Your rights to object
- a) ask us to stop using your personal information for directmarketing purposes. If you exercise this right, we will stop using your personal information for this purpose; and
- b) ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest
1. How Vorwerk UK Limited will be processing personal data
We process personal data for the following purposes:
a) Access data in server log files
You can visit our websites without providing any personal information. Each time a web page is called up, the web server merely automatically stores a so-called server log file which contains, for example, the name of the requested file, your IP address, the date and time of access, the data volume transferred and the requesting provider (access data), and documents the retrieval.
This access data is evaluated exclusively for the purpose of ensuring interference-free operation of the page and to improve our offer. In balancing the various interests, this serves to safeguard our legitimate interests in the correct presentation of our offer. All access data will be deleted no later than seven days after your visit to the page.
b) Data collection and use in connection with contract processing and opening a customer account
We collect personal data (name, address, email address and telephone number) if you voluntarily provide it to us in connection with your order, when you contact us (e.g. by contact form or email), agree to a private demonstration, or open a customer account. Mandatory fields are marked as such, since, in these cases, we need this information to process the contract or your contact message, or to arrange a private demonstration, or to open the customer account, and you cannot complete the order and/or open the account, agree to a private demonstration or send the contact message without providing it. The information that is collected can be seen from the respective input forms. We use the data you provide to process the contract and handle your enquiries. After complete processing of the contract or deletion of your customer account, your data will be restricted for further processing and deleted upon the expiry of any legal retention periods, unless you have expressly consented to a further use of your data or we have reserved the right to further legally-permitted data use, about which we inform you below. You can delete your customer account at any time either by sending a message to email@example.com or via a dedicated function in the customer account.
c) Data usage when registering for the e-mail newsletter
If you consent to receive any marketing communications, we will use your name and email address provided by you to regularly send you marketing communications via email.
d) Data usage when registering for telephone advertising
If you have given us your consent, we will use the telephone number you have provided to inform you by telephone about current Vorwerk product offers and promotions.
e) Use of data for postal advertising and your right of objection
Provided you have given us your consent, we will use your first and last name as well as your postal address for our own advertising purposes, e.g. to send offers and information about our products and services by post. You may withdraw your consent for the processing of your data for these purposes, at any time, by sending an email to firstname.lastname@example.org.
f) Abuse and Fraud Prevention
On the basis of our legitimate interest, the following personal data will be forwarded to infoscore Consumer Data GmbH, Rheinstrasse 99, D-76532 Baden-Baden, Germany for the purposes of preventing misuse and fraud:
- Your data collected during the ordering process (purchase item, shopping cart, name, postal address, e-mail address, delivery address, payment method and bank details) and
- The device and usage data of your visits to this website (country settings, device information, start, end and scope of visited web pages, and click paths).
This data is passed on and processed in order to automatically check whether this or any future order or order attempt suggests misuse of the website or fraud.
Detailed information on how Infoscore Consumer Data GmbH works can be found here. Appropriate measures to safeguard your rights, freedoms and legitimate interests will be taken into account. You will be notified if a contract is rejected on the basis of mathematical procedures, and the main reasons for the decision will be given on request. You have the opportunity to present your point of view by contacting email@example.com and to challenge the decision, in which case the decision will be reviewed again by an employee.
g) Data transfer to the device transaction pool
On the basis of our legitimate interests, the following personal data will be transmitted to the database device transaction pool (DTP) and stored there:
- Data collected during the ordering process (purchase item, shopping cart, name, postal address, e-mail address, delivery address, payment method and bank details) and
- The device and usage data of your visits to this website (country settings, device information, start, end and scope of visited web pages, and click paths)
The purpose of the DTP is to be an industry-wide alert service to protect member companies involved in the DTP against fraud and bad debts. Where a member company submits a request to the DTP, only the results of the suspicious activity review are sent to that member company. In this regard, positive data may also be used, i.e. terminals via which, for example, payments are made often and punctually, are rated positively. Individual member companies do not store result data beyond the specific case of a single use. The DTP is operated by Infoscore Tracking Solutions(ITS) GmbH, Kaistrasse 7, 40221 Dusseldorf, Germany as order processor of the member companies.
