Privacy Policy
Panasonic Privacy
Notice
Panasonic treats your
privacy and personal information with the utmost respect. We are compliant with
the EU’s General Data Protection Regulation.
This Privacy Notice is
intended to tell you how we use any information we collect about you (called
"personal information", explained below). We've tried to explain what
we do in enough detail to give you the information you need at a glance, with
the option of following a link if you want to find out more. If you still can't
find the information you need, you can email us at uk-aircon@eu.panasonic.com.
The Privacy Notice
applies to devices, products, websites or applications that refer to or link to
the Privacy Notice (collectively, our “Services”) and will apply whether you
access our Services using a computer, mobile phone, tablet, TV, or other device.
1. Who are we?
I. Panasonic Italia, Branch Office of Panasonic Marketing Europe GmbH, Viale dell’Innovazione 3, 20126, Milan, Italy (“Panasonic”, “we”, “us” or “our”);
II. We are part of the Panasonic Corporation, headquartered in Kadoma, Osaka Prefecture, Japan;
III. We have a number
of Affiliates who can be found here
http://www.panasonic.com/global/corporate/profile/group-companies.html#renketsu.
2. What is Personal
Information?
For the purposes of
this Privacy Notice "Personal Information" consists of any
information that relates to you and/or information from which you can be
identified, directly or indirectly. For example, information which identifies
you may consist of your name, address, telephone number, photographs, payment
details, a specific Panasonic product/device identification number, location
data, an online identifier (e.g. cookies identifiers and your IP address) or to
one or more factors specific to your physical, physiological, genetic, mental,
economic, cultural or social identity. When we combine other information (i.e.
information that does not, on its own, identify you) with Personal Information,
we treat the combined information as Personal Information.
3. What Personal
Information does Panasonic collect about you?
A. Personal
Information you provide directly
Some Services we offer
enable you to give us Personal Information directly.
When you create a
Panasonic account or profile
When you create an
account or profile on a Panasonic website or application (such as when you
register a product for warranty extension or sign up to be a Panasonic
Partner), we ask you to provide certain Personal Information, including your
name and email address. Any Panasonic account you create will be
password-protected and we use your name to help verify your account when you
contact our customer support representatives or contact us for other purposes.
When you communicate
with Panasonic
When you contact us
with a sales inquiry or interact with our customer support representatives via
email, telephone or in person, we may collect Personal Information, such as
your name, mailing address, phone number, email address and contact preferences;
and we may also collect information about the Panasonic products or devices you
own, such as their serial numbers and date of purchase. We also may create
logs/reports that are useful in diagnosing product or application performance
related issues, and capture information relating to the issue. We use this
information to provide you with customer and product support. We may access
your relevant Panasonic profile/account, in order to provide you with the
necessary assistance or support you require or have requested. We may also
record and review your conversations with our customer support representatives
(e.g. when you contact us by telephone), for training and complaints handling,
and also to review any information you have provided in response to a voluntary
customer survey(s). We will only record and/or review your conversations with
us where we are permitted to do so by applicable laws and we will always tell
you we are doing so
B. Information about
your use of the Services
We may collect
information about your use of our Services through software on your Panasonic
device/product and other means, or your use of our online applications. For
example, we may collect:
I. Device/product
information - such as your hardware model, device/product IMEI number, the MAC
address of the device’s wireless network interface and the mobile phone number
used by the device), mobile network information, your mobile operating system,
the type of mobile browser you use, time zone setting, and other unique device
identifiers, IP address, operating system details, and settings of the device
you use to access the Services.
II. Log information -
such as the time and duration of your use of the Service, search query terms
you enter through the Services, and any information stored in cookies that we
have set on your product/device or our application.
III. Location
information - such as your product or device’s GPS signal or information about
nearby WiFi access points and cell towers that may be transmitted to us when
you use certain Services. Some of our location-enabled Services require your
Personal Information for the feature to work. If you wish to use the particular
feature, you will be asked to consent to your data being used for this purpose.
You can withdraw your consent at any time by altering the settings in your
device/product.
C. Personal
Information from third party sources
We may receive
Personal Information from third parties (i.e. other companies), for further
details on this please see the following additional information:
Information from
publicly available sources
We may receive
Personal Information about you from publicly available sources, provided the
receipt of such information is in accordance with applicable laws, which we may
combine with other information we receive from or about you.
