1. GENERAL
Glen Dimplex Flame Europe part of Glen Dimplex Benelux BV together with all group companies ("we" "us" "our" "our") are committed to protecting and respecting your privacy. Under data protection legislation, we are the data controller and will process your personal data in accordance with the Australian Privacy Principles in the Privacy Act 1988 and associated state and territory laws relating to the processing of personal data.
Please read the following carefully to understand our views and practices regarding your personal data and how we will deal with them.
2. VISITORS TO OUR WEBSITE
2.1 We may collect and process personal data about you in the following circumstances:
2.1.1 when you complete forms on our website ("Site"). This includes email, name, address and telephone number which is provided when you register to use our Site, when you ask us to contact you about our goods or services, subscribes to our mailing list, or subscribes/requests or goods or services;
2.1.2 when you provide us with information when you report a problem with our site, make a complaint, ask a question or contact us for any other reason. If you contact us, we may keep a record of that correspondence;
2.1.3 data about your visits to our Site, including, but not limited to, traffic data, location data, weblogs and other communications data, whether they are needed for our own billing purposes or otherwise, and the sources you can access (see section 2.2.2 on cookies below); and
2.1.4 when you provide your details to us, or we otherwise collect information from you, through our Site.
2.2 We may also collect data in the following ways:
IP address
2.2.1 We may collect information about your device, including, if available, your Internet Protocol address, for reasons of fraud protection. We may also collect information about your device's operating system and browser type, for system administration. administration. These are statistical data about our users' browsing actions and patterns and do not identify individuals.
Cookies
2.2.2 Our Site uses cookies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site. For detailed information about the cookies we use and the purposes for which we use them can be found in our Cookie Policy.
2.3 We may use your personal data for our legitimate interests to:
2.3.1 to provide you with information, or services that you have requested from us;
2.3.2 enabling you to participate in interactive features of our Sites, when you choose to do so;
2.3.3 ensuring that the content of our Site is presented in the most effective way for you and for your device;
2.3.4 improve our site and services;
2.3.5 process and handle complaints or queries from you; and
2.3.6 to contact you for marketing purposes if you have opted in (see section 6 for more information).
Links to the website
Our Site may from time to time contain links to and from third-party websites. Please note that if you follow a link to any of these websites, these websites have different terms for the collection and privacy of your personal data and we accept no responsibility or liability for this policy. When you leave our Site, we encourage you to read the privacy of each website you visit.
3. CUSTOMERS
3.1 We collect data such as email, name, address and phone number when you order goods or services from us via our Site. We use this data to process your order and fulfil our contractual obligations.
3.2 In order to carry out our contact with you, we may also need to share personal data with third parties, such as payment providers and postal organisations to help deliver goods or services you have ordered;
3.3 We may also advertise your feedback on our website and in our marketing materials (with your prior consent, where necessary);
3.4 We will retain your data for as long as we need it to provide you with the goods or services you have ordered from us and for a period of five years. If you have signed up to receive marketing correspondence from us, we will retain your personal data during the period described in point 6 below.
4. SUPPLIERS
We collect data such as contacts, emails, names, address and phone number to contact you about goods or services ordered from you, to place further orders and to pay you for the goods and/or services provided. We will retain personal data for 5 years after delivery of the goods/services.
5. IF YOU FAIL TO PROVIDE PERSONAL DATA
If we have to collect personal data by law or under the terms of a contract we have with you and you fail to provide the data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at that time.
6. MARKETING
6.1 In addition to the uses described in paragraphs 2-4 above, when you indicate that you wish to receive marketing correspondence from us, subscribe to our mailing lists or newsletters, enter one of our competitions or provide us with your details on networking events, we may use your personal data for our legitimate interests to provide you with information about our Goods, services, business updates and events that we think might be of interest.
6.2 You always have the right to unsubscribe from receiving the information described in section 6.1. To unsubscribe from receiving of such information you can:
6.2.1 tick the relevant box on the form on which we collect your data;
6.2.2 clicking the unsubscribe button in such received communication; or
6.2.3 Email us at GDPR@glendimplex.eu or call +31 (0)513-656500 and give us your name and contact details.
6.3 If you have signed up to receive marketing correspondence from us, we will retain your personal data for 5 years from the time you have given us your consent.
6.4 In order to carry out our contact with you, we may need to share personal data with third parties, such as suppliers for our mailing system, website agencies, marketing agencies, payment providers and postal service organisations to assist in the Supply of products and/or services in connection with our marketing activities.
