We have certain legal obligations under the laws and regulations of the countries in which we collect, use, hold and/or processes your personal data. This Policy is designed to provide you with information on how and why we gather your personal data, the type of personal data we collect, what we use them for, when we might disclose them and how you can manage your personal data. If you are accessing and using the Website and/or the App from and/or visiting KEF’s Physical Locations outside the European Economic Area (“EEA”), by accessing and/or using the Website, downloading and/or using the App, as well as providing your personal information to us at KEF’s Physical Locations and via email correspondences outside the EEA, you are accepting our Policy below. If you do not agree to the terms of this Policy, please stop accessing or using the Website, or downloading or using the App, and do not provide your personal information to us whether through the Website, the App, at KEF’s Physical Locations, email correspondences or otherwise. If you are accessing and using our Website and/or App from within the EEA (i.e. including an EU Member State), or if you visit KEF’s Physical Locations and/or send email correspondences to us within the EEA, please refer to Section 13 of this Policy which applies in conjunction with the remaining Sections of the Policy.
If you are less than the age of majority in the country where you live, and:
- if you are accessing and using the Website and/or the App from and/or visiting KEF’s Physical Locations outside the EEA, you must have a legal representative such as a parent or guardian accept this Policy on your behalf.
- if you are accessing and using the Website and/or the App from and/or visiting KEF’s Physical Locations within the EEA, please refer to Section 13.1 of this Policy which applies in conjunction with the remaining Sections of the Policy.
We reserve the right to change the provisions of this Policy at any time and you should review the terms of this Policy from time to time. We will alert you that changes have been made by indicating on this Policy the date it was last updated and by publishing a notice regarding such changes on the Website and/or the App and/or by sending notifications to you via the App. Your continued use of the Website, App and/or KEF’s services following the posting or notification of changes to these terms will mean you accept those changes. If you have any questions about this Policy, you should contact us at email@example.com.
1. What and how personal data is collected from you
We generally collect two types of data from you: “Personal Data” and “Non-Personal Data”.
“Personal Data” is any information that can identify a person individually and includes, without limitation, name, e-mail and/or postal address, telephone number, user name, password, date of birth, gender, credit card number, billing and/or other contact information. Personal Data may be supplied to us at various instances including, without limitation, when you register for a membership account or purchase products as a guest on the Website, register and/or use the App, when you purchase goods or use our services at the KEF Physical Locations, as well as through other means such as those listed in section 1.1 below.
“Non-Personal Data” includes “aggregate” and/or automatic information, which is data collected about the use of the Website or App or about a group or category of users from which individual identities or other individually identifiable information has been removed. This Policy does not restrict or limit our collection, use and provision of Non-Personal Data.
1.1 Collection of Personal Data
The following are the most common situations when we may collect and store your Personal Data, and by using the Website and/or App and/or visiting KEF Physical Locations, you agree to us collecting your Personal Data through the following means, although these means are not exhaustive:
- registration to use the App and/or Website; - browsing, using, purchasing products, signing-up for KEF’s newsletters through the App and/or Website and/or otherwise using KEF’s services through the App and/or Website - visiting KEF’s point of sale locations and marketing campaigns (such as KEF Music Gallery, other KEF retail shops and pop-up stores, and other events and exhibitions) (“KEF Physical Locations”); - visiting KEF’s social media platforms, including but not limited to KEF’s Website, Facebook or Instagram page) and creating user-generated contents on those platforms (such as comments, discussions, likes, private messages, etc.); - submission of surveys and/or event questionnaires (e.g. via webforms on the Website) and entry into sales promotions; - registration for product warranties and maintenance services; - request for customer service or other assistance on the App and/or Website. - contacting us by email, post, fax or any other means of communication
We may also collect your Personal Data from social media sites: when you log in to use the App or Website or accesses KEF’s social media platforms (such as KEF’s Facebook or Instagram pages) using your Facebook or other social media accounts, we may collect the Personal Data that is made available to us on that page or account including your account ID / username, profile, mobile number and other information and activities about you on Facebook and/or other social media accounts. However, we will endeavour to comply with the privacy policies of the corresponding social media platform and will only collect and store such Personal Data that we are permitted to collect by these social media platforms.
In order for you to register for an account on our Website, you must provide us with your name, email address and password, or else you may not be able to sign up for such account. If you wish to purchase products on our Website, you must also provide us with your postal address, telephone number and payment verification information. Otherwise, we will not be able to process the order for you.
If any Personal Data provided by you do not belong or relate to you but to a third party, you hereby agree and confirm that you have provided a copy of this Policy to the third party to whom the personal data belongs or relates, who has read and agreed to all terms in this Policy, and that you have authority from such third party to provide the relevant personal data from us.
