Panasonic Privacy Notice
The Privacy Notice applies to services, devices, products, websites or applications that refer to or link to the Privacy Notice (collectively, our “Services”) and will apply whether you access our Services using a computer, mobile phone, tablet, TV, or other device.
1. Who are we?
Panasonic Energy Europe NV, with registered address at Brusselsesteenweg 502, 1731 Zellik, Belgium and registration number 0414.688.361 (“Panasonic”, “we”, “us” or “our”);
We are part of the Panasonic Corporation, headquartered in Kadoma, Osaka Prefecture, Japan;
2. What is Personal Information?
For the purposes of this Privacy Notice, "Personal Information" consists of any information that relates to an identified or identifiable individual (such as you). For example, information which identifies you may consist of your name, address, telephone number, photographs, payment details, a specific Panasonic product/device identification number that you purchased, location data, an online identifier (e.g. cookies and your IP address) Information which does not identify you on its own but that we link to you also qualifies as Personal Information.
3. What Personal Information does Panasonic collect about you?
A. Personal Information you provide directly about yourself
Some Services we offer enable/require you to give us your Personal Information.
When you create a Panasonic account on our websites, applications
When you create a Panasonic account on a Panasonic website or application, we ask you to provide certain Personal Information, such as your gender, first name, last name, email address, date of birth and country of residence. The required specific information may vary on the service you have chosen.
When you register a product or device with Panasonic
If you choose to register the relevant product or device with us in order to enable certain features or benefit from any extended warranty or promotion. In order to register your product or device we may collect Personal Information, such as your name, address, phone number, email address and information about the Panasonic product or device you own, such as its serial numbers (or other product/device identifier) and the date of purchase.
When you communicate with Panasonic
When you contact us or interact with our customer support representatives via email, live chat, telephone or in person, we may collect Personal Information, such as your name, mailing address, phone number, email address and contact preferences; and we may also collect information about the Panasonic products or devices you own, such as their serial numbers and date of purchase. We also may create logs/reports that are useful in diagnosing product or application performance related issues, and capture information relating to the issue. We use this information to provide you with customer and product support. We may access your 'My Panasonic' Account, or other relevant Panasonic accounts, in order to provide you with the necessary assistance or support you require or have requested. We may also record and review your conversations with our customer support representatives (e.g. when you contact us by telephone), for training and complaints handling, and also to review any information you have provided in response to a voluntary customer survey(s). We will only record and/or review your conversations with us where we are permitted to do so by applicable laws and we will tell you that we are doing so at the start of the conversation at the latest.
Message boards and forums
Some Panasonic websites and applications have message boards, forums, bulletin boards, chat functionality, blogs, and similar features ("Community Postings") through which you can post information, messages and other materials. When you disclose any Personal Information through such services we recommend you to be very careful as this may become public information and be available to visitors to our websites and to the general public.
In order to participate in Community Postings we collect certain Personal Information, which includes your name, username, password, email address, date of birth and contact details (e.g. email address, telephone number) and in certain cases product information such as model and serial number and any other information that you decide to communicate on such Community Postings.
Promotions, games, prize draws and competitions
If you enter into sweepstakes, contests, online games, prize draws, competitions or online promotions, e.g. cash back ("Activities"), we may use the Personal Information you provide to administer the Activities which includes, your first name, last name, address, email address, date of birth and country of residence.
To the extent that the terms and conditions of any such promotion regarding the treatment of Personal Information about you conflict with this Privacy Notice, the terms and conditions of the promotion will prevail and we advise you to review any Activity specific terms and conditions carefully.
Subscriptions and newsletters
Where you subscribe to our promotional communications and newsletters we will collect Personal Information from you including your email address, first name, last name and gender. We will only provide such subscription services to you in accordance with applicable laws and where you have expressly requested us to do so.
When you upload Personal Information to a Panasonic website or online application
In addition to the above, we may collect such other Personal Information that you provide by uploading content (e.g. videos or photos) onto our websites or online applications. In such cases, the following Personal Information may be collected in order to publish the content on the our websites or online applications: your name, email address, invoicing details as proof of evidence (e. g. for some online promotions) and any Personal Information in the content that you choose to upload. Where we collect such content we will only do so in accordance with applicable laws.
B. Information about your use of the Services
We may collect information about your use of our Services through software on your Panasonic device/product and other means, or your use of our online applications. For example, we may collect:
- Device/product information - such as your hardware model, the MAC address of the device’s wireless network interface and the mobile phone number used by the device in case you contact Panasonic mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, and other unique device identifiers, IP address, operating system details, and settings of the device you use to access the Services.
