On this page you will find information about the management of personal data on the website www.smeguk.com (hereinafter called “ the Website”). We provide this information not only to comply with our legal obligations regarding personal data protection pursuant to (EU) General Data Protection Regulation no. 2016/679 (hereinafter called “the GDPR”), but also because personal data protection is one of our company’s fundamental values, and we wish to give you with all the information you may require to help protect your privacy and control how your data is used in relation to your browsing experience on our Website.
This Site is owned by Smeg S.p.A (the "Company", “Smeg”, “we” or “us”) whose local subsidiary (Smeg (UK) Limited) registered office is at The Magna Building, Wyndyke Furlong, Abingdon, Oxfordshire, OX14 1DZ and our company registration number is 2365886, and we are the ‘data controller’ of the personal information you provide us.
We are committed to protecting and respecting your privacy when visiting our website and providing us with your personal information and this privacy policy statement summarises what personal details we may collect from you and what we will do with this data. You can contact us via the postal address above or via email at [email protected] should you have any questions on our policy or the data we hold for you.
What personal data do we collect?
We only collect personal information that you provide us with, if for example you contact us with an enquiry; register on the website; enter a competition or prize draw; request us to provide you with further information; post information to a public area of our sites or take advantage of a promotion.
If you share other people’s data with us, for example if you buy one of our products for another family member, you will need to check that person consents to you providing that information to us.
We may process the following personal data (ie. data relating to identified or identifiable people):
- data provided by you when filling in our online forms, for example to request support or information about Smeg’s products and offers, including identifying data (forenames and surname), contact details (e-mail address, postal address and telephone number), any information provided by you about the products purchased for which you require support, and the type of support you request (including the information contained in the request details field);
- data we collect while you browse the Website (known as “browsing data”), such as your IP address, Uniform Resource Identifier, the time when you submit your request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and environment. The transmission of such information is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its nature could, by means of associations and processing with data held by third parties, allow users to be identified. These data may also be used (among other things) to ascertain liability for computer crimes committed against our Website.
How do we use your personal data and on what legal grounds?
Your data will mainly be processed with IT systems and analysis tools by authorised personnel specifically trained by Smeg. We implement measures designed to ensure the application of the principles of fairness, legality and transparency laid down by the data protection legislation (including the GDPR), and protection of your privacy by means of technical and organisational security measures designed to prevent loss, unlawful and incorrect use of your data, and unauthorized access to it. We may also contact you by digital communication methods (e.g. e-mail, instant messaging services, etc.), by telephone (phone calls or text messages) or by post.
We may also use the information held about you in the following ways:
- To notify you of any changes to our service.
- To ensure that our content is presented in the most effective manner
- To provide you with information, products and services requested from us
- To provide you with helpful information about our products or services which you use, including any software updates for ‘smart’ products.
- To send you details about how to look after your Smeg products.
- To provide product safety notices.
- To allow you to participate in interactive features of our service, should you choose to do so.
- To perform our obligations concerning any contracts entered into between you and us, including under relevant product warranties.
Where you have given your permission for us to use your data for particular purposes, or where we send you communications relating to Smeg products and services, you can at any time change your preferences as to how your data is used by us.
We may also use information about your visits to our Site to enhance your visit to our Site and to create a general demographic profile of visitors. However, once your session ends (approximately 20 minutes after leaving the Site or upon closing all instances of your web browser), the data will only be used in a collated form and we will not be able to identify you personally from such data.
Telephone calls and e-mail correspondence with Smeg at the email addresses accessible through, or obtained from, this Site may be recorded or monitored. By using these communication methods you are consenting to the recording and/or monitoring of your calls and emails.
Purpose of data processing and legal basis for data processing
We need your data to enable you to browse the Website safely, receive product support or product-related services, manage other specific requests and receive operational communications. With your consent, we may contact you to suggest Smeg products and services that you might be interested in.
