Groupe SEB Vietnam Joint Stock Company (the “Company”, “we, “us”) attaches great importance to the protection of your privacy. In the course the Company activities, especially when you interact with us and/or with our products, we process information that can directly or indirectly relate to you (“personal data”). The purpose of this notice is to provide you with information about the processing of your personal data by the Company.

1. Scope

This information notice applies to all clients and/or potential clients of the Company.

2. Categories of personal data

In accordance with the principle of relevance and personal data minimisation, the Company will only process personal data that are strictly necessary for the purposes listed in this notice.

Such personal data belong to the following categories:

• “Identity Data”, such as your first and last name, date of birth and gender;
• “Contact Data”, such as your billing and/or delivery address, email address and telephone number;
• “Household Data”, such as number of persons in your household, number of children, marital status;
• “Correspondence Data”, such as emails or letters sent between you and the Company;
• “Financial Data”, such as your bank account references or your payment card details;
• “Products and Services Data”, such as details about products and/or services you have purchased from us;
• “Profile Data”, such as your usernames and passwords, purchases or orders made by you, your interests, feedback and survey responses;
• “Usage Data”, such as information about your use of our websites and/or applications;
• “Technical Data”, such as information collected when you access and/or use our websites and/or applications, your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, application version, operating system and platform and other technology on the devices you are using;
• “Geolocation Data”, such as the geolocation of IoT products whose functions are depending on their location (such as air quality analysis, etc.);
• “Marketing and Communications Data”, such as your marketing and communication preferences. We also track when you receive and read marketing communications from us and which of our events you attend, which information we use to improve our marketing services, provide you with more relevant information and improve the quality of our marketing materials. Additional information about the personal data we process in connection with marketing is included with the marketing communications we send you;
• “Professional Information”, such as your job title, professional email address, professional phone number and professional post address;
• “Special Categories of Personal Data”, such as well-being data or dietary preferences, which we process in very limited circumstances, for example, where required to do so for legal or regulatory purposes (e.g.: we can ask you for your dietary requirements if we are arranging catering for you).

In most cases, this data is collected directly from you. However, it can also be collected from third parties (e.g. other entities of the Company, etc.)

3. Purposes and legal basis

The Company processes personal data belonging to the above-mentioned categories for the following purposes:

Purposes	Legal basis
To create your user account and your login, if you already have an account on a site / application of the Company or another Groupe SEB company.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your prior to entering into a contract.
To use information about your habits, customs and behaviour to send you personalised information and offers, respecting your choices on this matter.	The processing is based on your consent.
To give you information or provide a service appropriate to your location.	The processing is based on your consent.
To respond to your searches and information requests about the products and services we sell, including through the use of our online chat tool.	The processing is necessary for the purposes of the following legitimate interests: to continually improve our products and services.
To manage all your orders placed on our sites / applications and in particular to dispatch and track the products ordered, print invoices and process any complaints.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your prior to entering into a contract.
To offer you personalised content and offers on the sites / applications that you are likely to be interested in (notably based on personal data collected via the use of cookies or similar technologies).	The processing is based on your consent.
To let you participate voluntarily in questionnaires, surveys or tests relating to our products and services.	The processing is based on your consent.
To let you participate voluntarily in games or quizzes or receive reimbursement and sponsorship offers on our sites / applications.	The processing is necessary for the performance of a contract to which you are a party or in order to take steps at your prior to entering into a contract.
To understand the uses made of our sites / applications and improve their operation (notably based on personal data collected via the use of cookies or similar technologies).	The processing is based on your consent.
To manage your subscription to a mailing list (newsletter).	The processing is based on your consent.
To allow you to share information from our sites / applications by e-mail or on social networks.	The processing is based on your consent.
To allow you to leave a comment or review on our sites / applications.	The processing is based on your consent.

In some cases, we will produce statistics, market research and analyse trends in order to improve our products and services. To do so, we will use anonymized information in aggregated format, which means it will not be possible to personally identify you directly or indirectly.

4. Provision of personal data

Generally, the provision of your personal data is voluntary. However, in certain circumstances, the Company can be required by law to process your personal data in order to comply with applicable legislation. In other cases, even where the collection of your data is not required by law, we have to collect your data because it is a contractual requirement, or a requirement necessary to enter into a contract with you. Thus, if you refuse to provide us with the related personal data, the Company would not be able to sell its products to you/provide you with its services.