We also may receive
information about you from social networking sites when you choose to connect
with those sites.
D. Other ways we may
collect your Personal Information
We may collect your
Personal Information in other ways, for further details on this please see the
following additional information:
Message boards and
forums
Some Panasonic
websites and applications have message boards, forums, bulletin boards, chat
functionality, blogs, and similar features ("Community Postings")
through which you can post information, messages and other materials. When you
disclose any Personal Information through such services we urge you to be very
careful as this may become public information and be available to visitors to
our websites and to the general public.
In order to
participate in Community Postings we are required to collect certain Personal
Information as part of the registration process, which includes your name,
username, password, email address, date of birth and contact details (e.g.
email address, telephone number).
Promotions, games,
prize draws and competitions
If you enter into
promotions, contests, online games, prize draws, competitions or similar
promotion ("Activities"), we may use the Personal Information you
provide to administer those Activities. To administer such Activities we may
require you to provide certain Personal Information, which may include, your
name, username, password, email address, date of birth and contact details
(e.g. email address, telephone number).
To the extent that the
terms and conditions of any such promotion regarding the treatment of Personal
Information about you conflict with this Privacy Notice, the terms and
conditions of the promotion will prevail and we advise you to review any
Activity specific terms carefully.
Subscriptions and
newsletters
Where you subscribe to
our promotional communications and newsletters we may collect Personal
Information from you in order to enable us to provide this service to you. The
Personal Information required will include your email address and postcode. We
will only provide such subscription services to you in accordance with
applicable laws and where you have expressly requested us to do so.
When you upload
Personal Information to a Panasonic website or online application
In addition to the
above, we may collect such other Personal Information that you provide by
uploading content (e.g. certification or photos) onto our websites or online
applications. In such cases, the following Personal Information may be
collected in order to publish the content on the our websites or online
applications: your name, email address and any Personal Information in the
content that you choose to upload. Where we collect such content we will only
do so in accordance with applicable laws.
Website and campaign
response activity
If you have opted-in
to our tracking cookies, our Marketing automation systems will track your
website and campaign response activities (such as trade shows attended or
Newsletters clicked). We do this in order to understand our customers better
and customise marketing communications for relevancy.
Panasonic Business
Partner Portal
To become a Panasonic
Partner, we will need to collect basic information on the company, the employee
registering the company (name, email, phone) and what Panasonic Products the
company is interested to promote.
Panasonic Training
The Panasonic Training
tool is a learning platform used to train Panasonic business partners
face-to-face or via e-learning. It will keep record of the training results for
all the partner employees who participate. Personal information recorded will
include name, email and training results.
4. How do we use
your information?
We may use the
Personal Information we collect for the following purposes:
I. Registering
products/devices - to register you or your device or product for any of our
Services;
II. Provide our
Services - to provide our Services or any specific feature that you request,
including to enable us to fulfil our obligations under any contract with you
(such as, any product or device warranty);
III. Surveys – to ask
for your opinions or comments on our Services and to conduct other surveys;
IV. Customised and
Targeting Content - to provide customised content and make recommendations
based on your past activities on our Services. We may use Personal Information
to more effectively target our Services, content, recommendations,
advertisements and communications (more information on this can be found in our
Cookie Policy);
V. Advertising - for
advertising, such as providing customised advertisements and sponsored content
and sending you promotional communications;
VI. Analysis Purposes
- for assessment and analysis of our market, customers, products, devices and
other Services (including asking you for your opinions on our products and
services and carrying out customer surveys);
VII. Statistics – to
create anonymous, aggregated statistics about the use of our Services. This
anonymised data may be shared with third parties;
VIII. Service
Improvement – to develop and improve new and existing Panasonic products and
Services, recommendations, advertisements and other communications and learn
more about your preferences;
IX. Customer Support
Services - to provide customer support services for your device or product, or
to deal with any other support queries you may have (such as complaint
handling);
X. Crime Prevention -
for the prevention or detection of fraud or crime;
XI. Business Purposes
- for business monitoring and internal record keeping;
XII. Publish your
comments – where you upload product or device reviews, comments or content to
our websites or applications, or where you have responded to a voluntary
survey, we may link to, publish or publicise your comments including in our own
advertisements;
XIII. Legal
Obligations - to comply with our legal obligations;
XIV. Competitions and
Promotions - to conduct prize draws, competitions and other promotions or
offers, as permitted by law;
XV. Training – for
staff training and quality assurance purposes, particularly in relation to our
customer support representatives; and
XVI. Updates - to
communicate with you, including communicating with you about your account,
profiles or transactions with us, giving you important information about your
products, devices, application or other Services, sending you notices about any
material changes to our Privacy Notice, and, where permitted by you and
applicable laws, marketing, sending you offers and promotions for our Services.