You will find additional information below. In particular, we may process your data for the following purposes:
- processing your requests for support regarding the use and maintenance of an appliance or answering your questions about our products, services and promotions. If we ask you to fill in a form in order to send your request, please note that fields marked with an asterisk are mandatory, and in the absence of the corresponding data we will be unable to fulfil your requests. We can collect and process these data without your express consent because this information is needed to fulfil your request;
- allowing the registration of your appliance, including requests for extended warranties. If we ask you to fill in a form for this purpose, please note that fields marked with an asterisk are mandatory, and in the absence of the corresponding data we will be unable to fulfil your requests. We can collect and process these data without your express consent because this information is needed to provide the requested service;
- receiving the Smeg newsletter and keeping in touch with us, if you register for this service. In this case, processing of your data is necessary in order to provide the service;
- receiving commercial and promotional communications by automated means such as e-mail and text message, and non-automated telephone calls relating to Smeg products, participating in market research and customer satisfaction surveys relating to the products and support received, and invitations to take part in Smeg’s projects and events. Your consent is required for this purpose and represents the legal basis for processing of your data. Unless you object by contacting us at the addresses specified above, we only wish to send communications likely to interest you, and will therefore only contact you with offers and communications in line with your profile, on the basis of your preferences, the appliances you have registered, and the use of our services. Please note that even if you refuse your consent or do not provide the data needed for these purposes, you can still use our services fully and freely, but will not receive any marketing or promotional communications relating to our products;
- receiving marketing and promotional communications from our business partners relating to their marketing activities, also based on your preferences and the products you have purchased. For this purpose we require your consent, which represents the legal basis for processing your data. Please note that if you refuse your consent or do not provide us with the data needed for these purposes, you can still use our services.
‘Smart’ Products
If you have purchased one of our internet-enabled ‘smart’ products, we may collect and handle personal information directly from such product when connected to the internet. The information we collect might include: information about how the product is used to help us review and improve performance. We may also collect information about your internet connection [and mobile device].
The information we collect may also include location data showing the location of your smart product. We collect this data so we can assess the environment in which the product is situated, to help us maximise performance of your product.
Social Media
You may contact us or comment on our products and services through social media. The information we collect from social media and online sites sometimes includes personal information that has been put online and is publicly available. Please refer to the relevant social media sites for details of their own privacy policies on how they collect and share your personal data.
How do we store and protect your data?
We will endeavour to ensure that the personal information you submit to us is kept private and secure, and held in accordance with relevant laws. We will not sell, rent or otherwise disclose the personal information you provide to us through the Site to third parties (other than as listed below) unless we are required to do so by law.
Data retention
We retain your data for the period strictly necessary to fulfil the purposes for which the data were collected and, for statutory purposes, no longer than 10 years. When you sign up for our newsletter or agree to receive our marketing communications, you can ask to be unsubscribed from those services at any time by writing to the addresses specified below. In this case your data will only be retained in order to provide other services requested by you (e.g. product registration to obtain the warranty, support requests, etc.).
Sharing and disclosing your data
Smeg uses third-party suppliers to guarantee the operation of the Website and provide you with the services offered on it. Access to your data by these third parties is governed by specific contractual agreements which restrict the use of your data to the processing necessary for the operation of the Website and the services provided on it. These third-party suppliers act as data processors (hereinafter called “Data Processors”) and may be held directly liable if they process data in breach of the instructions received.
In addition to disclosures required to comply with our legal obligations, your data may be communicated to Smeg’s authorized personnel who have been suitably informed and trained, or to third parties’ personnel who work on Smeg’s behalf and in accordance with its instructions in the capacity of Data Processors, including companies that provide pre/after-sales service relating to your appliance. In particular, in the event of a request for assistance and support, your data will be accessed, in the capacity of Data Processors, by the companies that provide this service on our behalf, which can access information relating to appliance malfunctions and defects.
If you consent to processing of your data for marketing purposes, your data may also be processed by marketing agencies or other companies, in the capacity of Data Processors, for purposes relating to management and sending of newsletters and business information via email, direct sales, market research or other promotional activities, such as competitions.
Smeg generally stores the data in Italy or the European Union, but some data may be managed by suppliers located outside the European Union. In such cases Smeg has entered into specific agreements requiring the supplier not only to provide the warranties indicated above but also the further warranties specified by the GDPR (e.g. the use of contracts approved by the European Commission pursuant to the GDPR). In addition, for specific reasons associated with the location of SMEG’s servers (or those of its suppliers), SMEG uses the services of suppliers located in non-European countries (such as those providing call centre or hosting services), which act in the capacity of Data Processors. In these cases SMEG undertakes to guarantee appropriate protection and safeguarding of data subjects’ rights, including the use of standard terms of contract. In the course of our ordinary business activities, your data may be disclosed to professionals, consultancy firms or other parties acting in the capacity of independent Data Controllers.
Furthermore, with your consent, your data may be disclosed to other parties acting as independent Data Controllers, including SMEG’s business partners, for their marketing purposes or service provision.
If SMEG should be involved in ordinary or extraordinary corporate transactions, your data may be disclosed to the parties involved in such transactions and to the professionals representing SMEG or the other parties to the aforementioned transactions, if necessary for the purpose of the related evaluations.
