Haier

Protecting the personal privacy of every customer, vendor, and employee is a crucial part of gaining and keeping your trust in Haier Group Corporation. As a global operating organization, we strive to provide a high level of privacy protection across all of our businesses and services.

This Privacy Statement (“Statement”) does not apply to third-party applications, products, services, websites or social media features that may be accessed through links that we provide on our Apps. Accessing those links may result in the collection of information about you by a third party. We do not control or endorse those third-party websites or their privacy practices.  We encourage you to review the privacy policies of such third parties before interacting with them. 

Please read this Statement carefully. When using our services that link to or reference this Statement, you agree to be bound by the terms and conditions of this Statement.

Your personal data – what is it?

Personal data relates to a living individual who can be identified from that data. Identification can be by the data alone or in conjunction with any other data in the data controller’s possession or likely to come into such possession. The processing of your personal data is governed by applicable privacy laws.

What roles do we play in processing your data?

We are the data controller. Data controller means a Person or a juristic person having the power and duties to make decisions regarding the collection, use, or disclosure of the Personal Data. This means that we decide how your personal data is processed and for what purposes. We know that you care how data about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. 

When are your personal data collected?

Some of your data can, in particular, be collected by us:

· whenever you register to use our online services and become our customer;

· whenever you use our services and products;

· whenever you contact us via the various channels we offer you.

Our collection of personal data

The personal data we collect include any and all data you provide to us when you enter into contract with us, register an account with us, use our Apps or add information to your account, or give us in any other way. You can choose not to provide data to us, but we may then not be able to service you where such services require processing such data. We use the data that you provide for purposes administering your use of our services, such as communicating with you, responding to your requests, managing your account, customizing your service experience with us and improving our products and services. We may communicate with you by mail, email or telephone. We will send you strictly service-related announcements or information on rare occasions when it is necessary to do so.

Examples of the data we collect and store include:

When you register to be our user, we collect data you entered, including account (any field of information is acceptable), nation, etc.

When you use our Apps, we collect information including: for our after-sales service staff, in order to ensure the quality of service, we will collect the face information for face recognition and location.

We routinely back-up a copy your data to prevent loss of your data in case of a server breakdown or human error. However, all such copies of your data in our backup database will be retained only for as long as our data retention policy permits (see “How long do we keep your personal data?” below), and will in any case be deleted immediately upon your request.

How do we process your personal data?

We comply with our obligations under applicable privacy laws by keeping personal data up to date; by storing and destroying it securely; by collecting and retaining only the necessary data that we need to service you; by protecting personal data from loss, misuse, unauthorized access and disclosure and by ensuring that appropriate technical measures are in place to protect personal data.

The processing operations we perform on your data cover automated and non-automated means of collecting, recording, organizing, structuring, storing, altering, retrieving, using, transmitting, disseminating or otherwise making available, aligning or combining, restricting, and/or erasing your data.

We use your personal data for the following purposes:

· To design and deliver our services and activities to you.

· To operate our Apps to provide you access to and use of our services.

· To provide services and products requested by you as described when we collect the information.

· To contact you to conduct research about your opinions of current services and products or of potential new services and products that may be offered by us.

· To share your contact details with our affiliate offices around the world within our group companies, for the purposes of internal administration and back-office support, to ensure our network security, and to prevent fraud.

· To maintain the integrity and safety of our data technology systems which store and process your personal data.

· To provide anonymous reporting for internal and external customers.

· To provide you with location based personalized services (such as leave and back home function).

· To enforce or defend our policies or contract with you.

· To detect and investigate data breaches, illegal activities, and fraud.

What is our lawful basis for processing your personal data?

In general, the lawful bases for us to process your personal data for the various types of processing performed on your data (please refer to “How do we process your personal data?” section of this Statement) is, as applicable, processing based on your consent, as necessary for us to enter into and to perform our contract with you, or as necessary to pursue the legitimate interest of our company or of third parties.

We will collect, process and use the personal data supplied by you only for the purposes communicated to you and will not disclose your data to third parties except under the circumstances of data disclosure described in the “Sharing your personal data” section below.