The law allows us to
use the Personal Information as set out above on the basis that we are acting
in our "legitimate interests".
Product recall – in
the highly unlikely circumstance that Panasonic needs to recall any product,
including for safety purposes, your information is used to contact you with
instructions on how to return your product.
Marketing
communications
Panasonic may use your
Personal Information to provide you with newsletters and other communications
by post, email, telephone and/or text message (SMS), only if you have provided
your consent or we are otherwise permitted to do so under applicable law. For
further information on this, see the 'Your Choices' section of this Privacy
Notice.
Combining Personal
Information
We may combined the
Personal Information that we collect from you (including information received
from other Panasonic Affiliates) to the extent permitted by applicable law. For
example, we may combine various different databases that contain your Personal
Information to allow us to provide better support services and more
personalised content (such as, marketing and advertisements).
5. To whom do we
disclose your information?
We will not disclose
your Personal Information to third parties for their own independent marketing
or business purposes. However, we may disclose your information to the
following entities:
I. Panasonic
Affiliates
We may need to
transfer your Personal Information to other Panasonic Affiliates to provide the
Services you require or any other services/assistance you request. All
Panasonic Affiliates are required to follow the privacy practices set forth in
this Privacy Notice, or such other privacy policy that they may notify to you.
II. Service Providers
We use third party
service providers to help us to administer certain activities and services on
our behalf, such as call centre providers used by Panasonic to service our
customers, data supply, data cleaning, fulfilling your purchases and delivering
products, processing credit card payments, sending postal mail and emails,
sending text messages (SMS), providing advertisements, analysing usage of our
Services, tracking effectiveness of our marketing campaigns, allowing users to
connect to their social network, providing fraud checking services and customer
support services. We may share Personal Information about you with such third
party service providers solely for the purpose of enabling them to perform
services on our behalf and they will operate only in accordance with our
instructions. Here are examples of third-party service providers we use:
a. Email Service
Providers – Cloud services from Marketo and Oracle Marketing Cloud are used to
assist us in sending emails to you in accordance with your marketing
preferences;
b. Analytics Service
Providers – analytics providers are used to assist us in understanding the
usage of our products/devices and other Services, to enable us to improve our
Services. The analytics providers we currently use are Google Analytics,
Marketo and Oracle Marketing Cloud For further information see our Cookie
Policy.
III. Social Network
Providers
We may provide your
Personal Information, such as your email address, to certain social networking
providers so that they can help us display advertisements about our Services on
your social network pages. We will only share your Personal Information with
social networking providers in accordance with your marketing preferences and
any applicable laws.
IV. Third parties when
required by Law or to Protect our Services
We will disclose your
Personal Information to comply with applicable law or respond to valid legal
process, including from law enforcement or other government agencies; to
protect our customers (e.g. to prevent spam or attempts to defraud users of our
Services); to operate and maintain the security of our Services (e.g. to
prevent or stop an attack on our systems or networks); or to protect the rights
or property of Panasonic, including enforcing any terms or agreements governing
the use of our Services.
V. Anonymous
statistics
We prepare and develop
anonymous, aggregate or generic data and statistics for various reasons (as
indicated in this Privacy Notice). As this data is anonymous (i.e. you cannot
be identified from it) we do not consider this information to be Personal Information.
As such, we may share it with any third party (such as our Affiliates,
partners, advertisers or otherwise).
VI. Other Parties in
Connection With Corporate Transactions
We may disclose your
Personal Information to a third party (or other Panasonic Affiliate) as part of
a reorganisation, merger, transfer, sale, joint venture, assignment or other
disposition of all or any portion of Panasonic's business, assets or stock, including,
without limitation, in connection with any bankruptcy or similar proceeding.
VII. Third party
competition providers
We may disclose your
Personal Information to third party sponsors of sweepstakes, contests, free
prize draws, competitions and similar promotions. These third party providers
will be identified to you prior to when you enter into any competition, sweepstake,
prize draw or similar promotion.
