“Personal Data” refers to any information that may be used, alone or in combination with other information, to identify you. For purposes of this Privacy Policy, we consider all of the below information we collect about you "Personal Data". When you use the HomeWhiz Application and the Services, we may – as detailed further below in this Privacy Policy and only to the extent permitted by applicable law – collect certain Personal Data relating to you, including your name, surname, e-mail address, user name and password, phone number, identity authentication information (password, token), IP address, the country where you live and your location, your appliances supporting the HomeWhiz Application and the Services, the software used together with the HomeWhiz Application, the operating data about the appliance in connection with which the HomeWhiz Application is used, such as when and how long the appliance is used, the appliance’s sensor data such as water hardness levels, power mains data, the appliance’s temperature levels, the operating data about the components of the appliance, any appliance error information such as errors and alerts displayed and when such errors and alerts are displayed, information about the devices such as smart TV, smartphone or tablet on which you run the HomeWhiz Application and the identification details of such devices like MAC number and serial number, and updates to the HomeWhiz Application and other related software.

To the extent permitted by applicable law, we use your Personal Data for the following purposes and based on the following legal bases: Contractual necessity We may process your Personal Data where it is necessary to enter into a contract with you for the provision of our products or services or to perform our obligations under that contract. For example, we may need to process your Personal Data: i. To register you and to enable you to use the HomeWhiz Application and the Services; ii. To send you important notices such as correspondence on changes to our HomeWhiz Terms of Service and this Privacy Policy (via email or push notifications); and iii. To keep internal records on software updates, technical services and other transactions to the extent necessary for the provision of the HomeWhiz Application and the Services. If you do not provide us with certain Personal Data for processing as described above, we may not be able to provide the service or product requested. Legal obligation We may be required by law to collect and process certain Personal Data about you. For example, we may need to process and disclose your Personal Data when we have a good faith believe that doing so is necessary to comply with applicable law or to respond to a valid legal process, including from law enforcement or other government agencies. Our legitimate interests We may process your Personal Data where it is necessary for our legitimate interests as a company, including to manage, promote and improve our business and manage our and our users’ risk. For example, we may process your Personal Data: i. To inform you of any new product or service of the Company and its affiliates and subsidiaries, by sending notices, advertisements or pictures through e-mail, SMS and other similar electronic communication means or via the HomeWhiz Application and the Services, unless your consent is required for such communications (see below). If you would prefer not to receive these communications, simply follow the unsubscribe instructions in the promotional communications that you receive or contact us as described below; ii. To enable us to analyse and improve the HomeWhiz Application and the Services and our other products and services, contents and advertisements; iii. To enforce the HomeWhiz Terms of Service and this Privacy Policy, including investigating potential violations; iv. To detect, deter or otherwise address any fraud or security issues related to the HomeWhiz Application or the Services; and v. To provide you additional warranty based on the usage of the appliance. Your consent Where required by applicable law, we will seek your separate consent to process your Personal Data for specific purposes. For example, we may seek your separate consent to send you direct marketing messages or to collect location data to offer location-based services. We may also seek your separate consent to create a profile of you to personalise and improve our appliances and other products, services and advertisements, including providing you with personalised marketing communications and advertisements, as well as content recommendations (e.g., recipe suggestions) and to provide you with improved and better-targeted after-sale services. We create this profile by combining the Personal Data collected under this Privacy Policy with the data we obtain from other sources, such as data obtained via our sales teams and technical service units, and data obtained via your other devices (e.g., information relating to your home appliances, smart home devices and electronic home devices). Some appliances are able to be connected to internet prior to your download and use of HomeWhiz Application. Once you link your internet connected appliance with the HomeWhiz application, we will combine previously collected data (e.g. IP address, Appliance Mac ID, Serial number, Usage history, Error data, Sensor data with your HomeWhiz account, subject to your consent. If we have sought your consent to process your Personal Data, you may subsequently withdraw it at any time by contacting us using the contact details listed in the section below on How to Contact Us without affecting the lawfulness of processing based on consent before its withdrawal.

Your Personal Data will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements. If a deletion of your Personal Data would only be possible with unreasonable efforts, we will anonymise it instead of deletion. We will not collect Personal Data about you that is not necessary for the purposes it is collected for.

Subject to the following paragraph, and as already mentioned above, we may use your Personal Data for marketing purposes, in particular to display to you or present you with advertisements and promotional materials, to conduct free prize draws and prize competitions, or to provide you information about our new products and other such information which we believe may be of interest to you based on your use of and your interests in our Services, always provided that such use complies with applicable law. Depending on the jurisdiction you reside in and in accordance with applicable law in your country, we will ask you to expressly consent to receiving marketing material or product information before we send you any marketing or promotional material. You can change your mind about your preferences in respect of direct marketing at any time by using the unsubscribe button on every marketing communication, by updating your user profile or account data or by contacting us at as detailed in the section below on How to Contact Us. If you do so, note that we will not remove your Personal Data from our databases to the extent that this Personal Data is still required by us under the terms of this Privacy Policy or otherwise to continue to provide our Services to you.

The Company may collect the location of your device through the HomeWhiz Application and the Services in order to provide location-based services, such as automatic operation of HVAC devices while you are arriving at or leaving home. Your location can be determined based on the public IP address of the device or GPS. Where required by applicable law, we will seek your separate consent to collect and otherwise process such location data.