- Log information - such as the time and duration of your use of the Service, search query terms you enter through the Services, and any information stored in cookies that we have set on your device (such as your pc, mobile phone or tablet) or our application.
- Location information - such as your product or device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services. Some of our location-enabled Services require your Personal Information for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose at the time of data collection. You can withdraw your consent at any time by altering the settings in your device/product.
- Voice information - such as recordings of your voice that we make and may store on our servers when you use voice commands.
- Other information - about your use of the Services, such as the online applications you use, the websites you visit, and how you interact with content offered through our Services.
C. Personal Information from third party sources
We may receive Personal Information from third parties (i.e. other companies), for further details on this please see the following additional information:
Information from publicly available sources
We may receive Personal Information about you from publicly available sources, provided the receipt of such information is in accordance with applicable laws, which we may combine with other information we receive from or about you.
When you login to account with your social media credentials
We also may receive information about you from social networking sites when you choose to connect with those sites.
Panasonic Account allows you to sign up and log in using your Facebook, Youtube [or other social network] account. If you do so, you allow Facebook [or other social network account] to share certain Personal Information from your Facebook account with us. This Personal Information includes your name, gender, general location, a link to your Facebook profile, your time zone, your date of birth, your profile picture, your “likes” and your list of “friends”. This Personal Information is collected by Facebook, as controller, is provided to us and become subject to this Privacy Notice.
We recommend that you become familiar with Facebook functioning so as to know how you can control your Personal Data and its sharing by Facebook with us using any privacy setting in your Facebook account.
4. On which legal basis do we process Personal Information?
We are not allowed to process Personal Information if we cannot rely on a valid legal ground. Therefore, we will only process your Personal Information when:
- we have obtained your prior unambiguous consent;
- the processing is necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
- the processing is necessary to comply with our legal or regulatory obligations;
- the processing is necessary to protect your vital interests or those of another natural person;
or the processing is necessary for our legitimate interests except where they are overridden by your interests or fundamental rights and freedoms. Examples of such ‘legitimate interests’ include:
- to benefit from cost-effective services (e.g. we may opt to use certain platforms offered by suppliers);
- to protect the security of our IT systems, architecture and networks; and
- to meet our corporate and social responsibility objectives.
5. How do we use your Personal Information?
We may use the Personal Information we collect for the following purposes:
- Create an Account/Log in on our Websites, Applications– to enable you to create a profile on our websites, applications, and to enable you to log in to such websites, and applications
- Registering products/devices - to register you or your device or product for any of our Services;
- Provide our Services - to provide our Services or any specific feature that you request, including to enable us to fulfil our obligations under any contract with you (such as, any product or device warranty);
- Surveys – to ask for your opinions or comments on our Services and to conduct other surveys;
- Marketing activities - to provide you with newsletters and other communications by post, email, telephone and/or text message (SMS), only if you have provided your consent or we are otherwise permitted to do so under applicable law.
- Profiling – to make predictions about your interests and provide you with direct marketing on that basis;
- Advertising - for advertising, such as providing customised advertisements and sponsored content and sending you promotional communications;
- Analysis Purposes - for assessment and analysis of our market, customers, products, devices and other Services (including asking you for your opinions on our products and services and carrying out customer surveys);
- Statistics – to create anonymous, aggregated statistics about the use of our Services. This anonymised data may be shared with third parties;
- Service Improvement – to develop and improve new and existing Panasonic products and Services, recommendations, advertisements and other communications and learn more about your preferences;
- Customer Support Services - to provide customer support services for your device or product, or to deal with any other support queries you may have (such as complaint handling);
- Business Purposes - for business monitoring and internal record keeping;
- Publish your comments – where you upload product or device reviews, comments or content to our websites or applications, or where you have responded to a voluntary survey, we may link to, publish or publicise your comments including in our own advertisements;
- Security – to protect our customers (e.g. to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of Panasonic, including enforcing any terms or agreements governing the use of our Services;
- Legal Obligations - to comply with our legal obligations under European Member States laws or under European Union law;
- Competitions and Promotions - to conduct Activities and record your participation thereto, as permitted by law as well as to provide your Personal Information to our partners and sponsors of such Activities;
- Training – for staff training and quality assurance purposes, particularly in relation to our customer support representatives;
- Updates - to communicate with you, including communicating with you about your account, profiles or transactions with us, giving you important information about your products, devices, application or other Services, sending you notices about any material changes to our Privacy Notice;
- Combining Personal Data – to combine Personal Information we collect from you, for example to allow us to provide better support services and more personalised content;
- Corporate Transaction – to manage corporate transactions involving our company including reorganisation, merger, transfer, sale, joint venture, assignment or other disposition of all or any portion of Panasonic's business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.