Where we talk about our legitimate interest or that of third parties, such legitimate interest can include:

· Implementation and operation of a group-wide organizational structure and group-wide information sharing;

· Right to freedom of expression or information, including in the media and the arts;

· Prevention of fraud, misuse of company IT systems, money laundering or any other activities required by the competent authorities;

· Operation of a whistleblowing scheme;

· Physical security, IT and network security;

· Internal investigations; and

· Proposed mergers and acquisitions

Necessity to provide us data

You are not under any obligation to provide us any personal data. As noted below, the choice is yours. However, please note that without certain data from you, we may not able to undertake some or all of our obligations to you under our service contract with you, or adequately provide you with our full range of services. If you would like to obtain more detail about this, please contact us following the instructions in the “Whom should I contact” section below.

Sharing your personal data

Your personal data will be treated as strictly confidential, and will be shared only with the categories of data recipients listed below. We will only share your data with third parties outside of our company with your consent, and you will have an opportunity to choose for us not to share your data.  

We may disclose your personal data to:

· our affiliated entities within our global group of companies worldwide and authorized employee to provide you services such as facilitating order processing and shipping, for internal administration purposes, to detect and deal with data breaches, illegal activities, and fraud, and to maintain the integrity of our information technology systems.

· third party service providers whom we sub-contract to work on our behalf or for us and therefore may have access to your data only for purposes of performing these tasks on our behalf and under obligations similar to those described in this Statement, who perform functions such as data processing, auditing, order fulfillment, managing and enhancing customer data, providing customer service, conducting customer research or satisfaction surveys, logistics support, marketing support, payment processing and invoice collection support, informational systems technical support, to help us provide, analyze, and improve our services such as data storage, maintenance services, database management, web analytics, improvement of our service features, and to assist us in detecting and dealing with data breaches, illegal activities, and fraud.

· governments and/or government-affiliated institutions, courts, or law enforcement agencies, to comply with our obligations under relevant laws and regulations, enforce or defend our policies or contract with you, respond to claims, or in response to a verified request relating to a government or criminal investigation or suspected fraud or illegal activity that may expose us, you, or any other of our customers to legal liability; provided that, if any law enforcement agency requests your data, we will attempt to redirect the law enforcement agency to request that data directly from you, and in such event, we may provide your basic contact information to the law enforcement agency.

· third parties involved in a legal proceeding, if they provide us with a court order or substantially similar legal procedure requiring us to do so.

We may provide you with opportunities to connect with third party applications or services. If you choose to use any such third party applications or services, we may facilitate sharing of your information with your consent. However, we do not control the applications or services of those third parties or how they use your information, and your use of such applications and services is not governed by this Statement. Please review the terms and the privacy policies of those third parties before using their applications or services.

We will display your personal data and account activity in your profile page and elsewhere on our service portals according to the preferences you set in your account. You can review and revise your profile information at any time. Please consider carefully what information you disclose in your profile page and your desired level of anonymity. In your profile page, we will also display your device information as well as provide the network connection information for the devices to the applications that connect to your devices.  

How long do we keep your personal data?

We keep your personal data for no longer than reasonably necessary for the given purpose for which your data is processed. If you will provide us, or have provided us, consent for us to process your data, we will process your data for no longer than your consent is effective. Notwithstanding the above, we may retain your personal data as required by applicable laws and regulations, as necessary to assist with any government and judicial investigations, to initiate or defend legal claims or for the purpose of civil, criminal or administrative proceedings. If none of the above grounds for us to keep your data apply, we will delete and dispose of your data in a secure manner according to our data protection policy.

Privacy of data subjects  have limited or no legal capacity

Our products and services are not targeted to persons have limited or no legal capacity. We do not knowingly collect or process personal data from persons have limited or no legal capacity. Please note that if you are limited or no legal capacity, you will need to provide us a written signed consent from your parent or guardian indicating that your parent or guardian has consented for us to process your data and send us the consent through contact information provided from the section of “Whom should I contact?”

Your rights and your personal data

Unless subject to an exemption under applicable privacy laws, you have the following rights with respect to your personal data:

· The right to request that we correct any personal data if it is found to be inaccurate or out of date.

· The right to request to erase your personal data where it is no longer necessary for us to retain such data, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

· The right to withdraw your consent to the processing at any time, if and where we rely on your consent to process your data. This includes cases where you wish to opt out from marketing communications that you receive from us.

· The right to restrict our processing of your personal data where you believe such data to be inaccurate, our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.

