The company LG Electronics Italia S.p.A., in its capacity as data controller, undertakes to protect users’ privacy. The present policy privacy (“Privacy Policy”) applies only to the websites and services controlled by LG Electronics Italia S.p.A., including the website lg.com, the e-commerce services, call centres and customer assistance managed by LG Electronics Italia S.p.A. or by its authorised partners, in which the Privacy Policy is published or referred to (hereinafter, altogether, the “Websites”). Please read the Privacy Policy carefully before using the Websites.
With this Privacy Policy LG Electronics Italia S.p.A., with registered office at Via Aldo Rossi 4, 20149 Milan (hereinafter, “LGE”, “we” and “our”), in its capacity as data controller, informs users of the Websites on the methods and purposes of personal data processing carried out by LGE through the Websites, also through the use of cookies, observing the provisions of the General Data Protection Regulation (EU) 2016/679 (“Regulation”). As the Websites may enable access to third-party websites, we specify that this Privacy Policy does not apply to the said third-party websites and that LGE is not responsible for the personal data processing activities carried out by the third parties, which operate as independent data controllers (see also our Cookie Policy).
LGE may collect users’ personal data in various ways and process them for different purposes. The purposes for which we process personal data, the legal bases of the processing and the categories of personal data that we process are listed below.
| Main purposes of processing | Data processed | Legal basis |
|---|---|---|
Management of interaction with the Websites or of contact requests We process data for this purpose when users contact us regarding our products or services or when users interact with our Websites. This interaction may consist, for example, of registering on Websites by creating a user account, operations to recover credentials, participating in surveys, contacting our call centre, or sending requests via forms present on the Websites, including managing complaints. For some categories of users who receive specific dedicated services provided through the Websites (for example, professionals, shop assistants and/or distribution staff), we may also collect information regarding the profession or commercial affiliation with LGE in order to check that the applicant is effectively entitled to receive the services or to access specific areas of the Websites. | Name and surname, address of domicile or residence, email address, telephone number, date of birth (or the fact that the user is of adult age), credentials for access to the Websites, information on products or services purchased or of interest, information on the commercial affiliation | Execution of a contract or of pre-contractual measures adopted at the user’s request |
Management of the purchase of products or services We process data for this purpose when users purchase LGE products or services, in order to manage the order, the payment and all activities or services connected to or associated with the purchase of products or services through the Websites (e.g.: delivery, installation, return, withdrawal, collection of used products). As regards payment, we specify that LGE does not collect or store any data regarding the payment methods used by users (for example credit card number). These data are collected and processed independently by the digital payment companies or payment operators involved in the payment processes according to their respective privacy disclosures. These parties only provide LGE with information regarding whether the payment has been made (for example payment successful or refused). | Name and surname, address of domicile or residence, email address, telephone number, date of birth (or the fact that the user is an adult), information on products or services purchased, tax ID Code or VAT number, company name, identity documents, information on the types of payment services used | Execution of a contract or of pre-contractual measures adopted at the user’s request |
Management of purchases under reduced VAT scheme We process data for this purpose in order to fulfil obligations, in compliance with applicable legislation, for requests for application of the reduced VAT scheme in the context of sales through Websites offering technical and IT support to customers with disabilities. | Besides the data processed in managing the purchase of products or services, particular categories of data (for example: data related to health condition, including any existence of disability) | Execution of a contract or of pre-contractual measures adopted at the user’s request . |
After-sales support We process the data for this purpose in order to manage requests for after-sales support by telephone, chat and/or instant messaging systems (for example: WhatsApp), also connected to providing remedies under legal or conventional warranties (for example: repair, product replacement, price reduction and/or refund). | Besides the data processed in the context of managing the purchase of products or services, banking data (only for cases of refund) | Execution of a contract or of pre-contractual measures adopted at the user’s request |
After-sales support through the remote video-support system (“Telespresence”) We process data for this purpose when users provide consent to use the Telespresence, which involves a remote video-support service provided by personnel from our after-sales support network for diagnostics, assistance and troubleshooting regarding products and services purchased. | Besides the data processed in the context of after-sales support, also audio/video data (for example: the user’s image and voice) | The user’s consent. Compliance with a legal obligation |
Improvement of after-sales support functions and processes We process data for this purpose in order to verify, monitor, optimise and improve internal company processes offering support to customers through our call centre. | Besides the data processed in the context of after-sales support, also voice recordings | Legitimate interest of LGE in improving the quality of the services and after-sales support processes |