6. To whom and where do we disclose your Personal Information?
We will not disclose your Personal Information to third parties for their own independent marketing or business purposes without your consent. However, we may disclose your Personal Information to the following entities:
A. Third party recipients of the Personal Information
We may need to transfer your Personal Information to other Panasonic Affiliates to provide the Services you require or any other services/assistance you request. All Panasonic Affiliates are required to follow the privacy practices set forth in this Privacy Notice.
We may share your Personal Information with our carefully selected business partners, including wireless carriers. These partners may use your Personal Information to provide you with Panasonic Services you request (such as, video content), make predictions about your interests and may provide you with promotional materials, advertisements and other materials.
We use third party service providers to help us to administer certain activities and services on our behalf, such as fulfilling your purchases and delivering products, administering Activities, processing credit card payments, sending postal mail and emails, sending text messages (SMS), providing advertisements, analysing usage of our Services, tracking effectiveness of our marketing campaigns, allowing users to connect to their social network, providing fraud checking services and customer support services. We may share Personal Information about you with such third party service providers solely for the purpose of enabling them to perform services on our behalf and they will operate only in accordance with our instructions. Here are examples of third-party service providers we use:
- Email Service Providers – Cloud services from e.g. Eloqua by Oracle are used to assist us in sending emails to you in accordance with your marketing preferences;
Social Network Providers
We may provide your Personal Information, such as your email address, to certain social networking providers so that they can help us display advertisements about our Services on your social network pages. We will only share your Personal Information with social networking providers in accordance with your marketing preferences and any applicable laws.
Third parties when required by Law or to Protect our Services
We will disclose your Personal Information to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies; to protect our customers (e.g. to prevent spam or attempts to defraud users of our Services); to operate and maintain the security of our Services (e.g. to prevent or stop an attack on our systems or networks); or to protect the rights or property of Panasonic, including enforcing any terms or agreements governing the use of our Services.
We prepare and develop anonymous, aggregate or generic data and statistics for various reasons (as indicated in this Privacy Notice). As this data is anonymous (i.e. you cannot be identified from it) we do not consider this information to be Personal Information. As such, we may share it with any third party (such as our Affiliates, partners, advertisers or otherwise).
Other Parties With Your Consent or At Your Direction
We may share Personal Information about you with third parties when you consent to or request such sharing.
A number of Panasonic's Services give you the option and ability to upload and share certain Personal Information, such as, messages, photos, videos and other content. Any Personal Information that you choose to upload and share on a publicly accessible profile may be viewed and accessed by others. As such, you should always exercise caution when using such Panasonic Services.
B. International Transfer of Data
The Personal Information that we collect from you may be stored and processed in your region, or transferred to, stored at or otherwise processed outside the European Economic Area ("EEA"), including but not limited to Canada and Japan or in any other country which do not offer an adequate level of data protection as recognised by the European Commission and where Panasonic or its Affiliates, subsidiaries or service providers maintain facilities.
Where we transfer your Personal Information outside the EEA, we will ensure that suitable safeguards such as appropriate transfer agreements and mechanisms (such as the EU Model Clauses) are in place to help ensure that our third party service providers provide an adequate level of protection to your Personal Information. You may request additional information in this respect and obtain a copy of the relevant safeguards upon request through sending a request to the contact indicated in the Contact Us/Further Information section of this Privacy Notice, below.
7. What do we do to keep your Personal Information secure?
Panasonic have put in place appropriate physical and technical measures to safeguard the Personal Information we collect in connection with our Services. These measures take into account:
- the state of the art of the technology;
- the costs of its implementation;
- the nature of the data; and
- the risk of the processing.
The purpose thereof is to protect against accidental or unlawful destruction or alteration, accidental loss, unauthorized disclosure or access and against other unlawful forms of processing.
However, please note that although we take appropriate steps to protect your Personal Information, no website, product, device, online application or transmission of data, computer system or wireless connection is completely secure and therefore we cannot guarantee the security of your Personal Information.
All Personal Information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain Services, you are responsible for keeping this password confidential and we ask you not to share your password with anyone.
C. Other security measures
Information security, including the protection of Personal Information is organized in a global Panasonic Program called “Information Security Management” (ISM). The related aim, standards and implementation measures are organized in globally valid policy, standards and guidelines. All central European IT systems are externally assessed and fall under the information security management rules applicable under the ISO 27001 certification. The program in all its parts follow a strong yearly PDCA (Plan-Do-Check-Act) approach to secure the confidentiality, integrity and availability of all data (including your Personal Data) for the whole information lifecycle from collection to destruction of such data.