1.2 Collection of Non-Personal Data
When you use the App and/or Website, we and/or our data processors (which process non-personally identifiable data on our behalf) may keep an activity log that does not identify you individually and cannot be used to identify the identity of any particular visitor of the App and/or Website. Generally, we collect and store the following categories of data, which shall be considered Non-Personal Data to the extent that they do not fall within the definition of “Personal Data” under any laws applicable to our collection, holding, processing and/or use of your personal data: to the extent that the laws of certain jurisdictions treat this “Non-Personal Data” as Personal Data (for example under EEA Member State laws), KEF will comply with those laws, as described elsewhere in this Policy.
- device information about your mobile or other device that you use to access the App and/or Website. This information may include the device name, IP address of your device, your device’s operating system and version, your router name SSID (service set identifier), the type of mobile Internet browser you use, the browser’s type and configuration, the geo-location information and other unique device identifiers of the device accessing the App and/or Website, browsing preferences such as region, language settings, etc., as well as the App version accessed by you;
- device information about the speaker linked to the App and/or Website and/or linked to the device that you use to access the App and/or Website. This information may include the MAC (media access control) address, SSID and firmware of such speaker, as well as the speaker sound and volume settings;
- information about your use of the App and/or Website including without limitation the specific actions you take on the App and/or Website, the number of new or returning visits, statistics on the pages visited and referred, a reading history of the pages you have viewed, search terms used and search results, error and crash statistics, traffic data (such as time and date of access),
- information about the music played through the App, such as the names of music tracks and type of media files that have been played, name of media server, music source, playback time, etc.
We may collect, use and share to third parties (including those specified under section 4 below) these Non-Personal Data, including for customizing, enhancing, optimizing, maintaining and/or improving the quality of the App and/or Website, such as for determining the optimal screen resolution, language and font settings. To the extent that the above Non-Personal Data do not amount to personal data under any law applicable to our collection, holding, processing and/or use of your Personal Data, this Policy in no way restricts or limits our collection, use, handling and provision of such Non-Personal Data.
We use web analytics services including Google Firebase Analytics, Google Analytics and Google Adwords to obtain various types of non-personally identifiable demographics information from our App and/or Website users including, but are not limited to, gender, age, location and interests our App and Website users. These information are obtained for us to operate, maintain and/or improve the App and/or Website.
1.3 Collection of Your Source IP Address/Location Information
We may share the geo-location data of your device with our data processors for customizing, providing and improving our services and your browsing experience on the App and/or Website. When this type of data is shared with our data processors for the above purposes, the data do not individually identify you, and the other parties do not have access to your personally identifiable information.
Most browsers are initially set up to accept cookies. You can manage and adjust your cookies settings at any time by changing the browser setting (e.g. Google Chrome setting) for your device to disable cookies or clear all cookies and web browsing histories. However, if you choose to decline or disable cookies on your device, certain features and functionality of the App and/or Website will not work properly, e.g. the items added to your shopping cart may be deleted once you exit the App and/or Website.
We use the following types of cookies when you access our App and/or Website:
Essential cookies: These cookies enable you to use our Website and/or App; they are essential to enable you to browse our Website and/or App and use certain features. Disabling them may prevent you from using certain parts of the Website and/or App. These cookies also help keep our Website and App safe and secure.
Preference cookies: These cookies store information such as your location data and language selection, login data and website preferences. Without these cookies, our Website and/or App may not be able to remember certain choices you have previously made or personalize your browsing experience by providing you with relevant information. These cookies can also be used to recognize your device so that you do not have to provide the same information more than once.
Performance cookies: These cookies collect information about how you use our Website and/or App, such as which pages you visit regularly. These cookies are used to provide you with a high-quality experience by doing things such as tracking page load, site response times, and error messages. They are also used to gather feedback on customer satisfaction through surveys.
Content / advertising cookies: These cookies gather information about your use of our Website and/or App so we may improve your experience and provide you with more relevant content and advertising. They remember that you've visited our Website and/or App and help us understand how you use them. Some of these cookies are from third parties that collect information about users of our Website and App in order to provide advertising based on users’ online activities. The third parties involved in this type of advertising collect internet browsing information (e.g., websites visited, time of visit) across different websites and over time, and they may use the information they collect on our Website to provide you ads (from us and other companies) across the internet.
