As at 07/2023

ONLINE PRIVACY POLICY

Hansgrohe and its affiliates (collectively the "Company", "we" or "us") want you to know how we collect, use and disclose information. This Privacy Policy describes how we handle the information we collect in connection with the following:

  • Websites we operate from which you access this Privacy Policy (the "Websites")
  • Software from which you access this Privacy Policy (the "Apps")
  • Our social media pages and apps at [URL] (referred to together as our "Social Media Pages")
  • Emails in HTML format that we send to you with a link to this Privacy Policy or other relevant communications with you
  • Your offline business interactions with us

We refer to the Websites, Apps, Social Media Pages, emails and offline business interactions together as the "Services".

PERSONAL DATA

"Personal data" means data that can be used to identify you as an individual or that relates to you as an identifiable individual. The Services collect personal data, such as:

  • Name
  • Postal address (including billing and shipping address)
  • Telephone number
  • E-mail address
  • IP address (we can also determine your approximate location from your IP address)
  • Payment card details
  • Profile picture
  • ID for Social Media Accounts

Collection of personal data

We and our service providers collect personal data in a variety of ways, including:

  • Via the Services.
    • We collect personal data via the Services, e.g. when you subscribe to a newsletter, create an account to access the Services, visit our shops, attend one of our events, place a telephone order, contact customer service or make a purchase.
  • From other sources.
    • We obtain your personal data from other sources, such as:
      • publicly available databases;
      • joint marketing partners, when they share this data with us.
    • If you link your social media account to your account for the Services, you share certain personal information from your social media account with us, such as your name, email address, photo, list of social media contacts and other information that is accessible or that you make accessible when you link your social media account to your account for the Services.

Collecting personal data is necessary to provide the requested Services to you. If you do not provide the required information, we may not be able to provide the Services. If you disclose personal information about other persons to us or our service providers in connection with the Services, you represent and warrant that you are authorised to do so and allow us to use the information in accordance with this Privacy Policy.

Using your personal data

We and our service providers may use personal data for the following purposes:

  • To ensure the Services function and to fulfil your requests.
    • To provide you with the Services, such as access to your registered account, and related benefits, special offers and customer service.
    • To answer your questions and fulfil your requests when you contact us via one of our online contact forms or by other means, e.g. when you send us questions, suggestions, praise or complaints or when you request a quote or other information about our Services.
    • To process your transactions, handle returns and exchanges, verify your information and provide related benefits, promotions and customer service.
    • To send administrative information, such as changes to our terms and policies.
    • To allow messages to be sent to others via the Services, if you wish to do so.

    We do this to manage our contractual relationship with you and/or to comply with a legal obligation.

  • To provide our newsletter and/or other marketing materials and to make it possible to share content on social media.
    • To send marketing emails with information about our services, new products and other news from our Company.
    • To enable the share function you want to use.

    We do this with your consent or where we have a legitimate interest.

  • To analyse personal data for business reporting and to provide personalised services.
    • To analyse and predict the preferences of our users in order to produce aggregated trend reports on use of our digital content so that we can improve our Services.
    • To understand your interests and preferences better so that we can personalise our interactions with you and provide you with information and/or offers tailored to your interests.
    • To understand your preferences better so that we can deliver content via our Services that we think is relevant and of interest to you.

    We provide personalised Services on the basis of our legitimate interest and, to the extent required by applicable law, with your consent.

  • To make it possible to take part in prize draws, competitions and other promotions.
    • We may give you the opportunity to enter prize draws, competitions or other promotions.
    • Some of these promotions are subject to additional rules. Those rules provide information about how we use and disclose your personal information. Please read the additional rules before you decide to take part.

    We use this information to manage our contractual relationship with you.

  • To aggregate and/or anonymise personal data.
    • We may aggregate and/or anonymise personal data so that it is no longer personal data. We do this to generate more data that we can use and disclose for any purpose, as it no longer can be used to identify you or anyone else.
  • To achieve our business goals.
    • For data analysis, e.g. to make our services more efficient.
    • For audits to verify that our internal processes are working as intended and to meet statutory, regulatory and contractual requirements.
    • To prevent fraud and for security monitoring against fraud, e.g. to detect and prevent cyber attacks or attempted identity theft.
    • To develop new products and services.
    • To optimise, improve, repair, modify or maintain our current products and services and to implement safety and quality assurance measures.
    • To identify usage trends, e.g. to understand which parts of our services are of most interest to users.
    • To determine the effectiveness of our advertising campaigns so that we can tailor our campaigns to the needs and interests of our users.
    • To conduct and expand our business activities, e.g. to understand which parts of our services are of most interest to users so that we can focus on meeting our users' interests.

    We do this to manage our contractual relationship with you, to comply with a legal obligation and/or on the basis of our legitimate interest.