7. CONTROL AND REGISTRATION
We may monitor and record communications with you (such as phone calls and emails) for quality assurance purposes and training.
8. AUTOMATED PROCESSING
We do not carry out automated decision-making with your personal data.
9. LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
9.1 We use your personal data only where permitted by law. In general, we use your personal data in the following circumstances:
9.1.1 for the performance of a contract we enter into with you;
9.1.2 if necessary to comply with a legal or regulatory obligation to which we are subject;
9.1.3 if necessary to protect your vital interests in relation to a product you have purchased from us; and
9.1.4 for our legitimate interests (as described in this policy) and your interests and fundamental rights do not outweigh these interests.
10. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
10.1 In addition to the third parties listed above, we may provide your data to third parties for our following legitimate interests as follows:
10.1.1 to staff members to facilitate the delivery of goods or services to you;
10.1.2 to our affiliated entities to support internal administration;
10.1.3 IT software providers who host our website and store data on our behalf;
10.1.4 professional advisers including consultants, lawyers, bankers and insurers who provide us with advice, banking services banking, legal, insurance and accounting services;
10.1.5 Tax authorities, regulators and other authorities requiring reporting of processing activities in certain circumstances; and
10.1.6 third parties we may choose to sell, transfer or merge parts of our business or assets. We may also seek to take over other companies or merge with them. If there is a change in our business then the new owners can take your use personal data in the same way as set out in this privacy policy.
10.2 We may disclose personal data to the police, regulatory authorities, legal advisers or similar third parties where we are required by law to disclose or share personal data. have a duty to disclose or share personal data to comply with a legal obligation, or to enforce or apply our website terms and conditions and other agreements; or to protect our rights, property or the safety of our customers or others. This includes sharing information with other companies and organisations for the purpose of fraud protection and credit risk reduction.
10.3 We will not sell or distribute personal data to other organisations without your consent.
11. CROSS-BORDER DATA TRANSFER
Your Personal information may be transferred to and processed in other countries. We may use servers located in the European Union (EU) to store Personal information where it is protected by laws equivalent to those in Canada and USA.
We may transfer Personal information to other members of the Glen Dimplex Group in the EU. We have put in place appropriate safeguards to protect your personal information in the event of these transfers.
If you would like to see a copy of any relevant safeguards used by us to protect the transfer of your personal information, please contact GDPR@glendimplex.eu.
12. DATA SECURITY
12.1 If we have given you (or you have chosen) a password that allows you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
12.2 Unfortunately, the transmission of information over the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk.
12.3 Information you provide to us is shared on our secure servers. We have appropriate physical, technical and organisational measures taken to secure your information against accidental loss and unauthorised access, use, modification or disclosure. In addition, we restrict access to personal data to those employees, agents, contractors and other third parties who are have a legitimate business need for such access.
13. GAINING ACCESS TO PERSONAL INFORMATION WE HOLD
You can request access to your personal information, subject to some limited exceptions as permitted or required by law. Such requests should be made in writing to the contact details set out in section 16. We may charge reasonable costs for providing you access to your personal information.
14. KEEPING PERSONAL INFORMATION UP TO DATE
If you believe that any personal information we have collected about you is inaccurate, not up-to-date, incomplete, irrelevant, or misleading, you may request that it is corrected. To do so, please contact us via the details set out in section 16.
15. CHANGES TO OUR PRIVACY POLICY
We reserve the right to update this privacy policy at any time and any changes we make to our privacy policy will be published on this page. We will notify you if there are any changes to this policy that materially affect how we collect, store or process your personal data. If we wish to use your previously collected personal data for purposes other than those we informed you about at the time of collection, then notify you and, if required by law, seek your consent before we use your personal data for a new or unrelated purpose. We may process your personal data without your knowledge or consent when required by applicable laws or regulations.
16. CONTACT
We have appointed a Data Protection Lead to oversee compliance with this privacy policy. If you have any questions, comments or requests regarding this policy or how we use your personal data please contact us via email at GDPR@glendimplex.eu.
You can lodge a complaint with the Office of the Australian Information Commissioner (https://www.oaic.gov.au/) if you consider that our processing of your personal information infringes applicable law.