For more information about the Data Processors who process your data on behalf of SMEG, you can write to the SMEG offices (for the attention of the DPO) or to the e-mail address [email protected]
Third parties who provide services on our behalf
We share your personal information with certain third parties who provide services on our behalf. They only have access to the personal information they need to perform those services. They are required to keep your personal information secure and confidential and may only use it as permitted by us in accordance with this Privacy Policy.
The third parties who provide services on our behalf fall into the following categories:
- Other Smeg group companies in Europe
- Our logistics service providers who store and transport our products
- Our service repair engineers
- Marketing agencies appointed to provide services to us
- The service providers operating this Site on our behalf
- Social media platforms
How Long Do we Store Your Data?
We will not keep your data for longer than is necessary for the relevant purposes set out in this Privacy Policy. Where you have purchased a product or service from us, we will hold your relevant personal details to enable us to provide after-sale services and to administer the relevant warranty. Different retention periods apply for different types of data, however the longest we will normally hold your data is six years.
Your rights
Under the General Data Protection Regulation (GDPR) and The Data Protection Act 2018 (DPA) you have a number of rights with regard to your personal data.
You have the right to request from us access to and rectification or erasure of your personal data, the right to restrict processing, object to processing as well as in certain circumstances the right to data portability.
If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time which will not affect the lawfulness of the processing before your consent was withdrawn.
You have the right to lodge a complaint to the Information Commissioners’ Office if you believe that we have not complied with the requirements of the GDPR or DPA with regard to your personal data.
Please contact us in writing if you have any queries in relation to your rights.
Sale and transfer
In the event of a sale, transfer, merger, change of control, consolidation, reorganization or liquidation of Smeg, we may sell, transfer or assign to third parties information you have provided to us, including but not limited to personally identifiable information and other information concerning your relationship with us.
Public areas
Any information you post on the public areas of the Site (e.g. chat rooms, bulletin boards) is accessible to and used by others and may result in unsolicited messages or other contact from others. You are advised to use caution when posting personal information about yourself in public areas of this Site.
Cookies
We may use "cookies" to help us recognise you on any return visits you make to our Site and to make any registration or other procedures easier for you. Cookies are small pieces of information, which will be stored by your browser on your computer's hard drive. The cookies used by us will not give us any personal details about you and we do not use any data collected by the cookies to identify any individuals. If you do not wish cookies to be stored on your browser please refer to the relevant help menu looking under cookies, privacy or security but note that in doing this you may be unable to access certain parts of our site. For more information on cookies, please visit http://www.allaboutcookies.org
No data collected from children
Our Site is not directed at children and should not be accessed by them. We will not knowingly collect information from minors without their parent's or guardian's consent.
Third Party Websites
From time to time our Site may contain links to and from the websites of our partner networks and affiliates. If you visit any of these sites, please note that they have their own privacy policies and you should check these before submitting any personal data. We cannot accept any responsibility or liability for these policies.
We welcome any questions, comments and requests regarding this privacy policy and invite you to email them to [email protected]
Contacting Us
Please contact us via the registered office address stated above or by email at [email protected]. If you wish us to remove your personal details from our marketing database at any time, please write to us at the registered office address stated above or by email at [email protected].
Data subject’s rights
According to data protection law, you can control how your data is processed, and restrict its use if applicable. You can exercise these rights at any time, free of charge, by contacting us at the addresses indicated above. SMEG will do everything necessary to facilitate the exercise of your rights. In particular, according to articles 15-21 of the GDPR, you are entitled to:
• receive confirmation of the existence of your personal data, access your data and obtain a copy (right to access);
• update, amend and/or correct your personal data (right to rectification);
• request the erasure or restriction of the processing of your personal data in the cases specified by the GDPR, including where data has been processed unlawfully or if its storage is not necessary in relation to the purposes for which the data were collected or otherwise processed (right to erasure and right to restriction);
• withdraw your consent, where given, at any time, without prejudice to the lawfulness of processing based on the consent given prior to the withdrawal (right to withdraw consent);
• within the limits of the provisions of the GDPR, to receive a copy of the data provided by you in a structured, commonly used format readable by automatic devices, and request the transmission of such data to another data controller if technically feasible (right to data portability);
• object to the processing of your data in the cases specified by the GDPR (right to object).
Requests for erasure of data are subject to the applicable legislative and regulatory document retention obligations.
You may exercise your rights at any time by sending an e-mail to [email protected] or a letter to SMEG’s offices, at the contact addresses listed above.
When contacting us, please include your name, e-mail address, postal address and/or telephone number(s) to ensure that we can process your request correctly.
If you believe that your personal data have not been processed in accordance with the law or wish to complain about their use, you can lodge a complaint with the supervisory authority of the member state where you live or work, or where you believe the alleged unlawful conduct occurred.
Ref: smegprivacypolicy-DOC097V2.0
