HOMEDIRECT PRIVACY POLICY
HOMEDIRECT PRIVACY POLICY
This Privacy Policy describes how Arcelik A.S., its
affiliates and subsidiaries (collectively, the "Company") collect,
process, share and protect your Personal Data that you provide when you
download and use the HomeDirect application and the functions provided by the HomeDirect
application (collectively, the "Services"). The Company may process
your Personal Data in accordance with this Privacy Policy.
This Privacy Policy is an integral part of HomeDirect's Terms
of Service.All terms used herein that are not otherwise defined in this Privacy
Policy shall be understood as defined in the HomeDirect Terms of Service. Any
matters not contained in these Terms of Service shall be governed by the HomeDirect'sTerms of Service.
Any personal data collected and processed by devices (such as
a smart TV, smartphone or tablet) on which the HomeDirect application is
running or by third party software that is installed on such a device, is not
subject to this Privacy Policy. Such devices and software may process your personal
data in accordance with their own privacy policies, and the Company shall not
be held for any personal data processed in this way.
1.What personal data we collect
When you use the HOMEDIRECT application and the Services, we
may, in accordance with the provisions of this Privacy Policy, collect certain
personal data about you, including: name, surname, email address, user account,
phone number, user name, data about the equipment operated by the HomeDirect
application, the software used together with the HomeDirect application, the
operational data of the equipment used to operate the HOMEDIRECT application,
such as when and how long it is used, data from equipment sensors such as water
hardness levels, mains data, equipment temperature levels, operational data
about equipment components any equipment error information, map data collected
by Lidar sensor, such as displayed errors and alerts, when such errors and
alerts are displayed, information about the devices such as smart TV,
smartphone or tablet on which you run the HomeDirect app and identification
data of such devices, such as MAC number and serial number, and updates to the HomeDirect
application and other Software.
We refer to all personal information that we collect about
you as "personal information" or "personal data".Personal
data or information refers to information and data that can be used to
determining your identity.
2.Local regulations
The terms of this Privacy Policy are applicable to all our
users. However, the laws of certain countries may require different levels of
protection for personal information and data. For example, directives and
regulations adopted by member countries of the European Union may impose
different standards of protection for personal information and data.
Users agree and state that they are aware that the Company,
its affiliates and subsidiaries may be located in a country outside the
European Union and they consent to the collection, use and transfer of their
personal information in accordance with this Privacy Policy.
Notwithstanding the foregoing, the Company, its affiliates
and subsidiaries agree and undertake to provide the protections required by EU Directives
and Regulations - including under the EU General Data Protection Regulation,
hereinafter called the "RODO".
This commitment by the Company, its affiliates and
subsidiaries does not relieve you of the obligation to comply with the laws of
your country.
Special terms of this Privacy Policy are reserved.
3.How we use personal data
In accordance with applicable law, we use Personal Data for
the following purposes based on the following legal bases:
Necessity of the contract
We may process your personal data where it is necessary for
us to enter into a contract with you for the supply of our products or services
or to perform our obligations under such contract. For example, the processing
of your Personal Data may be necessary for:
i.to
register you and enable you to use the HOMEDIRECT application and Services;
ii.to
send you important notices and correspondence regarding changes to the Terms of
Service and this Privacy Policy (via email or "push" notifications);
iii.keep
internal records of software updates, technical services and other transactions
to the extent necessary to provide HOMEDIRECT applications and Services.
Failure to provide certain Personal Data for processing for
the above purposes will prevent us from providing you with the requested
services or products.
Legal obligation
We may be required by law to collect and process certain
Personal Information about you. For example, we may be required to process and
disclose your Personal Information where we determine in good faith that it is
necessary to do so in order to comply with applicable law or for purposes
related to pending proceedings by, among others, judicial or other governmental
authorities.
Legitimate interest of the controller
We may process your Personal Data where it is necessary to
pursue our legitimate interests as a Company, including to manage, promote and
improve its business and to manage our and our users' risks. For example, we
may process your Personal Data in order to:
i.To
inform you about new products or services of the Company and its affiliates by
sending notices, advertisements or photographs by email, SMS and other similar
electronic means of communication or through the HOMEDIRECT application and
Services, unless receiving such communications requires your consent (see
below). If you do not wish to receive such communications, simply follow the
unsubscribe instructions included in the promotional communications you receive
from us or contact us as described further in this Privacy Policy;
ii.To
enable us to analyse and improve the HOMEDIRECT application and Services, as
well as our other products and services, content and advertising;
iii.To
comply with HOMEDIRECT's Terms of Service and this Privacy Policy, including to
investigate possible breaches thereof;
iv.To
detect, deter or otherwise address any fraud or security issues including but not limited to
filtering any spam.
v.To give you advice on the
contents, channels and your purchase of other products of our Company.