Chat function We process data in order to enable users to launch an interactive chat session with one of our operators to receive after-sales support services. | Besides the data processed in the context of after-sales support, any further data sent via the chat | Execution of a contract or of pre-contractual measures adopted at the user’s request |
Review and comments function We process data in order to invite users, via email, to review a product or a service purchased and to enable users to publish a comment on content or a review of a product or service, using the specific function provided through the Websites. | Nickname, email address, telephone number, information on products or services purchased or of interest | Execution of a contract or of pre-contractual measures adopted at the user’s request. Legitimate interest of LGE in improving the quality of the products and/or services |
Video-promoter/personal shopper service We process data for this purpose in order to allow users to book and/or launch a session with a video-promoter/personal shopper using the special function available on the Websites. | Name and surname, e-mail address, telephone number and audio/video data (for example: the user’s image and voice) | The user’s consent |
Management of participation in competitions and other promotional initiatives We process data for this purpose in order to manage participation in special events or initiatives organised by LGE that users register for, including trade fairs, exhibitions, courses or seminars, promotions or competitions (hereinafter, the “Events”), also including follow-up activity, such as accreditation of users for participation in Events, delivery of prizes to which users have the right, and to respond to users’ requests. | Name and surname, address of domicile or residence, email address, telephone number, date of birth (or the fact that the user is an adult), tax ID Code or VAT number, identity documents, information on the types of payment services used, banking data in the case of cash-back initiatives | Execution of a contract or of pre-contractual measures adopted at the user’s request |
PR activity We process data for this purpose in the event of receiving requests for information from the press or for PR purposes. | Name and surname, employment position, email address, telephone number | Execution of a contract or of pre-contractual measures adopted at the user’s request |
Compliance with legal and regulatory obligations | In accordance with regulations applicable in each case | Compliance with a legal obligation |
Protecting rights and preventing fraud We process data for this purpose to ensure that LGE is able to protect its own rights and interests, as well as to prevent fraud and abuse in use of the Websites or initiatives organised by LGE (e.g. the Events). | Name and surname, address of domicile or residence, email address, telephone number, date of birth (or the fact that the user is an adult), tax ID Code or VAT number, identity documents, information on the types of payment services used, banking data, information on products or services purchased | Legitimate interest of LGE in protecting its own rights and interests |
Service communications related to the Websites, the products or the services We process data for this purpose to contact users with service (non-promotional) communications related to LGE’s Websites, products or services, including communications related to managing the user account (for example: in order to request an update of the user’s data for creating the account). | Name and surname, address of domicile or residence, email address, telephone number | Execution of a contract or of pre-contractual measures adopted at the user’s request. |
Registration of professional repairers We process your data to enable you to exercise your right to access information on repair and maintenance, in accordance with the European legislation on the subject of Ecodesign. This involves also the acquisition of information and documentation in order to establish your qualification as “professional repairer” and the related technical and insurance requisites required by the aforesaid legislation. | Name and surname, country of domicile or residence, email address, telephone number, professional certifications, insurance information | Compliance with a legal obligation |
| Further purposes of processing | Data processed | Legal basis |
|---|---|---|
Direct marketing We process data for this purpose in order to send commercial communications regarding products and services of LGE or its partners, as well as to perform market research, surveys or studies into levels of customer satisfaction, or to send invitations to Events, by email, SMS, instant messaging systems such as WhatsApp, push notifications, desktop notifications, and traditional methods such as paper mail and phone calls with operators. | Name and surname of user, address of domicile or residence, email address, telephone number, information on products or services purchased | The user’s consent |
Profiling We process data for this purpose in order to build profiles of users based on their preferences, habits and interests, also enabling us to generate promotional content in line with their interests. | Name and surname, address of domicile or residence, email address, telephone number, information on products or services purchased, data related to browsing on the Websites (for example: pages visited, time spent on the pages, shopping cart) | The user’s consent |
Sharing with third-party commercial partners for their marketing purposes We share users’ data with our commercial partners specialised in the sale of insurance services, additional after-sales cover or product warranty extension, which may contact users, as autonomous data controllers, for their marketing purposes via email. | Name and surname, email address | The user’s consent |
If users provide personal data of third parties, users must take the necessary measures to ensure that providing such data to LGE and its subsequent processing for the purposes specified in this Privacy Policy occurs in compliance with applicable legislation (e.g. prior to providing the personal data of third parties, users must inform them and obtain their consent to processing, if required by the legislation.
