Privacy Notice

We are delighted that you have shown interest in our company and products. Group (as defined below) takes your data protection rights very seriously and we are committed to improving your customer experience in compliance with all applicable data protection laws and regulations.  Please find below our Privacy Notice, which explains the way we process your personal data.

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We are Arçelik A.Ş., a company incorporated under the laws of Italy, having its registered office in Via Varesina n.204, 20156 Milano (MI), Italy, a part of the Group ("Whirlpool", "us" or "we").  In our capacity as data controller, we intend to provide the users of our websites, our apps and/or our home appliances that connect to the Internet (respectively, “Website”, “App” and “Smart Appliances”) and any other individual interacting with us ("Users", "you" or "your"), with information concerning the methods used for collecting and processing personal data, in accordance, with the European General Data Protection Regulation no. 679/2016 ("Regulation") and any other applicable local laws and regulations.

“Group” means the group of entities to which Whirlpool belongs.

We may modify or update this Privacy Notice also in order to comply with applicable laws.

Where applicable, we will process your personal data we have collected or been provided with for the following purposes:

allowing you to register on the Website or on the App by opening a personal account, to register a product on the Website and to purchase a product on the Website;

providing you with the Smart Appliance services, including notifications for purposes of assistance and maintenance and communications functional to using your account or your Smart Appliance, including those related to customer services and the warranty;

completing the online purchase of the product and providing additional services (after-sale services, extended warranty, the prevention of fraud, the management of returns, contact you in case of a security issue related to your household appliance);

performing the home delivery of our products and providing you with any requested services;

arranging for a repair on your product;

managing the requests for information you send us, including handling complaints and communications received via our interactive chat service;

entering a prize promotion / competition;

complying with the statutory provisions and regulations and enforcing our own rights before the courts;

sending you customized marketing communications related to our products and services electronically (including email, SMS, MMS, social network notifications, mobile applications). Email marketing is based on consent. However, depending on the country in which you are located, certain e-mail marketing activities may be based on Whirlpool’s legitimate interest (soft opt-in);

contacting you for marketing purposes by phone (non-automated) and via paper mail. Such processing may be based on your consent or on Whirlpool’s legitimate interest (in such a case you are granted with the right to opt-out);

for the purpose of sending you customer care communications concerning products registered by you or which you showed interest in and in order to carry out customer satisfaction surveys;

upon your consent, sharing your personal data for customized marketing communication with our selected trusted partners as set forth in Section 6 below;

carrying out activities useful for the transfers of business and business branches, takeovers, mergers, demergers or other transformations and for the execution of such transactions;

for internal training, documentation purposes and quality control / assurance purposes we might listen to the recorded phone calls made to our consumers’ call centers

1.The provision of the personal data for the purposes under Section 2, para. a), b), c), d), e), f) and g) is necessary for the purpose the data was provided or shared with us, which includes but is not limited to the registration on the Website, the online purchase of products and the use of ancillary specific services, as well as the participation to prize promotions and competitions. The legal basis for such processing of personal data is the performance of a contract of which you are part or the fulfilment of a request made by you;

2.The provision of personal data for the purposes under Section 2, para. h) is mandatory since required to comply with the applicable laws. The legal basis for such processing of personal data is the compliance with a legal obligation;

3.The provision of the personal data for the purposes under Section 2, para. i), l) and n) is optional. Unless otherwise provided for by the law applicable in the country in which you are located, without your consent Whirlpool, the companies part of the Group and/or trusted partners will not be able to send you customized marketing communications via automated means, nor record the phone calls you made to our consumers’ call center. In any event, upon the withdrawal of the Users' consent we will no longer process the personal data for which we rely on your consent;

4.The provision of personal data for the purposes under Section 2, para. j), k) and m) is necessary to pursue the legitimate interests of Whirlpool and the Group, which will be appropriately balanced with your interests. We may also use, in compliance with the applicable data protection laws, your electronic contact details (email) we collected in the context of a sale of a product or service, in order to send you marketing communications related to similar products or services. In such a case, you may object to such use of your electronic contact details by clicking the “unsubscribe” link at the bottom of the email / SMS at each time the customized marketing communication is sent; or in accordance with Section 9 of this Privacy Notice below. Unless otherwise provided for by the law applicable in the country in which you are located, our legitimate interest is the legal basis on which we rely for the processing of your personal data for the purposes described herein.

Whirlpool will process the personal data for as long as it is necessary to achieve the intended purposes pursuant to Section 2 above. In any case, the following retention periods shall apply:

1.the data collected for the purposes of Section 2, para. a), b), c), d), e), f) and g) will be retained for the period strictly necessary in order to respond to data subjects' requests and comply with applicable laws and regulations;

2.the data collected for the purpose of Section 2, para. h) will be retained for the period mandatorily prescribed by the applicable law provisions (e.g., for tax purposes);

3.the data collected for the purposes of Section 2, para. i) and l) will be retained for the maximum data retention period set forth by the applicable law provisions; and

4.the data collected for the purposes of Section 2, para. j), k) and m) will be retained for the period strictly necessary in order to pursue Whirlpool business interests.