Disclosure of personal data

We share personal data as follows:

  • We share personal data with our affiliates for the purposes described in this Privacy Policy.
  • You can find a list of our affiliated companies and their locations here. Hansgrohe SE is the data controller for management of the personal data that is shared. We share personal data with external service providers to make possible the services that are provided for us.
    • These may be service providers for services such as website hosting, data analysis, payment processing, order processing, return authorisation, fraud prevention, provision of IT and related infrastructure, customer service or related benefits (including special promotions), emailing, audits and other services.
  • We share personal data with external dealers. For example:
    • You can use the showroom locator to send a contact request to the dealer you have selected via our Services. We do not check the information you submit, but pass on your enquiry directly to the dealer, who will then receive the information you have submitted, including your personal data.
  • We share personal data with third parties who sponsor prize draws, competitions and other promotions.
  • When using the Services, you may choose to disclose personal data as follows.
    • On message boards, in chats, on profile pages, blogs and other websites that allow you to publish information and content (in particular our pages on social media). Please note that any information you post or disclose in this way becomes public and may be available to other users and the general public.
    • By sharing on social networks. When you link your account for the Services to your social media account, you are sharing information with friends linked to your social media account, with other users and with your social media account provider. By doing so, you are allowing us to share information in this way and you understand that use of such shared information is subject to the privacy policy of the social media provider.

Other use and disclosure

Your personal data is also used and disclosed by us where it is necessary or appropriate to do so, in particular where we have a legal obligation to do so or a legitimate interest in doing so:

  • To comply with applicable law and regulations.
    • This may include laws other than those of your country of residence.
  • To cooperate with public and government authorities.
    • To respond to a request or to provide information as we consider necessary or appropriate.
    • This may include authorities outside your country of residence.
  • To cooperate with law enforcement agencies.
    • For example, when responding to law enforcement requests and orders or providing information we consider important.
  • For other legal reasons.
    • To enforce our conditions.
    • To protect our rights, privacy, safety and property and/or those of our affiliates, you or third parties.
  • In connection with a sale or business transaction.
    • We have a legitimate interest in disclosing to or sharing your personal data with third parties in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition (including in connection with insolvency or similar proceedings) affecting our business, assets or stock or any part thereof.

OTHER DATA

"Other data" means any data that cannot be used to identify you as an individual and that does not directly relate to you as an identifiable individual. For more information, please see our Cookies or Similar Technologies Policy.

Use and disclosure of other data

We may use and disclose other data for any purpose, except where prohibited by applicable law. If we are required by applicable law to treat other data as personal data, we may use and disclose it for the same purposes as set out in this Policy for personal data. In some cases, we combine other data with personal data. In such a case, we treat the combined data as personal data for as long as it is combined.

SECURITY

We strive to implement appropriate organisational, technical and administrative measures to protect personal data at our Company. Unfortunately, no one can guarantee that a data transfer or storage system is 100% secure. If you have reason to believe that your interaction with us is no longer secure, please inform us immediately using the details under "Contact" below.

CHOICES AND ACCESS

Your choices regarding use and disclosure of your personal data

We offer you choices regarding the use and disclosure of your personal data for marketing purposes. You can deselect the following:

  1. Receiving marketing emails from us. If you no longer wish to receive marketing emails from us in the future, you can unsubscribe right from the email.
  2. Sharing of your personal data by us with affiliated companies for their direct marketing purposes. If you would like us to stop sharing your personal data with our affiliates for their direct marketing purposes in the future, you can let us know by emailing us at privacy@hansgrohe.com.
  3. Sharing of your personal data by us with unaffiliated third parties for their direct marketing purposes. If you would like us to stop sharing your personal data with unaffiliated third parties for their direct marketing purposes in the future, you can let us know by emailing privacy@hansgrohe.com.

We will endeavour to comply with your request(s) as soon as possible. Please note that, if you opt out of receiving marketing emails from us, we may still continue to send you important administrative communications that you cannot opt out of.

Accessing, changing or deleting (erasing) your personal data

If you want to request that personal data is corrected, updated, removed, restricted or deleted (erased) or want to request access to personal information; or if you want to object to or end the processing of personal data; or if you want to request a copy of your personal data for transfer to another company (to the extent you are entitled to such rights under applicable law), you may contact us using the details under "Contact" below. We will process your request in accordance with applicable law. If you are a California resident, please see the "Additional Information for California" section for more information about the requests you may make under the California Consumer Privacy Act (CCPA). Please state clearly in your request which personal data you would like to have changed or whether you would like your personal data to be deleted (erased) from our database. For your protection, we can only comply with requests for personal data linked to the email address you use to send us the request and we may need to verify your identity before processing the request. We will endeavour to comply with your request as soon as possible. Please note that we may need to retain certain information for our records and/or to complete transactions that you initiated before requesting the change or deletion (e.g. if you make a purchase or take part in a promotion, you may not be able to change or delete the personal information that you have provided until after the purchase or promotion is complete). You can also lodge a complaint with the EU/EEA data protection authority for your country or region of habitual residence or employment, or where an alleged breach of applicable data protection law is taking place. A list of data protection authorities is available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

RETENTION PERIOD

We retain personal data for as long as necessary or allowed with regard to the purpose(s) for which it was collected and in accordance with applicable law.

