Glen Dimplex Americas Ltd Privacy Notice

 

Welcome to the Glen Dimplex Americas Privacy Notice

This Privacy Notice explains how we collect, use, disclose and protect your Personal Information and respect any rights you benefit from the relevant national, regional and state data privacy legislations. This includes, The California Consumer Privacy Act (CCPA) and The Personal Information Protection and Electronic Documents Act (PIPEDA).

Your Personal information is controlled by Glen Dimplex Americas (GDAM) part of the Glen Dimplex Group.

When we refer to “we”, “us” and “our” in this notice it means GDAM (including its Brands; Cadet, Dimplex and Faber).

When we say “you” and “your” and “individuals” in this notice, we mean anyone whose Personal information we may collect.

GDAM’s registered office is 1367 Industrial Road, Cambridge, Ontario, N3H 4W3

 

1. How we obtain your Personal Information

Personal Information collected directly from you

We may collect personal information from you directly from various sources including:

  • Anyone who order goods or services from us either via our website, telephone, email, SMS, live chat or social media;
  • Anyone who enters a competition or promotional survey
  • Anyone who corresponds with us for any reason e.g. making a complaint
  • Anyone who registers their product warranty
  • Anyone who visits our website
  • Anyone who has a business relationship with us

Personal Information collected automatically

Some Personal Information may be collected automatically when you visit or use our Sites (and those of our third-party service providers acting on our behalf), such as data collected by cookies and other technologies (such as web analytic tools and pixel tags) on our websites. Please also consult our Cookie Policy for more information on how we make use of cookies and other automated means of data collection.

Personal information collected automatically may include:

  • information about your (mobile) device or your type of browser
  • information about the way you use our websites, such as details of the web pages you have viewed, the banners and the hyperlinks you have clicked, etc.
  • whether you have opened e-mails sent by us to you
  • the websites you have visited before arriving at one of our websites
  • your IP address
  • the hyperlinks you have clicked
  • your MAC address
  • information you choose to share by using social media tools incorporated in our websites or using your social media log-in details to access certain GDAM product sites or applications; and
  • information you share with us about your location. Where we are required to do so by local law, we will only use that information where you have agreed that we can

Personal Information obtained from other sources

We may also collect Personal Information about you from other sources.

These other sources may include:

  • our trusted business partners
  • social media sites
  • consumer research organisations
  • other members of our group

2. Type of Personal information we collect

The table below sets out the different types of personal information that we collect and the sources we collect it from.

Contact Information

Types of personal information

  • Name
  • Address
  • Telephone number
  • Email address

Collected from

  • You
  • Your organisation
  • Retailer or insurance provider booking service call on your behalf

Billing information

Types of personal information

  • Your payment details when purchasing products and services from us

Collected from

  • You

Browsing and device usage information

Types of personal information

  • Information automatically generated through your use of our websites and other digital platforms
  • IP address
  • Information revealing the location of your electronic device

Collected from

  • You and your use of our digital platforms

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)

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

To exercise any of your rights under applicable law described above regarding your personal information, please contact us using the details set out in below.

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