BSH HOME APPLIANCES TRADING LLC
PERSONAL DATA PROTECTION AND PROCESSING PRIVACY NOTICE (“Privacy Notice”)
Your personal data may be processed in the capacity of Data Controller by BSH Home Appliances Trading L.L.C. (“Company”), residing at Happiness Street, City Walk Building 10, City Walk, Dubai, UAE, P.O. Box 46710, in accordance with the United Arab Emirates Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (“UAE Data Protection Law” or the “Law”) within the scope described below.
Gaggenau operates as a registered trademark operating under the BSH Home Appliances Trading LLC.
Detailed information regarding the purposes of processing your personal data by our Company can be found in the Personal Data Protection and Processing Policy available at https://www.gaggenau.com/ae/general/legal. For any questions regarding our data protection processes or to exercise your rights as a data subject, you may contact our company’s Data Protection Officer (DPO) via email: irem.yazlar@bshg.com
1. PURPOSE OF PROCESSING YOUR PERSONAL DATA
Your collected personal data may be processed in accordance with the basic principles stipulated in the Law and within the personal data processing conditions specified in Articles 4 and 6 of the Law for the following purposes (“Purposes”):
- Selling, providing, and/or tracking products and/or services, fulfilling information and promotional activities about our products and services,
- Creating membership registrations upon your request and operating membership accounts, evaluating requests/complaints,
- Carrying out commercial and operational activities conducted by our Company, customer relationship management, and executing information security processes,
- Performing payment processes, accounting, and finance transactions,
- Ensuring compliance with global regulations within the scope of export control, providing information/documents to authorized persons or organizations pursuant to legal obligations,
- Personalized marketing (including segmentation and profiling - automated processing), carrying out advertising, promotional, and marketing activities in digital and other media, and conducting data analytics studies,
- Processing your health data (limited to hearing impairment) to provide the relevant support service if you wish to benefit from our sign language call center service.
- Decisions made through profiling and automated systems are utilized to personalize your customer experience.
2. PARTIES TO WHOM YOUR PERSONAL DATA IS TRANSFERRED AND INTERNATIONAL TRANSFER
Your collected personal data may be transferred by our Company to our dealers, authorized services, business partners, suppliers, legally authorized institutions, and the parties specified below within the scope of the Purposes, based on the Cross-Border Transfer rules specified in Articles 22 and 23 of the Law (presence of an adequate level of protection, presence of standard contractual clauses approved by the UAE Data Office, or your explicit consent):
- For Marketing, Profiling, and Data Analytics Purposes: To SAP AG, Google LLC, and Meta Inc. based on the legal ground of the existence of relevant data protection standard contracts and international transfer agreements,
- For Information Security, Cloud Computing, and Global Reporting Purposes: To SAP AG, Robert Bosch GmbH, BSH Hausgeräte GmbH, and our group companies based on the existence of relevant data protection standard contracts,
- Within the Scope of Digital Assistant (Chatbot) Usage: Due to the use of the Kore.ai platform, it may be transferred to the supplier Kore.ai Inc. located abroad, based on the existence of contracts containing necessary technical and administrative measures.
3. METHOD AND LEGAL BASIS FOR COLLECTING YOUR PERSONAL DATA
Your personal data is collected electronically via our websites, call center, digital solutions, e-mail, social media, and mobile applications, and physically through authorized services and showrooms. Pursuant to the UAE Data Protection Law, your personal data is processed within the scope of the following legal bases:
Provided that it is directly related to the establishment or performance of a contract
- Sales, provision, and/or tracking of products and/or services,
- Creating membership registrations upon your request and operating membership accounts,
- Performing payment processes,
- Performance of operational contract processes carried out by our Company.
Being explicitly stipulated by laws and relating to the Company's legal obligation
- Ensuring compliance with global regulations within the scope of export control,
- Carrying out verification and controls arising from current legislation, complying with retention obligations, providing information/documents to authorized organizations,
- Retaining personal data to constitute evidence in possible future disputes and following up on legal affairs.
Based on the legal ground of explicit consent if you provide your explicit consent) (Note: Since there is no general "Legitimate Interest" exception in the UAE Data Protection Law, the following activities that do not fall under the performance of a contract or legal obligation are carried out based on your explicit consent.)
- Customization of your identity, contact, customer transaction, and marketing data according to your usage habits; designing personalized marketing (including profiling) and promotional activities,
- Carrying out advertising and customer acquisition activities in digital channels, conducting data analytics and data enrichment studies,
- Sending advertising, promotional, campaign, and similar commercial electronic messages regarding all brands of our Company to your preferred contact information,
- Processing your health data (related to hearing impairment) to provide sign language call center services (Processing of Sensitive Personal Data).
4. YOUR RIGHTS AS A DATA SUBJECT UNDER THE UAE DATA PROTECTION LAW
As a data subject, we would like to inform you that you have the following rights:
- To learn the purposes of processing your personal data, with whom it is shared, and the protection measures,
- In cases where the processing is based on consent or a contract and carried out by automated means, to receive your data in a structured and machine-readable format or to request its transfer to another data controller,
- To request the correction of inaccurate data or the erasure of your data in cases such as the disappearance of the purpose of processing or withdrawal of consent,
- To request the restriction of processing your data when you object to the accuracy of the data or in cases of unlawful processing,
- To object to and request the cessation of data processing activities, especially for direct marketing and statistical survey purposes,
- To object to decisions based solely on automated processing, including profiling, which have legal or negative effects on you, and to request human intervention
You can submit your applications regarding your rights listed above to our Company's application form available at https://www.gaggenau.com/ae/en/contact-form/contact-us .Furthermore, if you believe that our data processing processes violate the UAE Data Protection Law, you have the right to lodge a complaint with the UAE Data Office pursuant to Article 24 of the Law.