Criteria for determining retention periods:

  • The period during which there is an ongoing business relationship with you and we are providing the Services to you (for example, for as long as you have an account with us or use the Services).
  • Whether we are under a legal obligation (e.g. we are required under certain regulations to retain records of your transactions for a certain period of time before we can delete them).
  • Whether retention is required with regard to our legal situation (such as in relation to applicable statutes of limitations, procedures or regulatory investigations)

THIRD-PARTY SERVICES

This Privacy Policy does not cover, and we are not responsible for, any privacy, information or other actions of third parties, including operators of websites and services that are linked to in the Services. A link in the Services does not mean that we or our affiliates endorse the linked website or service. We are also not responsible for the data collection, use, disclosure or security policies and practices of other companies such as Facebook, Apple, Google, Microsoft, RIM and other app developers, app providers, social media platform providers, operating system providers, mobile carriers and device manufacturers, including with regard to personal data you disclose to other companies via or in connection with the Apps or our social media pages.

THIRD-PARTY ADVERTISING

We work with third-party advertising companies to place advertisements for goods and services that may be of interest to you when you access or use the Services and other websites and online services.

  • You may see advertisements based on information about your access to and use of the Services and other websites and online services on one of your devices, as well as information received from third parties. These companies set or recognise a unique cookie on your browser (including using pixel tags). They may also use these technologies, combined with the data they collect about your browsing behaviour, to recognise you on your various devices, such as your mobile phone and laptop. If you would like to know more about this process and how to turn it off on computer and mobile browsers on the device you are using to access this Privacy Policy, please go to: http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You can download the AppChoices mobile app to control interest-based advertising at: www.aboutads.info/appchoices.

USE OF SERVICES BY MINORS

The Services are not targeted at anyone under the age of sixteen (16) and we do not knowingly collect personal data from anyone under the age of 16.

Your right to request the removal of content

If you are a California resident, under the age of 18, and a registered user of the Services, you may request that we remove any content or information you have posted on the Services by emailing us at privacy@hansgrohe-usa.com, pursuant to California Business and Professions Code Section 22581. Please note that your request does not ensure complete or comprehensive removal of content or information, because e.g. parts of your content may have been re-posted by another user.

JURISDICTION AND CROSS-BORDER DATA TRANSFER

Your personal data may be stored and processed in any country where we are located or where we employ service providers. By using the Services, you understand that your data may be transferred to countries other than your country of residence, including the United States, with data protection laws that may differ from those of your country. Under certain circumstances, courts, law enforcement, regulatory and security authorities in these other countries may be entitled to access your personal data.

ADDITIONAL INFORMATION ABOUT THE EEA: For some non-EEA countries, the level of data protection has been found by the European Commission to be adequate according to EEA standards (a full list of these countries is available here). For transfers from the EEA to countries not considered to have an appropriate level of protection by the European Commission, we have taken appropriate measures, such as standard contractual clauses adopted by the European Commission and binding Group rules to protect your personal data. For an explanation of these measures, contact us using the details under "Contact" below.

SENSITIVE DATA

We ask that you do not provide us unsolicited with sensitive personal information (e.g. national insurance numbers, information about racial and ethnic background, political opinions, religion or other beliefs, health, biometric or genetic characteristics, criminal background or trade union membership) on or via the Services or in any other way.

EXTERNAL PAYMENT SERVICES

The Services may provide you with the option to make payments to the Company via external payment services with which you have created your own account. If you make a payment to us via such a service, your personal information is collected by those third parties and not by us and is subject to the privacy policy of those third parties and not this Privacy Policy. We have no control over and no responsibility for the collection, use and disclosure of your personal information by such third parties.

UPDATES TO THIS PRIVACY POLICY

The "Current as at" date at the top of this Privacy Policy indicates when it was last updated. Changes shall come into effect on publication of the revised Privacy Policy in the Services.

CONTACT

Hansgrohe Limited, with registered office at Unit 2, Edgehill Drive, Tournament Fields, Warwick, CV34 6XQ, United Kingdom, is responsible for the collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you have any questions about this Privacy Policy, please contact us at

privacy@hansgrohe.co.uk

or

Unit 2, Edgehill Drive
Tournament Fields
Warwick
CV34 6XQ

You can also contact our Group data protection officer at: privacy@hansgrohe.com.

As email traffic is not always secure, please do not include credit card details or other sensitive information in your emails to us.

ADDITIONAL INFORMATION FOR CALIFORNIA

In accordance with the California Consumer Privacy Act 2018 (CCPA), we provide the following additional information about the categories of personal information we collect, use and disclose for California residents here.

 

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