5.the data collected for the purposes of Section 2 para. n) will be retained for no longer than the period set forth by the applicable laws.

Please consider that data retention periods may vary, depending on the applicable local laws.

We will share your personal data with our trusted partners, such as our extended warranty providers, that intend to use it for direct marketing purposes only when we have specifically informed you and you have given us specific consent to do this.

We may share your personal data with:

1.companies of the Group located in the EEA and outside the EEA, acting as autonomous controllers;

2.our carefully chosen third party suppliers located in the EEA and outside the EEA, such as call centre operators, content rating service providers, shippers, suppliers of services or technicians assigned to assistance and other suppliers working on our behalf in the role of duly appointed data processors for the purposes described in this notice; other third parties as part of a corporate transaction such as a merger or sale of assets;

3.our extended warranty provider Domestic & General (“D&G”) [Domestic & General Insurance PLC ].  D&G will act as joint controller (along with Whirlpool) for the purpose of promoting and sale of extended warranties, as well as handling repair requests pursuant to such extended warranties. In particular, D&G will process the personal data for the following purposes: (i) register and manage your account / profile, as well as manufacturers’ warranties; (ii) promotion, sale and administration of service contracts and products / services; (iii) in certain countries, handle and respond to inbound customer service calls and update such data with information from such consumers; (iv) take and receive personal data from consumers to make sales of service contracts, and update such data with information from consumers; (v) handle and respond to inbound consumer complaints (including any litigation); (vi) to manage bookings and provision of repair services and supply replacement products to consumers and correct and update such data with information from consumers in connection with such repair services and/or the provision of replacement products and/or to update such personal data; (vii) carry out surveys on the quality of the products and services performed.

4.Third parties providing e-payment services, for the purpose of managing the payments related to your orders. For the sake of clarity, Whirlpool does not process any banking / financial data (including credit card information) of the Users, save for those strictly necessary for the purposes of Section 2, para. c) (e.g. to provide consumers with extended warranty).  In connection with such processing, third parties providing e-payment services will process your personal data as autonomous controllers, in accordance with the Regulation (and any other applicable local laws and regulations) and their own respective privacy policies.  Whirlpool shall not be liable for any damage (including those arising from the violation of the Regulation and any other applicable data protection law) arising from the processing of Users’ banking / financial data (including credit card information) by said third party providing e-payment services.

5.For the distribution, repair and maintenance service of our products we share our Users’ address and contact data with our partners only when strictly necessary;

6.We may also be required to disclose personal information in response to lawful requests by government authorities, including requests from national security agencies or law enforcement.

Such third parties will process your personal data on our behalf in the role of duly appointed data processors (with the exception of what is detailed at letter d)) for the purposes described in this notice in accordance with our data privacy and security requirements and are not allowed to use personal data they receive from us for any other purpose.  

Any transfer of your personal data outside the EEA (both within and outside Group) is carried out based on the following suitable safeguards in accordance with the Regulation:

When the European Commission has issued an adequacy decision; or

appropriate safeguards have been provided by or to the Group company exporting your personal data including but not limited to standard data protection clauses. Without prejudice to the foregoing, transfer based on standard data protection clauses is featured by additional organizational and technical measures, designed to ensure an adequate level of protection of your personal data.

You, at any time and at no charge, can have and/or exercise the following rights:

the right to be informed on the purposes and methods of the processing of your personal data;

the right of access to your personal data (commonly known as “data subject access request”). This enables you to receive a copy of the personal data we hold about you;

the right to ask for updating or rectification of the personal data 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;

the right to request erasure of your personal data. This enables you to ask us to delete or remove your 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 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;

the right to restrict the 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;

the right to object to the processing, wholly or partly, of your personal data where we are relying on 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;

where we are relying on consent to process your personal data, the right to revoke the consent to the processing of your personal data freely and at any time, also by clicking on the unsubscribe option at the bottom of our marketing communications;

the right to data portability of your personal data to you or to a different provider. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format;

the right to contact us by sending us an email at data_protection_emea@europeanappliances.com or using our contact us form and

the right to lodge a complaint in front of the competent national data protection or judicial authority.

If you wish to exercise the rights mentioned above, or raise any questions about the personal data we hold about you, please send us an email at data_protection_emea@europeanappliances.com or write to us at: Arçelik A.Ş., Via Varesina n.204, 20156 Milano (MI), Italy, with the addition “for the attention of the Data Protection Office”. Where available, you can also use our contact us form .

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, you have the right to contact the competent national data protection or judicial authority as described above in Section 9 on the Rights of Data Subjects.  You also may contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request..