Appropriate measures to safeguard your rights, freedoms and legitimate interests will be taken into account.
h) Data collection and use in relation to Advisors
If you are an Advisor, we will collect and use certain personal data in order to perform our contract with you, including your name, your postal address, your email address, your telephone number, your VAT number (if applicable), your credit/debit card details, information provided when you correspond with us, and any updated to information provided to us;
We will collect, use and store the personal data listed above to enable you to perform your obligations under the contract, to perform our obligations under the contract, to deal with enquiries or issues you have, to provide you with details concerning demonstrations, to pay you your commission and to comply with any procedures, laws and regulations which apply to us;
Our use of your personal information may also be necessary for complying with our legal obligations (for example, providing your personal information to HMRC).
2. Recipients of personal data
Vorwerk Group entities
- a) We may share personal data with other Vorwerk companies in order to provide products and services and to ensure consistently high service across Vorwerk companies
- a) when providing products to you, we may share personal data to persons acting on our behalf or otherwise involved in the transaction, including:
- b) service providers with whom personal data is being shared, including Vorwerk International and other business partners who provide services to us, such as IT hosting providers, repair services, communication services, debt collection, tracing, fraud prevention and others. Whenever we transfer data with them we ensure that necessary safeguards are in place
- c) For the fulfilment of the contract, we will pass on your data (name, address, email address and telephone number) to the mail order company in charge of delivery if this is necessary for the delivery of ordered goods
3. International transfers of personal data
The Recipients of personal data areffereto above may be located outside of the European Economic Area (EEA). Unless the country to which data is being transferred has been determined by the European Commission as the country with adequate level of protection, Vorwerk requires such recipients to comply with data protection measures enshrined in the data processing agreement and standard contractual clauses. A copy of these agreements can be obtained from the Data Protection Officer on 0330 660 0834 or via email at firstname.lastname@example.org.
4. Your data protection rights
You have a right to information about the personal data collected and stored by us and receive a copy of that data, and if applicable, a right in respect of the correction of data in case your personal data collected is inaccurate.
You have a right to object and restrict data processing or request deletion of data. These rights are not absolute under the General Data Protection Regulation (GDPR) as sometimes there might be overriding interest to continue data processing, but we will consider your request and respond to you with the outcome within 30 days of receipt of your request. You may also object to direct marketing by clicking “Unsubscribe” in any of our emails to you, or by emailing us at email@example.com. The data processing that was conducted for direct marketing will be stopped within 30 days of receipt of your request.
Where we process your personal data on the basis of consent, you have a right to withdraw that consent at any time. Please note that withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
When we process your data based on consent or when data processing is required for enetering into or performance of the contract with us you may have the right to request your personal data to be transferred to you or another controller.
In those cases when we process your personal data through automated decision making including profiling you will be informed about such data processing taking place, the logic involved, and be informed of the possible consequences of such processing. You have the right to contest the decision based on automated decision making by contacting the Data Protection Officer on 0330 660 0834 or via email at firstname.lastname@example.org.
For questions about the collection, processing or use of your personal data, the disclosure, correction, blocking or deletion of data or objection to a particular processing of data, data portability please contact the Data Protection Officer on 0330 660 0834 or via email at email@example.com.
5. Security of data processing
At Vorwerk UK Limited we have implemented appropriate technical and organisational measures (for example; staff training, lockable filing cabinets and passwords for system acces) to prevent unauthorised or unlawful access to personal data you have shared with us.
6. Retention of personal data
The criteria we use to determine the periods for retaining your personal data include the retention requirements under applicable laws, regulations and our operational requirements, such as account maintanance, enabling customer relationship management and responding to legal claims, compliants and regulatory and law enforcement requests.
If you are not satisfied with any aspect of data processing of your personal data by Vorwerk UK Limited or any of it’s appointed data processors, we would like to understand it better and discuss with you how can we improve the situation. You can contact the Data Protection Officer on 0330 660 0834 or via email at firstname.lastname@example.org. Nonteheless, you may also submit a complaint to:
- Information Commissioners’ Office (ICO)
- Wycliffe House
- Water Lane
- SK9 5AF
- 0303 123 1113
9. Data Protection Officer contact information
Telephone: 0330 660 0834
- Data Protection Officer
- Vorwerk UK Limited
- Ashurst Manor
- Church Lane
- SL5 7DD