Your consent
Where required by applicable law, we are
required to obtain your separate consent to process your Personal Data for
certain purposes. For example, we may ask you to give separate consent to send
you direct marketing communications or to collect data about your location in
order to offer you services based on it. We may also ask you to provide
separate consent for us to create your profile in order to personalise and
improve our devices and other products, services or advertising and to provide
you with improved and profiled after-sales services tailored to you. We create this profile by combining your
Personal Information collected in accordance with this Privacy Policy with data
collected from other sources, such as data collected through our sales and
support teams, as well as data collected through other devices belonging to you
(e.g., information regarding your home appliances, smart home devices, and
electronic home appliances).
4.Direct marketing
We may use
your personal information for marketing purposes, in particular, to display or show
you advertisements and promotional materials, to inform you about our new
products or to conduct free draws and prize competitions and other such
information that we think may be of interest to you based on your history of
and interest in our Services, but always provided that such use complies with
applicable law. We will only send you any advertising, marketing, promotional
materials or product information if you have opted in to receive such
information by email and/or post.
Depending on the jurisdiction to which you
are subject and in accordance with the applicable law in your country, we will
ask you to give your express consent to receive the materials referred to above
before sending them to you.
You
may change your mind about your direct marketing preferences at any time by
using the unsubscribe information on any such communications, updating your
user profile, account details or contacting us. If you do so, we will not
remove your personal information from our databases to the extent that it is
still required by us under the terms of this Privacy Policy or in order to
continue to provide our Services to you.
5.Location-based services
The Company may collect information about the location of
your device and use, store, transmit or share such location based data through
the HomeDirect Application and Services to provide location based services for
its products.
Location data is collected anonymously in a product-based
form that does not identify you personally and is used to provide and improve
location-based products and services. Any such information will be processed in
accordance with the terms of this Privacy Policy.
6.Data processed by third party applications, software or services (third
party services)
When using the Application and the Services, you may also use
several applications, programs and services provided by different third parties
(such as the provider of the device on which the HomeDirect application is
running or providers of other software running on the same device).
Such applications, software or services may process your
personal information or data and are subject to separate terms of use and
privacy policies.
Accordingly, the Company is not responsible for these privacy
policies or practices of third parties.
7.The sharing of your personal data with third parties
In principle, we do not share or disclose your personal
information or data to third parties. However, the Company may be required to
share or use personal information and data in the following cases:
i.Other Arcelik Group companies: your Personal Information may be shared with other Arcelik
Group companies, which may use it for the purposes set out in this Privacy
Policy;
ii.Business Partners: Your Personal Information may be disclosed to third parties, such as
business partners and suppliers, as necessary to provide the Services to you. For
example, your Personal Information may be disclosed to third parties to enable
them to provide you with advanced after-sales and repair services.
For
more information, please see the section 6.
iii.Third Parties:
Your Personal Information may be disclosed to a third party where it is
necessary to comply with a legal obligation or decision of a court, public
authority or governmental body, or where disclosure is necessary in connection
with national security, law enforcement or an important public interest.
iv.Service Providers: Your Personal Information may be disclosed to companies that provide
services to us, such as cloud computing companies. Service providers are
required to maintain the confidentiality of your Personal Information and may
not use it for purposes other than to provide services to us.
v.Third Parties and Company Sales: If we sell or assign our business assets or merge
companies, we may transfer your Personal Information to one or more third
parties as part of such transaction.
vi.Other Third Parties and Your Consent: With your consent, we may also share your Personal
Information with other parties.
Disclosure of your personal information pursuant to the above
may include disclosure to affiliates, subsidiaries or third parties located
outside the European Union ("EU") or European Economic Area
("EEA"). If you are a resident of an EU or EEA member state, data protection
laws outside the EU/EEA may not provide an equivalent level of protection as in
your country.However,
before transferring the personal information and data of a resident of an
EU/EEA member state, we will take steps to ensure that such data is afforded
the same level of protection as under existing EU/EEA data protection laws.
Your personal data
will not be shared with third parties for purposes other than those set out in
this Privacy Policy and will not be sold.
