before the courts;
8. upon your consent, and without prejudice to Whirlpool’s legitimate interest, sending you customized marketing communications related to our products and services electronically (including email, SMS, MMS, social network notifications, mobile applications);
9. unless you opt-out, contacting you for marketing purposes by phone (non-automated) and via paper mail;
10. for the purpose of sending you customer care communications concerning products registered by you or which you showed interest in and in order to carry out customer satisfaction surveys;
11. upon your consent, sharing your personal data for customized marketing communication with our selected trusted partners as set forth in Section 6 below; and
12. carrying out activities useful for the transfers of business and business branches, takeovers, mergers, demergers or other transformations and for the execution of such transactions.

3. LEGAL BASIS FOR THE PROCESSING

1. The provision of the personal data for the purposes under Section 2, para. a), b), c), d), e) and f) is necessary for the purpose the data was provided or shared with us which includes but is not limited the registration on the Website, the online purchase of products and the use of ancillary specific services, as well as the participation to prize promotions and competitions;
2. The provision of personal data for the purposes under Section 2, para. g) is mandatory since required by the applicable laws;
3. The provision of the personal data for the purposes under Section 2, para. h) and k) is optional. In the absence of your consent, Whirlpool, the companies part of the Whirlpool Group and/or trusted partners will not be able to send you customized marketing communications via automated means. In any event, upon the withdrawal of the Users’ consent we will no longer process the personal data for the purposes of para. h) and k) above. Our expectation is that consent to receive marketing communications and data sharing (where applicable) is given by the data subject whose personal data has been provided;
4. The provision of personal data for the purposes under Section 2, para. i), j) and l) is necessary to pursue the legitimate interests of Whirlpool and the Whirlpool Group, which will be appropriately balanced with your interests.

We may also use, in compliance with the applicable data protection laws, your electronic contact details (email, phone number) we collected in the context of a sale of a product or service, in order to send you customized marketing communications related to similar products or services. In such a case, you may object to such use of your electronic contact details by clicking the “unsubscribe” link at the bottom of the email / SMS at each time the customized marketing communication is sent; or in accordance with Section 9 of this Privacy Notice below.

4. DATA RETENION

Whirlpool will process the personal data for as long as it is necessary to achieve the intended purposes pursuant to Section 2 above. In any case, the following retention periods shall apply:

1. the data collected for the purposes of Section 2, para. a), b) and c), d), e) and f) will be retained for the period strictly necessary in order to respond to data subjects’ requests and comply with applicable laws and regulations;
2. the data collected for the purpose of Section 2, para. g) will be retained for the period mandatorily prescribed by the applicable law provisions (e.g., for tax purposes);
3. the data collected for the purposes of Section 2, para. h) and k) will be retained for the maximum data retention period set forth by the applicable law provisions; and
4. the data collected for the purposes of Section 2, para. i), j) and l) will be retained for the period strictly necessary in order to pursue Whirlpool legitimate interests.

Please consider that data retention periods may vary, depending on the applicable local laws.

5. DATA PROCESSING PROCEDURES

Your personal data is processed with the support of Information Technology and/or paper means and it is protected by appropriate security devices suitable to ensure the secrecy and safety of the personal data. In particular, Whirlpool adopts the appropriate administrative, technical, personal and physical measures designed to safeguard the personal data held against any loss, theft as well as unauthorised use, disclosure or change in the personal data.

6. COMMUNICATION OF DATA

We will share your personal data with our trusted partners, such as our extended warranty providers, that intend to use it for direct marketing purposes only when we have specifically informed you and you have given us specific consent to do this.

We may share your personal data with:

1. companies of the Whirlpool Group located in the EEA and outside the EEA, acting as autonomous controllers;
2. our carefully chosen third party suppliers located in the EEA and outside the EEA, such as call centre operators, shippers, suppliers of services or technicians assigned to assistance and other suppliers working on our behalf in the role of duly appointed data processors for the purposes described in this notice; other third parties as part of a corporate transaction such as a merger or sale of assets.

In the above cases, these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose. Should an extra-EEA transfer occur, we will implement suitable safeguards in accordance with the Regulation. See in particular Section 7 below.

7. E.U.-U.S PRIVACY SHIELD ANS SWISS-U.S. PRIVACY SHIELD

Whirlpool Corporation participates in and has certified its compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks. Whirlpool Corporation is committed to subjecting all personal data received from EU member countries and Switzerland, in reliance on the Privacy Shield Frameworks, to the Frameworks’ applicable Principles. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List.

Whirlpool Corporation is responsible for the processing of personal data it receives, under the Privacy Shield Frameworks, and subsequently transfers to a third party acting as an agent on its behalf. Whirlpool Corporation complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Whirlpool is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

In certain situations, the Whirlpool Group may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern related to the Privacy Shield Framework that you believe we have not addressed satisfactorily, you may contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

8. MINORS UNDER THE AGE OF 18

The Website does not address subjects under the age of 18, nor is Whirlpool knowingly collecting personal data from people under the age of 18.

9. RIGHTS OF DATA SUBJECTS

You, at any time and at no charge, can have and/or exercise the following rights:

1. the right to be informed on the purposes and methods of the processing of your personal data;
2. the right of access to your personal data (commonly known as “data subject access request”). This enables you to receive a copy of the personal data we hold about you;
3. the right to ask for updating or rectification of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
4. the right to request erasure of your personal data. This enables you to ask us to delete or remove your 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 or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
5. the right to restrict the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
6. the right to object to the processing, wholly or partly, of your personal data where we are relying on legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
7. where we are relying on consent to process your personal data, the right to revoke the consent to the processing of your personal data freely and at any time, also by clicking on the unsubscribe option at the bottom of our marketing communications;
8. the right to data portability of your personal data to you or to a different provider. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format;
9. the right to contact us by sending us an email at data_protection_emea@whirlpool.com and
10. the right to lodge a complaint in front of the competent national data protection or judicial authority. and

If you wish to exercise the rights mentioned above, or raise any questions about the personal data we hold about you, please send us an email at data_protection_emea@whirlpool.com or write to us at: Whirlpool UK Appliances Limited, Morley Way, Peterborough, Cambridgeshire, PE2 9JB, for the attention of the Data Protection Office.

10. AMENDMENTS AND UPDATES

We keep this Privacy Notice under regular review. We may update this Privacy Notice to reflect changes to our privacy practices. If we make any material change, we will inform you by updating this Privacy Notice prior to its effective date. We encourage you to periodically review our Privacy Notice for the latest information on our privacy practices. This Privacy Notice was last updated in May 2018.