2. How we use your data
We may use your Personal Data and Non-Personal Data in the following ways:
3. Use of Personal Data in Direct Marketing
We also intend to use your Personal Data in direct marketing, but we will not do so without obtaining your prior consent. We and/or our data processors acting for and on our behalf may collect and use your name, gender, birthday, email and postal address, telephone number, company, job title, education, marital status,interests and purchase activity to provide you with information regarding our audio and electronic goods and services, if you choose to allow us to do so.
Our direct marketing activities may include communication by post, telephone, email, SMS, App notifications and/or other mobile communication applications (such as WhatsApp, WeChat and/or Line) about our App, Website, KEF Physical Locations as well as our products, services, newsletters, events, contests, competitions, surveys, offers and promotions connected with the audio and/or electronic goods and services provided by us.
When you first register for an account on the Website and/or the App or when you first provide your personal information to us at the KEF Physical Locations or through other means of communication such as email, if you do not want your Personal Data to be used for direct marketing purposes, please do not tick the checkbox which allows you to opt into our newsletters and/or direct marketing activities.
You may also change your mind and request that we stop sending you direct marking materials/communications or to cease using or providing your Personal Data for any direct marketing purposes at any time by following the opt-out / unsubscribe facility provided in our marketing materials or by emailing us at firstname.lastname@example.org. We will, at no cost to you, act on your request within 7 working days in order to ensure that you are not included in future direct marketing promotions.
We do not share, sell, transfer, provide, rent or trade Personal Data to or with third parties for their own direct marketing purposes unless we have obtained your consent in accordance with the requirements under the applicable law.
4. Who do we provide your data to?
We take measures to keep your Personal Data secure and confidential. We may share your Personal Data with the following third parties, and will only seek your consent to do so if this is required by your local law.:
-third party logistics company in order to arrange delivery of the goods you have purchased from our App, Website and/or KEF Physical Locations; - agents, contractors or other third-party service providers providing administrative, telecommunications, computer, payment, fraud prevention, insurance, data processing or other services to us in connection with the operation of our business (such as professional advisors, telemarketing companies, call center service providers, or data entry companies) - our affiliates or subsidiaries in the audio and electronics industry for the purposes mentioned in section 2 above; and - e-commerce platform providers on which KEF sells and/or offers its products for sale for the purpose of processing your purchase orders, sales delivery, conducting KEF’s marketing campaigns as well as any other purposes as specified under section 2 above for and on KEF’s behalf.
The above parties will only process your Personal Data for and on our behalf as set out in this Policy and will not process your Personal Data for their own purposes. They owe a duty of confidentiality to us and we require them to contractually agree to hold, process and use your Personal Data in compliance with this Policy and in accordance with our instructions.
We may also share your Personal Data with third party businesses in the event that all or substantially all of our assets are sold or transferred to another party, or another transaction occurs in which your personal information is one of the business assets transferred.
In addition, we may also share your Personal Data to third party websites, mobile apps or social media platforms (“Third Party Services”) if you choose to link or otherwise connect your KEF membership account or App with such Third Party Services. If you choose to connect your KEF membership account or App with any Third Party Services such as Facebook, you will be sharing your Personal Data with these Third Party Services. We are not responsible for, have no control over and shall not be liable for how the Third Party Services will use, process or share your Personal Data. You should make sure you read and agree to their respective privacy policies before connecting with any Third Party Services and only connect your KEF membership account or App with Third Party Services that you trust.
We may also disclose your Personal Data to law enforcement agencies, regulatory bodies, or other people or entities if such disclosure is reasonably necessary to (i) satisfy any applicable law, regulation, legal process or enforceable governmental request including but not limited to those under the applicable law; (ii) detect, prevent or otherwise address fraud or security issues; or (iii) protect against harm to the rights, property or safety of us, our subsidiaries, affiliates or the public as required or permitted by law.
5. Children’s privacy
We do not knowingly collect personal information from children aged under 13 or individuals under the age of majority in the country that they live. If you believe that we have inadvertently collected such information, please contact us at email@example.com so that we can promptly obtain parental consent or remove the information.
6. Data Security
Physical records of your Personal Data will be stored in a secure location with restricted access. Electronic copies of your Personal Data will be stored on servers maintained by us and/or our third party service providers, which are situated in secure locations and protected by adequate data security measures (for example, sensitive data is encrypted before being transmitted over the Internet). The App, the Website and the computers and servers that supply data to the App and/or Website incorporate reasonable safeguards to protect the security, integrity, completeness, accuracy and privacy of the Personal Data that we may collect and we have put into place reasonable precautions to protect such information from loss, destruction, misuse, unauthorized access, disclosure and alteration.