When you use the HomeWhiz Application and the Services, you may also use several applications, software and services provided by various third parties (such as the provider of the device on which the HomeWhiz Application runs or the providers of other software running on the same device). Such applications, software or services may process your Personal Data and they are subject to their own terms of use and privacy policies for which the Company does not assume any responsibility. If you choose to use the third-party applications, software or services, the providers of such third-party applications, software and services will have access to a minimum amount of Personal Data about you that is necessary to connect the HomeWhiz Application and the Services to that third-party application, software or service. For example, if you choose to connect your HomeWhiz Application with your Amazon account, Amazon will have access to your account information (i.e., email address) and device ID information. Similarly, if you choose to use advanced after-sales services, certain Personal Data, such as information about the appliance on which the HomeWhiz Application is installed (e.g., type of appliance, your usage of the appliance and performance of the appliance) is shared with third-parties for purposes of providing the customized after-sales services.

We may share your Personal Data in accordance with applicable law in the following cases: i. Other Arcelik group companies. We may share your Personal Data with other companies belonging to the Arcelik group who may use your Personal Data for the purposes set out in this Privacy Policy. ii. Business partners. We may disclose your Personal Data to third parties, such as business partners and suppliers where this is necessary in order to provide the Services to you. For example, we may disclose your Personal Data to third parties to be able to provide you with advanced after-sale services and repair services. For more information, see above section on Data Processed by Third-Party Applications, Software or Services. iii. Third parties where required by law. We may disclose your Personal Data to a third party if it is necessary to comply with a legal obligation or the decision of a judicial authority, public authority or a government body, or if disclosure is necessary for national security, law enforcement or important public interest. iv. Service providers. We may disclose your Personal Data to companies that provide services to us, such as companies that provide cloud computing services. The service providers are required to keep your Personal Data confidential and are not permitted to use your Personal Data for any other purpose than to carry out the services they are performing for us. v. Third parties in connection with a business sale. If we make a sale or transfer of assets, or are otherwise involved in a merger or transfer, we may transfer your Personal Data to one or more third parties as part of that transaction. vi. Other third parties with your consent. We may also share your Personal Data with other third parties when you consent to such sharing.

Your Personal Data will be processed by Arcelik A.S. who is located in Turkey. In addition, when we share your Personal Data with other companies belonging to the Arcelik group or other companies with whom we contract (as described in the section above on Sharing of Your Personal Data with Third Parties), such companies may also be located outside the European Economic Area (“EEA”), the UK, and Switzerland in countries with different laws for the protection of Personal Data than the laws in your country of residence. Before transferring your Personal Data outside the EEA, the UK, and Switzerland, we will take steps to ensure that such data will be afforded the same level of protection as under applicable data protection laws within the EEA, the UK and Switzerland. For data transfers outside of the EEA, the UK and Switzerland, the Company uses applicable safeguards, including the standard contractual clauses adopted by the European Commission, where appropriate, and will make available a copy to you upon request. We will not make your Personal Data available to third parties for any purposes other than as described in this Privacy Policy and we will not sell your Personal Data.

The Company takes appropriate administrative, technical and physical measures to protect your Personal Data against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. We protect the security of your Personal Data by using encryption and password protection where appropriate, and limiting access to your Personal Data. 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 Personal Data transmitted to us using unsecured means; any transmission is at your own risk. You should also continue to take appropriate steps to keep your Personal Data safe and secure, such as keeping your password and other user identification safe and secure, in particular by avoiding obvious user ID's or passwords, by changing your password regularly and by ensuring that you do not disclose your password(s) or grant any other person access to your user account.

Our Services may contain some services or links that may direct you to third-party websites, services or external content resources, who may have different and less stringent privacy policies. These privacy policies are outside of our control and we are not responsible for the processing of your Personal Data by such third-party websites, services or external content resources. We urge you to read their privacy policies before providing any personally identifiable information to such third parties.

The Company may change and update this Privacy Policy from time to time. The Company will notify you of any material changes or additions to this Privacy Policy and will provide you with a copy of the amended Privacy Policy by use of your email address provided to the Company, or by any other suitable means which ensures that you will be notified of any material changes to this Privacy Policy.

You can display the content of the latest "HomeWhiz Privacy Policy" on the HomeWhiz Application. If you withdraw your separately declared consent to specific processing operations, you may not be able to use all functions of our Services.

You have the following rights with respect to your Personal Data we process, subject to conditions set out in applicable law: a) to learn whether your Personal Data is processed by us and, if processed, to request a copy of your Personal Data and information relating to the processing of your Personal Data, including the purposes of processing your Personal Data and whether such data is used for intended purposes and the third-parties to whom your Personal Data is disclosed; b) to request the correction of any inaccurate or incomplete Personal Data; c) to request the erasure of your Personal Data or the restriction of the processing of your Personal Data; d) to object to any further processing of your Personal Data; e) to withdraw any consent you have given without affecting the lawfulness of processing based on consent before its withdrawal; f) under certain circumstances to demand data portability; g) to lodge a complaint with a supervisory authority; and h) to contest certain automated decisions we make about you that have legal or otherwise similarly-significant consequences. We do not typically carry out such automated decision-making but, if we do, we will make it clear where such decisions are being made. To exercise your rights, you can use the contact details as indicated in Section 14 below.