8.Security measures taken to protect your personal data
The Company takes administrative, technical and physical
measures to protect your personal data from loss, theft, misuse, unauthorised
access, disclosure, alteration and destruction.
We take care of the security of your personal data by using
encryption and password protection where required and by restricting access to
your data.
The automatic update status of the product during the initialization phase is off, and the user can set the automatic update to on in the settings after the device is initialized on the page of "Device"- "Setting"-"Device update"-"Automatic Updates" in the App.
9.Links to external content resources
Our Services may contain certain services or links that may
redirect you to other websites, services or external content resources that are
beyond our control.
We are not responsible for such direction and privacy of any
personal information and data you provide on other websites. We do not accept
any responsibility for these privacy policies.
10.Changes to this Privacy Policy
The Company may change and update this Privacy Policy from
time to time. The Company will notify you of any material changes or additions
to this Privacy Policy and will provide a copy of the revised Privacy Policy to
you via the email address provided to the Company or by other appropriate means
by which the Company notifies you of any changes to this Privacy Policy.
11.Access to the Privacy Policy and Withdrawal of Consent
In the HomeDirect application you can view the content of the
latest "HomeDirect Privacy Policy", which you have read.
12.Your Rights for Your Personal Data
You have the following rights in relation
to your personal data that we process:
i.the right to
be informed as to whether your Personal Data is being processed by us and to
request a copy of your Personal Data, as well as information regarding the
processing of your Personal Data, including information on the purposes for
which your Personal Data is being processed and whether it is being processed
for the intended purpose, and information on third parties to whom your
Personal Data is disclosed;
ii.the right to
request rectification of any inaccurate or incomplete Personal Data;
iii.the right to
request erasure of your Personal Data or restriction of its processing;
iv.the right to
object to further processing of your Personal Data;
v.the right to
withdraw your consent without affecting the lawfulness of the processing of
personal data based on your consent before its withdrawal;
vi.the right to
data portability in certain circumstances;
vii.the right to
lodge a complaint with a supervisory authority;
viii.the right to
challenge certain automated decision-making relating to you which produces
legal or other significant effects. We do not normally make decisions by
automated means, but we will nevertheless inform you if we do.
You can use the following contact details
to exercise these rights:
Company Name: Arçelik A.Ş
Address:
Karaağaç Cad. No:2-6 Sütlüce Beyoğlu, ISTANBUL
Phone:
0 212 314 3434
E-Mail: musteri.hizmetleri@grundig.com
Customer Services: 444 888
13.How to Contact Us for your Personal Information and Data
Please do not hesitate to contact us to learn
more about our commitment to this Privacy Policy. You may use the contact
information indicated in Section 12 of this Privacy Policy for this purpose.
VULNERABILITY DISCLOSURE POLICY
We take security issues extremely seriously and welcome feedback from security researchers in order to improve the security of our networked products, apps and cloud services. We operate a policy of coordinated disclosure for dealing with reports of security vulnerabilities and issues. We appreciate reporting identified vulnerabilities, regardless of service contracts or product’s, apps’ and/or cloud services’ lifecycle status.
To privately report a suspected security issue to us for one of our networked products, mobile apps or cloud services, please send your report to psirt@homewhiz.com.
We will be glad if you can give some basic details, typically:
• Name/type of affected product/app/service, plus specific model number, serial number, etc.
• Any Proof of Concept(PoC) setup details
• Description of the steps to reproduce the issue
• Public references if there is any
We recommend you to encrypt all e-mail communications with our Product Security Incident Response Team’s public PGP key.
By following the HomeWhiz Vulnerability Disclosure Policy, we will respond you within a maximum 48 hours upon receving the initial report. If the reported security issue will be confirmed by looking at the impact, severity and exploit complexity of the vulnerability report; we may ask for your further contribution to resolve the potential vulnerability within 90 days, and we will be updating you about the progress every 2 weeks. We also kindly ask you to keep the vulnerability confidential, and expect you to refrain from, such as conducting unapproved denial of service attacks, load tests, social engineering or other undesirable activities, until we make a fix available.
Once the fix is available, we will notify you and recognise your efforts on this page, upon your confirmation.
Our company's vulnerability disclosure policy is based on the CVSS score.
Hall of Fame
HomeWhiz recognizes the efforts of vulnerability reporters and researchers. We would like to thank everybody who contribute to our products’, apps’ and cloud services’ security infrastructure and helps to make our World more secure.