VIII. Other Parties
With Your Consent or At Your Direction
We may share Personal Information
about you with third parties when you consent to or request such sharing.
A number of
Panasonic's Services give you the option and ability to upload and share
certain Personal Information, such as, messages, photos, videos and other
content. Any Personal Information that you choose to upload and share on a
publicly accessible profile may be viewed and accessed by others. As such, you
should always exercise caution when using such Panasonic Services.
6. What do we do to
keep your information secure?
Panasonic have put in
place rigorous physical and technical measures to safeguard the Personal
Information we collect in connection with our Services. However, please note
that although we take rigorous steps to protect your Personal Information, no
website, product, device, online application or transmission of data, computer
system or wireless connection is completely secure and therefore we cannot
guarantee the security of your Personal Information.
Location of Personal
Data
The Personal
Information that we collect from you may be stored and processed in your
region, or transferred to, stored at or otherwise processed inside or outside
the European Economic Area ("EEA"). The Personal data that we collect
from you may be stored in countries who have been deemed to have adequate data
protection laws by the European Commission including, but not limited to, the
UK and Japan. In addition, the Personal Information that we collect from you
may be stored and processed in a country which does not offer an adequate level
of data protection as recognised by the European Commission and additionally
where Panasonic or its Affiliates, subsidiaries or service providers maintain
facilities.
Where we transfer your Personal Information outside your region, we will ensure that suitable safeguards such as appropriate agreements and mechanisms are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Information.
You may request
additional information in this respect and obtain a copy of the relevant
safeguards upon request through sending a request to the contact indicated in
the Contact Us/Further Information section of this Privacy Notice, below.
Encryption
All Personal
Information you provide to us is captured, transmitted and stored using
encryption. Data is stored in highly secure data centres.
Other security
measures
Information security,
including the protection of Personal Information is organized in a global
Panasonic Program called “Information Security Management” (ISM). The aim,
standards and implementation measures are organized in a globally valid Policy,
standards and guidelines. All central European IT systems are externally
assessed and fall under the regulation of ISO 27001 certification. The program
and all its parts follow a strong yearly PDCA approach to secure the
confidentiality, integrity and availability of all data for the whole
information lifecycle from collection to destruction of such information.
Using social media and
forum features
Certain Services
include social networking, chat room or forum features. You should ensure that
when using these features that you do not submit any personal Information that
you do not want to be seen, collected or used by other users.
7. Accessing your
Personal Information and other rights you have
Panasonic will
collect, store and process your Personal Information in accordance with your
rights under any applicable data protection laws.
Your rights under
applicable data protection laws include, the right to access a copy of your
Personal Information, the right to request the deletion or updating of any
inaccurate Personal Information and the right to object, in some cases, to our
processing of your Personal Information. Right to Withdraw Consent – where you
have consented to our processing of your Personal Information, you have the
right to withdraw such consent at any time. In the event you wish to withdraw
your consent to processing, please contact us using the details given at the
end of this Privacy Notice.
Enforcing your rights
If you wish to enforce
any of your rights under applicable data protection laws, then please contact
us using the details given at the end of this Privacy Notice. We will respond
to your request without undue delay and by no later than one month from receipt
of any such request, unless a longer period is permitted by applicable data
protection laws, and we may charge a reasonable fee for dealing with your
request which we will notify to you. Please note that we will only charge a fee
where we are permitted to do so by applicable data protection laws.
Complaints
If you are concerned
that we have not complied with your legal rights under applicable data
protection laws, you may contact the Information Commissioner's Office
(www.ico.gov.uk) which is the data protection regulator in the UK which is
where Panasonic UK a branch of Panasonic Marketing Europe GmbH is located.
Alternatively, if you are based outside the UK, you may contact your local data
protection supervisory authority.
8. Data Retention –
How long we will store/keep your Personal Information
We will retain your
Personal Information for the period necessary to fulfil the purposes for which
your Personal Information has been collected.
In particular, we
classify Personal Information into the following specific categories with
different retention periods:
• Competition entrants
- 1 year.
• Marketing opt-ins -
Will remain as an opt-in until you unsubscribe at which point your information
will be retained on a suppression list in order to ensure that we comply with
your request.
• Contact us sales
forms or inbound telephone sales inquiries - 1 year.
• Warranty
registrations and customer service calls - 5 years. We may need to contact you
in case of product recalls (health and safety).