5. Recipients of personal data

Your personal data can be shared with other entities of Groupe SEB (a list of Groupe SEB brands is available at this address: https://www.groupeseb.com/en/our-brands).

Additionally, in compliance with the applicable data protection legislation, personal data can be shared with third-party recipients belonging to the below categories:

• commercial partners (such as companies participating in co-branding events with the Company);
• technical providers (such as hosting, security and IT monitoring companies, software providers);
• marketing services suppliers (such as advertising agencies, reviews/verified reviews providers, market research consultants, or companies allowing us to organize prize draws, competitions and/or promotions);
• client relationship providers (such as customer services companies, account management providers, sales support providers);
• sales and logistics suppliers (such as sales support, logistics and/or transportation companies);
• professional advisers or consultants (such as external auditors, lawyers, bankers, accountants and insurers);
• successor company in the event of a merger or and acquisition; and,

more generally, any person or entity to whom we are required to make such disclosure by a court of competent jurisdiction or by a governmental, taxation or other regulatory authority, law enforcement agency or similar body.

6. Transfers of personal data

When they are not located in your country of residence, the recipients mentioned above are generally located in the European Economic Area and/or in countries that provide an adequate level of personal data protection.

However, in some instances, personal data can be transferred to a country not ensuring a sufficient level of protection of privacy. In this case, the Company will ensure that appropriate safeguards are put in place, such as the use of “standard contractual clauses” as adopted by the European Commission (more information can be obtained at the following address: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).

Where required, we will also ask for your consent to the transfer of your personal data.

7. Personal data retention

Your personal data will only be kept for as long as necessary to fulfil the purposes we collected it for (taking into account applicable statutes of limitations for the establishment or defence of legal claims).

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.

In some circumstances we can anonymise your personal data (so that it can no longer be directly or indirectly associated with you) for research or statistical purposes in which case we are allowed to use this information indefinitely without further notice to you.

8. Your rights

You have the following rights in relation to the processing of your personal data:

• Right of access, which means you can ask to access all or part of personal data relating to you.
• Right of rectification, which means you can ask us to correct personal data relating to you that is inaccurate or not up to date.
• Right of erasure, which means that, in certain circumstances, you can ask us to delete all or part of personal data relating to you, in particular where they are no longer necessary for the performance of the purposes for which they have been collected.
• Right of objection, which means that, in certain circumstances, you can object to the processing of personal data relating to you. However, we draw your attention to the fact that we can have to continue processing such personal data if there are compelling legitimate grounds or for the establishment, exercise or defence of legal claims.
• Right of restriction, which means that you can, in certain circumstances, request personal data relating to you to be processed in a limited way, where you are disputing the accuracy of personal data, if you have raised an objection to processing, if processing of personal data is unlawful and you oppose erasure and request restriction instead or if the personal data is no longer required by us but you require the personal data to be retained to establish, exercise or defend a legal claim.
• Right to portability, which means you can request personal data relating to you to be exported in a machine-readable format to a third party, when their processing is carried out by automated means and is based on a contract or your consent.
• Right to withdraw consent, which means that, when a processing is based on your consent, you can withdraw said consent at any time. However, such withdrawal will not affect the lawfulness of processing activities before its withdrawal.

You can exercise those rights by clicking on the data management link on your customer page, by going directly to the “Contact us” page of our websites, or by contacting our customer service via the telephone number provided on the relevant application.

Finally, you have the right to lodge a complaint with the supervisory authority in your country of residence or where you believe that a problem relating to the use of your personal data has occurred.

9. Your marketing preferences

In accordance with your preferences, if you have consented to receive such communications, we can send you promotional and commercial offers likely to interest about products and services offered by the Company or other Groupe SEB brands, by post, e-mail, SMS and push notifications, and from our partners, when applicable.

You can choose not to receive such marketing messages at any time, via the unsubscribe link present in the relevant communications, via the parameters of your smartphone or tablet, or by logging into your customer page.

10. Contact us

You can contact the Company at the following address:

Groupe SEB Vietnam Joint Stock Company

Floor 12, Lottery Tower, 77 Tran Nhan Ton, ward 9, District 5, Ho Chi Minh City, Vietnam

Tel: +84 28 39381600

If you have any questions relating to the processing of your personal data, you can also contact the Company Data Protection Officer at vn.info@groupeseb.com.

11. Updates

This information notice was last updated on 01/06/2021. It can be subject to change from time to time. If so, a new version of this notice will be communicated to you via the channel the Company normally communicates with you.