Last update: Sep. 2023
3. How we use your Personal Information
We use Personal information for the following business purposes:
- to provide aftersales services including repairs to any of our products that you have purchased from us or one of our retail partners
- to offer spare parts and accessories for you to purchase for your product
- to manage our business, conduct market research and manage our relationships with business partners to meet the legitimate needs of our business
- to send marketing information about our products and services if we have received your specific consent
- To arrange and provide delivery services for your purchases
There is no obligation to provide us with personal information, but we cannot provide our products and services without it.
Anyone whose personal information we hold has the right to object to us using it.
They can do this at any time by telling us and we will consider the request and either stop using their personal information or explain why we are not able to. Further details can be found below.
4. Lawful processing of personal information
Under data protection law we must always have a “lawful basis” for processing your personal information. The Personal information purposes table below sets out the purposes for which we process the different categories of your Personal information and the corresponding lawful basis for that processing. For some processing activities, we consider that more than one lawful basis may be relevant, depending on the circumstances.
Responding to your enquiries
- To perform a contract
- For our legitimate interests (It is important that we can respond to your enquiries)
To arrange a service call
- To perform a contract
Taking payment from you in respect of our services
- To perform a contract
Arranging delivery of products and spare parts
- To perform a contract
Sending you direct marketing communications
- Your consent
- For our legitimate interests (We would like to send you information on other products and services we think you would be interested in, where the law allows)
Analysing how our electronic marketing communications are used by you (including whether you open them and click through to access their contents)
- For our legitimate interests (We need this information to ensure we are providing you with information that you are interested in)
Conducting surveys for benchmarking, continuous improvement and marketing purposes
- Your consent
- For our legitimate interests (We need to collect your feedback in relation to our services, in order to resolve any problems or complaints and improve and innovate)
For our general record-keeping
- To perform a contract
- To comply with a legal obligation
Managing our business relationship with you
- To perform a contract
- For our legitimate interests (We need to be able to try and maintain our position of being your trusted advisor and resolve any complaint or dispute you might raise with us)
Performing identity, financial and credit searches
To comply with a legal obligation
Monitoring our systems and processes to identify, record and prevent fraudulent, criminal and/or illegal activity
- To comply with a legal obligation
- For our legitimate interests (We need to be able to monitor our systems in this way to help protect them, us and you from illegal activity)
Complying with instructions, orders and requests from law enforcement agencies
- For our legitimate interests (We must be able to establish and defend our legal rights and understand our obligations, and seek legal advice in connection with them)
Obtaining legal advice, establishing, defending and enforcing our legal rights and obligations
For our legitimate interests (We must be able to establish and defend our legal rights and understand our obligations, and seek legal advice in connection with them)
Complying with our general regulatory and statutory obligations
- To comply with a legal obligation
Managing the proposed sale, restructuring, transfer or merging of any or all part(s) of our business
- To comply with a legal obligation
- For our legitimate interests (We have a legitimate interest in being able to sell any part of our business)
Monitoring and producing statistical information regarding the use of our platforms
- For our legitimate interests (We need to perform this routine monitoring to make sure our platforms work properly, analyse how they are used and improve them) (We have a legitimate interest in being able to sell any part of our business)
5. Sharing your personal information
Intra group data sharing
Sometimes we share your Personal information with other companies within The Glen Dimplex Group for the purposes set out in this Privacy Notice.
For more information about us, our companies, our brands and presence in your jurisdiction, please visit www.glendimplex.com .
Third-party service providers
We also ask trusted third-party service providers to carry out certain business functions for us. In order to do this, we may need to share your personal information.
These include:
- IT support, cloud platform and data hosting providers who help us with the operation of our websites, mobile applications, data rooms, document and workflow management systems and other systems and applications;
- marketing service providers, including companies who send out surveys and marketing communications on our behalf
- product review providers who help collate customer feedback for us;
- Logistics partners who provide home delivery services
- Service partners who provide after sales product repairs
We have agreements in place with these business partners which will restrict how they are able to process your personal information and ensure appropriate levels of security are applied by them.
Acquisitions
If another company acquires (part of) our company, business, or our assets, that company may acquire all or part of the Personal information collected by us and will assume the rights and obligations regarding your Personal information as described in this Privacy Notice. In the unlikely event of an insolvency, bankruptcy or receivership, your Personal information may also be transferred as a business asset, subject of applicable law.
Disclosure
We may disclose your Personal information if we believe in good faith that such disclosure is necessary for our legitimate interest or prudent considering our obligations under applicable law:
- regulatory bodies and law enforcement agencies, where necessary for any investigations or to respond to enquiries in relation to our compliance with applicable law.
