Privacy NOTICE 

(360insights Client Branded Site) 

360insights (Canada) Ltd. and our affiliated companies, including 360insights (USA) Ltd., 360insights (Europe) Ltd., and 360insights (EEA) GmbH (collectively referred to as “360insights,” “we,” “us,” or “our”) provides incentive programs (“Incentive Programs”) at www.hotpointrewards.com  on behalf of Whirlpool UK Appliances Ltd (our “Partner”). 

Privacy is a fundamental right, and we’ve drafted this Privacy Notice to inform you on how we handle the Personal Information of the visitors (“you”) to this Partner-branded website (the “Branded Site”). This Privacy Notice outlines the legal basis on which we process your Personal Information and provides other information as required by privacy laws and regulations around the world. 

Please read through this Privacy Notice carefully so that you may decide to consent, refuse to consent, or later withdraw your consent to the collection and use of your Personal Information. 

This Privacy Notice is effective: ​​May 31, 2024.  

1. General Overview            

1. Performance of the Incentive Program 

You acknowledge that your Personal Information will be processed in accordance with this Privacy Notice in order to manage the Incentive Program and perform the Terms and Conditions governing the use of the Branded Site (the “Terms”). 

2. Providing Consent 

Without prejudice to paragraph (a), should you acknowledge this Privacy Notice and also provide your express prior, you expressly allow Partner to send you personalized marketing communications based on your interests, always in accordance with Partner privacy notice available at the link [----]           . 

3. If you Elect Not to Provide Your Consent 

You may choose to not consent to the processing of your Personal Information in accordance with this Privacy Notice. However, if you choose not to consent or you later withdraw your consent, then we may not be able to provide you with the abovementioned personalized marketing communications.   

As for the Incentive Program, if you do not accept the Terms or acknowledge the Privacy Notice, you will not be able to create an account or participate on this Branded Site, and hence you will be unable to apply for and receive any form of rebate or incentive from our Partner. In some cases, a rebate or incentive may be available by obtaining a mail-in form from our Partner. 

4. Withdrawing Consent 

Except as required or permitted by applicable data protection laws, we will not use or disclose your Personal Information for any purpose for which you refuse us consent or later withdraw your consent. You may at any time withdraw your consent with future effect and without affecting the lawfulness of the processing of your Personal Information based on your previous consent. 

If you withdraw consent, you agree that despite this withdrawal we may continue to use the Personal Information previously provided to us (i) to the extent that we are contractually obligated to do so, (ii) to the extent necessary to enforce any contractual obligations you may have to Partner and/or 360insights, and (iii) for any other legitimate purpose (including fraud prevention) permitted by applicable data protection laws. If you withdraw your consent to use and disclose this information, we may no longer be able to communicate with you or provide you the Incentive Programs on behalf of Hotpoint​​. 

2. What Is Personal Information? 

“Personal Information” is broadly defined to include all information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. Personal Information could be as simple and direct as your name, but it could also be less explicit like how a certain individual interacted with a website or an advertisement.  

3. Your Privacy Rights on this Branded Site 

We believe in the fundamental right to privacy and that your rights should not differ based on where you live. Accordingly, no matter your residency, you have the following rights with respect to the Personal Information that we collect, use, or share: 

To exercise your rights, you may reach out to us by email at [email protected] or [[email protected]]. If you live in California, you or your authorized agent can also reach us by calling our toll-free number at 1 (866) 684-2308. 

You also have the right to approach the competent data protection authority with your request or complaint. If you live within: 

• Canada, you may contact the Office of the Privacy Commissioner at Contact the OPC - Office of the Privacy Commissioner of Canada. 

• United States: 

• California, you may contact the California Department of Justice’s Privacy Unit at State of California - Department of Justice - Office of the Attorney General. 

• Virginia, you may contact the Attorney General of Virginia. 

• the European Economic Area (EEA), a list and contact details of local data protection authorities is available here.  

• the United Kingdom (UK), you may contact the UK Information Commissioner’s Office at Contact us | ICO. 

If for whatever reason you are unsure of which competent data protection authority is applicable in your circumstances or you are unsure of how to contact such authority, let us know, and we’ll endeavor to help you. 