· The right to object to us using your personal data, where the legal justification for our processing of your personal data is our legitimate interest. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defense of legal claims. 

· The right to lodge a complaint regarding our processing of your data, with the competent authority where you reside or in which your data is processed.

If you would like to exercise any of the above rights, please do so by providing your request to the contact window set forth in the “Whom should I contact” section.

After receiving your request, we will evaluate your request and inform you how we intend to proceed on your request. Under certain circumstances in accordance with applicable privacy laws and regulations, we may withhold access to your data, or decline to modify, erase, or restrict the processing of your data.

Please be advised that if you exercise the rights to erase data, restrict or object to our processing, or to withdraw your consent, we may not be able to continue our services to you if the necessary data is missing for processing.  

Transfer, Storage, and Processing of Data Abroad

As noted in the “Sharing your personal data” section of this Statement, as a part of a globally operating company, we may share your information with our affiliate companies or third parties.  Please refer to the “Sharing your personal data” section of this Statement for the recipients of your data and the reasons for our provision of your data to them. Where such entities are located in other countries and jurisdictions, we will therefore be transferring your personal data outside the country or jurisdiction where your personal data was collected. In making such data transfers, we make sure to protect your personal data by applying the level of security required by applicable privacy laws. Where we transfer your data to a country or jurisdiction that cannot guarantee the required level of protection as required by applicable privacy laws, we have enhanced our IT security measures to increase the protection of your personal data.

Further processing

If we wish to use your personal data for a new purpose not covered by this Statement, then we will provide you with a new notice explaining this new use prior to commencing such further processing for a new purpose, setting out the relevant new purpose and processing conditions. In such case, we will find a lawful basis for further processing, and whenever necessary we will seek your prior written consent to such further processing.

Security

We protect your data using technical measures to minimize the risks of misuse, unauthorized access, unauthorized disclosure, loss or theft, and loss of access. Some of the safeguards we use are data pseudonymization, data encryption, firewalls, and data access authorization controls. We take our data security very seriously. Therefore, the security mechanisms used to protect your data are checked and updated regularly to provide effective protection against abuse.

The information we collect are usually encoded. Moreover, we have put in place additional and comprehensive state-of-the-art security measures when your data are accessed via the internet. Firewalls prevent unauthorized access. Diverse encryption and identification layers protect your data from intrusion or disclosure to third parties during data transfer. Moreover, an electronic identifier is generated during data transfer to safeguard your information.

For your confidentiality and security, we use ID and password to secure your personal information. It is important for you to protect your ID, password, or any personal information. Do not disclose your personal information (especially password) to anyone. When you are finished using our services, please do not forget to log out from your account.

Despite our best efforts, however, security cannot be absolutely guaranteed against all threats. If you believe that the security of your data has been compromised, or if you like more information on the measures we use to protect your data, please contact us following the instructions in the “Whom should I contact” section below.

What are your choices?

You have the choice to allow us to collect and process your data. The collection and processing of your personal data is neither a statutory nor a contractual requirement, although as noted above, we will be unable to provide you with certain services without the data necessary for such services purposes.

You can always choose not to provide your data to us, although we may need such data to process your requests, in which case we will inform you of our constraints.  

To the extent that you have consented to our processing of your data, you can choose to discontinue our processing at any time.   

You can choose to add or update data that you have provided to us.   

You can choose to erase your data, or you may choose to restrict our processing of your data instead.

You can choose to object to our processing of your data.

Your choice or request on any aspects of data processing listed above can be communicated to us using the channels set forth in the “Whom should I contact” section of this Statement.

In summary, what we are allowed to do with your data is, with limited exceptions under applicable privacy laws, up to you. However, in the event that you choose for us not to further process your data, such choice may affect the delivery of our obligations or services to you; in this situation, we will inform you of our constraints.

Whom should I contact?

If you have any question about this Statement, or if you would like to exercise any of your rights, or if you have any complaints that you would like to discuss with us, please in the first instance send us signed and dated request, together with a copy of your identity card. Please be as accurate as possible:

by post to

Haier Group Brand Management Dept.

Ecosystem Brand Center of Haier Innovation Ecosystem Park, Laoshan District, Qingdao, Shandong, China

or

by e-mail to zhangxi@haier.com