Last Updated: 31st May 2018
Optoma Europe respects your privacy and is committed to protecting your personal data. This privacy notice outlines the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and will also tell you about your privacy rights and how the law protects you.
We provide products and/or services to both consumers and businesses which includes, but is not limited to, the supply of visual and audio products. This privacy notice relates to our processing of your personal data where you are our customer or are a prospective customer (whether as an individual/ consumer or as an authorised representative of a business) or are a third party who interacts with us (including by visiting our website).
Optoma Europe Ltd (company number: 03399395) is the data controller and is responsible for your personal data (collectively referred to as “Optoma Europe”, “we”, “us” or “our” in this privacy notice).
If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.
Our full details are:
Full name of legal entity: Optoma Europe Ltd
Email address: GDPR@optoma.co.uk
Postal address: 1 Bourne End Mills, Hemel Hempstead, HP1 2UJ
Telephone number: 01923 691 800
You have the right to make a complaint at any time to a supervisory authority in Europe, in particular in a country where you live or work or where your legal rights have been infringed. In the UK, the Information Commissioner’s Office (ICO) is the supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the relevant supervisory authority so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
We may change this privacy notice from time to time. Any changes we make to this privacy notice in the future will be posted on our website and, where appropriate, notified to you by email. This version was last updated on 31st May 2018.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you depending on the nature of products and/or services we are providing and what we are contracted to do for you or the business on whose behalf you are acting. We have grouped together the types of personal data as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
The products and/or services which we provide together with our website are not intended for children and we do not knowingly collect any data relating to children. It is possible that we could receive information pertaining to children by the fraud or deception of a third party. If we are notified of this, as soon as we verify the information, we will, as required by law to do so, immediately obtain the appropriate parental consent to use that information or, if we are unable to obtain such parental consent, we will delete the information from our servers. If you would like to notify us of our receipt of information relating to a child, please do so by contacting us.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you or the business on whose behalf you are acting and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you or the relevant business (as the case may be). In this case, we may have to cancel such products and/or services but we will notify you or your business (as appropriate) if this is the case at the time.
We use different methods to collect data from and about you including through:
Information collected from you about other people
When you provide personal information to us which does not relate directly to you but is personal information of a third party (for example, details of other officers or employees where our customer is the business on whose behalf you are acting), you confirm that you are authorised to do so and shall ensure that this privacy notice is brought to the attention of such individuals at the earliest opportunity so that those individuals understand how their personal data will be used by us. We will hold and use such personal information in accordance with this privacy notice and data protection laws.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
We do not use your information for automated decision making.
Generally, we do not rely on consent as a legal basis for processing your personal data except in those circumstances set out in the table below relating to sending direct marketing communications via email or as otherwise set out in this privacy notice. You have the right to withdraw consent to marketing at any time by following the links on any marketing message sent to you or by contacting us at GDPR@optoma.co.uk.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we may use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at GDPR@optoma.co.uk if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To communicate with you in connection with our products and/or services, for example, responding and dealing with your enquiries and requests through our website including online forms and enquiry submissions
(a) Performance of a contract with you where you are an individual/ consumer, sole trader or a general or limited partnership
(b) Necessary for our legitimate interests where you are acting on behalf of a company or a limited liability partnership (LLP) (to enable us to assist you and provide you with the best possible service)
To deliver products and/or services to you where we have contracted directly with you or to deliver products and/or services to your company/LLP where you are acting on its behalf
(a) Performance of a contract with you where we have contracted directly with you as an individual/ consumer, sole trader or a general or limited partnership
(b) Necessary for our legitimate interests where you are acting on behalf of a company or an LLP (to perform the contract and run our business effectively and to enable us to provide the best possible service)
To manage our relationship which will include:
(b) Asking you to complete a survey following delivery of our products and/or services
(c) Responding to any complaints raised in respect of the products and/or services provided by us
a) Performance of a contract with you where we have contracted directly with you as an individual/ consumer, sole trader or a general or limited partnership
(b) Necessary to comply with a legal or regulatory obligation
(c) Necessary for our legitimate interests (to keep our records updated and to evaluate customer feedback for the purposes of developing and growing our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
To use data analytics to improve our website, products, services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and/or services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you by email about services that may be of interest to you/your business
(f) Marketing and Communications Data
(a) Your consent to the processing where you are an individual/consumer, sole trader or a general or limited partnership.)
(b) Necessary for our legitimate interests (to develop our products and services and grow our business) where you are a representative of a company or an LLP which is an existing customer of ours and have not opted out of marketing messages
We have set out below further information on the meaning of each of the legal bases for processing set out in the third column of the table above:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to provide the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at GDPR@optoma.co.uk.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means processing your personal data where you have provided a freely given, specific, informed and unambiguous indication of your agreement to us processing your personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing. You will only receive marketing communications from us if we have a lawful basis for sending such marketing, details of which can be found in the table above.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at GDPR@optoma.co.uk.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at GDPR@optoma.co.uk.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with selected people or organisations for the purposes set out in the table in paragraph 4 above. This will include, but is not limited to, sharing personal data with:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Optoma Group. This may involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by implementing certain safeguards.
Please contact us if you want further information on the specific safeguards used by us when transferring your personal data out of the EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy, which is available upon request by contacting us at GDPR@optoma.co.uk.
In some circumstances you can ask us to delete your data: see ‘Request erasure’ below for further information.
Furthermore, in some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us at GDPR@optoma.co.uk.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
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