• Customers and
partners - 6 years from the last time we engage with you (email, meeting,
telephone call).
Please note: If your
Personal Information belongs to more than one category, the longest retention
period will prevail.When your Personal Information is no longer required for
the purpose it was collected or as required by applicable law, it will be deleted
and/or returned to you in accordance with applicable law.
9. Third-Party
Links and Products on Our Services
Our websites,
applications and products may contain links to other third party websites that
are not operated by Panasonic, and our websites or your product and devices may
contain applications that you can download from third parties. These linked
sites and applications are not under Panasonic's control and as such, we are
not responsible for the privacy practices or the content of any linked websites
and online applications. If you choose to use any third party websites or
applications, any Personal Information collected by the third party’s website
or application will be controlled by the privacy policy of that third party. We
strongly recommend that you take the time to review the privacy policies of any
third parties to which you provide Personal Information.
10. Cookies
What are cookies?
Panasonic, as well as
certain other third parties that provide content, advertising, or other
functionality on our Services, may use cookies and other technologies in
certain areas of our Services. Cookies are small text files that can be read by
a web server in the domain that put the cookie on your hard drive. We may use
cookies to store your preferences and settings, help you with signing in,
provide targeted ads, and analyse site operations.
Further information on
cookies
For further
information on what cookies are, how Panasonic and other third parties use
them, and for details of how cookies can be disabled, please see our Cookie
Policy.
11. Your Choices
(e.g. marketing related emails or otherwise)
We and other Panasonic
Affiliates may use your Personal Information (such as your contact details
(e.g. name, address, email address, telephone number)) to send you
marketing-related correspondence by post, email, telephone and/or text message
(SMS) related to Panasonic products, devices and other Services in accordance
with your email and contact preferences in your PRO Club Account.
When you purchase
Panasonic products or device, contact our customer support representatives,
create an account or profile for one of our Services, or subscribe to one of
our Services, you may be given the opportunity to opt-in to (or where permitted
by applicable law, opt-out of) the receiving of such marketing-related
correspondence.
We do not share
Personal Information with third parties for the third parties’ marketing
purposes.
We may also use your
Personal Information to personalize and to target more effectively our
marketing communications to ensure, to the extent possible, that any
marketing-related correspondence is relevant to you.
To opt out of
receiving marketing-related correspondence from Panasonic, please update your
email and contact preferences in your PRO Club Account or click
"Unsubscribe" from any marketing or promotional email or text message
(SMS) you receive from us.
12. Children's
Personal Information
I. Who is a child?
Panasonic considers a
child to by anyone under the age of 16, or such younger age as may be specified
by applicable data protection laws.
II. Do we collect
Personal Information from children?
We do not knowingly
collect or try to collect Personal Information from or about children without
the consent of a parent or guardian. Where we do collect Personal Information
from children, we will always use reasonable efforts to verify that consent has
been given or authorised by the child's parent or guardian.
III. What do we do
when children submit Personal information to us?
If we become aware
that Personal Information that has been submitted to us relates to a child
without the consent of a parent or guardian, we will use reasonable efforts to:
• delete that Personal
Information as soon as possible; or
• if deletion is not
possible, we will ensure that this Personal Information is not used for any
purpose, nor disclosed further to any third party.
IV. Parent or guardian
queries
If you are a parent or
guardian and you have queries regarding Panasonic's processing of your child's
Personal Information, please contact us using the details provided in the
“Further Information” section below.
Changes to this
Privacy Notice
It also is important
that you check back often for updates to the Privacy Notice, as we may change
this Privacy Notice from time to time. The “Date last updated” legend at the
bottom of this page states when the policy was last updated and any changes will
become effective upon our posting of the revised Privacy Notice.
We will provide notice
to you if these changes are material and, where required by applicable law, we
will obtain your consent. We will provide this notice by email or by posting
notice of the changes on the Panasonic website or through any relevant Services.
13. Contact Us / Further Information
If you have any
questions regarding the collection, processing, or use of your Personal
Information or if you wish to correct, block, rectify, object, access, revoke
your consent to any applicable aspect of this Privacy Notice or delete any of
your Personal Information, please contact us:
Panasonic Marketing Europe GmbH, Viale
dell’Innovazione 3, 20126, Milan, Italy
By mail:data_protection@eu.panasonic.com