Future Electronics respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data and tell you about your privacy rights and how the law protects you.
1. Important Information and Who We Are
1.1. Purpose of this Policy
This privacy policy aims to give you information on how Future Electronics collects and processes your personal data, including any data you may provide through our websites, when you sign up to our newsletter, purchase product or a service.
Our websites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy or notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.
1.2. Controller of Personal Data
Future Electronics is the controller and responsible for your personal data. Reference to Future Electronics (or “we”, “us” or “our”) in this policy refers to all companies within the Future Electronics group of companies.
1.3. Data Protection Officers and EU Representative
Future Electronics currently has two Data Protection Officers (DPOs), one responsible for regions outside of Europe, the Middle East and Africa (EMEA) and the other responsible for the EMEA region, and a EU Representative. Contact details for each DPO and the EU Representative are as follows:
DPO for EMEA:
Email Address: DPOEMEA@FutureElectronics.com
Postal Address: Future Electronics, Future House, The Glanty, Egham, Surrey TW20 9AH, United Kingdom
EU Representative:
Email Address: EUREP@FutureElectronics.com
Postal Address: Future Electronics, Bobrowiecka 8, Warsaw, 00-728 Poland
DPO for Regions other than EMEA:
Email Address: DPO@FutureElectronics.com
Postal Address: Future Electronics 237, Hymus Boulevard, Pointe-Claire, Quebec H9R 5C7, Canada
Please contact your regional DPO or EU Representative with any questions about the operation of this policy or if you have any concerns that this policy is not being or has not been followed. You have the right to make a complaint at any time to your national supervisory authority for data protection. We would, however, appreciate the chance to deal with your concerns before you approach your national supervisory authority so please do not hesitate to contact us in the first instance.
1.4. Your Duty to Inform Us of Changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1.5. Third Party Content and Privacy Statements
Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their content or privacy statements. We encourage you to read the privacy policy or notice of every website you visit.
2. The Data We Collect About You
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data, which includes first name, last name, username or similar identifier;
- Contact Data, which includes billing address, delivery address, email address and telephone numbers;
- Financial Data, which includes bank account and payment card details;
- Transaction Data, which includes details about payments to and from you and other details of products and services you have purchased from us;
- Technical Data, which includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites;
- Profile Data, which includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;
- Usage Data, which includes information about how you use our websites, products and services; and
- Marketing and Communications Data, which includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data (described above) to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3. If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that 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 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 the time.
4. How is Your Personal Data Collected?
We use different methods to collect data from and about you, including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Purchase our products or services;
- create an account on our websites;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
- Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from third parties, notably analytics providers.
5. How We Use Your Personal Data
5.1. General Approach and Guidelines
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
5.2. Purposes For Which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we may to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
In this policy, a legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| PURPOSE/ACTIVITY | TYPE OF DATA | LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE INTEREST |
|---|---|---|
| To register you as a new customer | (a) Identity (b) Contact | Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us | (a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications | (a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our websites, products/services, marketing, customer relationships and experiences | (a) Technical (b) Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our websites updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile | Necessary for our legitimate interests (to develop our products/services and grow our business) |
5.3. Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
5.4. Promotional Offers From Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us, purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and in each case you have opted into receiving that marketing communication.
5.5. Third-Party Marketing
We will get your express opt-in consent before we share your personal data with any company outside the Future Electronics group of companies for marketing purposes.
5.6. Opting Out
You can ask us or third parties to stop sending you online marketing messages at any time by using the “Unsubscribe” feature contained at the bottom of each such email message. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
5.7. Cookies
You can set your browser to refuse all or some browser cookies, or to when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our websites may become inaccessible or not function properly. Please also refer to any policies governing cookies that we may adopt from time to time (which will be found on our websites).
5.8. Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
6. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 5.2 above.
- Internal third parties, notably other companies within the Future Electronics group of companies;
- External third parties, notably service providers acting as processors who provide IT and system administration services to Future Electronics, professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services, and regulators and other authorities who require reporting of processing activities in certain circumstances; and
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International Transfers
7.1 Transferring data outside of the EEA
We share your personal data within the Future Electronics Group. This will involve transferring your data outside the European Economic Area (EEA). We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Where necessary by law, we formalize these transfers with binding corporate rules.
Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. In such cases, we take every effort to ensure a similar degree of protection is afforded to your personal data and, to that end, implement the following:
- Where we use certain service providers, we may use specific contracts or contractual provisions approved by the European Commission which give personal data the same protection it has in Europe; and
- Where we use providers based in the United States, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7.2 China Cross-border provision of personal information
In order to provide cross-border e-commerce transactions, technical support and maintenance of equipment or systems, ensure information security, and conduct operational management, we may provide some of the personal information we collect to Future Electronics affiliates outside China, or allow Future Electronics outside China to Affiliates access personal information stored in China. We will abide by applicable laws and ensure that your personal information outside China is protected at least as well as applicable requirements within China through contractual agreements, internal policies and standards.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of China.
8. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. How Long Will You Use my Personal Data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data can be requested from us by contacting us.
In some circumstances you can ask us to delete your data. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. This includes the following:
- The right to be informed about our collection and use of personal data;
- The right of access to the personal data we hold about you;
- The right to rectification if any personal data we hold about you is inaccurate or incomplete;
- The right to be forgotten – i.e. the right to ask us to delete any personal data we hold about you;
- The right to restrict (i.e. prevent) the processing of your personal data;
- The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
- The right to object to us using your personal data for particular purposes;
- Rights with respect to automated decision making and profiling; and
- The right to withdraw consent at any time where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above please contact us.
11. Administrative Fees
Where permitted under law, we may charge a reasonable administrative fee to process any request you may have with respect to your personal data or this policy.
12. What We May Need From You
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
13. Time Limit to Respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, but we will contact you if this is the case.