4. Why We Collect Personal Information 

We collect your Personal Information to enable and manage your participation in this Incentive Program, and for the other uses described here. By providing your Personal Information to us, you are also consenting to our sharing of that information with the Partner. 

Specifically, we collect your Personal Information: 

1. To facilitate our Incentives Programs on this Branded Site on behalf of the Partner, which may include: Registering and managing your account, including qualifying purchases, claims, warranties, and nominations; and the fulfilment, provision and administration of any prizes, rewards, events or payments. 

2. To communicate with you, regarding information concerning your account; our Partner’s Incentive Programs; or any updates to the terms of an agreement, including this Privacy Notice. 

3. To respond to you, after you have made initial contact with us regarding inquiries, comments, or concerns; requests for technical support, online services, information regarding your account; or any other communication. 

4. For analytics, such as to better understand, analyze, and respond to your needs and preferences, as well as to learn how visitors including you use the Site in order to improve it; subsequently develop, enhance, and/or provide products and services to meet those needs and preferences; or keep track of your product preferences and instructions and analyze that information. 

5. How We Collect Personal Information 

The Personal Information that we collect varies depending on the nature of and reason for your interaction with us. We collect Personal Information:  

1. when you register for an account or interact with our Branded Site and its respective Incentive Program; 

2. when you communicate with us or sign up to receive promotional materials or information via email, push notifications, or text messages; 

3. when you engage with our online communities or advertising, including when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields, blogs, message boards, events, and other community forums sponsored by or affiliated with 360insights; and, 

4. when we leverage and/or collect cookies, device IDs, location data from the environment, and other tracking technologies: We may collect certain Personal Information using cookies and other technologies such as web beacons, device IDs, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising. Our Cookie and Device Identifiers section contains more information and options to control or opt-out of certain data collection or uses. 

6. Who is Your Data Controller and Processor? 

Beko Europe, Morley Way, Woodston, Peterborough, PE2 9JB is the Data Controller of this Incentive Program.  

360insights is the Data Processor for the processing activities described in this Privacy Notice. As noted below, we may share Personal Information with affiliated 360insights companies. 360insights companies are jointly responsible for the protection of your Personal Information. 

1. If you live within Canada, we have arranged for you to be able to centrally exercise all your rights through 360insights (Canada) Ltd. 

2. If you live within the EEA, we have arranged for you to be able to centrally exercise all your rights through 360insights (EEA) GmbH. 

3. If you live within the United Kingdom, we have arranged for you to be able to centrally exercise all your rights through 360insights (Europe) Ltd. 

4. If you live within the United States, we have arranged for you to be able to centrally exercise all your rights through 360insights (USA) Ltd. 

5. If you live anywhere else. we have arranged for you to be able to centrally exercise all your rights through 360insights (Canada) Ltd. 

7. Legal Basis of Processing 

We process your Personal Information because such processing is necessary for:  

1. the Performance of the Incentive Program. In this case, the legal basis is constituted by the Terms, i.e. the performance of a contract to which you are a party;  

2. the sending of personalized marketing communications. In this case, the legal basis is constituted by your consent, that you may freely withdraw anytime; 

3.           compliance with our legal obligations; and,  

4. protecting our legal titles and interests before courts.  In this case, the legal basis is constituted by our legitimate interest to protect our interests in court, which will be duly balanced with your rights and freedoms under applicable data protection laws.                 

8. What Personal Information Do We Collect? 

We have collected the following categories of personal information from consumers: 

1. Marketing Communications 

Where we are legally required to do so, we ask you for your prior consent before providing you with promotional materials or information (referred to as “Commercial Electronic Messages,” or “CEMs”). You may withdraw your consent to the receipt of CEMs at any time. This will not affect the processing of your Personal Information in relation to any rebate or incentive claim submitted to us on behalf of any of our manufacturer or distributor ​​​​clients. 

2. Cookies and Device Identifiers 

This Branded Site uses “cookies” and device identifiers to help personalise your online experience with us. A cookie is a small text file that is stored on your computer to help us make your visit to our Branded Site more “user-friendly.” Cookies provide us with information about your use of the Branded Site that can help us improve the Branded Site and your experience with it.  