We take reasonable administrative, physical and electronic measures designed to safeguard and protect your information from unauthorized access or disclosure. This includes utilizing Secure Sockets Layer (SSL) software, which encrypts the Personal Data and information you input (such as Website log-in details), and storing your information in an encrypted form behind a firewall designed to block access from outside our network.
However, while we try our best to safeguard your Personal Data once we receive it, no security or encryption method can be guaranteed to protect information from hackers or human error, and no transmission of data over the Internet or any other public network can be guaranteed to be 100% secure.
7. Storage or processing of data
The information that we collect may be stored or processed on computers or servers located in Hong Kong, Shanghai, United Kingdom, United States, as well as any country where we do business. If you are accessing the Website and/or the App from and/or visiting KEF’s Physical Locations outside the EEA, by providing us with your Personal Data or by accessing and using the App and/or Website, you consent to the transfer of your Personal Data to our facilities outside of the country in which you have provided your Personal Data to us. The personal data protection laws of those countries where your Personal Data are stored might not be as stringent or comprehensive as those in your country, but we will take all reasonable steps to ensure the protection of your privacy and will only collect and use your Personal Data for the purposes which are set out in this Policy.
If you are accessing the Website and/or the App from and/or visiting KEF’s Physical Locations inside the EEA (i.e. including an EU Member State), please see Section 13, below, for information about our international data transfer practices.
8. Your obligation to keep your access rights secure
If you register an account on our Website and/or App, you are entirely responsible for ensuring and protecting the security and confidentiality of your password and account. You are also entirely responsible for any and all activities that occur under your account and we shall not be held liable for any claims, loss or damage resulting from a breach of the foregoing or any unauthorized use of your account.
9. Data retention
We will not keep your Personal Data for longer than is necessary to fulfil the purposes and any directly-related purposes for which such Personal Data is collected. We will take into account any legal obligations that require us to retain the Personal Data for a certain period of time as well as the duration of your use of our Website and App. If you wish to de-register from our Website and/or App, amend or update your Personal Data, or request that we no longer use your Personal Data to provide you with the information or services you have requested, please contact us at firstname.lastname@example.org.
10. Links to third party websites
Our Website and/or App may contain links to third party websites. These links are provided solely as a convenience. KEF does not endorse any third party websites. Access to any other website through any links provided on our Website and/or App is at your own risk. KEF is not responsible for the content of any such websites or the accuracy or reliability of any information, data or other contents of those websites. We encourage you to consult the privacy policies of any third party websites that you visit.
11. Access to, update and withdrawal use of Personal Data
If you are accessing the Website and/or the App from and/or visiting KEF’s Physical Locations outside of the EEA, please note that you may exercise your right to know whether we hold your Personal Data, what type of Personal Data is held and request access to, correction of, or deletion of your Personal Data held by us. If you wish to:
- have access to your Personal Data, for which we may charge a reasonable fee for complying with your request; - correct any Personal Data relating to you which is inaccurate; or - withdraw your consent to the use of your Personal Data by us (however, withdrawing consent may affect your access and use of our App and/or Website),
If you are accessing the Website and./or the App from inside the EEA (i.e. including an EU Member State), please see Section 13, below, for information about your rights as a data subject.
12. Controlling your Personal Data
You can stop our collection of information by the App by opting-out using the functions in the App. You may also stop our collection of information by the App and/or Website by uninstalling the App and by cease using the Website. To uninstall the App, you may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network.
You may always opt-out of receiving communications from us. We provide you with the opportunity to opt-out of receiving communications at the point where we request information about you and/or provide communications to you, or you can contact us via email@example.com.
13. Users from the European Union
This section of the Policy only applies if you are accessing and using our Website and/or App from and/or visiting KEF’s Physical Locations in the EEA (including an EU Member State). It supplements the information in the rest of the Policy, above.
GP Acoustics International Limited is the data controller in respect of the processing of users’ Personal Data collected through the Website, the App and/or at KEF’s Physical Locations.
13.1 Legal basis for processing of Personal Data
We describe in Section 1 what types of Personal Data we collect from you. In Section 2, we describe the purposes for which we use and process that Personal Data. In this section we set out the legal bases on which we rely for processing the Personal Data.
We rely on the following legal bases for processing Personal Data about you when you visit our Website, App from and/or the KEF Physical Locations in the EEA (including an EU Member State):
It is in KEF’s legitimate interests to:
Process your contact information, user name and password for the purposes of registering you to our Website and/or App, verifying and managing your account, including sending you information about your account.
Process your name and contact details as described in this Policy in order to provide you with information that you seek from KEF about our products and services, including contacting you with information regarding purchases you have made with us and arranging delivery of products, as well as customer service support information and information about changes to our policies or terms and conditions.