When users limit themselves to visiting and consulting the Websites without consenting to the use of profiling cookies, as defined below, we do not collect or process the users’ personal data because the processing is limited to only “browsing data” hat is data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified data subjects but which by their very nature could, through processing and associations with data held by third parties, make it possible to identify the users. This data category includes IP addresses, browser type, operating system, domain name and addresses of websites from/to which access or exit has been made, information on the pages visited by users in the Websites, access times, time spent on the single page, analysis of internal route and other parameters related to the user’s operating system and IT environment. These data are collected and used in an aggregate and anonymous manner for the sole purpose of improving the quality of the services offered on the Websites, optimising the functions of the Websites and preparing statistical information concerning use of the Websites.
The conferment of personal data for the “main purposes of processing” illustrated in section 2 is obligatory to be able to conclude a contract with us, to enable us to provide the service or product requested or to respond to users’ requests, and to be able to provide the after-sales support or be able to fulfil the legal obligations related to conclusion of the contract. In the case of non-conferment of the personal data, LGE will not be able to establish a contractual relationship with users, give execution to the same or to the aforesaid obligations. Conferment of the personal data for the “further purposes of processing” illustrated in section 2 (that is marketing purposes, profiling purposes and communication to third parties for marketing purposes) is optional. In the case of non-conferment of the same we shall not be able to send commercial communications and/or customised commercial communications to users, or communicate their personal data to our commercial partners, but there will be no negative consequences for users. In any case, users may at any time withdraw their consent for marketing purposes, profiling purposes and communication to third parties for marketing purposes and, with specific reference to marketing purposes, may withdraw their consent for all means of communication or only some of them using the methods indicated below or those indicated in each communication.
If users are already our customers, or in any case have already used services provided by LGE communicating to us their email in the context of the sale of a service or product, we shall be able to send commercial communications by email in relation to LGE’s products and services analogous to those involved in the sale of the service or product on the basis of our legitimate interest to perform this promotional activity and the user’s prior consent will not be necessary. Also in this case, users may object at any time to the sending of commercial communications using the methods indicated below or those indicated in each communication.
Observing the principle of purpose limitation and minimisation, users’ personal data may be communicated to the following third parties that perform activities functional to those related to the services offered by LGE through the Websites, such as:
• suppliers of assistance and consultancy services for LGE with reference to the activities of the technological, accounting, administrative, legal and insurance sectors;
• LG group companies (affiliates, subsidiaries, parent companies) with reference to the activities of the technological and administrative sectors;
• commercial partners that are part of the distribution chain of our products and services (postal couriers, call centres, marketing/PR agencies);
• Banks, credit institutions, financial and insurance brokers, credit recovery companies;
• public bodies and authorities whose right to access personal data is expressly recognised by law, or in regulations or measures issued by the competent authorities, including companies engaged in the collection of fair compensation for private copying;
• third parties that are potential buyers in the context of extraordinary operations (mergers, acquisitions, sales of business units) and related consultants;
• with the user’s consent, commercial partners for marketing purposes of the said third parties.
These recipients, as the case may be, process personal data as independent data controllers or processors. Users may request an updated list of data processors and recipients of their data contacting LGE using the methods described below.
LGE does not intentionally collect, process or store personal data of individuals under the age of 18 years, nor does it intentionally allow these minors to use the Websites. Minors under the age of 18 years are asked not to register on the Websites and not to provide their personal data. If we become aware that a minor under the age of 18 years has provided us with personal data, we act to promptly and definitively erase these data.
As part of a group with global operations, LGE, our affiliates, subsidiaries, parent companies and our suppliers may find that they are required to send users’ personal data out of the country where they are based. This may involve sending users’ personal data out of the European Economic Area (the European Economic Area is understood as the states of the European Union, plus Iceland, Liechtenstein and Norway). The transfer abroad of personal data is necessary to provide services to users and for the other purposes indicated in this Privacy Policy. The regulations regarding protection of personal data of some of the jurisdictions to which we transfer data may not guarantee the same level of protection that users enjoy within the European Economic Area. However, before transferring data out of the European Economic Area, LGE adopts adequate precautions, also of a contractual and technical nature, as defined by the applicable privacy legislation, in order to guarantee the protection, security and confidentiality of personal data to be transferred.