- professional advisors (such as third-party law firms) and other third parties in connection with our legitimate business activities.
These organisations may use your personal information as a “controller” – they will have their own privacy notices which you should read, and they have their own responsibilities to comply with applicable data protection laws.
To obtain a full list of all third parties your personal information is shared with please contact data.privacy@glendimplex.com
6. Cross border transfers of your personal information
Your Personal information may be transferred to and processed in other countries. We may use servers located in the European Union (EU) to store Personal information where it is protected by laws equivalent to those in Canada and USA.
We may transfer Personal information to other members of the Glen Dimplex Group in the EU. We have put in place appropriate safeguards to protect your personal information in the event of these transfers.
If you would like to see a copy of any relevant safeguards used by us to protect the transfer of your personal information, please contact data.privacy@glendimplex.com .
7. How we keep your personal information secure
We will put in place appropriate security measures to protect your personal information from unlawful or unauthorised processing and accidental loss, destruction or damage.
When collecting or transferring sensitive personal information we use a variety of additional security technologies and procedures to help protect your information.
The personal information you provide us with is stored on computer systems located in controlled facilities which can only be accessed by a limited number of persons who have a need to know in order to carry out their tasks and any services requested by you.
When we process highly confidential information (such as credit card numbers) over the Internet, we protect it using encryption.
However, it should be noted that we cannot guarantee the security of personal information you submit to us online. Transmission of data over the internet is at your own risk.
8. How long we keep your personal data
We will only retain your personal information for a limited period, and for no longer than is necessary for the purposes for which we are processing it for as set out in this Privacy Notice or otherwise to comply with legal or regulatory requirements applicable to us.
You can request a copy of our personal information retention schedule by contacting data.privacy@glendimplex.com .
9. Your rights
USA residents
Depending on the jurisdiction in which you are located, you may have the right to request that we modify, delete, or stop processing your personal information,
You may also have the right to request that we provide the following information regarding the personal information we hold about you:
- The categories and/or specific pieces of personal information we collected
- The categories of sources from which personal information is collected
- The business or commercial purpose for collecting personal information
- The categories of third parties with whom we shared personal information
California residents
The California Consumer Privacy Act provides Californian consumers with additional safeguards for protecting their personal information.
Personal information includes information that identifies, describes, or could reasonably be linked with a consumer or their household.
You can request:
- access to the PI that we have collected about you
- that we delete PI collected about you
To make any of these requests or for any related query you can contact us using the details set out below.
Canada residents
You have various rights in relation to your personal information.
You have a right to:
- obtain confirmation that we are processing your personal information and request a copy of the data we hold about you
- ask that we update the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete
- ask that we delete personal information that we hold about you, or restrict the way in which we use such personal information
- withdraw consent to our processing of your personal information (to the extent such processing is based on consent)
- to the extent prescribed by applicable law, receive a copy of the personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and to transmit such personal information to another party (to the extent the processing is based on consent or a contract)
- object to our processing of your personal information.
You can exercise these rights by contacting our data privacy team at data.privacy@glendimplex.com.
Complaints
You can lodge a complaint with your relevant supervisory authority if you consider that our processing of your personal information infringes applicable law.
You can lodge a complaint with Canada’s federal Privacy Commissioner here: https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/.
You may also direct your inquiry/complaint to the relevant Information and Privacy Commissioner in your jurisdiction of residence.
10. Children
Our Sites are not directed towards children and we request that children below the age of 16 do not provide Personal information through our Sites.
If you are the parent or legal guardian of a child under 16 who has registered on one of our Sites, or who you believe has otherwise provided Personal information to us, please contact us using the details set out at “how to contact us” below to have the information deleted.
11. How to contact us
We welcome your feedback. If you have any comments, questions or complaints regarding this Privacy Notice or our processing of your personal information, would like to contact our Privacy Officer, or exercise any of the rights set out above, you can contact us in the following ways.
Email: data.privacy@glendimplex.com
You may also write to us at:
Address: Privacy Officer, Glen Dimplex Americas Ltd, 1367 Industrial Road, Cambridge, Ontario , N3H 4W3
12. Changes to our Privacy Notice
This Privacy Notice was last updated in April 2021. This document is a notice to you and not a contract between us.
Occasionally it may be necessary to make changes to this notice. When that happens, we will provide an updated version at the earliest opportunity. Where changes are material, we will take steps to let you know. The most recent version will always be available on our website