Process your information such as gender, date of birth, location, company, job title, education, marital status and interests, when you choose to provide some or all of this information to us, in order to understand the demographics of users of our App and/or Website and to verify your account.
Process information that you choose to publish on our App, Website or our social media platforms in order to contribute to our marketing campaigns.
Process your financial information (including account information and purchase activity) in order to fulfil your orders and in order to prevent fraud and other illegal activities on our Website and/or App.
Using information about your visits to and usage of our Website and/or App (including your IP address, browsing preferences, device information, unique device identifiers, geolocation information and other information about your use of the Website and/or App), visits to the KEF Physical Locations and information you provide us in surveys, marketing research questionnaires and/or focus groups in which you choose to participate in order to customize, enhance and optimize your experience on the Website and/or App and to help us to provide, maintain, optimize and improve the Website and/or App and improve your experience at the KEF Physical Locations.
Monitor compliance with our terms and conditions of use on our Website and/or App and monitor any illegal activity on our Website and/or App.
Performing a contract that we have entered into with you to provide you with the information, products or services that you have requested or purchased from us (or won, in the case of contests, competitions or promotions that you have chosen to enter), including fulfilling our maintenance services and customer and/or technical support services obligations to you.
Complying with applicable laws and regulations and KEF’s legal obligations such as accounting and tax requirements.
Where necessary, we will procure your consent for processing certain Personal Data (for example, with respect to electronic marketing communications, as described in Section 3, above, and with respect to the use of geolocation data, if you choose to enable location tracking on your device, as described in Section 1.3, above). If we process your Personal Data on the basis of your consent, you may subsequently withdraw that consent at any time by the means indicated at the time consent is procured and/or by emailing us at firstname.lastname@example.org. This does not affect the lawfulness of the processing that occurred on the basis of your earlier consent, before its withdrawal.
You are not required to provide KEF with Personal Data when you visit or use our Website and/or App or when you visit the KEF Physical Locations, but if you do not do so in the circumstances described above, we will not be able to provide you with certain information you request or with all of our products and services, and you will not be able to use all the features of our Website and/or App.
13.2 International data transfers
Please note that your Personal Data may be transferred to KEF affiliates or subsidiaries operating in countries outside the EEA, including but not limited to the United States, Hong Kong, China, Singapore, Taiwan, Japan and Dubai. In addition, the service providers and other third parties with whom KEF may share information (as described in Section 4) may be based outside the EEA. Data protection laws may or may not apply in jurisdictions outside the EEA or may not be as stringent as those in the EEA. In any case, KEF will implement appropriate contractual measures (such as standard data protection clauses, a copy of which you can obtain by contacting email@example.com) to ensure that the relevant KEF entities and third parties outside the EEA provide an adequate level of protection to your Personal Data as set out in this Policy and as required by applicable local law.
13.3 Your rights as a data subject
You are entitled to request access to, rectification or erasure of Personal Data relating to you or restriction of processing or to object to processing of such Personal Data and other rights in accordance with applicable law. You may also ask for your Personal Data to be ported to third parties in accordance with applicable law. If you wish to enforce your rights, please contact us at firstname.lastname@example.org. We will provide you with a response in accordance with applicable data protection law. KEF may refuse to provide such information in limited circumstances under applicable local law.
You also have the right to lodge a complaint before your local data privacy authority should we violate applicable data privacy laws(s) in our processing of your personal information.
14. Enquiries / Contact Us
This Policy applies to the collection, use, holding and processing of your personal data by us, which includes the following entities:
- GP Acoustics International Limited - GP Acoustics GmbH - GP Acoustics (China) Limited - GP Acoustics (HK) Limited - GP Acoustics (Singapore) Pte Ltd - GP Acoustics (Taiwan) Limited - GP Acoustics (UK) Limited - GP Acoustics (US) Inc. - GP Acoustics (Middle-East) DWC-LLC - KEF Japan Inc
If you have any questions or complaints, or if you wish to access or correct your Personal Data or withdraw your consent to the use of your Personal Data held by us, or exercise any of your other rights, please contact our Data Manager at email@example.com.
If you are a data subject in the EEA (including an EU Member State), you may also contact us by post via any one of the following addresses closest to you:-
GP Acoustics International Limited 9/F, Building 12W,Hong Kong Science Park, New Territories, Hong Kong
GP Acoustics GmbH Kruppstraße 82-100, 45145 Essen
GP Acoustics (UK) Limited Park House Crawley Business Quarter Manor Royal Crawley West Sussex RH10 9AD United Kingdom
GP Acoustics (US) Limited 10 Timber Lane Marlboro, NJ 07746