This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe in compliance with the General Data Protection Regulations (GDPR) (EU) 2016/679.
When you are using the Empress website, Nortek Global HVAC (UK) is the data controller.
For simplicity throughout this notice, ‘we’ and ‘us’ means Nortek Global HVAC.
The GDPR (EU) 2016/679 law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order an item from us for delivery, we’ll collect your address details to deliver your purchase, and pass them to our courier.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting Nortek Global HVAC (UK) to law enforcement .
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services.
We will also use your address details to send you brochures and direct marketing information by post, telling you about products and services we think might interest you.
When you make an online purchase and check out as a guest (in which case we just collect transaction-based data).
When you create an account with us.
When you contact us by any means with queries, complaints etc.
When you comment on or review our products
When you’ve given a third party permission to share with us the information they hold about you.
When we collect data from publicly-available sources when you have given your consent to share information or where the information is made public as a matter of law.
When you visit our premises which usually have CCTV systems operating for security. These systems may record your image during your visit.
If you have an account with us: your name, billing/delivery address, orders and receipts, email and telephone number.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, wish list choices, voucher redemptions, products you show interest in, web pages you visit and how and when you contact us.
To deliver the best possible web experience, we collect technical information about your internet connection and browser as well as the country and telephone code where your computer is located, the web pages viewed during your visit, the advertisements/promotions you clicked on, and any search terms you entered.
We want to give you the best possible customer experience. One way to achieve that is to get the best picture we can of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below, and this can be done at anytime.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services/orders you’ve asked for.
Here’s how we’ll use your personal data and why
To process any orders that you make by using our websites, if we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product or service that you ordered, and we may keep your details for a reasonable period afterwards in order to fulfil any contractual obligations such as refunds, warrantees and so on.
To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this based on our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
To protect our customers, premises and assets from crime, we operate CCTV systems in our premises and car parks which record images for security. We do this based on our legitimate business interests.
To process payments and to prevent fraudulent transactions. We do this based on our legitimate business interests. This also helps to protect our customers from fraud.
If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, product recall notices, and legally required information relating to your orders, we do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
Some examples of customer data retention periods:
When you place an order, we’ll keep the personal data you give us for 5 years so we can comply with our legal and contractual obligations. In the case of certain products, we may be obliged to keep the data for 10 years.
If your order included a warranty, the associated personal data will be kept until the end of the warranty period.
We sometimes share your personal data with trusted third parties.
For example, delivery couriers, for fraud management, to handle complaints, to help us personalise our offers to you and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
We provide only the information they need to perform their specific services.
They may only use your data for the exact purposes we specify in our contract with them.
We work closely with them to ensure that your privacy is respected and protected at all times.
If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
IT companies who support our website and other business systems.
Operational companies such as delivery couriers.
You have the right to request:
Access to the personal data we hold about you, free of charge in most cases.
The correction of your personal data when incorrect, out of date or incomplete.
The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end (such as the end of a warranty or fulfilment of an order/or back order).
A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.
Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.
That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.
That we stop using your personal data for direct marketing (either through specific channels, or all channels).
That we stop any consent-based processing of your personal data after you withdraw that consent.
You can contact us to request to exercise these rights at any time.
If we choose not to action your request, we will explain the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as administration of an extended warranty.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.
If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
You can stop direct marketing communications from us by responding with ‘unsubscribe’ to any email communication that we send you. We will then stop any further emails from that particular division.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.