LGE adopts the Standard Contractual Clauses defined by the European Commission to transfer data to the parent company LG Electronics Inc. in South Korea.
Users may ask what contractual measures we adopt with reference to transfer of data out of the European Economic Area contacting LGE through the contacts indicated below.
We adopt all reasonable measures to store users’ personal data only for the time strictly necessary in order to provide services or to achieve the purposes for which the data have been collected, or to comply with legal obligations. We also apply specific criteria to determine the period of storage appropriate for the various categories of personal data provided by users.
We store personal data required to exercise our right to defence in the event of legal disputes, including personal data relating to a contract (as in the case of sale of a product) or provision of services, for the entire validity of the contract or service and for a period of up to 10 years after the end of the contract.
Recordings of telephone calls managed by our call centre are stored for a period of 90 days.
Recordings of audio/video data connected with the after-sales support service via the remote video-support system are stored for a period of 6 months from their acquisition.
If we have collected personal data based on the user’s consent and have no other valid legal basis to continue processing them, if the user withdraws consent, we shall erase the personal data affected by this withdrawal. For further information on methods for withdrawing consent, please consult section 8, below.
While it is always possible to withdraw consent at any time, as regards the processing of your data for profiling purposes, the profiles will be stored for a total period of 12 months.
At the end of the storage period established by LGE, the personal data will be deleted or made anonymous, unless the further processing is necessary to pursue other legitimate purposes of LGE (for example: the resolution of pre-disputes or disputes launched previously, the need to cooperate with investigations of the judicial authority or of the competent authorities launched before expiry of the storage period).
As indicated in section 3, above, under the terms of this Privacy Policy, LGE may process users’ personal data on the basis of express, free and optional consent given by the latter, in order to send communications for purposes of marketing, market research and studies into levels of customer satisfaction, as well as to carry out profiling with users’ data or to send them to our commercial partners for marketing purposes. If users wish to stop receiving communications for the purposes of marketing, market research or studies into customer satisfaction or do not want their personal data to be used for profiling or no longer want their data to be shared with third-party partners of LGE for marketing purposes, they have the right, at any time, to withdraw the consent provided for each of the aforementioned purposes. This withdrawal can be performed by users in various ways: by selecting the specific setting within the reserved area of the Websites, by following the instructions for de-registering illustrated in each marketing communication that users receive or by contacting the controller at the addresses indicated in section 12, below.
Regarding registration of calls managed through our call centre, users may object to recording of the call, by specifying this in real time to the operator as soon as possible.
Some sections of the Websites allow users to interact, through open-text-field messaging functions, with human operators or automated systems, e.g. the chat function or contact form. This functionality enables the provision of specific services to users making the request, e.g. to provide pre- and after-sales support or to provide information. We make all reasonable efforts to minimise collection of users’ personal data required for operation of the services and functionalities indicated above. Despite this, in order to avoid non-relevant personal data being processed by us (e.g. because they are stored in logs of chat sessions), users are recommended to provide only the data and information expressly requested by the operator or by the system (e.g. name, surname and contact details) or in any case the data and information strictly useful and necessary for provision of the service requested (e.g. product and model number or description of faults or problems with operation).
Users also have the option of publishing reviews (or editing reviews already published) through a specific function if available on the Websites. Users are reminded that, once published, the content (including the name or nickname entered by the author) will be publicly visible to all visitors to the Websites, without limitation. Users are therefore invited not to divulge personal information or data that they do not wish to be spread on the Internet.
The characteristics, functions and services offered by the Websites may change in the future. Consequently, this Privacy Policy may be updated at any time by LGE. LGE will notify users and visitors of the Websites of any changes made through a communication published on the Websites themselves. LGE invites users to visit this section regularly to keep up-to-date with the purposes and methods of processing their personal data. The previous versions of the Privacy Policy can be requested from LGE through the contacts indicated below.
LGE adopts security measures aimed at protecting the confidentiality of users’ personal data. However, due to the nature of the Internet, continuous technological developments and other factors outside our control, the security of data transmission via the Internet cannot be completely guaranteed. As a consequence, we cannot ensure or guarantee the security of the data and information that users transmit and users recognise and accept that this transmission takes place at their own risk. Users are also recommended to take appropriate precautions when using the Websites, such as keeping their access credentials strictly confidential and changing them periodically.
