PRIVACY POLICY

Dear User,
on this page you will find information about the management of your personal data on the website www.smeg.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.

Data Controller and Data Protection Officer
The Data Controller of your personal data, is  the person who takes decisions regarding the methods and purposes of data processing, is Smeg S.p.a., with registered office at Via Leonardo da Vinci 4, 42016 Guastalla (RE),  Italy, VAT number 01555030350 (hereinafter  called “SMEG”). The Data Protection Officer (“DPO”) is responsible for overseeing compliance with the GDPR in relation to the personal data processed by Smeg. You can get in touch with the DPO by sending an e-mail to [email protected] or a letter to Smeg’s office.

Type and source of personal data collected
When you visit or consult the Website, when you fill in our online forms (e.g. to ask for support), or when you decide to receive marketing communications, 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.

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.  

Processing means

Your data will mainly be processed with IT systems and analysis tools by authorized 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 organizational 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.

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].

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.

Further information and links
On our Website, you will also find links to third parties’ websites; please read their privacy policies to find out their means and purposes of data processing. When you access the area of our Website dedicated to product registration and purchasing of the extended warranty for your appliance and fill in the form, your data will be processed by Servizi Domestic & General Italia S.r.l. (“D&G”), which acts as independent data controller. For more information about how D&G processes your data, please see its privacy policy.

Privacy policy updates.
This privacy policy may be updated from time to time. SMEG will provide details of the last update at the end of the privacy policy.

Latest update: 22 November 2018