A device identifier is a unique label can be used to identify a mobile device. Device identifiers may be used to track, analyze and improve the performance of the Branded Site and the Services. 

There are three types of cookies used on this Branded Site: 

• Session-handling cookies, which are essential to your use of the site and its functionality.  

• Service-provision cookies, which are essential to the delivery of the requested web pages. 

• Analytic cookies, which are set by a third-party and allow us and the Partner to analyze and improve the performance of the Services. 

We do not use or place cross-site, targeting or advertising cookies on our Branded Site. 

3. Branded Site Usage Information 

Like most websites, this Branded Site gathers traffic patterns, usage information and other aggregated data in order to evaluate our visitors’ preferences and the effectiveness of our Branded Site. This aggregate usage data does not identify you individually. We may share anonymous, aggregated statistics about visitors to our Branded Site with others outside our company, or we may allow third parties to collect aggregate data through our Branded Site. 

4. Do Not Track Requests 

We do not track you over time and across third party websites to provide targeted advertising. Accordingly, we do not respond to Do Not Track (DNT) signals. 

9. How we use and share your Personal Information 

We do not sell Personal Information and have not done so in the past 12 months. We also do not use your data for targeted advertising. We will not share your Personal Information, except:  

1. to third parties performing clearly defined subprocessing functions on behalf of us or the Partner (such as reward fulfilment, service infrastructure, claim validation and processing, analyzing data, providing marketing assistance, and verification of data provided by you). Any processing of your Personal Information by these subprocessors will be protected by an agreement regarding privacy and data security;  

2. where we are required by law to disclose Personal Information; in connection with any legal proceedings or prospective legal proceedings;  

3. in order to establish, exercise or defend our legal rights;  

4. to the purchaser (or prospective purchaser) of any business or asset which we are (or are contemplating) selling. We will require any person or entity to whom we provide your Personal Information to agree to comply with our then current Privacy Notice. We will take reasonable commercial efforts to ensure that they comply with our Privacy Notice; and,  

5. in the event of a transfer of ownership or assets, or a bankruptcy, of 360insights or any of its affiliates.  

We may also share your Personal Information with one or more of our respective subsidiary and parent companies, and other affiliated legal entities and businesses who are under common corporate control. However, all of the parent, subsidiary and affiliated legal entities and businesses of 360insights that receive your Personal Information will comply with the terms of this Privacy Notice and all applicable data protection laws with respect to their use and disclosure of such Personal Information.  

10. Anonymized Data 

We may create de-identified or anonymized data from Personal Information that you provide to us by excluding data components (such as your name, email address or linkable tracking ID) that makes the data personally identifiable to you. Anonymized data is no longer considered Personal Information and is not subject to this Privacy Notice. 

11. International Data Transfers 

360insights is a global organization. Sharing Personal Information cross-border is required for us to fulfil the purposes for which you have disclosed that Personal Information to us.  

Sharing data across borders is essential so that you receive the same high-quality service wherever you are in the world. As a result, we will, subject to applicable data protection laws, transfer Personal Information collected in connection with the Services, to entities in countries where data protection standards may differ from those in the country where you reside. By accessing the Branded Site and utilizing the Services, you understand and consent to our transfer of your Personal Information globally. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries will be entitled to access your Personal Information. 

In the event we transfer Personal Information of EEA, UK, and/or Swiss residents to external recipients outside the EEA, Switzerland, or the UK, we will only do so if the recipient: (i) is in a jurisdiction deemed adequate by the EU or by the UK, or (ii) has entered into EU or UK Standard Contractual Clauses with us; or, (iii) has implemented Binding Corporate Rules in its organization.  

In the event we transfer Personal Information from residents of China to external recipients outside of China, we will only do so in compliance with all applicable law, including the Personal Information Protection Law. 

12. How We Protect Your Information 

To protect your Personal Information against accidental or unlawful destruction, loss, use, or alteration and against unauthorized disclosure or access, we and our subprocessors use appropriate physical, technical and organizational security measures. 