Under the terms of the Regulation, users have the right to make a complaint to the Personal Data Protection Authority according to the methods illustrated on the website https://ico.org.uk/.
In addition, users have the right to:
• ask for access to their personal data: they may have the right to obtain from us confirmation of the existence or non-existence of the personal data processing that regards them and, in the case of an affirmative answer, to request access to the personal data. The information accessed includes, among other things, the purposes of the processing, the categories of personal data involved and the recipients or categories of recipients to which the personal data have been or will be communicated. However, this is not an absolute right and the interests of other people may limit their right of access. They may have the right to obtain free of charge a copy of the personal data subject to processing. For further copies requested, we may charge a reasonable cost on the basis of the administrative expenses;
• ask for correction of their personal data: they may have the right to obtain from us the correction of inexact personal data that regard them. Depending on the purposes of the processing, they may have the right to have incomplete personal data completed, including by providing a supplementary statement;
• ask for cancellation of their personal data: in certain circumstances, they may have the right to obtain from us the cancellation of the personal data that regard them and we may be obliged to cancel these personal data;
• ask for limitation of their personal data: in certain circumstances, they may have the right to obtain from us the limitation of the processing of their personal data. In this case, the respective data will be marked and may be processed by us only for certain purposes;
• ask for the portability of the data: in certain circumstances, they may have the right to receive the personal data that regard them, which they have provided to us, in a structured format, in common use and readable by an automatic device and may have the right to transmit these data to another entity without being impeded by us;
• oppose the processing of their personal data: in certain circumstances, they may have the right to oppose, for reasons related to their particular situation, at any time, the processing of their personal data by us and we may be asked to stop processing their personal data.
LGE reminds users that limitations could apply to the above rights if an effective and concrete prejudice may derive from exercising the same, for example, to the interests of LGE or of third parties, and in the other cases provided for in the Regulation. Exercising these rights is free but LGE reserves the right to ask for a contribution in the case of manifestly unfounded or excessive requests, or to refuse to comply. To exercise their privacy rights or to request any information or clarification regarding this Privacy Policy, users may contact the data controller at the following address: LG Electronics Italia S.p.A., Via Aldo Rossi 4 – 20149 Milan; or at the email address: privacy.dati@lge.com
Users may also contact our Data Protection Officer at the following address: dpo-eu@lge.com
LG Electronics Italia S.p.A.
Via Aldo Rossi 4
20149 Milan
privacy.dati@lge.com
Last update: 13 December 2021
With the express, free and optional consent of the user, we may process personal data in order to perform marketing activities (directly by us or through our affiliates and commercial partners that act on our behalf) using automatic methods (email, newsletter and SMS/MMS) to inform users about special offers, updates and news on other products or services, to send users promotional material, and to perform market research and surveys into levels of users’ satisfaction regarding LGE products and services.
You are reminded that providing personal data for the aforementioned purposes is optional and refusal to provide this data will have no impact on the provision to users of services, functionality and information requested from or through the Websites.
Finally, you are reminded that users have the right to withdraw their consent at any time. For further information, please consult section 9 of the Privacy Policy for the Websites.
With express, free and optional consent of the user, we may share personal data with our commercial partners, specifically professionals specialised in the sale of insurance services, additional after-sales cover or warranty extension for LG-brand products. These partners, acting as independent data controllers, may contact users in order to offer or advertise products or services related or connected to the LG products purchased by the users.
You are reminded that providing personal data for the aforementioned purposes is optional and refusal to provide this data will have no impact on the provision to users of services, functionality and information requested from or through the Websites.
Finally, you are reminded that users have the right to withdraw their consent at any time. For further information, please consult section 9 of the Privacy Policy for the Websites.
With express, free and optional consent of the user, we may analyse users’ habits, interests and preferences in order to prepare profiles that will be used to offer services and to send commercial communications in line with the same;
You are reminded that providing personal data for the aforementioned purposes is optional and refusal to provide this data will have no impact on the provision to users of services, functionality and information requested from or through the Websites.
Finally, you are reminded that users have the right to withdraw their consent at any time. For further information, please consult section 9 of the Privacy Policy for the Websites.