D. Using social media and forum features
Certain Services include social networking, chat room or forum features. You should ensure that when using these features that you do not submit any personal Information that you do not want to be seen, collected or used by other users.
8. What are your rights and how can you exercise them?
A. What are your rights?
Panasonic will collect, store and process your Personal Information in accordance with your rights under any applicable data protection laws.
Your rights under the GDPR include, the right to access a copy of your Personal Information, the right to request the correction or the update of any inaccurate Personal Information and the right to object to the processing of your Personal Information under the conditions set out in applicable law..
You also have the right to request the erasure of your Personal Information and, where you have consented to the processing of your Personal Information, you have the right to withdraw such consent at any time (without this withdrawal affecting the lawfulness of the processing prior to such withdrawal).In addition, you also have the right to data portability in certain cases. This is the right to request the return of the Personal Information you have provided to us in a structured, commonly used and machine-readable format and to request the transmission of such Personal Information to a third party, without hindrance from us and subject to your own confidentiality obligations.
B. Exercising your rights
If you wish to exercise any of the above rights, please contact us by using any of the communication means below in the Contact Us/Further Information section of this Privacy Notice.
If you are not satisfied with how we process your Personal Information, you may contact us using any of the communication means below in the Contact Us/Further Information section of this Privacy Notice or alternatively you may file a complaint with the competent supervisory authority, in addition to your rights outlined above.
9.Data Retention – How long we will store/keep your Personal Information
We will retain your Personal Information for the period necessary to fulfil the purposes for which your Personal Information has been collected as outlined in this Privacy Statement unless a longer retention period is required by law. When your Personal Information is no longer required for the purpose it was collected or as required by applicable law, it will be deleted and/or returned to you in accordance with applicable law.
10. Third-Party Links and Products on Our Services
A. What are cookies?
B. Further information on cookies
12. Your Choices (e.g. marketing related emails or otherwise)
We and other Panasonic Affiliates may use your Personal Information (such as your contact details (e.g. first name, last name, gender, address, email address, telephone number)) to send you marketing-related correspondence by post, email, telephone and/or text message (such as SMS) related to Panasonic products, devices and other Services in accordance with your email and contact preferences or as you otherwise agree to.
When you purchase Panasonic products or devices, contact our customer support representatives, create an account or profile for one of our Services, or subscribe to one of our Services, you may be given the opportunity to opt-in to (or where permitted by applicable law, opt-out of) the receiving of such marketing-related correspondence.
We do not share Personal Information with third parties for the third parties’ marketing purposes.
We may also use your Personal Information to personalise and to target more effectively our marketing communications to ensure, to the extent possible, that any marketing-related correspondence is relevant to you.
To opt out of receiving marketing-related correspondence from Panasonic, please update your email and contact preferences or click "Unsubscribe" from any marketing or promotional email you receive from us.
13. Children's Personal Information
A. Who is a child?
Panasonic considers a child to by anyone under the age of 16, or such younger age as may be specified by applicable data protection laws.
B. Do we collect Personal Information from children?
We do not knowingly collect or try to collect Personal Information from or about children without the consent of a parent or guardian. Where we do collect Personal Information from children, we will always use reasonable efforts to verify that consent has been given or authorised by the child's parent or guardian.
C. What do we do when children submit Personal information to us?
If we become aware that Personal Information that has been submitted to us relates to a child without the consent of a parent or guardian, we will use reasonable efforts to:
delete that Personal Information as soon as possible; or
if deletion is not possible, we will ensure that this Personal Information is not used for any purpose, nor disclosed further to any third party.
D. Parent or guardian queries
If you are a parent or guardian and you have queries regarding Panasonic's processing of your child's Personal Information, please contact us using the details provided in the “Contact Us/Further Information” section below.
14.Changes to this Privacy Notice
Panasonic may change this Privacy Notice from time to time. The “Date last updated” at the bottom of this page states when the notice was last updated and any changes will become effective upon our posting of the revised Privacy Notice.
We will provide notice to you if these changes are material and, where required by applicable law, we will obtain your consent. We will provide this notice by email or by posting notice of the changes on the Panasonic website or through any relevant Services.
15. Contact Us / Further Information
If you have any questions regarding the collection, processing, or use of your Personal Information or if you wish to correct, block, rectify, object, access, revoke your consent to any applicable aspect of this Privacy Notice or delete any of your Personal Information, please contact us:Panasonic Energy Europe Ltd.
1731 Zellik Belgium
Registered No. 0414.688.361
Date last updated : 28 September 2018