13. Your Rights to Access, Portability, and to be Forgotten 

Before we can act upon your request, we must be able to identify you. Accordingly, you are required to provide sufficient proof of your identity to ensure the safety and security of your Personal Information. We will not provide you, edit, or delete your Personal Information if we cannot verify your identity or authority to make the request. You must also describe your request with sufficient detail to allow us to properly understand, evaluate and respond to you. If we deny or partially deny your request, you have a right to be provided reasons as to why your request was not fully granted. 

To exercise the access, data portability and deletion rights described above, please submit a valid consumer request to us at [email protected] or [email protected]      

If you are a resident of California, you or a person registered with the California Secretary of State that you authorize to act on your behalf, may also make a verifiable consumer request related to your Personal Information by calling our toll-free number at 1 (866) 684-2308. 

1. Your Right to Access 

The disclosure of information will be provided to you free of cost. If your access request is manifestly unfounded or excessive, in particular because of the requests repetitive character, then we may levy a charge to cover our administrative expenses (we also may refuse such repetitious or vexatious requests for access). 

We reserve the right to decline your request where the information requested:  

• would disclose Personal Information of another individual or of a deceased individual;  

• is subject to legal privilege;  

• is personal health information that was not provided to us directly by the individual requesting access; 

• is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;  

• does not exist, is not held, or cannot be found by us, could reasonably result in serious emotional harm to the individual or another individual, or serious bodily harm to another individual; or,  

• may harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions.  

We also will not disclose the Personal Information where a law of your country, state, province, or other subnational entity would bar such disclosure. 

2. Updating or Correcting Your Information 

You may in most cases correct or update your Personal Information by accessing your Account directly, or by instructing us to do so on your behalf. 

3. Your Right to Data Portability 

If we provided you access to your Personal Information, we will provide it to you in a structured, commonly used, and machine-readable format. If you made your request electronically, we would provide access in electronic form unless you request otherwise. Your request may also be delivered by mail. This format will be, to the extent technically feasible, in a readily useable format that allows you to transmit this information to another entity without hindrance. 

4. Data Retention and the Right to be Forgotten 

We do not hold onto your data forever. Instead, our default is to retain your Personal Information: 

• until it is no longer necessary for the purposes for which it was collected or otherwise processed; 

• to comply with legal obligations (such as retention obligations under employment, tax or commercial laws); or, 

• until you request that we delete it. 

If you make a deletion request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your Personal Information from our records, unless we or our Service Providers must retain your Personal Information to: 

• complete the enquiry for which your Personal Information was collected, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; 

• detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; 

• enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; 

• comply with any legal obligation; or, 

• make other internal and lawful uses of that information that are compatible with the context in which you provided it. 

14. We May Change this Privacy Notice 

In order to maintain or enhance our Services it might be necessary to change this Privacy Notice from time to time. We therefore reserve the right to modify this Privacy Notice at any time, subject to applicable data protection laws. Please visit the Branded Site from time to time for information on updates to this Privacy Notice. 

15. Other Sites 

This Privacy Notice solely applies to the Personal Information collected by us pursuant to this Branded Site. We create and maintain other branded websites on behalf of other partners for the provision of Incentive Programs to them and to their associates, customers, affiliates, and sales representatives. Each branded site is subject to its own separate privacy notice and this Privacy Notice does not apply to other branded sites. Please refer to the privacy notice on each branded site for information about how we collect, use, and share Personal Information collected on those sites. 

In addition, we also maintain a Corporate Site. This Privacy Notice does not apply to the Corporate Site; the Corporate Site is subject to its own separate Privacy Notice.  

16. Data Privacy Contact 

If you have any questions regarding this Privacy Notice or the privacy practices of Partner, 360insights or its ​​​​subprocessors, or if you require assistance to withdraw your consent to our processing of your Personal Information or wish to request that your Personal Information be deleted, please contact us by sending an email to [email protected] or [email protected], writing to us at 360insights, 300 King St., Whitby ON L1N 4Z4, Attention: Chief Privacy Officer, or [Beko Europe, Morley Way, Woodston, Peterborough, PE2 9JB]. If you’re a resident of California, you may also call our toll-free number at 1 (866) 684-2308.